QUESTIONS 2a & 2b: Would you agree that the long-term promise of nuclear energy is essentially unlimited through the development of advanced liquid metal reactor technologies? In your judgement, should DOE's program be more aggressive in this regard? ANSWER: DOE's program in developing liquid metal, as well as gas cooled reactor technologies, needs to be reviewed to be sure that the technology development has progressed sufficiently to construct a prototype commercial plant. We have had many years of research and development on liquid metal reactors that provide a good basis for building a demonstration reactor. I am unfamiliar with the details of the DOE funding or long-term schedule for its construction, but from a utility's perspective, the breeder option and whether it is exercised or It will depend on the economics of the technology and the cost of uranium as part of the light water reactor fuel cycle. When those two come together, the utilities will be in a position to make the decision to order a commercial liquid metal reactor. Before that point is reached however, it is my judgement that our focus legislatively, financially, and technically, should be aimed at developing the next generation of mid-sized and evolutionary plants of the light water variety to assure that there is a nuclear industry to be able to develop these future technologies. I cannot envision a situation where if we do not have new nuclear orders in the near-term, that in ten to perhaps fifteen years in the future we would not be interested in another nuclear technology since its base - both in technology as well as support and experience - will have been eroded. Thus, if I were to answer the question as to the priorities of the Department of Energy, they would be to assist in the design certification of more passive designs and evolutionary light water reactors; assist in the licensing reform to restore investor confidence in the technology, and; then fund the research and development portions of the liquid metal and gas cooled reactor technologies. We need to keep nuclear as an option and the only way to do that in the short term is with the next generation of light water reactors. -5 Institutional problems are often cited as the reason why we cannot build nuclear power plants in the United States. Japan and France are often used as examples of it taking only four to six years to build a nuclear power plant and put it into operation. QUESTIONS 3a & 3b: Why is this the case in Japan and France? If I am correct these countries rely on a licensing system similar to that in the United States. Would you comment? Are standardized designs critical to expediting this process? ANSWER: It is my understanding that the regulatory systems in Japan and France are quite different from those in the United States. The regulations, in terms of safety, may not be significantly different but it is the application of those regulations and the system that we have created in the United States that is a key factor in the greater length of time and money it costs to build nuclear plants. Both Japan and France have the equivalent of the Nuclear Regulatory Commission and have established safety standards comparable to ours. But, neither country has an adjudicatory system that emphasizes conflict rather than conflict resolution. I am much more experienced with the regulators in France. It is their position that when an issue develops, to resolve it with the utility to reach the best technical solution. France's regulatory criteria and solutions may be as stringent as those that might be applied in the United States, but they are able to resolve problems quicker. Resources are focused at resolving the problem rather than preparing for licensing proceedings. It is my recommendation that the committee, as they consider licensing reform, involve and seek testimony from the regulators in France and Japan to learn how they carry out their regulatory responsibility and contrast it to ours. It is clear that all nations strive for the safest operating plants they can and establish rules of conduct that would promote such practice. I believe that standardized design would certainly help the United States expedite the licensing process. As you may be aware, in the 1970s, the United States used a process called replication of nuclear designs. It was another word for standardization but I think it more accurately represents the realities given different siting conditions. In replication, the Atomic Energy Commission approved a standard design and issued an associated safety evaluation report. When a utility filed an application to construct a nuclear power plant, the safety review was limited only to differences from the standard that had already been previously approved. Thus, the review was rather quick since few, if any, changes were made. The only area of review that required analysis was that associated with the environmental report. -6 A specific case was the proposed Charlestown Nuclear Plant in Rhode Island. The replication process was used and it was found to work effectively. This plant was patterned after several similar plants that were going to be built in New England. The review process was quicker and much more efficient without reducing any safety levels. Where the process bogged down, unfortunately, was in the interventions associated with the application. The necessarily adversarial versus negotiation system to resolve conflict created and continues to create unnecessary delays. -7 QUESTIONS 4a, 4b, & 4c: Passive safety features are critical to the public's acceptance of nuclear power. Would you agree? In your judgement, do liquid metal reactors and high temperature gas-cooled reactors have advantages with regard to passive safety features? If we are concerned for the future of nuclear power, would you agree that there is a need for a more active federal support for these technologies in addition to "advanced" light water reactors? ANSWER: I would agree that public confidence in nuclear power is essential now and in the future. Public confidence is attained by good performance. If performance is good, the technical details of the design are immaterial. While passive safety features are important in the next generation of nuclear plants, to show that progress is being made in design, I do not believe they are going to be the critical issue as to whether or not new nuclear plants are ordered. It is unrealistic to assume that simply because some passive features have been incorporated into a new design, that no active safety-related components will be required. Rather than debate passive versus active, the responsibility to the public is to develop designs that are improved and to demonstrate why and how they are better. I do not think that the passive nature of new reactors should be over-sold because in the long run, nothing is ever totally passive. At this stage of the design process, the passive safety features of the Advanced Liquid Metal Reactors (ALMRs) and High-Temperature Gas Reactors (HTGRs), while different, do not have an overall safety advantage when compared to Passive-Advanced Light Water Reactors (P-ALWRS). My opinion is based upon Yankee's ongoing participation with other utilities in the review of the designs and supporting analyses for these reactor concepts. Any distinct advantage of the passive safety system for a particular reactor concept is not likely to become evident for several more years when the designs are more complete. It is important to remember that each advanced reactor concept must protect the public health and safety by restricting the actual and potential release of radionuclides within the same set of United States Nuclear Regulatory Commission (USNRC) requirements, primarily contained in the Code of Federal Regulations, and the Dose Protective Action Guidelines of the Environmental Protection Agency. Each reactor type must also address; the USNRC's Advanced Reactor, Safety Goal, Severe Accident, and Standardization Policy Statements in order to establish decision criteria against which the designs can be reviewed; and the USNRC regulatory guides and general design criteria, some of which are being reformulated to account for new design approaches. Finally, each reactor type must address utility requirements and recommendations in order to produce a viable plant design. This design development process is actively underway for several advanced reactor types with much design work yet to be completed. Thus, it is premature to draw strong distinctions -8 between the advanced reactor types at this time because perceived advantages or disadvantages are subject to change as the designs progress. As I said in the response to an earlier question, we should develop both technologies to a point where they can be demonstrated on a commercial scale and let the market place decide which is the more appropriate technology for use. We do not want to oversell either of these concepts because by doing so expectations are unnecessarily raised beyond those which might be achievable. |