ML013250076

Request to Review NEI 01-02, Guidance for Preparing an Early Site Permit Application

ML013250076
Person / Time
Issue date:	11/20/2001
From:	Lyons J Office of Nuclear Reactor Regulation
To:	Simard R Nuclear Energy Institute
KENYON T NRR/ADIP/NRLPO 301- 415-1120
References
Download: ML013250076 (4)

Text

November 20, 2001 Dr. Ronald L. Simard, Senior Director Business Services Department Business Operations Division Nuclear Energy Institute 1776 I Street, Suite 400 Washington, DC 20006 - 3708

SUBJECT:

REQUEST TO REVIEW NEI 01-02, GUIDANCE FOR PREPARING AN EARLY SITE PERMIT APPLICATION In your letter dated September 28, 2001, the Nuclear Energy Institute (NEI) requested the U.S. Nuclear Regulatory Commission (NRC) to review NEI 01-02, Guidance For Preparing an Early Site Permit Application. The stated purpose of the guidance is to provide an approach for implementing the requirements of Subpart A to 10 CFR Part 52.

Based on a limited review, the document appears to be a general overview of the early site permit (ESP) process and needs, but does not provide, clear cross-references to all of the NRC regulatory guidance documents concerning related topics. The document is duplicative of guidance currently publicly available, quoting (or paraphrasing) many of the related Commissions regulations. As discussed during a March 29, 2001 meeting with the NEI ESP Task Force (see May 8, 2001 meeting summary), a significant amount of guidance on format, content, and review plans is already available in the public domain in the form of Regulatory Guides, the Standard Review Plan (NUREG-0800), the Environmental Standard Review Plan (NUREG-1555), and other documents. NEI 01-02 does not appear to propose any new guidance that is necessary to support developing an ESP application. Existing NRC guidance to be used to prepare for future licensing activities that the staff plans to update has already been identified in SECY-01-0188, Future Licensing and Inspection Readiness Assessment, dated October 12, 2001.

In addition, NEI identifies certain policy issues in NEI 01-02 that have not been resolved, and have already been raised by the nuclear industry, such as the incorporation of information from previous reviews in an ESP application. These issues are currently being addressed through other agency processes, such as through petitions for rulemaking. The staff believes that review of NEI 01-02 is not the appropriate forum for discussing and resolving policy matters.

Therefore, on the basis of its cursory review of NEI 01-02, dated September 28, 2001, the staff concludes that the document does not appear to provide a complete summary of the guidance currently available for developing an ESP application, and does not provide any additional guidance to support such an effort. The staff has not reviewed the document in sufficient detail to determine whether it would be an accurate reference for a potential ESP applicant while

R. Simard developing an ESP application, and therefore, cannot endorse its use. If you have any questions concerning this matter, please contact Thomas J. Kenyon at (301) 415-1120.

Sincerely,

/RA/

James E. Lyons, Director New Reactor Licensing Project Office Office of Nuclear Reactor Regulation cc: G. Bagchi P.T. Kuo K. Manoly B. Zalcman K. Gibson E. Fox F. M. Reinhart J. Moore

ML013250076 OFFICE PM:NRLPO DD:NRLPO D:NRLPO NAME TKenyon:cn MGamberoni JLyons DATE 11/9/2001 11/9/2001 11/19/2001

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