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%...../I)~OLICY ISSUE

(Notation Vote)May 17, 1994 SECY-94-133

[DE: The Commissioners

o[ ROB: James M. Taylor

Executive Director for Operations

SUBJECT: UPDATED COMMISSION POLICY STATEMENT ON ADVANCED REACTORS TOREFERENCE THE COMMISSION'S METRICAT10N POLICY

PURp0SE:

In accordance with the Commission's request in COMSECY-94-002, the NRC staff s

is requesting Commission approval to issue the revised policy statement onadvanced reactors to reference the Commission'3 policy on metrication.

BACKGROUND:

On January 8,1992, the Commission (with all Commissioners agreeing) approvedthe proposed policy statement in SECY-91-390, " Metrication Policy," forpublication for public comment. The proposed policy statement was publishedin the f_ederal Reaister on February 10, 1992 (57 [B 4891). In October 1993,the NRC issued its final policy statement on metrication (57 f3 46202) afterreceiving comments from 12 responders from both the public and privatesectors. All commenters supported the policy.

On April 2, 1993, Asea Brown Boveri-Combustion Engineering (ABB-CE) requestedan exemption from the Commission's metrication policy. In its letter,

ABB-CE stated that the Combustion Engineering Standard Safety Analysis Reportfor the System 80+ had been submitted for review several years before

Contact: NOTE: TO BE MADE PUBLICLY AVAILABLEStephen Sands WHEN THE P1NAL SRM IS MADE504-3154 AVAILABLE

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Lthe NRC had issued its current metrication policy statement and to convert tothe metric system would not only add significant schedular delays, but w W igenerate unnecessary costs of millions of dollars. Therefore, in the taemor an-dum of May 5,1993, from Samuel Chilk, Office of the Secretary of W Comt ,s-sion (SECY), to James Taylor, Office of the Executive Director for Operat ons(EDO), the Commission (with all Commissioners agreeino) granted ABM raexemption from NRC's metrication policy for the ABB-CE ( stem 80+ deci@certification documents (DCD). The Commission also requested that tlc staffidentify other vendors that might wish to be granted similar exemptions.

On July 7, 1993, in response to the Commission's request, the staff sent aletter to GE Nuclear Energy (GE) asking if GE wanted relief from the responsi-bility of performing unit conver; ions or of providing dual units in anydocuments that are part of the des gn certification process, in itsAugust 27, 1993, response, GE requested that the NRC exempt the advancedboiling water reactor (ABWR) design certification application from compliancewith the Commission's metrication policy. The staff then forwarded its 3

recommendation along with GE's request for exemption on September 30, 1993, tothe Commission. Specifically, the staff recommended that GE be required toprepare the ABWR DCDs in the International System of Units SI (SI units). It

also recommended that GE provide a conversion table from Si to English unitsin the DCDs instead of giving dual units. 110 wever, the staff indicated itwould prepare the ABWR final safety evaluation report (FSER) in dual units inaccordance with Commission guidance.

in COMSECY-93-051, " Metrication Policy Exemption Request," the Commission(with all Commissioners agreeing) agreed with the staff recommendation that GEbe required to prepare the ABWR DCDs in SI units and provide a conversion ;

tsble from Si to English units instead of providing dual units. i

On October 12, 1993, Westinghouse replied to the staff's letter of July 6,1993, requesting an exemption from the metrication policy for the AP600 design 1

similar to that requested for the System 80+ design. In COMSECY-94-002, theCommission (with all Commissioners agreeing) approved the staff recommendation<

in its January 4, 1994, memorandum from James Taylor, EDO, to the commissionto grant an exemption from the NRC's metrication policy to Westinghouse forthe AP600 design,

in its response of November 5, 1993, to the staff's July 7, 1993, letter, GEinformed the staff that the DCDs for the simplified boiling water reactor(SBWR) would be consistent with the requirements of the metrication policy.In its oral response of March 1994, Atomic Energy of Canada Ltd. (AECL)informed the staff that the CANDU DCDs would also be consistent with the.

requirements of the metrication policy.'

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The Commis:ioner,. -3- |-

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DISCUSSION: :

On July 8,1986, the NRC issued a derument entitled " Regulation of AdvanMNuclear iower Plants; Statement of Policy" (51 [B 24643). Additionally, InJune 198L, it published hUREG-1226, " Development and Utilization of the PolicyStatement on the Regulation of Advanced Nuclear Power Plants." Both theadvanced reactor policy statement and HUREG-1226 were written to provideguidance f or the development of new regulatory requirements to support theadvanced designs. However, both documents preceded the Commission'smotrication policy, wnich was published in the Federal Reaister onOctober 7, 1992 (57 [B 46202). Therefore, the documents do not reflect thecurrent Commission position on metrication.

Since the mandate by Congress, together with economic pressure on U.S.companies to compete in global markets, has increased the motivation formetric conversion in the United States, it is important to provide adeoeatenotice to any prospective applicant that the Commission takes its poli y onmetrication seriously. Some industry codes and standards developed in theUnited States use the metric system in the form of dual-unit reporting orconversion tables. ?.dditionally, new codes end standards are increasinglybeing written in metric units to maintain their international presence andacceptance.

Therefore, in COMSECY-94-002, the Commission granted an exemption from NRC'smetrication policy to Westinghouse for the AP600 design on the basis thatconversion to the metric system would impose significant costs and seriousschedular delays. The Commission also requested that the staff update itspolicy statement on advanced reactors to reference the metrication policy.

The Commission has also granted ABB-CE an exemption from the metricationpolicy for the System 80+ design on the basis that conversion to the metricsystem of measurement would generate unnecessary costs. While economicimpracticability is not directly addressed in NRC's final statement of policy,published on October 7, 1992 (57 13 46202), it'is mentioned in the backgroundsection of the Federal Register notice. Therefore, the Commission hasdetermined, that under certain circumstances, the costs associated withconversion to the metric system outweigh the benefits, such as improvements inadministrative efficiency.

CONCLUSIONS:

The NRC believes that conversion to the metric system is important to thenational interest. The Commission strongly encourages its licensees andlicense applicants to employ the metric system of measurement wherever andwheever its ure is not potentially detrimentai to the public health andsafety or is not economically impracticable. Therefore, the NRC is issuingthis revised policy statement on advanced reactors to incorporate theCommis: ion's policy on metrication.

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The Commissioners 4--

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RECOMMEfC ILM:,.

The stai quests Commission approval to issue this revised policy statementon advance ~eactors (enclosed).,

| {DORDIRATJON:

The Office of the General Counsel hat reviewed this paper and has no legal4' objection. Additionally, since the Advisory Crmmittee on Reactor Safeguards i

had previously revit:wed both policy statenots, a copy of this paper is beingsent for their information.

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JayesH. Taylor &4

Exet tive Directo-for Operations

i4 .asure:Revised Policy Statement

on Advanced Reactors

Commissioners' commentu or consei. .hould be pr,fided directlyto the Office of the Sccretary by COB Priday, Jing 3, 1994.

Commission Staf f Of fice c omments, (f any, uld be submittedto the Commissioners NLT Thursday, May 26, .94: with an infor-mation copy to the Office of the Secretary. If the paper is of

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such a ncture that it requires ad6itional review ani comment,the Commissioners and the Secretariat should be apprised ofwhen comments may be expected-

DISTRIBUTION:CommissionersOGCOCAAOPAOIGOCAOPPEDO

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NUCLEAR REGULATORY COMMISSION.

10 CFR PART 50

REGULATION Of ADVANCED NUCLEAR POWER PLANTS;STATEMENT Of POLICY

AGENCY: Nuclear Regulatory Commissioni

ACTION: final Policy Statement

SUMMARY: The Nuclear Regulatory Commission (NRC) intends to .9 prove thelicensing environment for advanced nuclear power reactors to nJt.ir*:e complex-ity and uncertainty in the regulatory process. This statement gives theCommission's policy regarding the review of, and desired characteristicsassociated with, advanced reactors. This policy statement is a revision ofthe final policy statement titled " Regulation of Advanced Nuclear PowerPlants, Statement of Policy" (51 Federal Reaister 24643) that was published onJuly 8, 1986. The purpose of this revision is to update the Commission'spolicy statement on advanced reactors to reference the Commission'smetrication policy.

EFFECTIVE DATE:

FOR FURTHER INFORMATION CONTACT: Stephen P. Sands U.S. Nuclear RegulatoryCommission, Washington, DC 20555, Telephone: 301-504-3154.

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SUPPLEMENTARY INFORMATION:-

BACKGROUND

On July 8,1986, the Commission published its final policy statement onadvanced reactors in the Federal Reaister (51 Federal Reaister 24643). TheCommission's primary objectives in issuing the advanced reactor policystatement were threefold:

First, to maintain the earliest possible interaction of applicants,.

vendors, and government agencies, with the NRC;

Second, to provide all interested parties, including the public, with.

the Commission's views concerning the desired characteristics ofadvanced reactor designs; and _

Third, to express the Commission's intent to issue timely comment on the.

irnplica: loa., cf such designs for saf ety and the regulatory process.

On August 10, 1988, Congress passed the Omnibus Trade and Competitiveness Act[the Act), (19 U.S.C. 2901 et seq.), which amended the Metric Conversion Actof 1975, (15 U.S.C. 205a et seq.). Sectior. 5164 of the Act (15 U.S.C 205a)designates the metric system as the preferred system of weights and measuresfor U.S. trade and commerce.

in an effort to effect an orderly change to the metric system, the Actrequires that all Fader:1 ogc;, ies convert to the metric system of measurementin their procurement, grants, ano other business-related activities by the endof fiscal year 1992, "except to the extent that such use is impractical or islikely to cause significant inefficiencies or loss of markets to U.S. firms,such as when foreign competitors are producing competing products in non-metric units," Section 5614(b)(2).

In response to the Act, the NRC published its metrication policy statement forcomment in the ER.deral Reaister on February 10, 1992 (57 Federal Reaister4891). The purpose of the metrication policy statement was to inform NRClicenseas and the public how the Commission intended to meet its obligationsunder the Act Comments on the draft statement were submitted by 12responders, including 5 power reactor licensees, 3 standards organizations, areactor vendor, a materials licensee, the N'aclear Management and ResourcesCouncil, and a joint letter cubmitted by three individuals. All commenterssupported the Commission's positic.n and the final policy statement waspublished on October 7, 1992 (57 Federal Reaister 46202).

The Commission supports and encourages the use of the metric system ofmeasurement by NRC licensees and applicants. However, Commission experienceto date in design certification reviews is that it is impracticable anduneconomical to convert a design to the metric system late in the designprocess and that applicants should consider metrication early in the designprocess. Therefore, the Commission is revising the advanced reactor policystatement to incorporate its policy on metrication to encourage licensees andlicense applicants to employ the metric system of measurement wherever and

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whenever its use is not potentially detrimental to the public health and.

safety or is not economically impracticable.

COMMISSION P01.lCY

Consistent with its legislative mandate, the Commission's policy with respectto regulating nuclear power reactors is to ensure adequate protection of thepublic health and safety and the environment. Regarding advanced reactors,the Commission expects, as a minimum, at least the same degree of protection"f the public and the environment that is required for current-generationlight water reactors. Furthermore, the Commission expects that advancedreactors will provide enhanced margins of safety and/or utilize simplified,inherent, passive, or other innovative means to accomplish their safetyfunctions. The Cor nission also expects that advanced ceactor designs willcomply with the Commission's safety goal policy statement and the policy -

statement on conversion to the metric system.

Among the attributes that could assist in establishing the acceptability orlicensability of a prn;cscd advanced reactor design, and that therefore shouldbe considered in advanc -d designs, are:

Highly reliable and less complex shutdown and decay heat removal.

systems. The use of inhcrent or passive means to accomplish thisobjective is encouraged (negative temperature coefficient, naturalcirculation, etc.).

Longer time constants and sufficient instrumentation to allow for more.

diagnosis and management before reaching safety systems challenge and/orexposure of vital equipment to adverse conditions.

Simplified safety systems that, where possible, reduce required operator.

actions, equipment subjected to severe environmental conditions, andcomponents needed for maintaining safe shutdown conditions. Suchsimplified systems should facilitate operator comprehension, reliablesystem function, and more straightforward engineering analysis.

Designs that minimize the potential for severe accidents and their.

consequences by providing sufficient inherent safety, reliability,redundancy, diversity, and independence in safety systems.

Designs that provide reliable equipment in the balance of plant (80P).

(or safety-system independence from BOP) to reduce the number ofchallenges to safety systems.

Designs that provide easily maintainable equipment and components..

Designs that reduce potential radiation exposures to plant personnel..

Designs that incorporate defense-in-depth philosophy by maintaining.

multiple barriers against radiation release, and by reducing thepotential for and consequences of severe accidents.

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* ' Design features that can be proven by citation of existing technology or.

that can be satisfactorily established by commitment to a suitabletechnology development program.

If specific advanced reactor designs with some or all of the above foregoingattributes are brought to the NRC for comment and/or evaluation, theCommission can develop preliminary design safety evaluation and licensing i

criteria for their safety-related aspects. Combination of some or all of theabove attributes may help obtain early licensing approval with minimum '

req,ulatory burden. Designs with some or all of these attributes are alsolikely to be more readily understood by the general _ public. Indeed, thenumber and nature of the regulatory requirements may depend on the extent towhich an individual advanced reactor design incorporates general attributessuch as those listed above. However, until such time as conceptual designsare submitted, the Commission belims that regulatory guidance must besufficiently general to avoid placing unnecessary constraints on the develop-ment of new design concepts.

To provide for more timely and effective regulation of advanced reactors, theCommission encourages the earliest possible interaction of applicants,vendors, other government agencies, and the NRC to provide for early identifi-cation of regulatory requirements for advanced reactors, and to provide allinterested parties, including the public, with a timely, independent assess-ment of the safety characteristics of advanced reactor designs. Such licens-ing interaction and guidance early in the design process will contributetoward minimizing complexity and adding stability and predictability in thelicensing and regulation of advanced reactors.

While the NRC itself does not develop new designs, the Commission intends todev v the capability for timely assessment and- response to innovative andadvai.wd designs that might be presented for NRC review. Prior experience hasshown that new reactor designs -- even variations of established designs --may involve technical problems that must be solved in order to ensure adequateprotection of the public health and safety. The earlier such design problemsare identified, the earlier satisfactory resolution can be. achieved. Prospec-tive applicants are reminded that, while the NRC will undertake to review andcomment on new design concepts, the applicants are responsible for documenta-

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tion and research necessary to support a specific license application. (NRCresearch is conducted to provide the technical bases for rulemaking andregulatory decisions, to support licensing and inspection activities, and toincrease NRC's understanding of phenomena for which analytical methods areneeded in regulatory activities.)

During_ the initial phase of advanced reactor development, the Commissionparticularly encourages design innovations that enhance safety and reliability(such as those described above) and that generally depend on technology thatis either proven or can be demonstrated by a straightforward technology -development program. In the absence of a significant history of operatingexperience on an advanced concept reactor, plans'for innovative use of proven

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technology and/or new technology development programs should be presented tothe NRC for review as early as possible, so that the NRC can assess how theproposed program might influence regulatory requirements. To achieve these

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!'broad objectives, the Advanced Reactor Projects Directorate (PDAR) was.

established in the Office of Nuclear Reactor Regulation. This group is thefocal point for NRC interaction with the Department of Energy, reactordesigners, and potential applicants, and coordinates the development ofregulatory criteria and guidance for proposed advanced reactors. In addition,

the group maintains knowledge of advanced reactor designs,. developments, andoperating experience in other countries, and provides guidance on an NRC-funded advanced reactor safety research program to ensure that it supports,and is consistent with, the Commission's advanced reactor policy. The PDARalso provides guidance regarding the timing and format of submittals forreview.- The Advisory Committee on Reactor Safeguards plays a significant rolein reviewing-proposed advanced design concepts and supporting activities.

The NRC believes that conversion to the metric system is important to thenational interest. The Commission strongly encoura91s its licensees andlicense applicants to employ the metric system of meisurement wherever andwhenever its use is not potentially detrimental to the public hisP,h andsafety or is not economically infeasible. In order to facilitato use of themetric system by licensees and applicants, the NRC began publishing, as ofJanuary 7,1993, the following documents in dual units: new regulations,major amendments to existing regulations, regulatory guides, NUREG-seriesdocuments, policy statements, information notices, generic letters, bulletins,and all written communications directed to the public. Licensees and appli-cants should follow the guidance outlined in the Commission's position andfinal policy statement on metrication published on October 7, 1992 (57 FederalReaister 46202).

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