ML25196A471
| ML25196A471 | |
| Person / Time | |
|---|---|
| Issue date: | 01/21/1975 |
| From: | Kerr W Advisory Committee on Reactor Safeguards |
| To: | Anders W NRC/Chairman |
| References | |
| Download: ML25196A471 (1) | |
Text
ADVISORY COMMITTEE ON REACTOR SAFE.GUARDS United States Nuclear Regulatory Commission Washington, D. C. 20555 Honorable William A. Anders Chairman U. s. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Mr-. Anders:
January 21, 1975 In considering the future role of the Advisory Committee on Reactor Safeguards in support of l\\1R.C activities, the ACRS has reaffirmed the need for expeditious passage and implementation of the nonmandatory review requirement of Section 29 of the Atomic Energy Act. This change in the Committee's Charter has been proposed by the Committee on several occasions, most recently in a letter to the Honorable John A. Pastore, dated April 14, 1972 (copy attached), and the testimony of Dr. William R. Stratton, ACRS Chairman, during the JCAE Hearings on Nuclear Power Plant Siting and Licensing, on April 24, 1974 (copy attached).
The Atomic Energy Commission endorsed this change in the Act and this proposed change in the legislation was last forwarded to the Congress for ~ction during 1974.
The ACRS reaffirms the need for this legislative change fo~ tha reasons noted in ~r. Stratton's testimony and requests that this change be for-warded for Congressional action as soon as practical.
In addition to this change, it is suggested that, as soon as practical, the Congress also be requested to amend Section 20l(g)(l) of the Energy Reorganization Act of 1974 (P.L.93-438) by inserting, "The Advisory Committee on Reactor Safeguards." This section would then read as follows:
Sec. 20l(g)
(1)
The Advisory Committee on Reactor $3feguards; (2)
The functions of the Atomic Safety and Licensing Board Panel. * * * "
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Honorable William January 21, 1975 The statement by Senator Ribicoff (Congressional Record S19016, dated October 11, 1974) indicates that,"..* this transfer was agreed to by the conferees, but because of an oversight it was omitted from Subsection 20l(g)(l) of the act."
Attachments Sincerely yours,
~
W. Kerr Chairman
[*] 1.
Copy, Ltr from Dr. C. P. Siess, ACRS, to Hon. John A. Pastore>
J'CAE, dated April 14, 1972, Subj:
"AEC Proposed 'Discretionary ACRS Review' Legislation **. "
- 2.
Copy, Testimony of Dr. William R. Stratton, ACRS, before the J'CAE on April 24, 1974
[*]Seepages 2741-2742, Volume V 2748
'IfSTn*OW OF Dr* William ~. Stratton, Chainnan Advisory Ccmnitt.:ee on Reactor Saf~
Befc:re '!he JOINT CCX-:,MITI'EE ON A'IO.\\fiC ENERGY NUCLEAR Pa-JER PUN!' SITING & LICENSING LEGISIATIQ~
April 24, 1974 2749
The principal matter that the ACRS wishes to address in this testinony is that of the so-called nardatory review reouiranent of ever,, facili t.y as specified in Section 182b of the Atanic Energy Act *
'l'o provide ba.cJ,-..grourd for this *c.0 nti.,:ony I *will present ~
infoma-ti.on as to ~
we have been all,:-.catirg our time, the Ccr.nittee's work load rt:M and as we see it in tr.e fuhlre, an:1 sane thoughts on hcM we might ~-nplan::;nt a charge in tl13 law. In addition, I will rrake a sUJ(Jestion apropos t.1-ie EP..DA-!lCC (!~SIC) legislation.
Very briefly, the p::>siticn of the ACRS on the review of projects is that full review of every awlication by the ACR.5 will not be re-quired as stmxlardi?.aticn of n;:.::lear plants ba::ai.es a rcality,an:i sane flexibility in ACIS review of projects should be provided at t.lti.s time.
The ACRS statai its position in this regard in t.lm testimony by Dr. Spencer H. Bush, the.., Cha.irrran, am. Dr. Joseph M. Hendrie, past Chainran, at the hearing before t.l]e Subccmnittee on Legislation on June 27, 1971. '!his !X)sition was again reiterated in a letter to Senator John o. Pastore, Chai.nran, JCAE, fran Dr. c. P. Siess, Chairman of the ACRS, datai April 14, 1972.
The 1CRS continues to support t.lti.s previously proposed legislation which provides, "'lbat \\L-tl.ess the carmission spe::ifically requests a review an:i report on an application or portion thereof, the Ccr.mttee ray dispense with such revia*r arrl re;.:ort by notifying the Ccmnission in writil'Y;J that review by the Ccmnittee is not warranted". 'lne letter to Senc'ltor Pastore am. the suggcste:l wo:rd~ for Se-:::tion 182b are includo:1 as an J\\ppendix to this report.
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'!be~ believes that it shoold have the authority to nake a review when it considers that a review j_s appropriate. '!he carmission
\\<<>uld also have this authority un:ier this propose:i chan::_Je in the law.
'lhis provision would preclude any ay:,r:earan:e of lessenin::J t.he in:ieoenden::<
ard input of the ACPS in its role of prot:a::ting am assurin:; public healtl:
aid safety. The suggested '\\-JOrding ~
pe.nnit the ACRS to ~e its prooedures in an oroerly an::l gradual fashion an:l \\'.OUld lead to new procedures that would be consistent with its role as envisage:l in the le:;islation establishing the ACRS.
A change which was fa:esre~, *a few years ago ani t*+/-lich is occurrirg Iv::M is the ustarrlardization* of rux::lear p:y11er plants. 'lbe t~
- staroardization* is usai with sane reservation sioce structures as laxge, expensive, arrl canplicated as rro:iern pc:Mer stations can never be as similar as a series of ccmnercial airliners, for example. 'lhe site of a plant necessarily intrcxiuces differences an::l the pelJtttltation of utility, NSS vendor, azchitect engineering firm, as well as site ma:in that truly identical plants will be fa-1 and far between. Nevertheless the Camdttee has twice combined reviews of plants which inoorp:raterl the same mx:leu-steam supply systen arrl for which the timing of the canbined reviews was practical. One case, for an operatin:J license, involved three utilities with a total of four reactors, while more recently a construction pennit review involvcrl b..o utilities and five reactors.
'lbe time save::l durin:J our ~ting was considerable an1 we foresee more su::h possibilities in the future.
2751 A measure of mrk experrled on projects arrl \\IJOrk on general natters can be obtainErl by cotmtin:J sulxxmnittee rneeti.n:J days on the several subjects. These chta for the µist six years show that close to half (42% to 57%) of the subccmnittee effort is expended on projects arrl alx>ut half is expemErl on safety guides, criteria, technical issues, am reactor sa£ety research natters. These data are incluierl in Table I, attached. Thus, about half of rur time is expen:ied on what would be called generic matters.
I est:inate that during full Carrnittee mee~s, the allocation of time t-.'Otlld in:licate relative.1.y rrore effort on reactor
~jects, perha:9s as ITll.cil as bio-thirds, but specific time records have r.aot been maintained during our meetin]s.
'lhus, the ACRS already is expendin:J al:out half of its available time on general issues j,mp:>rtant to safety. ~les include: pressure vessel integrity, anticipated transien1s without scram, e:rnergency core cooling sys tans, reactor fuels, provisions for protection against imustrial sabotage, arrl many others. I expect that generic natters will oontinue to be of najor interest for sane time in the future.
'lhe Conmittee believes that project reviews are necessary to keep current in*thc latest developr.ents in reactor te=hnology arrl believ-es that the nunber of proja:::t revie,.>s per year that is appropriate wi11 de~t on a rrumber of qualitative as well as quantitative rratters.
On the other harrl, the carmittee believes that its generic reviews have been very useful in helping to focus needed attention on appropriate matters arrl prov~ sane guidarce to the irrlustcy in safety natters.
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In view of the projection for nu::lear pc:wer pl.ant constru::tion, scrre flexiliility in the require-rents far foz:nal review is neE:ded. 'lhe u:RS believes that by rel.axin;J the mandatory provision an:l by can-binin:.J reviews of starrlardized plants, the project case load can be ac;ccnm:x:1ated witb::mt impairiNJ the current level of safety and about the same effort on general matters can be sustained.
1he ACRS an:1 AfX: have not yet developed detailed procedures to irnplsnent no~tory revi£M 1::ut sane thought has been given to this question arrl mxe will be needa:1.
I personally believe that it "-Ould ha ~h better to accanplish a gradual transition to the new status a.rd to develop these procedures over a i::ericx:1 of tL"l'\\e.
'lhe lCP..S believes that a revia., of each project probably is necessary; selected projects could receive an abbrev-iated reviev,.r, others,-x,uJ..d receive a m:>re nearly standaro review.
The abbreviated or shortened reviE:"N couJ..d be, for example, a sul:ccmnittee e.~tion of the plant and r~tory staff evaluation, or a Camdttee discussion of the plant without asking for atterrlance by the applicant am regulatory staff, or a subcamtittee might ascertain that only very selected aroos would warrant the attention of the full Camti.ttee.
A nunber of possibilities can be iiragine:1.
'1he second matter that the ACIG wishes to bri.1¥J to your attention is connected with the PJ:OfX)Sed legislation that will create the ERm and the NOC.
'lbc Carrnittee believes that the provisions gov~ the safety review of ERDt1\\ reactors by NEC nay be too lirnital and that scne provision for a review to t.aJ.-..e place at the request of Eru:l.1\\ \\-~d contribute 2753
-s-positively to public health and safety. A current example is that of the FPTF am the Cl.inch River IMFBR Denonstration Plant. 'lhe foJJUer is a research reactor am \\'ntld not be reviewed urxler the prop:,sed
].e:Jislation, while the latter will be connected to the electrical grid of the 'lV1\\ an:i will be reviewoo. However, the ~
reactors are not unrelated1 the Ea-ne reactor vendor is designin;J and constructing the reactor core, an:l many canrX>!'lellts are of cannon design or develop.iental pattern. I have no doubt that aspects of safety p.ulosoµiy will be ocmoon to both plants am not necessarily coincident with re:JUlat.ory safety plilosophy unless re:JUla.tory inpit occurs early in the process.
1,., regulatory safety revie,, of b'le Stall.er plant ccw.d be vecy beneficial to design aIX1 construction of the larger daoonstration plant, am lat.er ca:merci.al. designs, as well as providing a useful exc~e of safetv related views.
'nlUS, the ACRS recarmenis that the proposerl legislation !?rovide specifically for t.ltls relations.up between the ERDA and the NEC.
In addition, specific provision for ACRS review of ERDA facilities should be inclttle::1 in the legislation that establishes these b.u aqencies as indi.catal in House Re~rt 93-707 (pages-26 an1 34).
Section 202 of H.R. l.1510 si;,ecifies review by NJ£ of ERM der.onstra-tion re.actors which operate as p.n:-t of the pcwer generating facilities of an electric utility systan. Because other carr:ierci.al applications of JllX:lear rca.ctors are po3sible, the 1\\CRS respectfully 5UJgests an added subsection in 202 (H.R. 11510) to provide that other dcm:mstration nuclear 2754
reactor::. be reviewed b<J NEC when constructexl for the PJI'!X)Se of, or
\\.hen oocrata:l in a nanner to es-tablish, the cararercial viability of the p1:oduction of process heat, the desalinization of water, or any other Fbysical or chanical precess that may have ccmnercial application.
'l'o amnarize, the major m1tter the Advisory Ccmnittee on Reactor Safeguards wishes to br~ to your attention is that of the nandatorv review provision in Section 182b of the Atanic Energy raw. The ACR5 p:cqoses provision su::h, "That unless the Corm.ission specifically requests a rE!'.riew and rep:,rt on '".n application or i;x:>rtion thereof, the camu.ttee may di.spP.r.se with such review am report by notifyirq the Ccmnission in writing that reviB-1 by the Catmittee is not warranted*.
A second matter the AC&5 wishes to bring to your attention is a possible? a:dssion in the proposed ERDA.-i.'lEX:! legislation. The ACRS believes that the provisions regulating the NEC and ACRS review of EPJl1\\ reactors needs to be stated specifically.
HI 2755