NUREG-1226 

Development and Utilization of 

the NRC Policy Statement on the 

Regulation of Advanced Nuclear 

Power Plants 

U.S. Nuclear Regulatory 

Commission 

Office of Nuclear Regulatory Research 

Peter M. Williams and Thomas L. King 
NOTICE 

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American National Standards Institute, 1430 Broadwa.v, New York, NY 10018. 
Development and Utilization of 

the NRC Policy Statement on the 

Regulation of Advanced Nuclear 

Power Plants 

Manuscript Completed: May 1988 

Date Published: June 1988 

Peter M. Williams and Thomas L. King 

Division of Regulatory Applications 

Office of Nuclear Regulatory Research 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555 

NUREG-1226 

ABSTRACT 

On March 26, 1985, the U.S. Nuclear Regulatory Commission issued for public 

comment a 11 Proposed Policy for Regulation of Advanced Nuclear Power Plants 11 (50 

FR 11884). This report presents and discusses the Commission•s final version 

of that policy as titled and published on July 8, 1986 11 Regulation of Advanced 

Nuclear Power Plants, Statement of Policy11 (51 FR 24643). It provides an overview of comments received from the public, of the significant changes from the 

proposed Policy Statement to the final Policy Statement, and of the Commission•s 

response to six questions contained in the proposed Policy Statement The report also discusses the definition for advanced reactors, the establishment of 

an Advanced Reactors Group, the staff review approach and information needs, and 

the utilization of the Policy Statement in relation to other NRC programs, including the policies for safety goals, severe accidents and standardization. 

In addition, guidance for advanced reactors with respect to operating experience, technology development, foreign information and data, and prototype 

testing is provided. Finally, a discussion on the use of less prescriptive and 

nonprescriptive design criteria for advanced reactors, which the Policy Statement encourages, is presented. 

NUREG-1226 iii 

CONTENTS 

Page 

ABSTRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i i i 

EXECUTIVE SUMMARY vii 

1 

2 

3 

4 

5 

6 

INTRODUCTION 

HISTORY AND BACKGROUND .................................... . 

COMMENTS ON PROPOSED POLICY ............................... . 

1-1 

2-1 

3-1 

3.1 Overall Reaction . . . . . . . . . . . . .. . . . . . .. . . . . . . . . . . . . . . . . . 3-1 

3. 2 Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3 

3.3 Interaction with NRC.................................. 3-3 

3.4 Standardization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4 

3.5 Responses to Questions................................. 3-4 

FORMULATION OF FINAL POLICY ............................... . 4-1 

4.1 Changes from Proposed Statement....................... 4-1 

4.2 Responses to Questions................................ 4-2 

GUIDELINES FOR UTILIZATION ................................ . 5-1 

5.1 Definition of Advanced Reactors....................... 5-1 

5.2 Advanced Reactors Group-Contacts and Information Needs. 5-2 

5.3 Review Approach and Related Policies, Practices and 

Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3 

5.3.1 Defense-In-Depth Philosophy..................... 5-4 

5.3.2 Safety Goal Policy ... . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5 

5.3.3 Severe Accident and Source Term Policies ....... 5-5 

5.3.4 Standardization Policy......................... 5-6 

5.3.5 Existing Regulations and Guidelines............ 5-7 

5.3.6 Industry Codes and Standards................... 5-8 

5.3.7 Treatment of Sabotage.......................... 5-8 

5.4 Supporting Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-9 

5.4.1 Operating Experience........................... 5-9 

5.4.2 Technology Documentation and Development....... 5-9 

5.4.3 Foreign Information and Data................... 5-10 

5. 4. 4 Use of Prototype Test . . . . . . . . . . . . . . . . . . . . . . . . . . 5-10 

5.5 The Use of Less or Nonprescriptive Design Criteria.... 5-11 

REFERENCES ................................................ . 6-1 

APPENDIX - NUCLEAR REGULATORY COMMISSION, 10 CFR PART 50, REGULATION 

OF ADVANCED NUCLEAR POWER PLANTS; STATEMENT OF POLICY 

WITH THE DISSENTING VIEWS OF COMMISSIONER ASSELSTINE AND 

ADDITIONAL VIEWS OF COMMISSIONER BERNTHAL 

NUREG-1226 v 
CONTENTS (Continued) 

Tables 

2.1 Advanced Reactor Regulatory Experience 2-3 

3.1 Table of Commenters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2 

NUREG-1226 vi 
DEVELOPMENT AND UTILIZATION OF THE NRC 

POLICY STATEMENT ON THE REGULATION 

OF ADVANCED NUCLEAR POWER PLANTS 

EXECUTIVE SUMMARY 

Advanced reactors have a long regulatory history, but until recently there has 

been essentially no explicit policy for their regulation other than case-bycase reviews which included determinations about their licensing requirements, 

including the extent of their conformance with Light Water Reactor (LWR) criteria. Accordingly the Commission has developed a Statement of Policy for 

Regulation of Advanced Nuclear Power Plants (Final Statement), published on 

July 8, 1986 (51 FR 24643) which encourages early interaction between NRC and 

advanced reactor designers to establish licensing guidance applicable to these 

designs. This report serves to document the comments on the proposed policy 

(published in the Federal Register on March 26, 1985, 50 FR 11884), to describe 

the significant changes made to the policy from that proposed to the final 

version and to provide guidance about implementation of the final policy, staff 

information needs and the staff approach to be used in the review of advanced 

reactor concepts under the Final Policy Statement. It is not the purpose of 

this document to impose technical design requirements on advanced designs. The 

staff reviews under the Final Policy Statement would occur before any formal 

application for authorization of construction or for a standard plant review 

and certification. However, the review principles and results would be expected to be used in the review of that design after a formal application. The 

key points contained in this document are summarized below: 

(1) The Final Policy Statement is applicable to reactors of innovative design 

but not to designs for which licensing requirements are essentially 

covered by the LWR-Standard Review Plan (i.e., evolutions from current 

generation LWRs). The specific determination of which new designs are 

considered to fall within the Final Policy Statement will be made case by 

case. At the present time certain high temperature gas-cooled reactor 

(HTGR) designs, liquid metal reactor (LMR) designs and innovative LWR 

designs qualify as advanced reactor designs. 

(2) Comments received on the proposed Policy Statement (50 FR 11884) were 

almost unanimous in the support of its objectives. Most commenters, 

however, stated that the objectives should not be imposed as requirements. 

(3) The Policy Statement established a charter for an Advanced Reactors Group 

(ARG). The ARG function is in the Office of Nuclear Regulatory Research 

and is located in the Advanced Reactors and Generic Issues Branch, Division of Regulatory Applications. The ARG serves as a project manager 

coordinating and scheduling activities both within and outside the NRC, 

as well as performing a significant portion of the technical review itself. 

In performing this review, use will be made of the existing licensing 

guidance for LWRs, where practical, and supplemented, as necessary, with 

additional criteria to address the unique characteristics of the advanced 

designs. 

NUREG-1226 vii 
(4) While the Final Policy Statement encourages innovative reactor designs and 

safety criteria, the review of advanced reactor designs will still require 

satisfactory consideration of the Commission's regulations, regulatory 

guides and other guidelines, such established and developing criteria as 

the defense-in-depth philosophy, standardization, the Commission's safety 

goal and severe accident policies, and applicable industry codes and 

standards. 

(5) The Commission and staff expect the licenseability of advanced reactor 

designs to be supported by technology through a suitable combination of 

operating experience, the existing technology base, planned technology 

development, probabilistic risk assessment, applicable information and 

data from foreign countries, and plant testing. Prototype testing is 

encouraged. 

(6) The use of less prescriptive, nonprescriptive, or performance related 

licensing criteria will be considered. Designers are encouraged to propose those criteria they believe are applicable to their designs and to 

address how such criteria will enhance safety and what changes or benefits 

in the traditional NRC process of regulation are expected from the use of 

such criteria. 

(7) Requests by advanced reactor designers for reviews of advanced reactor 

conceptual designs should be addressed to: 

Director, Office of Nuclear Regulatory Research 

USNRC 

Washington, DC 20555 

NUREG-1226 viii 
1 INTRODUCTION 

On May 1, 1986 the NRC approved the issuance of a document entitled, 11 Regulation 

of Advanced Nuclear Power Plants; Statement of Policy. 11 This Policy Statement 

was published in the Federal Register on July 8, 1986 [51 FR 24643] and forms 

the overall guidance for the NRC 1s activities regarding advanced nuclear power 

plants. The Policy Statement is provided in the Appendix to this document. 

The Policy Statement calls for early interaction between the NRC staff and 

advanced reactor designers; encourages greater safety margins through the use 

of inherent, passive, or other innovative means for safety design; and establishes an Advanced Reactors Group (ARG) as a focal point for its implementation. 

The Policy Statement originally established the ARG within the Office of Nuclear 

Reactor Regulation (NRR), but a subsequent NRC reorganization approved by the 

Commission on February 11, 1987 transferred the ARG function to the Office of 

Nuclear Regulatory Research (RES). 

The final Policy Statement is based on the development and revision of a proposed 

Policy Statement, published for comment on March 26, 1985 (50 FR 11884), including assessment of public comments. 

The stated primary objectives of the Policy Statement are: 

(1) 11 Encourage earliest possible interactions of applicant, vendors, and 

government agencies, with the NRC; 

(2) Provide all interested parties, including the public, with the Commission•s 

views concerning the desired characteristics of advanced reactor designs; 

and 

(3) Express the Commission•s intent to issue timely comment on the implications 

of such designs for safety and the regulatory process. 11 

The purpose of this document is to (1) summarize the public comments received 

on the proposed version of the Policy Statement, (2) identify the significant 

changes made in the Policy Statement from the proposed version to the final 

version and (3) identify the responsibilities, interfaces and other considerations which must be addressed in the implementation and utilization of the 

final Policy Statement. 

NUREG-1226 1-1 

2 HISTORY AND BACKGROUND 

The NRC and the Atomic Energy Commission before it, together with the Advisory 

Committee on Reactor Safeguards (ACRS), have a long history of review and evaluation of advanced reactors. Safety reviews for construction and operation of 

liquid metal-cooled, gas-cooled, and other types of non-water-cooled power reactors performed in the 1950s and early 1960s were similar to those perf.ormed 

for the early commercial Light Water Reactors (LWRs). The reviews performed by 

the regulatory staff and the ACRS were highly customized and were generally 

based on the engineering experience and judgment of participating individuals. 

The regulatory staff and ACRS members worked closely together in the review and 

assessment of information supplied by the designers, owners and constructors 

without the availability of the regulatory guidance and structure established 

later during the course of LWR commercial development. In more recent advanced 

reactor reviews, explicit use was made of LWR regulatory guidance where applicable, a practice that continues. 

The Advanced Reactor Policy Statement identifies previous experience with the 

regulation of high temperature gas cooled reactors (HTGRs) and liquid metal 

reactors (LMRs). Construction permits and operating licenses were granted to 

the helium cooled Peach Bottom-1 and Fort St. Vrain reactors and to the sodium 

cooled Fermi-1 and the Southwest Experimental Fast Oxide Reactor (SEFOR) reactors. 

The design of the Department of Energy•s (DOE 1 s) Fast Flux Test Facility (FFTF) 

was given a safety review by the NRC but a license was not required by law. Reviews were also performed on reactor designs that were not subsequently built. 

For gas cooled reactors these were the Summit and Fulton applications for large 

HTGRs, the General Atomic Company•s standard large HTGR plant (GASSAR), and a 

conceptual design for a gas-cooled fast breeder reactor (GCFR). With regard 

to LMRs, the Clinch River Breeder Reactor (CRBR) was reviewed, and a public 

hearing held, but the project was terminated by Congress in 1983 before a construction permit was issued and general construction began. It should be noted 

that since the CRBR was to be a power reactor prototype, it was subject to the 

same regulatory process as any current commercial nuclear power project. 

In addition to the background of individual licensing actions, the Nonproliferation Alternative Systems Assessment Program (NASAP) of 1979 provided 

both a broad policy study and a review of specific safety concepts on reactor 

regulation. In the NASAP studies the NRC considered the safety and licensability of a variety of advanced reactor concepts ranging from preliminary 

conceptual designs to variations on existing LWRs. 

Table 2.1, 11Advanced Reactor Regulatory Experience 11 provides in summary 

format further information on previous advanced reactor safety reviews in 

the United States. 

Until the present Policy Statement, the principal statement on advanced reactor 

review policy was given in the introduction to Part 50 of Title 10 of the Code 

of Federal Regulations: Appendix A, 11General Design Criteria for Nuclear Power 

Plants. 11 Specifically, this introduction states: 

NUREG-1226 2-1 
11These General Design Criteria establish m1n1mum requirements for the 

principal design criteria for water-cooled nuclear power plants 

similar in design and location to plants for which construction permits have been issued by the Commission. The General Design Criteria 

are also considered to be generally applicable to other types of 

nuclear power units and are intended to provide guidance in establishing the principal design criteria for such other units. 11 

This led to the 11 comparable level of a safety11 philosophy under which HTGRs and 

LMRs were reviewed for many years; that is, a comparable level of safety would 

be established for all reactor types, with the recognition that the licensing 

criteria for advanced reactors could be developed using those for light water 

reactors to the extent practicable. The implementation of this philosophy took 

three forms with respect to the existing criteria; direct adoption, suitable 

adaptation, and recognition of the need for and development of specialized 

criteria. Direct adoption of the existing criteria was possible in many instances and provided a ready means of ensuring a comparable level of safety. 

Examples of direct adoption are numerous and include industry standards for 

electrical and mechanical equipment and many of the NRC regulatory guides. 

For those existing criteria that could not be regarded as unequivocably applicable, suitable adaptations were developed to permit the use of the phrase, 

11meets the objectives of 11 or words to this effect. Development of such adaptations was usually a straightforward practice of the applicant identifying and 

justifying discrepancies from the criteria followed by a staff review of the 

applicant•s approach. An early example of the adaptive approach was the means 

for conformance of the Fort St. Vrain design to the Commission•s General Design 

Criteria for LWRs. 

For those portions of advanced reactor designs that were uniquely different 

from those of LWR designs (e.g., requirements for handling a sodium coolant or 

the use of a concrete reactor vessel for HTGRs), adoption or adaptation of 

existing regulations or standards was not possible or desirable. Such criteria 

needs were satisfied by engineering judgment and analysis resulting in the 

development of specialized licensing criteria. 

Although the above developments have taken place in the advanced reactor area, 

they only provide a general background for the scope and intent of the present 

Advanced Reactor Policy Statement. The first formal development of advanced 

reactor policy began at a Commission meeting held on November 30, 1983, during 

which the Commission•s responsibilities toward encouraging the development of 

reactor types of 11 greater inherent safety11 were discussed. NRC 1 s Office of 

Policy Evaluation (OPE) was asked to prepare an initial draft statement that 

was to include a discussion of the Commission•s role in advanced reactor design 

in relation to NRC 1 s enabling legislation. This draft was reviewed by the 

Office of Nuclear Reactor Regulation (NRR) and later discussed with the Commission at a meeting held on February 27, 1984. NRR participated with OPE in the 

further development of the statement and after substantial Commission and staff 

review, a statement of 11 Proposed Policy for the Regulation of Advanced Nuclear 

Power Plants 11 was published for comment on March 26, 1985 (50 FR 11884). The 

proposed Policy Statement included a description of the way the regulation of 

advanced reactors is guided by the legislative background and noted that the 

NRC 11 is precluded from designing, or doing research on, complete new designs 

NUREG-1226 2-2 
for the purpose of establishing or developing their commercial potential. 11 

This principle avoids a conflict of interest since the NRC would not be placed 

11 in a position to generate, and then have to defend, basic design data of its 

own. 11 

A 60-day comment period for the Policy Statement followed its publication and 

20 responses were received. These responses are identified and discussed in 

Section 3, 11Abstract of Comments. 11 After consideration of the comments and 

further review by the Commission and the staff, the final Policy Statement was 

issued. One of the features of the proposed Policy Statement was the inclusion 

of six questions on advanced reactor policy. The final Policy Statement 

restates these questions together with the Commission•s own responses. The 

commenters• responses to the questions are discussed in Subsection 3.5, 11 Response to Questions. 11 A discussion of the major changes in formulating final 

Commission advanced reactor policy from that proposed in 1985 is given in 

Section 4, 11 Formulation of Final Policy. 11 

NUREG-1226 2-3 
Table 2.1 Advanced Reactor Regulatory Experience 

Part A - High Temperature Gas-Cooled Reactors 

(The General Atomic Company and its successors were responsible for all HTGR designs) 

Project Identification 

Peach Bottom I - 40MWe, 

Philadelphia Electric 

Company, Peach Bottom, 

Penn. 

Fort St. Vrain - 330MWe, 

Public Service Company of 

N Colorado, Weld County, ~ Colo. 

1000 MWe HTGR Study 

Summit and Fulton Plants, 

Sited in Delaware and 

Pennsylvania, but 

never built, 

700-1000 MWe. 

Operational and/or 

Regulatory Experience 

Construction initiated 

in 1962. OL granted in 

1967. Highly successful 

operation between 1967 

and 1974. 

Constructed between 1968 and 

1974. OL granted in 1974. 

Operation sporadic, mainly 

caused by water ingress from 

helium circulator bearings. 

A 1969 study involving 

both the staff and ACRS to 

upgrade HTGR power level. 

Favorable ACRS letter 

issued. 

Licensing activities 1973 

to 1975. Favorable SERs 

and ACRS letters issued 

but plants cancelled for 

economic reasons prior 

to public hearings and CP 

issuance. 

Comments and Remarks 

First HTGR in U.S. Demonstrated cermanic (graphite) 

core design and ceramic fuel. Fuel concept differed 

from later HTGRs as design provided for fission product release and clean-up. Reactor project terminated 

for economic reasons. 

Provided basis for modern, large HTGR concept 

through introduction of PCRV, integrated primary 

coolant system, improved fission product retention 

in fuel particles through use of silicon carbide 

layer. Fuel and steam generator performance 

excellent. 

LWR type large containment vessel determined to be 

necessary for an HTGR of this size. 

Design based on 1000 MWe study. Substantial 

component development program planned. 
~ 

I 

U"' 

Project Identification 

Gas Cooled Fast Breeder 

Reactor - GCFR 

GASSAR - a standard 

plant review based on 

Fulton Reactor Design 

Severe Accident Source 

Term Study - PRA study 

performed by RES 

Contractors on 

2240MW(t) concept. 

Table 2.1 (Cont'd) 

Part A - High Temperature Gas-Cooled Reactors 

Operational and/or 

Regulatory Experience 

Concept reviewed by staff 

and ACRS between 1971 and 

1975. Staff concluded 

that a demonstration 

plant, subject to the 

conditions of its SER, 

could be built. 

Staff review initiated 1974, 

terminated in 1977 with an 

interim SER. 

Study performed between 

1982 and 1984. !neonconclusive quantitative 

results but valuable 

insights into HTGR severe 

accidents developed. 

Comments and Remarks 

Some SER concerns about ECCS were later addressed by 

use of a natural convection design for decay heat 

removal when pressurized. 

Detailed review of fission product 

release from fuel experiments published 

as NUREG-0111. 

Forms a basic starting point for continued HTGR 

severe accident analysis. Did not consider air 

and water ingress events. 
2: 

c 

~ 

~ 

~ 

~ Project Identification ~ 

~ 

en 

~ 

I 

en 

EBR-1 (Experimental 

Breeder Reactor) INEL 

Site, Idaho 1.4 MWt 

EBR-11 Idaho 

62.5 MWt INEL: Site 

(Experimental Breeder 

Reactor) 

SRE Sodium Reactor 

Experiment Santa Susana, 

Calif., 20 MWt 

Hallam Nuclear Power 

Facility - Hallam, Nebr. 

240 Mwe 

Fermi-! 

Lagoona Beach, Mich. 

200 MWt 

SEFOR (Southwest Experimental Fast Oxide Reactor) 

Strickler, Ark. 

20 MWt 

ETEC Facilities - Santa 

Susana, Ca 1 if. 

(Non-Nuclear) 

FFTF (Fast flux Test 

Facility), Hanford, Wash 

400 MWt 

Clinch River Breeder 

Reactor - Oak Ridge, 

Tenn. 975 MWt 

Table 2.1 (cont'd) 

Part B - Liquid Metal Reactors 

(Fast Reactors Unless Otherwise Noted) 

Operational and/or 

Regulatory Experience 

Plant not reviewed or 

licensed by NRC. Startup 

1951, Shutdown in 1964 

Plant not reviewed or 

licensed by NRC. Startup 

1963, Continues in 

operation 

Startup 1957, Shutdown 1964 

Startup in 1962, Shutdown 

1964 

Startup 1963, Shutdown 1963 

Startup in 1969, Shutdown 

in 1972 

Sodium equipment test 

facility 

Constructed 1971-1980, NRC 

performed a safety review 

of the design and issued an 

SER (NUREG-0365) in 1978. 

NRC completed the SER 

(NUREG-0968) and public 

hearing for CP in 1983. 

Comments and Remarks 

NaK cooled, first commercial 

power generation 

Has operated successfully for 24 years. 

Demonstrated inherent safety characteristics of liquid metal reactors and 

metal fuel 

Sodium Graphite Reactor (Thermal Reactor) 

Sodium Graphite Reactor (Thermal Reactor) 

Experienced fuel melting from partial core 

flow blockage. Returned to service but 

shutdown for economic reasons. 

Operated successfully until shutdown due to 

completion of its mission. Demonstrated 

inherent negative reactivity feedback in 

oxide fuel. 

Demonstrated liquid metal component 

performance. 

Plant has operated successfully for 6 

years. Has demonstrated oxide fuel 

system. 

Plant never built due to lack of funding. 

Much R&D done in support of design. 

Designer 

Argonne National 

Laboratory 

Principal Nuclear 

Contractor 

Argonne NatiOnal 

Laboratory 

Atomics International 

Atomics International 

Power Reactor 

Development Corp. 

General Electric 

Atomics International 

Westinghouse 

Westinghouse 
3 COMMENTS ON PROPOSED POLICY 

This section consists of abstracts and discussions of the public comments that 

were submitted on the Commission•s proposed Policy Statement on advanced reactors published on March 26, 1985 (50 FR 11884). The abstracts were prepared 

from the 20 sets of comments from the organizations listed in Table 3.1. These 

organizations, which are indicated parenthetically, can be categorized according 

to the following groups: nuclear utilities (4, 6, 12, 16, 19); nuclear industry, 

(1, 3, 8, 9, 10, 11, 13, 15, 18, 20); national laboratories (2, 7); academic 

institution (17); government agency (5); and public interest group (14). The 

general reactions of the commenters and their responses to the six Commission 

questions are discussed in the following sections. 

The abstracts are intended as accurate as possible representations of the oral 

and written comments that were received. In the interest of brevity, however, 

the commenters• reasons for their views are not given in detail; therefore, the 

abstracts may not be totally accurate. The reader who finds an abstract unclear and wishes to know exactly what the commenter said should consult the 

original comments; these are available for inspection at the Commission•s 

Public Document Room, 1717 H Street, N.W., Washington, DC 20555. 

3.1 Overall Reaction 

The commenters unanimously supported the issuance of a policy statement. All 

except one (14) endorsed the desirability of simplifying and stabilizing the 

regulatory process and called for less specificity in the NRC 1 s regulations, 

although they differed somewhat in the specific details of the process they 

would endorse. These commenters generally supported NRC 1 s use of top-level 

public risk objectives, with most explicitly referencing safety goals. Although 

generally endorsing the Commission•s objectives for advanced reactors that were 

stated in the proposed Policy Statement, all but two (13, 14) felt that they 

should not be considered as NRC requirements. Most believed that the baseline 

for acceptability should be the level of safety required of current light water 

reactors. 

Most commenters were supportive of an Advanced Reactors Group and continuing 

interactions between the industry and the NRC during the development process. 

However, there were some differences in their views. In addition, there was 

confusion among the commenters about the type of reactor to which the policy 

statement was applicable and the extent of the difference from current reactors 

before a reactor could qualify as an 11 advanced11 reactor; some explicitly 

suggested that the Commission clarify this point. Summarized below are the 

comments received on the individual sections of the proposed Policy Statement, 

including the six questions. 

NUREG-1226 3-1 
Table 3.1 Table of Commenters 

Reference 

Number Name 

1. Doan L. Phung 

2. J. 0. Zane 

3. John J. Taylor 

4. D. W. Edwards 

5. James W. Vaughan, Jr. 

6. H. L. Brey 

7. Herman Postma 

8. T. E. Northup 

9. L. D. Mears 

10. A. E. Scherer 

11. R. B. Bradbury 

12. L. Bernath 

13. John C. Young 

14. E. Nemethy 

15. Glenn G. Sherwood 

16. Hal B. Tucker 

17. M. Golay, D. Lanning 

and L. Lidsky 

18. E. P. Rahe, Jr. 

19. J. R. Thorpe 

20. R. P. Schmitz 

NUREG-1226 3-2 

Affiliation 

Professional Analysis, Inc. 

EG&G Idaho, Inc. 

Electric Power Research Institute 

Yankee Atomic Electric Company 

Department of Energy 

Public Service Company of Colordao 

Oak Ridge National Laboratory 

GA Technologies, Inc. 

Gas-Cooled Reactor Associates 

Combustion Engineering, Inc. 

Stone & Webster Engineering Corp. 

San Diego Gas & Electric 

International Energy Associates Limited 

Ecology/Alert 

General Electric Company 

Duke Power Company 

Department of Nuclear Engineering, 

Massachusetts Institute of Technology 

Westinghouse Electric Corporation 

GPU Nuclear 

Bechtel Power Corporation 
3.2 Scope 

The proposed Policy Statement defined advanced reactors as 11 reactor designs 

which are significantly different from the present generation light water reactors.11 Most commenters (1, 2, 6, 7, 9, 10, 11, 12, 13, 14, 16, 17, 20) either 

accepted or did not mention the Commission•s definition. Some (5, 8) explicitly 

supported the definition. The Electric Power Research. Institute (EPRI) (3) 

believed that the statement was applicable to both advanced reactor designs based on 11 evolutionary improvements demonstrated by current light water reactor technology11 and to those based on 11 substantial changes or radical departures from current technologies 11 and criticized the statement- for not defining criteria 

that distinguished between the two. Similarly, Westinghouse (18) stated that 

11 the policy statement should recognize that future designs do not necessarily 

require different features to be viable and licensable. 11 Others (4, 15) believed 

that the scope of the Policy Statement was unclear and needed revision. 

3.3 Interaction with NRC 

Many commenters (2, 3, 5, 8, 11, 13) supported the earliest possible interaction 

between the industry and the NRC during the development process, with the NRC 

Advanced Reactors Group responsible for this interaction. Others (1, 4, 6, 7, 

10, 14, 15, 17, 19) did not explicitly discuss this issue. Duke Power Company 

(16) expressed the opinion that the NRC should be cautious so as not to unduly 

influence, either positively or negatively, the selection of alternative concepts at the conceptual design stage and should deal with industry in a cooperative but independent manner. 

San Diego Gas and Electric (12) was negative in its reaction to the concept 

of early interaction with the Commission and disclosure of the Commission•s 

safety judgements to the public throughout the process. This commenter stated: 

11These •motherhood• statements are antithetical, since premature disclosure of 

design details, before being fully analyzed and verified, raises expectations, 

which subsequently may require substantial modification to be viewed by the 

regulators and the anti-nuclear activists as equivocation. Also, early interaction invites critical assessment before all design features are fully coordinated into a defensible, validated whole. The NRC should take care to minimize 

opportunities for demagoguery and the fostering of misconceptions. 11 

Gas Cooled Reactor Associates (GCRA) (9) felt that the Policy Statement needed 

to be revised to 11 include a statement to the effect that the NRC will actively 

pursue the development of mechanisms for the timely and effective incorporation 

of data from other countries into the licensing process. 11 Westinghouse (18) 

voiced opposition to the aspect of NRC interaction with foreign sources by stating: 11We strongly question the USNRC 1 s stated willingness in this policy 

statement to review designs proposed by foreign vendors. The Atomic Energy Act 

of 1954, as amended, provides no extraterritorial jurisdiction to the NRC in 

the review of designs which may neither be manufactured or licensed in the 

United States. Improper exercise of USNRC jurisdiction could give rise to legal 

challenges. 11 Westinghouse also felt that technical review responsibilities 

should rest with the current staff technical organization and not with a new 

staff group. 

NUREG-1226 3-3 
3.4 Standardization 

Only two comments were received with respect to standardization. The Department 

of Energy (DOE) (5) stated: 

11The Department considers that it is critically important to improve 

the efficiency of the nuclear licensing and regulatory process and 

has had introduced into both Houses of Congress the 11 Nuclear Facility 

Standardization Act of 198511 to accomplish that objective. Any policy statement on the regulation of advanced reactors should be supplementary and complementary to that prime objective. 11 

In contrast, the Public Service Company of Colorado (6) stated: 

11 As a general comment, PSC supports the Commission•s 1985 Policy and 

Planning Guidance statement that encourages industry to pursue standardization of the current generation of nuclear power reactors. 

However, the immediate application of this policy to advanced nuclear 

reactors may be inappropriate, since advanced reactors, by definition, are reactor designs which are significantly different from the 

present generation of light water reactors and the various advanced 

reactor concepts ordinarily differ in many ways from one another. 

Until a particular advanced reactor develops into a proven design 

that is capable of giving rise to a new family of nuclear power 

plants, it would be premature to think in terms of standardization 

for such units. 11 

3.5 Responses to Questions 

Question 1 - Regulatory Approach 

11Should NRC 1 s regulatory approach be revised to reduce dependance on prescriptive regulations and instead establish less prescriptive design objectives, such as performance standards? If so, in what aspects of 

nuclear power plant design (for example, reactor core power density, reactor core heat removal, containment, and siting) might the performance 

standards approach be applied most effectively? How could implementation 

of these performance standards be verified? 11 

All commenters agreed that a less prescriptive approach to regulation (than the 

current one) is desirable, with the exception of the commenter from Ecology 

Alert (14), who did not address the issue. Almost all of these expressed the 

view that advanced reactors should be subject to top-level risk objectives or 

safety goals concerned with public health and safety and that any subsidiary 

performance standards should be closely related to showing compliance with 

these goals: in other words, they did not want regulation to otherwise 

restrict the design of advanced reactors. Most commenters felt that any design 

objectives should be broad enough to permit or encourage innovation. EPRI (3) 

differentiated between designs evolving from current reactors, which it feels 

should be regulated under an improved version of the current process, and 

reactors based on radical design approaches, for which it deems performance 

standards practical. DOE (5) emphasized the importance of a predictable, 

NUREG-1226 3-4 
well-defined licensing process which identified information required and 

methodology used by NRC to judge compliance with the top-level criteria. Duke 

Power Company (16) contended that use of performance standards rather than 

design-oriented regulations is not enough to avoid prescriptive regulation. It 

also argued that the management structures of NRC and industry, and the interactions between them, must be changed. Oak Ridge National Laboratory (ORNL) 

(7) suggested establishing performance standards for essentially all aspects of 

the nuclear steam supply system and all systems which determine the safety of 

the public. Several commenters (5, 7, 18) stated that, to the extent that more 

detailed standards are needed, general NRC regulations should be supplemented 

as necessary by industry standards and codes. Several commenters (4, 7, 10, 

15) believed that standardization will reduce the need for prescriptive regulation. Several others (2, 7, 9, 13, 15, 16) discussed the need for standards 

which permit simple verification and give designers considerable latitude and 

responsibility for demonstrating compliance. 

Question 2 - Inherent Safety 

11 Should the regulations for advanced reactors require more inherent safety 

margin in their design? If so, should the emphasis be on providing features that permit more time for operator response to off-normal conditions, or should the emphasis be on providing systems that are capable of 

functioning under conditions that exceed the design basis. 11 

Commenters were divided in their opinions on whether advanced reactors should 

be more inherently safe but generally believed that the regulations should not 

require a degree of supplemental safety (beyond the top-level safety goals). 

Two (13, 14) believed that regulations should require more inherent safety. 

Four (3, 7, 8, 15) considered greater safety margins appropriate for advanced 

reactors and thought that NRC should encourage or give credit for margins 

incorporated by designers rather than require them. General Electric (15) 

stated that it would be more appropriate to reduce uncertainty in safety assessments. A number of others (2, 4, 5, 6, 9, 11, 12, 16, 18, 20) believed that a 

safety margin is not necessary because it would be redundant to a well-conceived 

design objective, would undermine the objective and lead to additional, unnecessary standards, and would not recognize the adequacy of the current level of 

safety. Two commenters (16, 19) suggested that a clear definition of design 

objectives would incorporate safety margins to the extent necessary and that 

separate margins would not be necessary. 

No commenters advocated requirements for systems capable of functioning under 

conditions that exceed the design basis. Ecology/Alert (14) recommended requiring passive measures. A number of commenters (1, 2, 5, 6, 7) did not 

express a view as to which safety approach should be emphasized, but advocated 

leaving the choice to designers. A number of others (3, 8, 9, 10, 13, 14, 15, 

16) suggested that designs should incorporate passive features which permit 

more time for operator response, but none stated a preference for requiring 

this. 

Question 3 - Simplified Designs 

11 Should licensing regulations for advanced reactors mandate simplified 

designs which require the fewest operator actions, and the minimum number 

NUREG-1226 3-5 
of components needed for achieving and maintaining safe shutdown conditions, thereby facilitating operator comprehension and reliable system 

function for off-normal conditions? 11 

While all commenters (except Ecology/Alert (14), who did not comment on 

Question 3) expressed the view that simplicity of design should not be a regulatory criterion, there was strong support for encouragement of simplicity in 

design (7, 8, 15). International Energy Associates Limited (lEAL) (13) stated 

that it is unnecessary for NRC to require simplicity; rather, inherent safety 

will yield simplicity. ORNL (7) believed that simpler designs are likely to 

make safety more predictable and verifiable and reduce burdens on both the 

operator and the regulator. 

ORNL (7) gave further support to this concept by stating that facilities 

to enhance operator comprehension and understanding and to achieve reliable system 

functions should be required for both normal and off-normal conditions. It 

noted that these may be achieved by simplification of design to require fewer 

operator actions e.g., by providing the operator with automated assistance, 

improved information display and more extensive analytical systems. 

Some commenters (2, 5, 8, 18) stated that the designer must be free to balance 

safety and ease of operation with plant availability, to balance greater time 

for operator action against plant economics, or to balance the extent of operator 

action against the degree of design complexity. DOE (5) further stated that regulatory policy should encourage flexibility. 

Other views included the statement of GCRA (9) that additional hardware complexity should be avoided where increased operator understanding can achieve a 

net gain in safety. Westinghouse (18) stated that reducing the number of operator actions results in more system complexity because it requires more automatic functions. lEAL (13) said that NRC should consider a goal for advanced 

reactors of 11walk away11 safety--that is, the reactor system will shut itself 

down to a safe condition without any operator action. In summary, commenters 

generally were opposed to any regulation of simplicity in design, but believed 

that the regulatory policy should encourage it. They further believed that 

once the top-level safety criteria had been achieved, it is the responsibility 

of the designer to trade off or balance design simplicity and increased safety 

margin with economics of the plant operation. 

Question 4 - Design Criteria 

11 Should the NRC develop general design criteria for advanced reactors by 

modifying the existing regulations, which were developed for the current 

generation of light water reactors, or by developing a new set of general 

design criteria applicable to specific concepts which are brought before 

the Commission? 11 

All but two commenters (18, 19) believed that a new set of design criteria 

should be developed. Westinghouse (18) believed that the current General Design 

Criteria are nonprescriptive and have proven to be 11 remarkably durable 11 , and that 

a new set of criteria would not be consistent with stability and certainty in 

the licensing process. On the other hand, GPU Nuclear (19) felt that the existing General Design Criteria did need to be modified to be 11 less prescriptive 

and more criteria-oriented. 11 EPRI (3) believed that the current criteria should be 

NUREG-1226 3-6 
employed for evolutionary reactors, unless they could be shown to be excessively conservative, and that new criteria may need to be developed for advanced reactors based on radical design changes. The remainder of the commenters 

(except for four who did not comment on this question), felt that a new set of 

General Design Criteria should be developed. Two commenters (1, 11) felt that 

a unified set of criteria was necessary, with specific implementation being 

reactor type specific. Four commenters (1, 8, 9, 17) specifically stated that 

these should be developed and traceable to a safety goal based on acceptable 

risk to the public health and safety. Eight (4, 5, 6, 7, 9, 13, 15, 20) stated 

that they believed the criteria should be reactor type specific. Four (4, 6, 

12, 13) felt that the industry and NRC should develop the criteria cooperatively. DOE (5) believed the criteria should be developed as part of the 

interactions between the NRC staff and each of the Department's advanced 

reactor programs during the development of the individual concepts. 

Question 5- Encouragement of Simplified and High Reliability Systems 

"Should the NRC favor advanced reactor designs that concentrate the primary 

safety functions in very few large systems (rather than in multiple subsystems), thereby minimizing the need for complex benefit and cost balancing in the engineering of safe reactors?" 

The 18 commenters that responded to the question supported the concept of 

design simplification. Fourteen commenters (1, 2, 3, 4, 5, 6, 8, 9, 11, 12, 

15, 18, 19, 20) stated that they were opposed to the NRC favoring any particular design. Generally, they believed that it was up to industry to balance 

among concepts to arrive at a final design without the NRC being prescriptive 

in defining design requirements. One commenter (14) felt that the NRC should 

change emphasis from "defense-in-depth" to "simplifying reactor design, placing 

the core at least 10 feet underground, and doubling the thickness of the containment since the concept of 'defense in depth,' with multiple safety systems, 

simply adds to the number of buttons, levers and blinking lights." The 

remainder did not address this latter point. 

Question 6 - Degree of Proof 

"What degree of proof would be sufficient for the NRC to find that a new 

design is based on technology which is either proven or can be demonstrated by a satisfactory technology development program? For example, is it 

necessary or advisable to require a prototypical demonstration of an advanced reactor concept prior to final licensing of a commerical facility?" 

Of the 20 commenters, 19 responded to this question. Nine of these (3, 4, 

6, 11, 13, 15, 16, 18, 20) commented that whether or not a prototype of a facility would be required would be a function of the degree of departure from 

existing proven technology, the degree of uncertainty in the technology and any 

specific concerns with the technology. They stated that these factors would 

determine the need for prototype testing of either the facility or subsystems. 

Six (5, 6, 8, 9, 10, 15) believed that prototype testing should not be a requirement but an acceptable alternative to traditional methods for demonstrating compliance with the NRC's regulations. Four commenters (2, 7, 14, 19) felt 

that prototype testing for advanced reactors should be required. ORNL (7) 

cautioned that prototype testing would not be able to simulate such events as 

NUREG-1226 3-7 
natural disasters, fire, sabotage, or aircraft impact. San Diego Gas and Electric (12) felt that the term 11 proof11 was 11 totally inappropriate. 11 Professional 

Analysis, Inc. (1) believed that a prototype facility is not sufficient to 

prove a concept due to the low probability of accidents of safety concern and 

that a concept could only be demonstrated through component prototype testing 

combined with risk analysis. 

NUREG-1226 3-8 
4 FORMULATION OF FINAL POLICY 

4.1 Changes From Proposed Statement 

Changes in the proposed Policy Statement that were incorporated in the final 

Policy Statement reflect review and consideration of the public comments and 

input provided by the staff to the Commissioners on August 21, 1985 (SECY-85-279) 11 Revised Advanced Reactor Policy Statement11 • In many cases the changes are for 

the purposes of clarification. The changes judged significant are described 

below in the order that they appear in the final Policy Statement: 

(1) For clarification, an explicit list of three primary objectives has been 

added. 

(2) For clarification, the definition for an advanced reactor has been added 

to differentiate between reactors of innovative design and reactors that 

represent evolutipnary improvement over current generation light water 

reactors. This definition is discussed further in Section 5.1. 

(3) The final policy statement explicitly deals with the question of enhanced 

margins of safety and safety goals with the added statement: 

11 Regarding advanced reactors, the Commission expects, as a minimum, at 

least the same degree of protection of the public and the environment that 

is required for current generation LWRs. Furthermore, the Commission expects that advanced reactors will provide enhanced margins of safety and/or 

utilize simplified, inherent, passive, or other innovative means to accomplish their safety functions. The Commission also expects that advanced 

reactor designs will comply with the Commission•s forthcoming Safety Goal 

Policy Statement. 11 

This was added to make it clear that the Commission expects but does not 

require enhanced safety margins other than those that may be required by 

the safety goal policy. 

(4) The listed desirable attributes that could assist in establishing the 

acceptability or licenseability of a proposed advanced reactor design has 

been increased from five to nine. These attributes are essentially the 

same as stated in the proposed Policy Statement except that they have been 

expanded for clarity. A proposed paragraph and attribute relating to 

increased standardization and shop fabrication was not carried over to the 

final Policy Statement since this is not unique to advanced reactors. 

(5) A paragraph requesting early identification of plans for the use of proven 

technology and/or technology development programs was added in order to 

provide for early identification of issues which could impact standard 

plant approval and certification. 

NUREG-1226 4-1 
(6) The charter of the Advanced Reactors Group was expanded to 11maintain knowledge of advanced reactor designs, developments and operating experience 

in other countries 11 and to 11 provide guidance regarding the timing and format of submittals for review. 11 The implication that the NRC would review 

applications directly from foreign designers was removed. 

4.2 Responses to Questions 

The Commission•s response to the six questions contained in the proposed Policy 

Statement are included in the final Policy Statement. These responses were 

developed considering the public comments received and the staff input provided 

in SECY-85-279. The questions and the Commission•s response to each are contained on pages 14 through 19 in the Appendix. The questions and responses 

address the following topics: (1) Regulatory Approach, (2) Inherent Safety, 

(3) Simplified Designs, (4) Design Criteria, (5) Encouragement of Simplified 

and High Reliability Systems, (6) Degree of Proof. 

NUREG-1226 4-2 
5 GUIDELINES FOR UTILIZATION 

The purpose of this section is to discuss the staff•s plans for utilization and 

implementation of the guidance contained in the Advanced Reactor Policy Statement, including staff information needs and the approach to be used in the review of advanced reactor concepts. These plans are based both on the provisions of the Policy Statement and on certain related policies and regulations. 

It is not the purpose of this section to impose technical design requirements 

on advanced designs. 

The following paragraphs reflect the staff 1 s plans at this time which may be 

subject to evolutionary changes based on progress in the reviews of advanced 

reactor concepts and further developments in the LWR licensing structure. 

These plans are described here in order to provide guidance on the staff 1 s 

information needs and the staff 1 s approach to be used in the review of advanced 

reactor concepts. The staff reviews performed under the charter of the Policy 

Statement would occur before any formal application for review of either a 

one-of-a-kind plant or a standard plant, including design certification. In 

that sense they are the first of a multi-step process, leading toward construction and operation of an advanced nuclear power plant. However, this first 

step is not mandatory but reactor designers are encouraged to take advantage of 

it to obtain feedback early in the design process on licensing requirements. 

The review principles and results of the review discussed in this document 

would be expected to be used in subsequent reviews of that design, if and when 

a formal application for either a specific plant or a standard plant, including 

design certification, is filed. 

5.1 Definition of Advanced Reactors 

Advanced reactors are defined broadly in the Policy Statement as 11 those reactors 

that are significantly different from current generation light water reactors 

under construction or in operation and to include reactors that provide enhanced margins of safety or utilize simplified inherent or other innovative 

means to accomplish their safety functions. 11 The staff considers that in this 

frame work the term 11 current generation reactors 11 refers also to the most 

recent evolutionary LWR designs (such as the General Electric-Advanced Boiling 

Water Reactor and the Westinghouse and Combustion Engineering Advanced Pressurized Water Reactors) which have improved safety features. The attributes 

listed in the Policy Statement for advanced reactor designs provide further 

definition. Also, in general, reactor designs that utilize inherent or passive 

safety features (features that perform their function without dependence on or 

influence by electric power, actuation of mechanical devices, or operator 

action) to perform their safety functions will be considered advanced reactors 

in the context of the Policy Statement. For each design submitted to the Commission for review, a determination will be made case by case about whether it 

should be classified as an advanced reactor and treated under the Policy Statement. In addition to the above, reactor designs that are classified as 11 advanced11 

and are reviewed as part of the staff 1 s activities under the Advanced Reactor 

NUREG-1226 5-1 
Policy Statement, should have licensing requirements significantly different 

than those contained in the LWR Standard Review Plan (SRP), NUREG-0800. Accordingly, their review as an advanced reactor is intended to help ensure that 

appropriate regulatory requirements addressing the unique characteristics of 

these designs are developed in a timely fashion. At the present time certain 

high temperature gas-cooled reactor (HTGR) designs, liquid metal reactor (LMR) 

designs and innovative LWR designs* qualify as advanced reactor designs. 

5.2 Advanced Reactors Group-Contacts and Information Needs 

The Policy Statement sets out a charter for an Advanced Reactors Group (ARG) as 

follows: 

11This group will be the focal point for NRC interaction with the Department of 

Energy, reactor designers and potential applicants, and will coordinate the 

development of regulatory criteria and guidance for proposed advanced reactors. 

In addition, the group will maintain knowledge of and expertise on advanced 

reactor designs, knowledge of developments and operating experience in other 

countries, and will provide 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 Advanced Reactors Group will also provide guidance regarding the timing and format of submittals for review. 11 

At the present time, the ARG functions as part of the Advanced Reactors and 

Generic Issues Branch, Division of Regulatory Applications, RES. The main 

function of the ARG is to serve as the focal point for NRC review of advanced 

reactors at the conceptual design stage. In general, the staff will implement 

the Policy Statement by reviewing designs at the conceptual stage (before any 

formal application), developing guidance on the licensing criteria applicable to 

that design and making a preliminary assessment of the potential of that design 

to meet those criteria. This review will be done primarily by the staff (under 

the coordination and direction of the ARG) and will include the involvement of 

the ACRS. Commission review will also be requested on those matters considered 

to have policy or other major implications. 

Once a design has reached the point at which a formal application for review 

is submitted (either a plant specific license application or an application for 

standard plant review), its review will use and build on the initial reviews 

done by the ARG at the conceptual design stage. 

Reactor designers proposing to initiate interactions with NRC on the review of 

an advanced reactor conceptual design should contact the Director, Office of 

Nuclear Regulatory Research, USNRC, Washington, DC 20555 prior to submitting 

design information for review. 

Because of resource limitations, the NRC staff will have to determine case by 

case a priority for review of the proposed advanced concept considering such 

factors as: 

Those LWR designs that are consistent with the EPRI Advanced Light Water 

Reactor Design Requirements and/or contain significant safety advances 

beyond current licensing requirements may be reviewed under the guidelines 

of the Advanced Reactor Policy Statement. 

NUREG-1226 5-2 
(1) the potential of the design to result in an improvement in safety; 

(2) level of support behind the design (industrial involvement, utility 

involvement); 

(3) congressional or executive branch mandate; and 

(4) utility interest. 

1n general, it is desired that the scope of review of an advanced concept 

include review of the entire plant (see Section 5.3.4 for further description). To enable the staff to perform a meaningful review, the following information is desired: 

• Description of the plant design and its proposed design, safety and 

licensing criteria, including analysis of major accident scenarios demonstrating acceptable plant response. 

• Probabilistic risk analysis (see Section 5.3.3 for further description). 

• Description of those applicant sponsored R&D programs considered necessary 

to support development and licensing of the design. 

The results of the staff review of this information would then be documented 

in a Safety Evaluation Report. This Safety Evaluation Report will identify 

the key safety issues associated with the design, provide guidance on the 

licensing criteria applicable to that design, provide an assessment of the 

adequacy of the applicant sponsored research and development programs proposed 

in support of the design and, in consideration of the above, assess whether 

any obvious impediments exist to licensing the advanced reactor design. 

The following sections provide additional information regarding the staff review and information needs. 

5.3 Review Approach and Related Policies, Practices and Regulations 

As stated in the Advanced Reactor Policy Statement an advanced reactor must, 

as a minimum, have the same degree of protection of the public and environment 

as is required for current generation LWRs. However, enhanced margins of 

safety over current generation LWRs are expected. The degree of the enhanced 

margin of safety will be based on a judgment of the designs involving: 

• the extent to which the designs incorporate those attributes listed 

as desirable in the Policy Statement, 

• the uncertainties associated with the safety analysis and supporting 

base technology for the designs, 

• the extent to which margins and defense-in-depth are employed to 

account for these uncertainties, 

NUREG-1226 5-3 
• the capability and margin included in the design to prevent and mitigate severe accidents, including compliance with the Commission•s 

severe accident and safety goal policies, 

• the previous operating experience, existing technology and proposed 

R&D supporting the design. 

In consideration of the above, the staff will consider giving credit for enhanced 

safety characteristics incorporated into the design. This credit may be in the 

form of changed design criteria or administrative requirements. This section 

provides additional description of the key factors to be considered in the 

staff•s review of an advanced design. 

The existing regulatory structure for advanced reactors, of which the Policy 

Statement is now a part, ranges from top-level nonprescriptive criteria, such 

as the safety goal policy, to very detailed industry codes and standards. In 

reviewing an advanced reactor design at the conceptual design stage use will 

be made of the following NRC policies, practices, and regulations: (1) defensein-depth philosophy, (2) safety goal policy, (3) severe accident policy (4) 

standardization policy, (5) existing LWR regulations and guidelines, where applicable, and (6) industry codes and standards. 

How each of these items will be utilized by the staff in the review of advanced 

reactors is discussed below. 

5.3.1 Defense-in-Depth Philosophy 

There has been much discussion over the past several years about using less 

prescriptive or performance based licensing criteria and, it is noted, that 

novel design approaches could reduce the need for some types of safety equipment traditionally required on LWRs. Alternatives ranging from probabilistic 

based criteria to descriptive goal based criteria have been suggested. The use 

of such criteria is being explored and will be considered for advanced reactors 

(see Section 5.5). It is the staff•s opinion that such criteria should be 

consistent with or the defense-in-depth philosophy. This is especially true 

when considering reactor types for which there is significantly less design, 

construction and operating experience as compared to LWRs. Accordingly, the 

staff believes that it is still essential and intends to employ engineering 

judgment and the defense-in-depth philosophy in the review of advanced reactors 

to account for uncertainties in the design. Such uncertainties may be in the 

areas of component/system performance, reliability, analytical tools or supporting technology. The application of defense-in-depth may take various forms, 

such as: 

• requirements to prevent accidents, such as high reliability, redundancy 

and/or diversity in systems, structures and components, 

• requirements to mitigate accidents, such as long response times, multiple 

barriers, or safety systems, 

• requirements to contain radioactive materials. 

NUREG-1226 5-4 
The exact nature and extent of defense in depth to be required on an advanced 

design will be determined case by case on the merits of the design under review 

considering factors such as: 

• reliability of safety systems 

• supporting technology 

• uncertainties in analytical tools, reliability, supporting data base 

• margin in design for accidents beyond the design basis 

5.3.2 Safety Goal Policy 

On August 4, 1986, the Commission published a policy statement on 11 Safety Goals 

for the Operation of Nuclear Power Plants 11 (51 FR 28044). This policy statement 

focused on the radiological risks to the public from nuclear power plant operation and established goals that broadly define an acceptable level of such risks. 

Specific guidelines are being developed to establish a consistent level of 

safety between licensing criteria for advanced reactors and the safety goal 

policy. For advanced reactors these guidelines will be used, wherever 

appropriate. 

5.3.3 Severe Accident and Source Term Policies 

The Commission•s 11 Policy Statement on Severe Reactor Accidents Regarding Future 

Designs and Existing Plants 11 was issued on August 8, 1985 (50 FR 32138). Advanced reactors are expected to comply with the provisions of this policy that 

pertain to new plant applications. The staff is currently developing more 

detailed guidance regarding implementation of this policy statement. In 

addition, the regulatory procedures and criteria are being developed that will 

use the improved information from extensive research on radioactive material 

releases (i.e., source terms) under severe accident conditions. While some of 

the details of these severe accident and source term regulatory provisions may 

not be applicable to specific types of advanced reactors, advanced reactors 

are, in general, expected to conform to the relevant guidance they provide. 

Thus advanced reactor designers, when considering severe accidents and source 

terms at the conceptual design stage, are expected to show that the applicable 

portions of their designs meet 11 the intent of 11 or 11 the objectives of11 the 

following: 

(1) Demonstration of or commitment to compliance with the procedural requirements and criteria of the current Commission regulations, including the 

Three Mile Island requirements for new plants as reflected in the construction permit rule, 10 CFR 50.34(f) 

(2) Demonstration of or commitment to technical resolution of all applicable 

unresolved safety issues and the medium-priority and high-priority generic 

safety issues, including a special focus on ensuring the reliability of 

decay heat removal systems and the reliability of both ac and de electrical 

supply systems; 

(3) Completion of a prob~bilistic risk assessment (PRA) at the conceptual design stage and consideration of the severe accident vulnerabilities that 

the PRA exposes, along with the insights that it may add to the assurance 

that there is no undue risk to public health and safety. 

NUREG-1226 5-5 
Advanced reactor designers when addressing the above criteria are expected to 

take notice that the Policy Statement lists among the desirable attributes for 

proposed advanced reactor designs 11 designs that minimize the potential for 

severe accidents and their consequences by providing sufficient inherent safety, 

reliability, redundancy, diversity and independence in safety systems. 11 Potentially, an advanced reactor could be proposed that would meet these preventative 

requirements with such sufficiency that relief could be justified in the type of 

source terms and severe accident mitigative features from that traditionally 

employed on LWRs. However, advanced designs are expected to consider a balance 

between prevention and mitigation consistent with the uncertainty associated with 

their analysis and to provide sufficient information to justify their design 

choices. 

PRAs performed for the advanced reactor concepts should cover the whole plant, 

should address internal and external events as well as various plant operating 

states (full power, low power, refueling, etc.) and should confirm the bases 

for component and system selections, confirm the adequacy of overall plant 

design, be used to identify and correct any areas of high risk, and confirm the 

adequacy of plant response to severe accidents and mitigation measures. In 

addition, the PRA should be used to improve knowledge of component and structural reliability requirements and inservice inspection and testing needs. Any 

PRA must also estimate and factor in the uncertainties associated with it. 

These uncertainties must be factored into decisions which utilize PRA results. 

In addition, analysis should be presented at the ~onceptual design stage to show 

the margin available in the design to accommodate events of low probability and 

to maintain protection of the public and environment. 

5.3.4 Standardization Policy 

On September 15, 1987, the Commission published a policy statement on 11 Nuclear 

Power Plant Standardization .. (52 FR 34884). The development of advanced concepts should be consistent with the Commission•s standardization goals and 

policy from the project•s inception. Attention to the principles of standardization on advanced designs is not intended to discourage innovation but, rather, 

is intended to ensure that the end product is amenable to being standardized. 

Therefore, it is expected that advanced reactor designers should have as an 

ultimate goal the development of a standard plant design. Specific items 

regarding standardization which should be considered on advanced designs at the 

conceptual design stage are: 

(1) The use of standardized practices in design, manufacture, construction, 

operation, and maintenance, to the extent possible; 

(2) The use of standard components, structures, systems, and human engineering 

practices; 

(3) The use of proven state-of-the-art technology, to the maximum extent possible, in the conception, design, and construction of any advanced reactor. 

Where the design deviates from state-of-the-art technology, a comprehensive research, development, and testing program will be necessary to 

demonstrate that the component or design feature being proposed performs 

with known characteristics and sufficient reliability to warrant standardization. To this end, the Commission stated in its Advanced Reactor 

NUREG-1226 5-6 
Policy Statement that it 11 favors the use of prototypical demonstration 

facilities as an acceptable way of resolving many safety related issues 11 

(Section 5.4.4 provides additional information on prototype testing). 

(4) As a minimum, at the conceptual design stage, the designer should present 

an essentially complete nuclear plant design for review rather than just 

the nuclear island or the safety-related components. Although the formal 

application for design approval 1 and design certification2 may request 

design approval and certification of only interface criteria for certain 

systems, structures and components, a representative design for the 

complete plant should be presented at the conceptual design stage to 

allow the staff to assess the adequacy of the interface criteria and to 

aid in the review. 

To ensure that each of the above considerations is adequately addressed, 

designers should provide more information at the conceptual design stage than a 

simple commitment to meet standardization goals. Information should be provided 

that describes their plans for achieving standardization. 

5.3.5 Existing Regulations and Guidelines 

The Standard Review Plan (SRP) Rule (10 CFR 50.34(g)) requires that applications 

for light-water-cooled nuclear power plant construction permits, operating 

licenses, preliminary design approvals and final design approvals docketed after 

May 17, 1982, include an evaluation of the facility against the SRP in effect 

on May 17, 1982, or the SRP in effect 6 months before the docket date of the 

application, whichever is later. The staff believes that advanced reactor 

designers should also review the SRP for applicability to their designs at the 

conceptual design stage. For those SRP sections identified as applicable, the 

advanced reactor design should be consistent with those requirements. Where 

advanced designs are different, designers should propose alternatives to the 

SRP requirements to account for the unique characteristics of their design. 

In general, the staff will develop licensing criteria for advanced reactors by 

utilizing LWR criteria, where applicable, and by modifying existing criteria or 

developing new criteria to account for the unique characteristics of the design. 

The use of less or nonprescriptive criteria will be considered as discussed in 

Section 5.5. 

1Design approval is addressed in 10 CFR 50, Appendix 0, whereby a standard 

reactor design, or a major portion thereof, is reviewed and approved by the 

NRC staff and ACRS. The approved design would then be relied upon by the 

staff and ACRS in their review of individual license applications that reference the design. Design approval is a prerequisite to design certification. 

2Certification through rulemaking is addressed in 10 CFR 50, Appendix 0, whereby 

a standard reactor design, or a major portion thereof, is reviewed and approved by the NRC staff and then certified by the Commission for use through 

a formal rulemaking process. That portion of the design approved in a rulemaking proceeding would not be subject to review by the staff or challenge 

in individual license applications that reference the certified design. 

NUREG-1226 5-7 
5.3.6 Industry Codes and Standards 

The use of industry codes and standards for the technical details of reactor 

and support systems designs has been a fundamental part of reactor licensing 

for many years. Over the years a large body of such codes and standards has 

been developed by experts in conjunction with the NRC and provide in most cases 

the essential details of how higher level criteria, policies, guides, rules, 

and regulations may be met. Like the use of appropriate operational experience, 

the use of these existing codes and standards, wherever practicable, is encouraged in advanced designs rather than proposing specialized unique approaches. 

One of the reasons for the successful use of industry codes and standards in 

licensing LWRs is that the standards committees consist of a combination of 

members representing different interests and experiences such as reactor vendors, utilities, equipment manufacturers, and government and sometimes foreign 

representatives. The output of these committees represents a consensus on the 

important characteristics to be controlled in the areas covered by the standards. 

The staff encourages that committees such as the American Nuclear Society•s 

ANS-53, 11 HTGR Management Committee 11 and ANS-54, 11Committee on LMFBR Standards 11 

be continued and used by advanced reactor designers. 

5.3.7 Treatment of Sabotage 

As indicated by the quote below from the Commission•s Policy Statement on 

Severe Accidents, the importance of sabotage as a contributor to severe accident risk is recognized: 

11The issues of both insider and outsider sabotage threats will be 

carefully analyzed and, to the extent practicable, will be emphasized as 

special considerations in the design and in the operating procedures 

developed for new plants. 11 

In addition, Generic Issue A-29, 11 Nuclear Power Plant Design for the Reduction 

of Vulnerability to Industrial Sabotage, .. is one of the medium-priority 

Generic Safety Issues for which that policy expects new designs to demonstrate 

technical resolution. 

The Advanced Reactor Policy Statement, in response to question number 1, indicated that in the area of sabotage the Commission intends to make use of existing and future regulations in reviewing advanced reactors. As such, the 

vulnerability of advanced reactors to sabotage is an important consideration 

and advanced reactors will be required to meet the same regulations regarding 

physical protection as LWRs. It is expected that, in many cases, advanced reactors, due to their inherent safety characteristics and simplified safety systems, will be less reliant upon physical security systems and procedures for 

protection against sabotage than current generation plants. Accordingly, at 

the conceptual design stage, advanced reactor designers should submit a short 

description of the advantages and disadvantages their design provides in 

protection from insider and outsider sabotage as compared to a current generation LWR. 

NUREG-1226 5-8 
5.4 Supporting Technology 

The Policy Statement addresses the role of supporting technology several times 

as quoted below: 

11The Commission expects that these designs [for advanced reactors] 

will reflect the benefits of significant research and development 

work and include experience gained in operating the many power and 

deve 1 opment reactors both in the United States and throughout th.e 

world. 11 

11 Among the attributes ... which, therefore, should be considered in 

advanced design are: ... Design features that can be proven by citation of existing technology or which can be satisfactorily established by commitment to a suitable technology development program. 11 

11 During the initial phase of advanced reactor development, the Commission particularly encourages design innovations which enhance 

safety and reliability ... and which are either proven or can be demonstrated by a straight-forward technology development program. 11 

In the subsections below are brief discussions on the use of supporting technology in the areas of operating experience, technology development, foreign information and data and use of prototype testing. Advanced reactor designers 

are expected to provide information on the application of each of these areas 

to their designs. 

5.4.1 Operating Experience 

The staff believes that the use of technology proven through operating experience is the most direct, least expensive and preferred means for the demonstration of licensability of reactor concepts. The available sources of operating 

experience should be used wherever possible. It is emphasized that sources of 

useful operating experience are not limited to reactors. For example, other 

industries provide valuable experience with water systems, testing and inspection 

procedures, control systems, and electrical and mechanical systems and components. 

5.4.2 Technology Documentation and Development 

Each submittal for review of an advanced design at the conceptual design stage 

should include a 11 technology development plan11 or equivalent documentation. 

The technology development plan should document the scientific and engineering 

data that will be developed to support the design and safety analysis of the 

advanced reactor concept. This scientific and engineering data could include 

laboratory research, component development and testing, verifications during 

plant preoperational testing or startup, periodic testing and/or inspection 

during plant operation, and the use of a reactor prototype test. At the 

conceptual design stage the staff review will provide a preliminary assessment 

of the adequacy of the technology development plan for the design, utilizing 

engineering judgment, experience and insights gained from its review of the 

design. 

NUREG-1226 5-9 
5.4.3 Foreign Information and Data 

Foreign programs can provide valuable design information, operating experience 

and basic data about advanced reactors. Regardless of the reliance to be 

placed on the information from foreign sources, each advanced reactor applicant 

submitting its design to the NRC for review should provide a summary of any applicable foreign reactor experience. This should include a discussion of major 

design differences and similarities, performance related experience and applicable research and development. How this information was factored into the 

advanced design should also be discussed. This is considered important because, 

in general, the experience base associated with advanced concepts is less than 

that for LWRs and the consideration of other experience is essential. The use 

of foreign data to support a U.S. advanced reactor design is acceptable provided 

the staff has sufficient access to the design, analysis and experimental data 

being used. 

5.4.4 Use of Prototype Test 

The Advanced Reactor Policy Statement does not require a priori that a prototype 

test reactor be constructed and operated; however, it does state that ''The Commission favors the use of prototypical demonstration facilities as an acceptable 

way of resolving many safety related issues." The staff will, however, have to 

be satisfied for the design being reviewed that there is a basis for each claim 

regarding system and equipment performance and reliability. For reactor designs 

that depart significantly from proven technology, the staff favors the use of a 

prototype full-scale test facility to demonstrate those features of the design 

which are fundamental to its safety performance. This alternative has the 

potential for reducing or removing uncertainties because it will represent an 

integrated test of all plant systems under prototypical conditions, including 

the effects of construction, maintenance and operation. As part of the review 

of the conceptual design, the staff will make a case-by-case judgment about the 

need for a prototype test to resolve safety issues considering such factors as: 

(1) Departure from proven technology, 

(2) Uncertainties in performance and how they could be reduced, 

(3) Degree of defense-in-depth, and 

(4) Other R&D programs planned in support of the design. 

It must be kept in mind that prototype tests cannot impact many of the uncertainties associated with certain types of events such as earthquakes, sabotage, 

and degraded core accidents. Risks from these types of events must be evaluated using engineering judgment and where applicable, probabilistic methods. 

Regarding the need for a protypical demonstration facility to support design 

certification, the Commission stated in its Policy Statement on Nuclear Power 

Plant Standardization that "When an advanced design concept is sufficiently 

mature, e.g., through comprehensive, prototypical testing, an application for 

design certification could be made." Accordingly, advanced reactor designers 

should, at the conceptual design stage, describe their plans for the construction, testing and operation of a prototype plant to support design certification. 

NUREG-1226 5-10 
5.5 The Use of Less or Nonprescriptive Design Criteria 

The Commission•s guidance on and encouragement of the use of less prescriptive 

or nonprescriptive criteria in the regulatory process is given in its responses 

to two of the six questions contained in the proposed Advanced Reactor Policy 

Statement. These responses are included in the final Policy Statement, attached 

as an appendix to this document and are excerpted below: 

Response to Question 1 (Regulatory Approach) 

11 In developing additional criteria and guidance to address those 

characteristics which differ from LWRs less prescriptive criteria 

will be considered. The use of less prescriptive criteria will 

depend upon the design in question and the ability to verify compliance with the criteria. Advanced reactor designers are encouraged as 

part of their design submittals to propose specific review criteria 

or novel regulatory approaches which NRC might apply to their 

designs. 11 

Response to Question 4 (Design Criteria) 

11 In following this approach, it is the Commission•s intent to establish, for each design reviewed, the licensing criteria that apply to 

that design. As stated in the response to Question No. 1, these 

criteria will be a combination of applicable LWR criteria and criteria developed to address the unique characteristics of that design. 

Reactor designers are encouraged to propose specific criteria and 

novel regulatory approaches which might apply to their design. 11 

The Policy Statement does not include a definition for nonprescriptive criteria 

but does observe that 11Many of the Commission•s existing regulations, criteria, 

and guidelines are of a nonprescriptive nature ... 11 and cites the safety goal 

policy as an example. The development of less prescriptive regulatory requirements is also a goal in 11 NRC Policy and Planning Guidance, 11 NUREG-0885, Issue 5, 

1986. 

The role of and the justification for the use of less or nonprescriptive 

licensing criteria in those areas where existing LWR criteria do not apply is 

an area which will receive considerable emphasis in the review of advanced 

reactors. While the use of less or nonprescriptive criteria may be desirable 

in many cases, certain information and study is needed to assure that, in the 

event they are used, an acceptable level of safety is attained. To illustrate 

the information and considerations which need to be addressed in this area, a 

list of items follows that designers should be prepared to address during the 

course of an advanced reactor review if they propose to use less or nonprescriptive criteria for their designs. This list serves to illustrate the way 

newly proposed criteria will be examined by the staff. The fact that the staff 

will carefully evaluate any proposed new criteria is not intended to discourage 

their development. On the contrary, the staff encourages the development of 

improved regulatory approaches and will give high priority to reviews of new 

criteria to support the development of advanced reactors. In general, the 

staff expects advanced reactor designers to propose those criteria which, in 

their judgment, apply to their design, including any less or nonprescriptive 

criteria. Where such criteria depart from the traditional level of specificity 

NUREG-1226 5-11 
employed on LWRs regarding design configuration and plant performance, the 

following informat.ion should be provided to justify and clarify the use of the 

less or nonprescriptive criteria and to assist the NRC in making the requisite 

assessment: 

(1) A description of why such criteria are being proposed and what changes 

in the scope or type of NRC regulation are desired or implied by the use 

of the new criteria. For example, if probabilistic based criteria are 

proposed, will NRC be required to regulate data bases, reliability assurance 

programs or maintenance programs to help ensure reliability goals are met? 

(2) A description of the way the proposed criteria will lead to a safer plant 

design and not detract from safety. For example, would the use of the proposed criteria lead to the use of components, systems or structures of 

superior reliability than would be required by the traditional regulatory 

structure? 

(3) A description of the extent to which less or nonprescriptive criteria are 

to be employed in the regulation of the proposed design, including the 

proper mix between nonprescriptive and deterministic criteria, and considering the need to preserve the defense-in-depth philosophy to account 

for uncertainties and unknowns. 

(4) Standardization of design has long been encouraged by the Commission. It 

is possible that the adoption of less or nonprescriptive regulations could 

work against standardization. Although a less or nonprescriptive approach 

may seem attractive for new and innovative designs it should be noted that 

in the past this flexibility has produced instead a multiplicity of designs with no clear advantage among them. Therefore, a description would 

be useful of the compatibility of the proposed regulatory approach with 

the Commission's standardization goals, along with a description of how 

the nonprescriptive regulation should be implemented to ensure there is no 

detrimental effect on the Commission's standardization efforts. 

(5) The scope of the analyses to be used to justify and implement the proposed 

criteria should be discussed. This should include discussion of the way 

analyses are to be maintained over the life of the plant. For example, 

to implement reliability based criteria, should the reliability analysis 

be updated over the life of the plant to reflect both plant specific and 

industry wide operating experience? 

NUREG-1226 5-12 
6 REFERENCES 

Code of Federal Regulations, Title 10, 11 Energy, 11 U.S. Government Printing 

Office, Washington, D.C., January 1, 1987. 

U.S. Nuclear Regulatory Commission, 11 Regulation of Advanced Nuclear Power Plants; 

Statement of Policy, 11 51 FR 24643, July 8, 1986. 

U.S. Nuclear Regulatory Commission, 11 Proposed Policy for Regulation of Advanced 

Nuclear Power Plants, 11 50 FR 11884, March 26, 1985. 

U.S. Nuclear Regulatory Commission, SECY-85-279, 11 Revised Advanced Reactor 

Policy Statement, August 21, 1985. 

U.S. Nuclear Regulatory Commission, NUREG-0800, 11 Standard Review Plan for the 

Review of Safety Analysis Reports for Nuclear Power Plants, LWR Edition, 11 

July 1981. 

U.S. Nuclear Regulatory Commission, 11 Safety Goals for the Operation of Nuclear 

Power Plants, 11 51 FR 28044, August 4, 1986. 

U.S. Nuclear Regulatory Commission, 11 Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants, 11 (50 FR 32138) August 8, 

1985. 

U.S. Nuclear Regulatory Commission, 11 Nuclear Power Plant Standardization, 

Policy Statement, 11 52 FR 34884, September 15, 1987. 

U.S. Nuclear Regulatory Commission, NUREG-0885, 11 NRC Policy and Planning ... Issued February 5, 1986. 

NUREG-1226 6-1 

APPENDIX 

NUCLEAR REGULATORY CO~~ISSION 

10 CFR PART 50 

REGULATION OF ADVANCED NUCLEAR POWER PLANTSj 

STATEMENT OF POLICY 

AGENCY: Nuclear Regulatory Commission. 

ACTION: Final Policy Statement. 

SUMMARY: The Nuclear Regulatory Commission intends to 

improve the licensing environment for advanced nuclear power 

reactors to minimize complexity and uncertainty in the 

regulatory process. This statement gives the Commission's 

r 

policy regarding the review of, and desired characteristics 

associated with, advanced reactors. This policy statement 

is a revision of the "Proposed Policy for Regulation of 

Advanced Nu.clear Power Plants" that was published for 

comment on March 26, 1985 (50 FR 11884). 

EFFECTIVE DATE: 

FOR FURTHER INFORMATION CONTACT: Ken Herring and Dennis 

Rathbun, Office of Policy Evaluation, U.S. Nuclear 

Regulatory Commission, Washington, D.C. 20555, Telephone: 

202-634-3295. 
- 2 -

SUPPLEMENTARY INFO~~TION: 

BACKGROUND 

The Commission's primary objectives in issuing an advanced 

reactor policy statement are threefold: 

0 

0 

0 

First, to encourage the earliest possible interaction 

of applicant, 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 of advanced reactor designs; 

and 

Third, to express the Commission's intent to issue 

timely comment on the implications of such designs for 

safety and the regulatory process. 

Such interaction and guidance early in the design process 

should enhance stability and predictability in the licensing 

and regulation of advanced reactors. 

Advanced reactors are considered here ~o be those reactors 

that are significantly different from current generation 

light water reactors under construction or in operation. 
- 3 -

The Commission expects that these designs will reflect the 

benefits of significant research and development work, and 

include the experience gained in operating the nany power 

and development reactors both in the United States and 

throughout the world. The Commission expects that advanced 

reactors would provide more margin prior to exceeding safety 

limits and/or utilize simplified, inherent, passive, or 

other innovative means to reliably accomplish their safety 

functions. The Commission expects, as a minimum, at least 

the same degree of protection of the public and the 

environment that is required for current generation LWRs. 

For the longer term, the Commission expects designs to 

provide enhanced margins of safety. To provide regulatory 

guidance during the development phase of advanced reactor 

design, the Commission wishes to encourage the earliest 

possible interaction between the NRC and other government 

agencies, reactor designers, and potential licensees. 

This advanced reactor policy statement sets forth the 

general characteristics of advanced reactor design, which 

the Commission believes advanced reactors should exhibit, to 

increase assurance of safety, to improve public 

understanding, and to promote more effective regulation. As 

the agency responsible for assuring the protection of the 

public from the potential hazards of nuclear power plants, 

the Commission will keep the public informed of its judgment 
- 4 -

on the safety aspects of advanced reactor designs as such 

designs come before the Commission. 

A report which discusses the revisions to the Policy 

Statement will be published shortly as NUREG-XXX "TITLE." A 

copy of NUREG-XXX will be available for inspection at the 

Commission's Public Document ~oom, 1717 H Street, N.W., 

Washington, D.C. 

REGULATORY POLICY FOR ADVANCED REACTORS 

The Comrr.ission intends to improve the licensing environment 

for advanced nuclear power reactors and to minimize 

complexity and uncertainty in the regulatory process. This 

is a statement of the Commission's policy regarding the 

review of, and desired characteristics associated with, 

advanced reactors. This policy statement is a revision of 

the "Proposed Policy for Regulation of Advanced Nuclear 

Power Plants" that was published for comr.1ent on Harch 26, 

1985 (50 FR 11884). 

The Commission's primary objectives in issuing an advanced 

reactor policy staetment are threefold: 

0 First, to encourage the earliest possible interaction 

of applicant, vendors, u.nd government agencies, with 

the NRC; 
0 

0 

- 5 -

Second, to provide all interested parties, including 

the public, with the Commission's views concerning the 

desired characteristics of advanced reactor ~csigns; 

and 

Third, to express the Commission's intent to issue 

timely comment on the implications of such designs for 

safety and the regulatory process. 

Such interaction and guidance early in the design process 

should enhance stability and predictability in the licensing 

and regulation of advanced reactors. 

The Commission considers the term "Advanced" to apply to 

reactors that are significantly different from current 

generation light water reactors (LWRs) now under 

construction, or in operation and to include reactors that 

provide enhanced margins of safety or utilize simplified 

inherent or other innovative means to accomplish their 

safety functions. 

Currently, certain high temperature gas-cooled reactors 

(HTGRs) , liquid metal reactors (LMRs) , and light-water 

reactors (LWRs) of innovative design are considered advanced 

designs. 
- 6 -

LEGISLATIVE BACKGROUND 

The Commission's policy with respect to regulation of 

advanced reactcrs is guided by the legislative background. 

The Energy Reorganization Act of 1974, which established the 

' Nuclear Regulatory Commission, specifically delegated to NRC 

"licensing and related regulatory authority" for 

demonstration nuclear reactors other than those already in 

existence " ••• when operated as part of the power generation 

facilities of an electric utility system, or when operating 

in any other manner for the purpose of demonstrating the 

suitability for commercial application of such a reactor •.• " 

The Energy Research and Development Administration (now the 

Department of Energy) was charged with " ••• encouraging and 

conducting research and development, including demonstration 

of commercial feasibility and practical applications of the 

extraction, conversion, storage, transmission, and 

utilization phases related to the development and use of 

energy from .•. nuclear .•• sources." 

Under Section 205 of the Energy Reorganization Act, the NRC 

must provide a "Long-term plan for projects for the 

development of new or improved safety systems for nuclear 

power plants." The NRC is precluded from designing, or 
- 7 -

doing research on, complete new designs for the purpose of 

establishing or developing their commercial potential. 11 

PREVIO~S EXPERIENCE 

The Commission has had experience in the regulation of HTGRs 

and LMRs as well as in the regulation of LWRs. The NRC has 

reviewed several applications for HTGR construction permits, 

and a conceptual design for a gas-cooled breeder reactor, 

and has granted an operating license to Peach Bottorn-1 and 

to Fort St. Vrain. The NRC also expended substantial effort 

from 1975 to 1919 in reviewing General Atomic's Standard 

high-temperature, gas-cooled nuclear reactor steam supply 

system (GASSAR). In addition, the NRC has supported a 

modest program of safety research on gas-cooled reactors 

every year since the agency's inception. 

The Commission has also had experience in the review and 

licensing of LMRs. In the past the FERMI-1 and SEFOR 

reactors were reviewed and licensed. DOE's Fast Flux Test 

Facility (FFTF) was reviewed and approved but not licensed, 

and a formal construction permit licensing proceeding was 

1/ The general principal defining the scope of NRC's 

research can be described as avoiding a conflict of 

interest-- "[NRC] should never be placed in a position 

to generate , and then have to defend, basic design 

data of its own" as expressed in the Conference Report 

to the Energy Reorganization Act of 1974. 
- 8 -

conducted for the Clinch River Breeder Reactor (CRBR). The 

CRBR was subject to the same regulatory process as any 

current commerical nuclear power project. 

Finally, the Commission notes that the precedent for the 

broad policy approach to advanced reactor regulation, as 

proposed here, is firmly established in the 1979 

Nonproliferation Alternative Systems Assessment Program 

(NASAP) , wherein the NRC considered the safety and 

licensability of a variety of advanced reactor concepts 

within the context of nonproliferation objectives. The 

concepts considered and reported on by the NRC in the 1979 

study ranged from preliminary conceptual designs to 

variations of existing (LWR) power plants designs. 

COMMISSION POLICY 

Consistent with its legislative mandate, the Commission's 

policy with respect to regulating nuclear power reactors is 

to assure adequate protection of the public health and 

safety and the environment. Regarding advanced reactors, 

the Commission expects, as a minimum, .at least the same 

degree of protection of the public and the environment that 

is required for current generation LWRs. Furthermore, the 

Commission expects that advanced reactors will provide 

enhanced margins of safety and/or utilize simplified, 

inherent, passive, or other innovative means to accomplish 
- 9 -

their safety functions. The Commission also expects that 

advanced reactor designs will comply with the Commission's 

forthcoming safety goal policy statement. 

Among the attributes which could assist in establishing the 

acceptability or licensability of a proposed advanced 

reactor design, and which therefore should be considered in 

advanced designed are: 

0 

0 

0 

Highly reliable and less complex shutdown and decay 

heat removal systems. The use of inherent or passive 

means to accomplish this objective is encouraged 

(negative temperature coefficient, natural 

circulation) . 

Longer time constants and sufficient instrumentation to 

allow for more diagnosis and management prior to 

reaching safety systems challenge and/or exposure of 

vital equipment to adverse conditions. 

Simplified safety systems which, were possible, reduce 

required operator actions, equipment subjected to 

severe environmental conditions, and components needed 

for maintaining safe shutdown conditions. Such 

simplified systems should facilitate operator 

comprehension, reliable system function, and more 

straight-forward engineering analysis. 
0 

0 

0 

0 

0 

0 

- 10 -

Designs that minimize the potential for severe 

accidents and their consequences by providing 

sufficient inherent safety, reliability, redunda~cy, 

diversity and independence in safety systems. 

Designs that provide reliable equipment in the balance 

of plant, (or safety-system independence from balance 

of plant) to reduce the number of challenges 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 the potential for an 

consequences of severe accidents. 

Design features that can be proven by citation of 

existing technology or which can be satisfactorily 

established by commitment to a suitable technology 

development program. 
- 11 -

If specific advanced reactor designs with some of all of the 

above of the foregoing attributes are brought to the NRC for 

comment and/or evaluation, the Commission can develop 

preliminary design safety evaluation and licensing criteria 

for their safety related aspects. Combination of some or 

all of the above attributes may help obtain early licensing 

approval with minimum regulatory burden. Designs with some 

or all of these attributes are also likely to be more 

readily understood by the general public. Indeed, the 

number and nature of the regulatory requirements may depend 

on the extent to which an individual advanced reactor design 

incorporates general attributes such as listed above. 

However, until such time as conceptual designs are 

submitted, the Commission believes that regulatory guidance 

must be sufficiently general to avoid placing unnecessary 

constraints on the development of new design concepts. 

To provide for more timely and effective regulation of 

advanced reactors, the Commission encourages the earliest 

possible interaction of applicants, vendors, ether 

government agencies, and the NRC to provide for early 

identification of regulatory requirements for advanced 

reactors, and to provide all interested parties, including 

the public, with a timely, independent assessment of the 

safety characteristics of advanced reactor designs. Such 

licensing interaction and guidance early in the design 

process, will contribute toward minimizing complexity and 
- 12 -

adding stability and predictability in the licensing and 

regulation of advanced reactors. 

While the NRC itself does not develop new designs, the 

Commission intends to develop the capability for timely 

assessment and response to innovative and advanced designs 

that might be presented for NRC review. Prior experience 

has shown that new reactor designs -- even variations of 

established designs -- may involve technical problems that 

must be solved in order to assure adequate protection of the 

public health and safety. The earlier such design problems 

are identified, the earlier satisfactory resolution can be 

achieved. Prospective applicants are reminded that, while 

the NRC will undertake to review and comment on new design 

concepts, the applicants are responsinle for documentation 

and research necessary to support any specific license 

application. (NRC research is conducted to provide the 

technical bases for rulemaking and regulatory decisions: to 

support licensing and inspection activities: and to increase 

NRC's understanding of phenomena for which analytical 

methods are needed in regulatory activities). 

During the initial phase of advanced reactor development, 

the Commission particularly encourages design innovations 

which enhance safety and reliability (such as those 

described above) and which generally depend on technology 

which is either proven or can be demonstrated by a 
- 13 -

straight-forward technology development program. In the 

absence of a significant history of operating experience on 

an advanced concept reactor, plans for iuuovative use of 

proven technology and/or new technology development programs 

should be presented to the NRC for review as early as 

possible, so that the NRC can assess how the proposed 

program might influence regulatory requirements. To achieve 

these borad objectives, an Advanced Reactors Group has been 

established in the Office of Nuclear Reactor Regulation. 

This group will be the focal point for NRC interaction with 

the Department of Energy, reactor designers and potential 

applicants, and will coordinate the development of 

regulatory criteria and guidance for proposed advanced 

reactors. In addition, the group will maintain knowledge of 

advanced reactor designs, developments and operating 

experience in other countries, and will provide 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 Advanced Reactors 

Group will also provide guidance regarding the timing and 

format of submittals for review. The Advisory Committee on 

Reactor Safeguards lACRS) will play a significant role in 

reviewing proposed advanced reactor design concepts and 

supporting activities. 
- 14 -

COMMISSION POSITION REGARDING POLICY STATEMENT QUESTIONS 

Six questions pertaining to the proposed policy for advanced 

reactors were included for comment in the original policy 

statement. The public responses to these questions are 

summarized in the "Abstract of Comments" section. After 

careful consideration of the public comments, the Commission 

response to the issues raised in each question is as 

follows: 

Question 1. Should NRC's regulatory approach be revised 

to reduce dependence on prescriptive regulations and, 

instead, establish less prescriptive design objectives, such 

as performance standards? If so, in what aspects of nuclear 

power plant design (For Example, reactor core power density, 

reactor core heat removal, containment, and siting) might 

the performance standards approach be applied most 

effectively? How could implementation of these performance 

standards be verified? 

CO~~ISSION RESPONSE 

Many of the Commission's existing regulations, criteria, and 

guidelines are of a nonprescriptive nature, and the extent 

to which the Commission's proposed safety goals, (which are 

also of a nonprescriptive nature) will be used in the 

regulation of nuclear reactors is currently being evaluated. 

In the review and regulation of advanced reactors the 

Commission intends to make use of existing and future 
- 15 -

regulations where they are applicable to advanced reactors. 

Many such regulations are expected to be of a 

nonprescriptive nature. The areas where existing 

regulations and guidelines would be used include: quality 

assurance, equipment qualification, external events, 

sabotage, fire protection, radiation protection, and 

operator training and qualification. In developing 

additional criteria and guidance to address those 

characteristics which differ from LWRs less prescriptive 

criteria will be considered. The use of less prescriptive 

criteria will depend upon the design in question and the 

ability to verify compliance with the criteria. Advanced 

reactor designers are encouraged as part of their design 

submittals to propose specific review criteria or novel 

regulatory approaches which NRC might apply to their 

designs. 

Question 2. Should the regulations for advanced reactors 

require more inherent safety ~~rgin for their design? If 

so, should the emphasis be on providing features that permit 

more time for operator response to off-normal conditions, or 

should the emphasis be on providing systems that are 

capablle of functioning under conditions that exceed the 

design basis? 
- 16 -

Commission Response 

The Commission encourages the incorporation of enhanced 

margins of safety in advanced designs and will encourage the 

use of designs that accomplish their safety functions in as 

reliable and simplified a fashion as practical. The 

Commission considers inherent or passive safety systems to 

have the potential for high reliability and encourages the 

consideration of such means (in lieu of active systems) in 

advanced designs. 

To encourage such action the Commission, in its review of 

these advanced designs, will look favorably on designs with 

greater safety margin and/or highly reliable safety systems. 

Such desirable features can be design-related or can take 

the form of reduced administrative requirements. 

Question 3. Should licensing regulations for advanced 

reactors mandate simplified designs which require the fewest 

operator actions, and the minimum number of components 

needed for achieving and maintaining safe shutdown 

conditions, thereby facilitating operator comprehension and 

reliable system function for off-normal conditions? 

Commission Response 

The Commission will encourage designs which are simpler and 

more reliable in accomplishing their safety functions. 

While current generation nuclear power plants, in operation 
- 17 -

or under construction represent no undue risk to either the 

public or the environment, the Commission believes that 

reactors with improved safety characteristics can and will 

be developed. Such improved safety characteristics support 

the Commission's Long-range Goal of minimizing the risk to 

the public and the environment through the "ALARA" approach. 

Question 4. Should the NRC develop general design 

criteria for advanced reactors by modifying the existing 

regulations, which were developed for the current generation 

of light water reactors, or by developing a new set of 

general design criteria applicable to specific concepts 

which are brought before the Commission? 

Commission Response 

In developing licensing criteria for advanced reactors, the 

Commission intends to build upon existing regulations 

wherever practical, as discussed in the response to Question 

No. 1. In following this approach, it is the Commission's 

intent to establish, for each design reviewed, the licensing 

criteria that apply to that design. As stated in the 

response to Question No. 1, these criteria will be a 

combination of applicable LWR criteria and criteria 

developed to address the unique characteristics of that 

design. Reactor designers are encouraged to propose 
- 18 -

specific criteria and novel regulatory approaches which 

might apply to their design. 

Question 5. Should the NRC favor advanced reactor designs 

that concentrate the primary safety functions in very few 

large systems (rather than in multiple subsystems) , thereby 

minimizing the need for complex benefit and cost balancing 

in the engineering of safe reactors? 

Commission Response 

While the NRC will not necessarily favor one design approach 

over another in regard to the number of safety systems, the 

NRC will encourage the use of simplified systems and systems 

of high reliability for the accomplishment of safety 

functions. 

Question 6. What degree of proof would be sufficient for 

the NRC to find that a new design is based on technology 

which is either proven or can be demonstrated by a 

satisfactory technology development program? For example, 

is it necessary or advisable to require a prototypical 

demonstration of an advanced reactor concept. prior to final 

liensing of a commercial facility? 
- 19 -

Commission Response 

The Commission requires proof of performance of certain 

safety-related components, systems or structures prior to 

issuing a license on a design. For LWR's this proof has 

traditionally been in the form of analysis, testing, and 

research development sufficient to demonstrate the 

performance of the item in question. Similar proof of 

performance for certain components, systems or structures 

for advanced reactors will also be required. The requisite 

proof will be design dependent. Therefore, the Commission's 

specific assessment of a safety technology development 

program for an advanced reactor design, or of the possible 

need for a prototypical demonstration of that design can be 

determined only by review of a specific design. However, 

the Commission favors the use of prototypical demonstration 

facilities as an acceptable way of resolving many safety 

related issues. 

The dissenting views of Commissioner Asselstine and the 

additional views of Commissioner Bernthal are attached. 

REGULATORY COMMISSION 

Samue 

Secretary of the Commission 

Dated ~t Washington, D.C. 

This !S"~ day of July , 19 86 
Additional Views of Commissioner Bernthal on Advanced Reactor Policy f::Ji:S' Statement 

Less than three years ago, the Commission began to consider seriously its 

responsibility (and the mandate of Congress) to become More deeply involved 

with early reviP.w and comment on new and advanced reactor design concepts. 

Such early design review has long been a commonplace within the Federal 

Aviation Administration, for.exaMple, where timely FAA review and comment 

on new airframe design proposals is longstanding tradition. 

The Commission has since undergone considerable progressive evolution in 

its thinking on this subject, and in this document the Commission, for the 

first time, has 90ne on record as suoporting such timely, anticipatory 

safety review of new design concepts. In addition, the Commission has 

plainly stated its expectation that next-generation reactors will exhibit 

enhanced and simplified safety characteristics, and has set down broad and 

diverse guidelines for how it believes such characteristics might be achieved. 

There is little doubt that this policy statement as it stands fails to 

conform in some respect with each Commissioner's ideal of what such a 

statement should be. But I find the statemP.nt to be a major step forward; 

it commits the Commission to exactly the kind of 11 proactive 11 planning 

that ComMissioner Asselstine still seems to find absent. 

Many of the specific objections raised by my colleague are puzzling. His 

sweeping statement that "containment capabilities are minimized to reduce 

costs'' and "core power densities have been driven to the limits of materials 

capabilities and our understanding of decay heat removal phenomena" are 

scientifically insupportable and inconsistent with the facts as generally understood. The fact is that containment capabilities were in general 

designed to cope with well-known accident scenarios, and core power limits 

were conservatively derived. 

Nor should the Commission insist on 11Specific requirements" for advanced 

reactor designs -- indeed, such insistence would go far beyond our mandate 

(and our capability). Such specificity was never the intent of this policy 

statement. Detailed specification of systems such as containment, for 

example, was never contemplated as an objective of the 11 advanced reactor" 

policy; indeed, one can imagine advanced reactor desiqns that might demand 

less containment capability than current generation LWR plants. 

In sum, it was never intended that this statement promulgate "a set of 

safety requirements ... As the statement notes, broad safety requirements 

are to be addressed in the Commission's forthcoming Safety Goal Policy 

Statement (to the extent they are not already addressed in the Severe 

Accident Policy Statement and elsewhere). Furthermore, The Commission's 

response to Question 6 makes clear its encouragement of plant designs 

firmly ~rounded in prototypical plants -- just as Commissioner Asselstine 

desires. 
- 2 - . 

Nor does this policy "accept the next generation of U.S. power plants if 

[they] provide a level of safety equivalent to that achieved in the U.S. 

designs that were completed 10 years ago." There is necessarily room for 

irterpretation in the Commission's pronouncemPnt, but whether or not thP 

Commission might ever issue (or be asked to issue) new construction permits 

replicating ''current generation plants, plants whose designs were largely frozen more than 10 years ago" is not the question. It is amply clear from 

this eolicy statement that "the Commission expects that advanced [emphasis added] reactors will provide.enhanced margins of safety .•. ••, and the 

Commission has broadly defined "advanced" to include reactors that lie 

beyond current generation designs. 

Finally, Commissioner Asselstine's comment that the "next generation of 

plants should be more reliable, more forgiving, simpler, easier to construct, 

easier to operate, and easier to maintain than the current generation" is a 

nice synopsis of the broad guidelines clearly set forth in this policy 

statement. I am pleased that he concurs in the desirability of those traits. 
Dissenting Views of Commissioner Asselstine 

I do ~ot believe that this advanced reactor policy statement provides the 

sound regulatory basis needed to support a new generation of nuclear power 

plants in this country. This policy statement encourages, but does not 

require, safety improvements in advanced reactor design, and expresses a 

willingness on NRC's part to conduct safety reviews of advanced reactor 

design concepts so that NRC will be in a position to act on any future 

plant or design license application. The primary decision made in developing this policy is the commitment to maintain a small advanced reactor 

group within the Agency that would serve as the focal point for interaction 

with reactor design groups. However it appears that even this commitment 

may be in jeopardy given current budgetary constraints. 

I believe that more is needed to articulate an effective regulatory policy 

and to ensure a successful program for future nuclear power plants in this 

count~, whether those plants are of a type similar to current light water 

reactors or whether they are of more fundamentally different design. Such 

a policy should reconsider the Commission's regulatory practices of the 

past thirty years. Those past practices can be characterized as primarily 

a reactive regulatory regime to what the designers propose. It leaves 

resolution of issues to what one industry executive has called the rough, 

tough, surly competitive elements. Safety systems are limited because of 

cost considerations. Containment capabilities are minimized to reduce 
- 2 -

costs. 11 Core power densities have been driven to the limits of materials 

capabilities and our understanding of decay heat removal phenomena. £1 

And the balance of plant is designed to lower standards than the reactor 

systems to minimize costs. These competitive forces are what led to the 

level of safety achieved in the current generation of nuclear power plants 

and are in part responsible for the poor performance of some of our plants. 

The NRC and AEC before it have often avoided developing stringent specifications or design reauirements because of a fear that if the Commission 

were to be too specific in its requirements, the emerging industry might be 

slowed in its growth and innovation might be discouraged. That argument 

might have had some validity in the 1960's and 1970's when the current 

generation of reactors was being designed without the benefit of signifil/ For example, to keep the containment size down, crucial pumps, heat 

exchangers, and emergency water supplies have been located outside the 

containment, which results in flow paths for. highly contaminated water 

that effectively bypass the containment. In addition, containment 

volumes and design pressures have been traded-off for pressure suppression schemes that substantially complicate safety analyses and 

that add additional vulnerabilities to the public health and safety. 

Initially containments were intended to be an independent barrier to 

substantial releases given a core meltdown. Some of that 

defense-in-depth was given up for the sake of costs, when large power 

reactors came on the scene in the mid-1960's and it became known that 

the decay heat and the core meltdown phenomena could fail the 

containment. 

For example, in the event of a loss of coolant accident, external 

water supplies must be rapidly injected into the core to keep it from 

melting. While some relatively small-scale integral experiments on 

loss of coolant phenomena have been completed, there are still multinational supported research programs underway to further examine 

thermal hydraulic phenomena during accidents. Further, we are .iust 

beginning expensive, integral effects tests on thermal hydraulic 

phenomena associated with a class of pressurized water reactors. 
- 3 -

cant operating experience or data. However, now that we have considerable 

worldwide experience with a large variety of nuclear reactor designs, I 

believe it is time for NRC to become more proactive in what it will require 

of future generations of reactors. 

Following the TMI-2 accident, the notion of a demarcation between the 

current generation of plants and a future generation of plants was raised, 

with the distinction that the latter would be designed based on a reformulation of the Siting Criteria and General Design Criteria to reflect all 

that had been learned over the years, including the broader lessons of 

TMI-2. Thus, the TMI Action Plan was developed with the current generation 

of plants in mind, leaving open the question of possible broader changes 

for a future generation of plants. One such broad change could be to go 

beyond the so-called single failure criterion which experience shows may 

not be serving us well. The June 9, 1985 accident at Davis-Besse is a case 

in point where 14 separate failures occurred. 

Many foreign countries are requiring four independent trains of safety 

systems whereas NRC requires only two. When NRC reviews advanced designs 

such as the one being jointly developed by a U.S. vendor and a foreign 

country, the NRC staff does not require as prudent additional safety 

features being required by the foreign country. Rather, Commission practices and procedures require a cost-benefit analysis to justify any additional safety feature. This analysis is typically incomplete and often 

crude. Furthermore, the Commission gives little consideration to the 
- 4 -

enormous uncertainties in reactor risks in its decisionmaking process. 

This approach to reactor safety needs improvement. 

There has been insufficient thought and effort in developing a map for the 

future. The Advanced Reactor Policy Statement provides no guidance on what 

containment capabilities will be required; on whether the single failure 

criterion is adequate for the future; on acceptable core power densities 

(an issue which has significant bearing on the core meltdown risks to the 

public); and on the root causes of the core meltdown risks that might be 

addressed by design improvements in a future generation of reactors. Nor 

is there guidance on what standards the balance of plant must meet. 

Nothing is said about the fuel cycle and the process for licensing the fuel 

cycle associated with some of the advanced designs currently being examined. For example, one problem area presented by some designs is the 

proliferation potential of the reactor•s fuel cycle. This fuel cycle 

could present the need for the Commission to reopen the aborted proceeding 

on plutonium recycle. And, finally the Commission gives essentially no 

guidance on whether a prototypical plant will be required before allowing 

widespread use of that design. This policy statement encourages much, just 

like the Commission encourages excellence in operations. However, the 

Commission too often accepts far less. I would have expected that NRC 

would approach a future generation of nuclear power plants with an attitude 

of correcting past weaknesses. Unfortunately, the Advanced Reactor Policy 

Statement does not reflect that kind of attitude. 
- 5 -

Other countries with extensive nuclear power programs appear to be designing, constructing, operating and maintaining better nuclear power plants 

than those of this country. Foreign countries are demanding more safety 

and reliability in their current generation of plants than the NRC is 

requiring of the U.S. plants. Yet, this Advanced Reactor Policy Statement 

accepts the next generation of U.S. power plants if such a design provides 

a level of safety equivalent to that achieved in the U.S. designs that were 

completed over 10 years ago. I do not think such a policy serves the 

country well. My concern is not merely that we should keep up with others. 

Rather, my concern is that the current generation of plants is still 

surprising us in their performance. As the Commission has recently acknowledged to the Congress, the current generation of nuclear power plants 

in this country can best be characterized as a complex technology that is 

not fully mature. There remain great uncertainties in the level of risk 

they pose to the public. In such circumstances, I believe prudent 

decisionmaking should come down on the side of improved safety, not only 

for the current generation of plants but for the next generation as well. 

If there is to be a future generation of nuclear power plants and if the 

nuclear option is to be an important element of the nation's future energy 

mix, then the NRC, the vendors, the utilities, and the Congress must ensure 

that the next generation of power plants is substantially better than the 

current generation. The next generation of plants should be more reliable, 

more forgiving, simpler, easier to construct, easier to operate, and easier 

to maintain than the current generation. Any design that does not accomplish this is not acceptable in my view. I say this for a straightforward 
- 6 -

reason. We cannot afford to will to the future reactor designs that have a 

fifty percent chance of a core meltdown every ten to twenty years in a 

population of 100 reactors. We should not will to the future the great 

uncertainties in safety levels that exist today. Nor should we will to the 

future consumer reactor designs that have a 50 to 60 percent capacity 

factor. 

We must step back and examine the strengths and weaknesses of past and 

current designs and the approaches taken in getting where we are today. 

Only then, in my view, can we intelligently map a course for the future. I 

a~ encouraged that there is a segment within the industry that is undertaking a fresh look at the nuclear technology. The forward-looking members of 

the industry are attempting to generate a set of requirements that, from 

the standpoint of the utilities, must be met before utilities will consider 

placing new orders. I find it disappointing that the NRC is unwilling to 

generate a set of safety requirements for the next generation of power 

plants. 

~RC FORM US 

12-841 

U.S. ~UCUAR REGULATORY COMMISSION 1 REPORT NUMBER IAIUfnodbv TIDC.•IId Vol No. it•nvl 

~RCM 1102. 

3201.3202 BIBLIOGRAPHIC DATA SHEET 

SEE t~STRUCTIONS ~THE REVERSE 

2. TITLE AND SUBTITLE 

Development and Utilization of the NRC Policy Statement 

on the Regulation of Adva.nced Nuclear Power Plants 

5. AUTHORISI 

Peter M. Williams and Thomas l. King 

7. PERFORMING ORuANIZA liON NAME ANO MAILI~G ADDRESS llnclutk ZIP C-1 

Office of Nuclear Regulatory Research 

U.S. N11clear Regulator:-y Commission 

Washington, D.C. 20555 

10. SPONSORING ORGANIZATION NAME AND MAILING ADDRESS llnclutkZop C-1 

same as above 

12 SUPPLEMENTARY NOTES 

13. ABSTRACT (200 words or !en I 

NUREG-1226 3 LEAVE BLANK 

4 DATE REPORT COMPLETED 

MONTH YEAR 

May J.988 6. DATE REPORT ISSUED 

MONTH YEAR 

June 

B. PROJECTITASKIWORK UNIT NUMBER 

9 FIN OR GRANT NUMBER 

llo. TYPE OF REPOF<T 

b. PERIOD COVERED (lnclusi~~e .,..1 

On March 26, 1985, the U.S. Nuclear Regulatory Commission issued for public 

comment a 11 Proposed Policy for Regulation of Advanced Nuclear Power Plants 11 (50 

FR 11884). This report presents and discusses the Commission's final version 

of that policy as titled and published on July, 8, 1986 11 Regulation of Advanced 

Nuclear Power Plants, Statement of Policy11 (51 FR 24643). It provides an overview of comments received from the public, of the significant changes from the 

proposed Policy Statement to the final Policy Statement, and of the Commission's 

response to six questions contained in the proposed Policy Statement Thereport also discusses the definition for advanced reactors, the establishment of 

an Advanced Reactors Group, the staff review approach and information needs, and 

the utilization of the Policy Statement in relation to other NRC programs, 

including the policies for safety goals, severe accidents and standardization. 

In addition, guidance for advanced reactors with respect to operating experience, technology development, foreign information and data, and prototype 

testing is provided. Finally, a discussion on ·the use of less prescriptive and 

nonpr.escriptive design criteria for advanced reactors, which the Policy Statement encourages, is presented. 

1 .. DOCUMENT ANAL "t"SiS- ... ;(["I',•.J0:10S:Ct!iCt";;F'':'"ORS 

Advanced Reactors, Policy Statements, Regulation, Standardization, 

Defense-in-depth, Safety Goal, Severe Accident Policy, Design Criteria 

IS AVAILABILI"JY 

STATEMENT 

unlimited 

16. SECURITY CLASSIF tCA TID .. 

ITtt•-1 

b. IDENTIFIERS/OPEN-ENDED TERMS unclassified 

unclassif;ed 

17. ~UMBER OF PAGES 

18 PRICE 




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