ML030230071

Resolution of Early Site Permit Topic 6 (ESP-6) Use of Plant Parameter Envelope (PPE) Approach

ML030230071
Person / Time
Site:	Nuclear Energy Institute
Issue date:	02/05/2003
From:	Lyons J NRC/NRR/NRLPO
To:	Simard R Nuclear Energy Institute
Jenkins R, NRR/NRLPO 415-2985
References
Download: ML030230071 (7)

Text

February 5, 2003 Dr. Ronald L. Simard Nuclear Energy Institute (NEI) 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

RESOLUTION OF EARLY SITE PERMIT TOPIC 6 (ESP-6), USE OF PLANT PARAMETER ENVELOPE (PPE) APPROACH

Dear Dr. Simard:

The purpose of this letter is to inform you of the Nuclear Regulatory Commissions (NRC) understandings and expectations regarding the use of the plant parameter envelope (PPE) approach for the preparation and review of early site permit (ESP) applications. This topic, which is identified as ESP-6 on the list of Nuclear Energy Institute (NEI) generic ESP issues, was discussed during public meetings between July 17 and December 5, 2002. Subsequently, NEI documented its position on this topic in a letter dated December 20, 2002. The NRC staff agrees with NEIs position that ESP applicants may use the PPE approach as a surrogate for facility information to support required safety and environmental review subject to the observations and clarifications below. However, the staff does not concur with all of the statements and assumptions in the NEI white paper (Enclosure 1 to the subject letter).

1. ESP applicants may use the PPE approach as a surrogate for actual facility information to support required safety and environmental reviews. In NEIs August 1, 2002, letter, NEI indicated that the information listed in 10 CFR 52.17(a)(1)(i)-(viii) is not required. Should this information not be provided, it may complicate the staff review (i.e., resulting in increased review time) and have a bearing on the staff assumptions and associated staff findings.

2. The ESP application information that contains PPE values along with site investigation efforts (i.e., data and analyses) and existing information (i.e., data and analyses) must adequately address three areas - site safety, environmental impacts, and emergency preparedness.

3. No comment on Item 3 of the subject NEI letter.

4. The staff understands that PPE values may differ among the ESP applicants. It is the staffs expectation that margins applied to account for uncertainties in PPE values will be identified in the subject application in order to avoid any ambiguity or confusion with the NEI PPE worksheet information.

5. NEI has indicated that the PPE values will represent composite parameters that are not indicative of any specific reactor design or type. Although the bounding PPE values are intended for future use (i.e., during the combined license (COL) application), issuing an

R. Simard ESP is an independent licensing action. As such, the NRC staff review will determine whether the PPE values are sufficient to enable the NRC staff to conduct its required review and that the PPE values are not unreasonable for consideration in the staff findings to comply with 10 CFR Part 52, Subpart A.

6. Given that PPE values do not reflect a specific design and will not be reviewed by the NRC staff for correctness, the granting of an ESP by the NRC does not indicate NRC approval of the site for any specific plant or type of plant. In addition to the emergency preparedness and environmental impact findings, site approval will be contingent on the staffs ability to make a finding, taking into consideration the site criteria contained in 10 CFR Part 100, that a reactor or reactors having characteristics that fall within the parameters for the site can be constructed and operated without undue risk to the health and safety of the public. This finding may result in conditions or limitations on the ESP in specific areas, as set forth in 10 CFR Section 52.24.

7. No comment on Item 7 of the subject NEI letter.

8. COL applicants who reference an ESP bear the risk that the design ultimately selected for the approved site might fall outside of the terms and conditions of the ESP.

9. The NRC review will be conducted using the review guidance cited in the Draft ESP Review Standard (ML023530045). The NRC review will result in safety and environmental impact determinations based upon the NRCs independent evaluation of the information provided in the ESP application, assumptions or limitations or both as established by the staff, as well as independent information developed by the staff. We agree that a combination of site characteristics and PPE values will comprise the ESP bases that will be the focus for comparison at COL with the design of the actual plant proposed for the site.

10. NEIs position regarding compliance with 10 CFR 52.17(a)(1) (Topic ESP-7) will be addressed in a separate staff response.

11. NEIs position regarding alternative site reviews (Topic ESP-18a) will be addressed in a separate staff response.

Please contact Ronaldo Jenkins, the ESP Senior Project Manager, at 301-415-2985 if you have any questions on this matter.

Sincerely,

/RA/

James E. Lyons, Director New Reactor Licensing Project Office Office of Nuclear Reactor Regulation Project No. 689 cc: See next page

R. Simard ESP is an independent licensing action. As such, the NRC staff review will determine whether the PPE values are sufficient to enable the NRC staff to conduct its required review and that the PPE values are not unreasonable for consideration in the staff findings to comply with 10 CFR Part 52, Subpart A.

6. Given that PPE values do not reflect a specific design and will not be reviewed by the NRC staff for correctness, the granting of an ESP by the NRC does not indicate NRC approval of the site for any specific plant or type of plant. In addition to the emergency preparedness and environmental impact findings, site approval will be contingent on the staffs ability to make a finding, taking into consideration the site criteria contained in 10 CFR Part 100, that a reactor or reactors having characteristics that fall within the parameters for the site can be constructed and operated without undue risk to the health and safety of the public. This finding may result in conditions or limitations on the ESP in specific areas, as set forth in 10 CFR Section 52.24.

7. No comment on Item 7 of the subject NEI letter.

8. COL applicants who reference an ESP bear the risk that the design ultimately selected for the approved site might fall outside of the terms and conditions of the ESP.

9. The NRC review will be conducted using the review guidance cited in the Draft ESP Review Standard (ML023530045). The NRC review will result in safety and environmental impact determinations based upon the NRCs independent evaluation of the information provided in the ESP application, assumptions or limitations or both as established by the staff, as well as independent information developed by the staff. We agree that a combination of site characteristics and PPE values will comprise the ESP bases that will be the focus for comparison at COL with the design of the actual plant proposed for the site.

10. NEIs position regarding compliance with 10 CFR 52.17(a)(1) (Topic ESP-7) will be addressed in a separate staff response.

11. NEIs position regarding alternative site reviews (Topic ESP-18a) will be addressed in a separate staff response.

Please contact Ronaldo Jenkins, the ESP Senior Project Manager, at 301-415-2985 if you have any questions on this matter.

Sincerely,

/RA/

James E. Lyons, Director New Reactor Licensing Project Office Office of Nuclear Reactor Regulation Project No. 689 cc: See next page ACCESSION NO. ML030230071 *See previous concurrence OFC PM:NRLPO SPA:NRLPO DD:NRLPO* D:NRLPO SPSB:BC NAME RJenkins JWilson MGamberoni JLyons MJohnson DATE 2/3/03 1/23/03 1/24/03 2/4/03 2/3/03 OFC RLEP:SC OGC EMEB:BC* SPLB:SC NAME JTappert JMoore GImbro SWeerakkody DATE 2/3/03 1/31/03 1/31/03 1/30/03 OFFICIAL RECORD COPY

Distribution for letter to R. Simard dated February 5, 2003 Hard Copy NRLPO Rdg.

RJenkins MGamberoni JLyons E-mail PUBLIC ACRS/ACNW RidsNrrAdip (RBorchardt)

RidsNrrAdpt (BSheron)

RidsOgcRp NRLPO Group RidsNrrOD (SCollins)

ESP-Generic Mr. James F. Mallay, Director Regulatory Affairs cc: FRAMATOME, ANP 3315 Old Forest Road Mr. David Lochbaum Lynchburg, VA 24501 Union of Concerned Scientists 1707 H Street, NW Mr. Ernie H. Kennedy Suite 600 Vice President New Plants Washington, DC 20006-3919 Nuclear Plant Projects Westinghouse Electric Company Mr. Paul Gunter 2000 Day Hill Road Director of the Reactor Watchdog Project Windsor, CT 06095-0500 Nuclear Information & Resource Service 1424 16th Street, NW, Suite 404 Dr. Regis A. Matzie Washington, DC 20036 Senior Vice President and Chief Technology Officer Mr. Ron Simard Westinghouse Electric Company Nuclear Energy Institute 2000 Day Hill Road Suite 400 Windsor, CT 06095-0500 1776 I Street, NW Washington, DC 20006-3708 Mr. Gary Wright, Manager Office of Nuclear Facility Safety Mr. Russell Bell Illinois Department of Nuclear Safety Nuclear Energy Institute 1035 Outer Park Drive Suite 400 Springfield, IL 62704 1776 I Street, NW Washington, DC 20006-3708 Mr. Vince Langman Licensing Manager Mr. Thomas P. Miller Atomic Energy of Canada Limited U.S. Department of Energy 2251 Speakman Drive Headquarters - Germantown Mississauga, Ontario 19901 Germantown Road Canada L5K 1B2 Germantown, MD 20874-1290 Mr. David Ritter Mr. James Riccio Research Associate on Nuclear Energy Greenpeace Public Citizens Critical Mass Energy 702 H Street, NW, Suite 300 and Environmental Program Washington, DC 20001 215 Pennsylvania Avenue, SE Washington, DC 20003 Rod Krich Vice President, Licensing Projects Mr. Tom Clements Exelon Nuclear 6703 Guide Avenue 4300 Winfield Road Takoma Park, MD 20912 Warrenville, IL 60555 Mr. Edwin Lyman Patricia Campbell Nuclear Control Institute Winston & Strawn 1000 Connecticut Avenue, NW 1400 L Street, NW Suite 410 Washington, DC 20005 Washington, DC 20036 Mr. Eddie Grant Mr. Jack W. Roe Exelon Generation SCIENTECH, INC.

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Vice President, Special Projects 500 TownPark Lane Exelon Generation Kennesaw, GA 30144 200 Exelon Way, KSA3-E Kennett Square, PA 19348 Mr. Joseph D. Hegner Lead Engineer - Licensing Dominion Generation Early Site Permitting Project 5000 Dominion Boulevard Glen Allen, VA 23060 Mr. George Alan Zinke Project Manager Nuclear Business Development Entergy Nuclear M-ECH-683 1340 Echelon Parkway Jackson, MS 39213 Mr. Charles Brinkman Westinghouse Electric Co.

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