Nuclear Reactor Safety

peculiarities will require that utilities or A-E's consider several SSAR's, these problems are bounded by the number of NSSS vendors. The site induced parameters are not as finitely bounded. We believe that a clear definition of AECapproved regional site parameters, together with appropriate natural phenomena characteristics could pave the way towards full implementation of reference systems option by all segments of the industry.

The final concern regarding restraint of trade implications, results from the Commission's statement that ". . . reasonable assurance should be provided that the design will be applied to several units within [a specified time period]". Although this requirement will undoubtedly pose problems to present component suppliers, the chief concern arises with the potential barrier it poses to a new supplier. After the policy has been in effect for several years and a particular number of component suppliers and designers have achieved design approval by the Commission, any new entrant into these fields could encounter stiff buyer resistance to his unapproved design. This requirement should be reassessed.

The Lawyers Committee of the Forum is currently engaged in assessing the antitrust aspects of standardization in more detail and expects to submit its views to the Commission at the conclusion of its study.

CONCLUSION

The goal of nuclear plant standardization is endorsed by the Steering Group. Specifically, we believe that the chief benefits are:

The orderly introduction of design changes.
The decrease in licensing time that can result.

The more efficient use of trained manpower in industry and the Commission.

We believe these goals to be in the best interest of the country as well as of the power industry.

Our principal recommendations have been outlined in Sections II and III, and more completely discussed throughout the text. We believe them to be constructive and worthy of careful consideration. We stand ready to discuss them with you further so that their intent and scope may be fully understood. We also believe that an exchange of views on these recommedations could lead to implemented standardization policy that achieves your major goals yet maintains the flexibility required by an innovative, creative, and free society.

GENERAL COMMENTS ON FINAL DRAFT, WASH-1250, JULY 1973

THE SAFETY OF NUCLEAR POWER REACTORS AND RELATED FACILITIES General Comments on the various sections of the report include: Introduction (11 pages)

A reasonable summary of the report, with the exception of general statements on the safety significance of fuel cladding defects, and that the newer larger plants are of increased complexity (with safety overtones) per se.

Chapter 1 (67 pages) system descriptions

(a) A relatively weak section of the report.

(b) Appears to be authored by persons who are not too familiar with actual plants and current designs.

(d) Reprocessing plant process description generally not applicable to certain of the new plants.

(e) Unwarranted assumptions here, and at other points in the report, that merely because processes probably can be developed for retention of Krypton-85 and Tritium, that such retention should be done, without cost-benefit on the small dose reduction that would be achieved.

(f) For reprocessing plants, still shows on-site high level liquid waste tank storage, and direct on-site burial of hot solid wastes (hulls, etc.).

(g) Chapter will become obsolete sooner than other sections of report as

tion for a power limitation whose sole purpose is that of allowing the standardization procedures to be implemented. We believe this may be appropriate for some short time period, however, we believe the AEC should state the period of applicability of this limit and the criterion for the next power level limitation. Additionally, the Commission should provide notice of any change in this limitation far enough in advance so that its implications can be considered in utility planning schedules.

XII. IMPLIED HIERARCHY OF SAFETY

In our comment letter of May 22, 1973, we commented upon the inference in the AEC's statements on its standardization policy that standardization will result in an "enhancement of safety", thereby suggesting a hierarchy of safety will exist between standard and non-standard plants. Our comment remains valid and nothing in the Commission's formal statements nor its published regulations has indicated any reevaluation of, nor explanation for, its position. Philosophically, there can be no safe, safer, and safest gradation in nuclear plant technical reviews nor in operating effectiveness. Any recently granted construction permit ought to serve as the basis for a duplication effort. However, we believe it is correct to point out that the increased depth of review that may become possible with a full implementation of standardization can discover potential problems earlier than present practice allows. The availability of more detailed permit review is the basis for this statement.

XIII. ANTI-TRUST CONSIDERATIONS

A major problem that could arise from the Commission's standardization policy is the danger it could pose to the competitive structure of the industry. Section 1 of the Atomic Energy Act provides that: "It is therefore declared to be the policy to the United States that . . . [T]he development, use, and control of atomic energy shall be directed so as to promote world peace, improve the general welfare, increase the standard of living and strengthen free competition in private enterprise [emphasis added]."

In addressing the September 20-22, 1973, ALI/ABA symposium on atomic energy licensing and regulation, Mr. George Freeman noted that, .. A number of cases over the years have held that the basic concept of public interest which is applicable to Federal regulatory actions generally encompasses consideration of the Federal Anti-Trust Laws. Accordingly, maintenance of competition in the industry is one of the factors, in addition to radiological health and safety and administrative convenience, which the Commission must consider in implementation of a standardization policy".

The duplicate plant option is an example of the possible anti-trust implications. Here the procedural regulations should clearly provide for certification of major standardized portions of the plant (such as the NSSS, the containment, and the "Balance-of-Plant"), together with associated and comprehensive interface criteria. This would allow the "building block" approach of selecting various standardized major systems with compatible interface criteria, thus lessening anti-trust implications.

In addition we also believe that the procedural regulations must clearly identify a "design change option". That is, procedures should allow an applicant to use an approved standardized design in substantial part, but elect certain clearly identified options that fall within the design and performance parameters of the standardized designs. These same procedures would recognize that technical review of this "design change option" is necessary but that such a review would be limited to that option's ability to meet the approved design, and/or interface, parameters. This required review of the "design change option" should not, per se, be the excuse for a re-review of the entire standardized design which is the basis for the application.

The Commission's acceptance and approval of a standardized safety analysis report (SSAR) could tend to limit competition in the design of similar systems or structures by others. A clear procedure which allows for considerations of alternative designs within the framework of an approved SSAR would tend to minimize this problem.

The difficulty of a utility's or a design-engineering firm's attempting to offer a SSAR must be ameliorated. These entities have design parameter envelopes

The final concern regarding restraint of trade implications, results from the Commission's statement that “. . . reasonable assurance should be provided that the design will be applied to several units within [a specified time period]". Although this requirement will undoubtedly pose problems to present component suppliers, the chief concern arises with the potential barrier it poses to a new supplier. After the policy has been in effect for several years and a particular number of component suppliers and designers have achieved design approval by the Commission, any new entrant into these fields could encounter stiff buyer resistance to his unapproved design. This requirement should be reassessed.

CONCLUSION

The goal of nuclear plant standardization is endorsed by the Steering Group. Specifically, we believe that the chief benefits are:

The orderly introduction of design changes.
The decrease in licensing time that can result.

The more efficient use of trained manpower in industry and the Commission.

We believe these goals to be in the best interest of the country as well as of the power industry.

GENERAL COMMENTS ON FINAL DRAFT, WASH-1250, JULY 1973

THE SAFETY OF NUCLEAR POWER REACTORS AND RELATED FACILITIES General Comments on the various sections of the report include: Introduction (11 pages)

Chapter 1 (67 pages) system descriptions

(a) A relatively weak section of the report.

(b) Appears to be authored by persons who are not too familiar with actual plants and current designs.

(d) Reprocessing plant process description generally not applicable to certain of the new plants.

(f) For reprocessing plants, still shows on-site high level liquid waste tank storage, and direct on-site burial of hot solid wastes (hulls, etc.).

(g) Chapter will become obsolete sooner than other sections of report as

Chapter 2 (81 pages) basic safety philosophy

(a) A good summary of defense in depth safety philosophy and practices. Chapter 8 (20 pages) regulatory role

(a) Generally a reasonable summary of current scene.

(b) Critical of utility management on attention to plant safety and quality

assurance.

(c) Critical of fuel performance, as interfering with achievement of "as low as practicable" on effluents, while in fact, all plants have performed within the design objectives initially selected with regard to effluents. (10CFR20)

Chapter 4 (110 pages) radioactive effluents

(a) As indicated by the 110 pages, far too much attention given in a reactor safety report. Gives the impression that effluents are related to safety.

(b) Reactor effluents based largely on AEC Staff testimony for ALAP Hearing, now over a year and a half old. Text improved in a number of places based on our comments on initial draft but no changes made in tabulated data.

(c) Plant boundary doses for all plants, both BWR and PWR, are over-estimates as bases was that the plant license emission rates would deliver a permissible dose to the fencepost, and thus overlooked the factors of conservatism in the plant license limits.

(d) The currently operating plants have been compared with proposed "as low as practicable" quantity and concentration limits. Such plants were not designed to meet such proposed objectives which were first stated in June 1971. We expect that at least some of the proposed numbers will be different in Appendix I as ultimately issued.

(e) Effluent doses to fence posts show no estimate of lesser dose that would apply to any actual neighbor.

(f) The table with the greatest problem is repeated in Chapter 8.

(g) Additional statement that high level reprocessing liquid wastes will be stored in tanks at the reprocessing plant.

(h) Will become obsolete soon, as augmented systems come into operation. Chapter 5 (22 pages) accident evaluation

(a) Reasonable summary of current methods, etc. Many of our members' prior comments were included.

(b) In places, the language is in terms of a single containment barrier, rather than the normal multi-barrier system.

Chapter 6 (48 pages) risk assessment

(a) Seems to be an excellent statement of risks in general, and nuclear power risks in perspective. Principal prior comments taken into account.

Chapter 7 (37 pages) safety research program

(a) Appears to be PWR oriented; similar concepts with differing details would apply to the BWR.

(b) Give some credit to R&D done by others, while earlier draft was limited to AEC programs and efforts.

Chapter 8 (41 pages) eight special interest topics

Useful public understanding type summaries on:

(a) Why a reactor is not a bomb.

(b) Brookhaven report, WASH-740.

(d) ECCS public hearing.

(e) Low level radiation, including Sternglass, and Gofman-Tamplin.

(f) Unusual occurrences in power plants.

(g) Physical protection of power plants.

APPENDIX 7

The following additional materials were submitted by Dr. Arnold of Westinghouse. Reference will be found in text on p. 440.

WESTINGHOUSE ELECTRIC CORP.,

POWER SYSTEMS Co., Pittsburgh, Pa., December 4, 1973.

Subject: President Nixon's Six Year Target.

Hon. DIXIE LEE RAY,

Chairman,

U.S. Atomic Energy Commission,

Washington, D.C.

DEAR DR. RAY: In a November 7, 1973 speech, President Nixon challenged the Atomic Energy Commission and the nuclear industry to reduce the time required to put nuclear power plants on line from ten years to six years.

A cycle of six years or less has been achieved in the United States in the past, is the practice abroad today, and again can be made the practice here in the immediate future. The steps that have to be taken are simple and possible. In this letter we have summarized our thoughts on what can be done in the licensing area. Further studies have to be carried out before concrete ideas can be formalized on means to expedite construction, assure material and manpower availability and raise the necessary funds. When these studies are completed, they will be the subject of a later letter.

The key strategy to achieve a six-year cycle is to replace the current series process, i.e., licensing followed by construction, with a process in which both licensing and construction are in parallel. With about 200 nuclear power plants in the United States either in operation, in construction or under design the nuclear community has the experience to implement a parallel process which maintains the high standards of safety currently practiced, recognizes the importance of preserving environmental values, and, at the same time, allows early delivery of nuclear energy to ease the energy shortage.

The attached Figure 1 depicts the present licensing-construction situation. Before an application can be reviewed, the utility must select a site, choose its suppliers and prepare the PSAR-a process which can take up to 24 months. A construction permit from the AEC then is required prior to beginning site preparation and construction. An average construction permit application review and public hearing takes about 30 months, and no site work is allowed until this review is complete. Construction takes about six years after the permit is granted. Thus, the total time required to put a plant on line today can approach 10 years.

We believe that dramatic improvement in lead time could be achieved by paralleling the licensing-construction process. Figure 2 shows the near-time benefit to be gained.

The single most important step for the near term is granting an exemption for site preparation and preliminary construction. To obtain such an exemption, we believe it is necessary first to have an Environmental Report prepared and a mini-NEPA review conducted. (Of course, unless this review indicates the benefits from proceeding with preliminary work outweigh the costs, the exemption should not be granted.)

An adequate Environmental Report can be prepared in six months for a new site and in three months for an existing site as long as a plan of proven design is committed. The Environmental Report should contain a cost/benefit analysis showing that the benefits of early power generation, availability of site characteristics during the Staff review, etc. more than offset the risk, to the utility,

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