demonstration" should be utilized to develop and demonstrate longer term options such as the ALMR and MHTGR. Those technologies are discussed below.

Finally, Section 12003(a) proposes certain nuclear plant features which being subject to interpretation could inhibit support for promising systems and, therefore, should be utilized in a non-exclusionary way. For example, all of the advanced light water reactors depend upon valves, relays, and other electrical or mechanical devices to put the plant into a condition where "passive" systems take over. Ambiguities of interpretation could be overly restrictive. Thus, I suggest you make clear that the prime requirements for support, consistent with the recently issued NPOC strategy plan, are safety, cost effectiveness, and standardization.

Question: c. At what point would the technology be ready to demonstrate?

Answer: GE's ABWR, which will start construction in Japan this year, is leading the way toward NRC certification of advanced standardized designs and is in fact ready now for an "institutional demonstration" in this country. ABB-CE's System 80+ design is following the ABWR towards certification and should be ready a couple of years later. We expect GE's SBWR, as well as W AP-600, to be ready for a demonstration in 1995 following NRC approval. The ALMR and MHTGR will need a "technology demonstration" currently planned through their prototype test program but may not need an "institutional demonstration" if the ALWR programs are successful.

Question: d. How many years are we away from commercialization of the more advanced technologies, such as the high temperature gas-cooled reactor or the liquid metal reactor?

Answer: As stated above, a technical prototype demonstration of the ALMR and MHTGR will be needed to supplement R&D programs and design analysis to achieve NRC certification. The current ALMR program plan has integrated the R&D at various national laboratories with the design and licensing activities of the industrial team to target establishment of commercial feasibility by 1995. Based on successful program results similar to those achieved to date, we would expect to proceed with a government - private sector partnership to finalize the design, and construct and test a full scale prototype unit by 2003. This would lead to NRC certification (after rulemaking proceedings) and readiness for commercialization by 2005. I'm not familiar with the detailed MHTGR schedule; however, I believe the MHTGR will have similar requirements and thus could also be ready for commercialization, following a prototype demonstration, after the turn of the century.

ADVANTAGES/DISADVANTAGES OF LIQUID METAL TECHNOLOGY

2. Obviously, there may be certain advantages to development of a commercial liquid metal reactor, such as its capability to breed and the potential for minimization of waste.

Question: a. Do you believe that concerns about fuel reprocessing and nuclear weapons proliferation would discourage the development or commercialization of LMRs?

Answer: No, I don't think so. The DOE program for processing of spent fuel is based on establishing the pyroprocessing technology (IFR) being developed at Argonne National Laboratory (ANL). This process has diversion resistance and nonproliferation advantages over previous reprocessing approaches as the fissionable materials are recovered along with other impurities. We believe that a demonstration of this process will show that such improved processing and recycle can be carried out in a manner consistent with U.S. non-proliferation goals.

Question: b. Wouldn't the existence of these public concerns be a good reason for a demonstration of the technology?

The technology

Answer: Yes, we agree a demonstration is appropriate. demonstration program already under way at ANL will provide this demonstration and the basis for achieving technical feasibility and public acceptance by 1995. The commercial (and economic) acceptance by utilities will follow as part of the ALMR prototype and commercialization program.

Question: c. How many years away are we from being able to prove the ability to significantly reduce the volumes of nuclear waste by actinide burning?

Answer: The actinide recycle technical feasibility of the ALMR program using the IFR fuel cycle approach will be established by 1995 under current DOE program planning, if adequate Federal resources (funds) are provided. Following the technical feasibility demonstration the actinide recycle potential and its impact on the U.S. High Level Waste solution could be integrated with current planning of the geological repository (which is scheduled for first material receipt in 2010) and the ALMR prototype demonstration (which is scheduled for completion by 2005).

THE PROCESS LAID OUT IN TITLE XII

3. You express a concern in your statement that title XII may be overly restrictive and could replace valuable ongoing R&D programs. The authority in title XII is intended to be in addition to existing authority for R&D programs.

Question: a. Would your concerns about title XII be diminished if it did not reduce the available funds for existing R&D programs?

Answer: Yes. Title XII needs to be clarified to assure support for current DOE advanced reactor programs which are well defined, at various stages of completion and aimed at an early "institutional demonstration" of an advanced light water reactor, such as ABWR. The Federal support should be consistent with these program plans in order to assure timely and effective results. Title XII, Section 12007, as written, does not tie funding into the specific programs and thus could be limiting in achieving targeted results.

Question: b. Would you then support a demonstration such as envisioned in title XII? Answer: As stated in responses to the questions above on Technology Demonstration, we support an "institutional demonstration" of an ALWR under an expanded Section 12005 whereby the Federal government provides "insurance" if new institutional requirements are imposed after issuance of a license for a standardized design. We additionally support Federal involvement in a "technical demonstration" of an advanced reactor, such as the ALMR and MHTGR, through the government/private sector partnership proposed in the program plan. This appears to be consistent with Section 12006 of title XII.

Question: c. Do you share Mr. Young's concern that title XII might actually harm the Department's current efforts to develop advanced reactors?

Answer: I am not sure what Mr. Young's concerns are. My response to Question a. above covers my concerns with title XII. In general, title XII should provide the flexibility to enhance current DOE programs, not limit, constrain or rearrange them. For example, ALWR first of a kind engineering support to be effective should follow NRC issuing a Final Design Approval (FDA) and perhaps work in parallel with the rulemaking procedures leading to certification of the design. This kind of support is not now covered in title XII and might, therefore, actually harm DOE program plans. This may be part of Mr. Young's concerns.

4. You say that you don't believe an advanced light water reactor -- the mid-sized socalled passively safe designs would qualify for a demonstration project under section 12006.

Question: a. Why not?

Answer: Advanced light water reactor technology, including that in so-called passively safe designs, is well demonstrated technically or can be most economically

tested in non power reactor test facilities. Thus, the federal government's role should be to enable the private sector to implement that technology in the new Advanced Light Water Reactors under Section 12005 protected from the financial risks associated with changes in government policies and requirements.

Question: b. Why wouldn't this be attractive to a utility looking to build a mid-sized advanced light water reactor?

Answer: While I cannot speak for the utilities, I believe that the major risks associated with light water reactor technologies after the designs have been certified and a substantial portion of the First-Of-A-Kind Engineering has been completed will be related to external regulatory changes. Government participation directly in a project is not necessary since implementation of proven technology is more appropriately the role of the private sector.

Additionally, limited government funding would be better applied to enable development of advanced technologies which are promising in the longer term but are unlikely to receive near-term private funding due to the high technology risk early in their development. This support for research and development of advanced technologies has been a role which government has traditionally and successfully performed.

CERTIFICATION OF STANDARD DESIGNS

5. There is currently some disagreement on what constitutes a standardized design for purposes of receiving a design certification from the Nuclear Regulatory Commission. The disagreement, as I understand it, rests with how much design detail, thereby substantially delaying the date by which the NRC could certify a reactor design.

On February 15, 1991, the NRC announced its policy on the level of design detail.

Question: Does the NRC's policy adequately address the concerns of reactor vendors?

Answer: The Commission issued its guidance to the staff in the form of a Staff Requirements Memorandum (SRM) on February 15, 1991 pertaining to level of design detail and related Part 52 implementation issues. As I stated in my letter to Chairman Carr on February 28th, I believe that the Commission has charted a reasonable and balanced course, one that provides a sound basis for proceeding with the ALWR applications under review by the staff.

I went on to state that GE intends to work diligently with the Commission and its staff to complete the final design approval and design certification phases of the ABWR review. This will be a major step in demonstrating that the new regulatory regime which Part 52 articulates can lead to the predictable and stable regulatory process intended.

GE believes that the Commission guidance resolves the major issues leaving the details to be worked out with the staff. Based on our experience to date, these do not appear to be insurmountable.

6. Based upon what we know about NRC's policy and process for approval of certified designs -

Question: a. How soon can we expect the NRC to certify each of the advanced reactor designs now being developed?

Answer: GE is working diligently with the staff to establish realistic schedules for completing the final design approval (FDA) and design certification phases of the ABWR review. As a first step, GE proposed its plans and actions to complete all ABWR submittals this summer clearing the way for issuance of the FDA by the end of 1991. The design certification phase is estimated to be completed within 12 to 15 months of FDA issuance.

ABB-CE's System 80+ will likely be certified about 2 years after the ABWR. Both GE's SBWR and W AP-600 are scheduled for certification in 1995. These schedules depend greatly on the timely and consistent implementation of the abovementioned Commission certification course on the ABWR, which is the first plant being certified.