ML030580136
| ML030580136 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 03/17/2003 |
| From: | Ronaldo Jenkins NRC/NRR/NRLPO |
| To: | Nuclear Energy Institute |
| Jenkins R, NRR/NRLPO 415-2985 | |
| Shared Package | |
| ML030580114 | List: |
| References | |
| Download: ML030580136 (10) | |
Text
March 17, 2003 ORGANIZATION: Nuclear Energy Institute (NEI)
SUBJECT:
SUMMARY
OF MEETING WITH THE NUCLEAR ENERGY INSTITUTE REGARDING EARLY SITE PERMIT (ESP) ISSUES On January 29, 2003, representatives from the Nuclear Energy Institute (NEI) met with the Nuclear Regulatory Commission (NRC) staff. The meeting was requested by NEI in order to discuss issues related to ESP applications and reviews. Representatives from Dominion Generation (Dominion), Exelon Generating Company (Exelon) and Entergy Operations, Inc.
(Entergy) were in attendance. is a list of the meeting attendees. NRC and NEI provided handouts during the meeting which can be accessed through the Agencywide Documents Access and Management System (ADAMS). This system provides text and image files of NRCs public documents. The handouts mentioned above may be accessed through the ADAMS system under Accession No. ML030300448. If you do not have access to ADAMS or if there are problems in accessing the handouts located in ADAMS, contact the NRC Public Document Room (PDR) reference staff at 1-800-397-4209, 301-415-4737 or by e-mail to pdr@nrc.gov.
Follow-up Items from the December 5th Meeting The staff deferred until later the following action items: (1) consideration of NEI comments on Inspection Manual Chapter (IMC) 2501, Nuclear Reactor Inspection Program Early Site Permit, (NEI will provide specific comments on IMC 2501 at the next meeting) and (2) additional comments on the ESP-8 presentation given during the December meeting (Staff will respond to the NEI issue resolution letter for ESP-8). Russell Bell of NEI noted that the Plant Parameter Envelope (PPE) Worksheet will be transmitted to the staff by February 7, 2003. NEI ESP Task Force (ESPTF) addressed an action item to respond to staff questions and comments on the environmental impact mitigation alternatives issue with Enclosure 1 (PPE White Paper) of the NEI Letter titled Resolution of Generic Topic ESP-6 (PPE Approach for ESP) dated December 20, 2002.
Topics for Next Meeting NEI ESPTF proposed the following topics to be discussed at the next meeting:
ESP-2 ESP inspection guidance - NEI to provide specific comments on IMC 2501; Staff to discuss future inspection procedures
ESP-4 Nominal NRC review timeline - NEI to provide specific comments
ESP-9 Criteria for assuring control of the site by the ESP Holder
ESP-13 Guidance for ESP seismic evaluations - Follow up by NEI
ESP-19 Addressing effects of potential new units at existing site
ESP-21 Understanding the interface of ESP with the COL process
ESP-22 Form and Content of an ESP - Additional NEI comments Industry Comments on RS-002, Draft ESP Review Standard The staff responded to comments (See handouts) which were transmitted via e-mail on January 16, 2003 on RS-002. The staff noted that a formal response to the subject comments requires that those comments be submitted in writing in accordance with the public comment procedure for RS-002. NEI stated that applicable comments will be submitted in accordance with the public comment procedure before the end of the comment period on March 31, 2003.
ESP-4 (NRC nominal review timeline)
The NRC staff provided a presentation (see handouts) on the Draft ESP Review Schedule detailing the steps needed to complete the Final Safety Evaluation Report and the Final Environmental Impact Statement for ESP applications. The staff estimates a 12-month period for the mandatory ESP hearing assuming there are no contentions. The subject schedule milestone dates represent bounding time intervals. For example, the time interval for Requests for Additional Information (RAIs) is intended to allow sufficient interaction time to clearly identify issues and concerns with the applicant given that this filing would be the first time use of the ESP process. Any reduction in the time period for RAIs would result in a corresponding reduction in the overall schedule. The staff noted that there may be up to three inspections which will be scheduled based upon an applicant specific timetable. Although the Advisory Committee for Reactor Safeguards (ACRS) milestones on the subject ESP Review Schedule will be subject to the available ACRS meeting time it was felt that the staff can plan around the multiple applications (i.e., Exelon and Entergy ESP applications) to be filed in June 2003.
ESP-18x (Alternative sources review under 10 CFR Part 52)
The NEI ESPTF discussed their e-mail note (See handouts) on the alternative sources review requirement which was transmitted to the staff on January 16, 2003. Although the staff indicated that both Title 10 of the Code of Federal Regulations (10 CFR) Part 52 and the applicable section of the Draft ESP Review Standard called for all alternatives to be addressed including alternative power sources, there may be some flexibility in how that requirement is addressed by the ESP applicant. NEI stated that they will submit their position on alternative sources as a comment to RS-002.
ESP-8 (Use of a bounding approach for providing fuel cycle and transportation info required by the National Environmental Policy Act (NEPA) (Table S-3 and S-4)
The NEI ESPTF provided a follow up presentation (See handouts) which was transmitted to the staff via e-mail on January 16, 2003. The NEI ESPTF seeks agreement with the staff that mitigating factors are adequate for the fuel cycle and transportation impacts using Tables S-3 and S-4 and that the subject methodology is applicable for any reactor technology. The
methodology is limited to the uranium fuel cycle. The staff noted that the final results should factor in previous information from the Pebble Bed Modular Reactor discussions and any application of the methodology should include justification regarding any assumptions (e.g., amount of yellow cake, centrifuge technology).
ESP-16 (Guidance for ESP approval of emergency plans)
The NEI ESPTF discussed a briefing sheet (See handouts) on Topic ESP-16 which was transmitted to the staff via e-mail on January 16, 2003. The staff had the following comments/observations: (1) reference to an existing emergency preparedness plan should be discussed in the ESP application; (2) the term significant implies the same level of importance that is consistent with past licensing decisions in this area; (3) the staff expects ESP applicants to address all of the planning standards and evaluation criteria identified in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, Supplement 2; (4) the staff prefers written letters establishing the arrangements between the ESP applicant and state and local officials; and (5) SECY-91-041, Early Site Permit Readiness, provides additional information on this subject to assist the ESP applicant. The staff stated that NRC interactions with the Federal Emergency Management Agency (FEMA) are managed through the memorandum of understanding between FEMA and the NRC and the staff meets with FEMA representatives on a quarterly basis. There were no concerns expressed regarding future performance of the joint emergency preparedness review by FEMA and NRC.
Status/Plans for the balance of generic ESP topics NEI discussed and distributed the Table of Generic ESP Interactions (See handouts) listing the status and future plans for the balance of those ESP topics which had not yet been discussed or resolved with the staff. The table also provides target dates as to when NEI expects to transmit resolution letters to the staff. The staff took an action item to consider the development of a Regulatory Guide (RG) to provide staff guidance on the form and content of ESP applications.
Public Comments A representative from Greenpeace commented that the industry only wants to talk about the benefits of nuclear power and did not want to address the impacts. He hopes the NRC staff will force the industry to address the impacts. He noted that it is inappropriate for the applicants to ask for finality on the Tables S-3 & S-4 (ESP-8) issue when the results of their analysis will not bound all of the designs they are considering and he hopes the finality of an ESP will be carefully considered such that issues won't be closed out prematurely. He also hopes that an ESP is not made so broad as to be useless. He requested that the Table of ESP Generic Interactions (See handouts) be put on the NRC website and that there be links to the correspondence associated with each ESP issues. The staff committed to place more information regarding the ESP issues on the NRC website.
The Entergy representative announced that the Grand Gulf ESP application will be filed during the last week of June 2003.
The handouts also contained transmittals from NEI entitled Industry Comments on Preliminary NRC Identification of SRP & ESRP Applicability to ESP and Industry Response to NRC Questions on ESP applications Using the Plant Parameter Envelope (PPE) Approach which were e-mailed to the staff on November 11 and December 20, 2002, respectively.
/RA/
Ronaldo V. Jenkins, Senior Project Manager New Reactor Licensing Project Office Office of Nuclear Reactor Regulation Project No. 689
Enclosure:
As stated cc w/encl: See next page
The handouts also contained transmittals from NEI entitled Industry Comments on Preliminary NRC Identification of SRP & ESRP Applicability to ESP and Industry Response to NRC Questions on ESP applications Using the Plant Parameter Envelope (PPE) Approach which were e-mailed to the staff on November 11 and December 20, 2002, respectively.
/RA/
Ronaldo V. Jenkins, Senior Project Manager New Reactor Licensing Project Office Office of Nuclear Reactor Regulation Project No. 689
Enclosure:
As stated cc w/encl: See next page ACCESSION NUMBER: ML030580114-Pkg.
OFFICE PM:NRLPO DD:NRLPO NAME RJenkins MGamberoni DATE 03/14/03 03/14/03 Document Name: C:\ORPCheckout\FileNET\ML030580136.wpd
OFFICIAL RECORD COPY
Distribution for Meeting Summary Dated March 17, 2003 Hard Copy NRLPO Rdg.
RJenkins MGamberoni (original)
E-mail PUBLIC RidsNrrOD (SCollins)
RidsNrrAdip (WBorchardt)
NRLPO Group FEltawila TBergman JTappert BZalcman TKenyon AKugler KManoly TFoley MEvans JBlake RGardner CPaulk CMunson GBagchi KCoyne CHinson SKlementowicz EThrom RMcIntyre PPrescott JMitchell AMurphy RKaras CGrimes AFernandez JMoore JLee AGill MKotzalas (NRR Communication Coord)
MEL-Zeftawy CAbbott SWeerakkody KGibson EImbro DThatcher DBarss BMusico LBanic
Meeting With the Nuclear Energy Institute January 29, 2003 Attendance List NRC Nuclear Energy Institute Marsha Gamberoni, NRR Russell Bell Ronaldo Jenkins, NRR Ronald Simard Joe Williams, NRR Robert Bishop Belkys Sosa, NRR Ellen Anderson Charles Hinson, NRR Michael Scott, NRR Other Attendees James Lyons, NRR Roger Huston, Licensing Support Services Nanette Gilles, NRR Stefan Doerffer, AECL Jim Wilson, NRR Jim Riccio, Greenpeace Stephen Koenick, NRR Mike Bourgeois, Entergy Barry Zalcman, NRR George Zinke, Entergy Bruce Musico, NRR Eddie Grant, Exelon Jay Lee, NRR Thomas P. Mundy, Exelon Kevin Coyne, NRR Bill Maher, Exelon Gene Imbro, NRR Marvin Smith, Dominion Thomas Kenyon, NRR Jenny Weil, McGraw-Hill John Tappert, NRR Robert Nitschke, INEEL Rebecca Karas, NRR Guy Cesare, Enercon Lee Banic, NRR Bill McNutt, FEMA Dan Barss, NRR James H. Purvis, FEMA Jocelyn Mitchell, RES Mike Cambia, Parsons E & C Antonio Fernandez, OGC Patricia Campbell, Winston & Strawn Enclosure 1
ESP-Generic Mr. Eddie Grant Exelon Generation cc: 200 Exelon Way, KSA3-E Kennett Square, PA 19348 Mr. David Lochbaum Union of Concerned Scientists Mr. James F. Mallay, Director 1707 H Street, NW Regulatory Affairs Suite 600 FRAMATOME, ANP Washington, DC 20006-3919 3315 Old Forest Road Lynchburg, VA 24501 Mr. Paul Gunter Director of the Reactor Watchdog Project Mr. Ernie H. Kennedy Nuclear Information & Resource Service Vice President New Plants 1424 16th Street, NW, Suite 404 Nuclear Plant Projects Washington, DC 20036 Westinghouse Electric Company 2000 Day Hill Road Mr. Ron Simard Windsor, CT 06095-0500 Nuclear Energy Institute Suite 400 Dr. Regis A. Matzie 1776 I Street, NW Senior Vice President and Washington, DC 20006-3708 Chief Technology Officer Westinghouse Electric Company Mr. Russell Bell 2000 Day Hill Road Nuclear Energy Institute Windsor, CT 06095-0500 Suite 400 1776 I Street, NW Mr. Gary Wright, Manager Washington, DC 20006-3708 Office of Nuclear Facility Safety Illinois Department of Nuclear Safety Mr. Thomas P. Miller 1035 Outer Park Drive U.S. Department of Energy Springfield, IL 62704 Headquarters - Germantown 19901 Germantown Road Mr. Vince Langman Germantown, MD 20874-1290 Licensing Manager Atomic Energy of Canada Limited Mr. James Riccio 2251 Speakman Drive Greenpeace Mississauga, Ontario 702 H Street, NW, Suite 300 Canada L5K 1B2 Washington, DC 20001 Mr. David Ritter Rod Krich Research Associate on Nuclear Energy Vice President, Licensing Projects Public Citizens Critical Mass Energy Exelon Nuclear and Environmental Program 4300 Winfield Road 215 Pennsylvania Avenue, SE Warrenville, IL 60555 Washington, DC 20003 Patricia Campbell Mr. Tom Clements Winston & Strawn 6703 Guide Avenue 1400 L Street, NW Takoma Park, MD 20912 Washington, DC 20005
Mr. Edwin Lyman Dr. Glenn R. George Nuclear Control Institute PA Consulting Group 1000 Connecticut Avenue, NW 130 Potter Street Suite 410 Haddonfield, NJ 08033 Washington, DC 20036 Arthur R. Woods Mr. Jack W. Roe Enercon Services, Inc.
SCIENTECH, INC. 500 TownPark Lane 910 Clopper Road Kennesaw, GA 30144 Gaithersburg, MD 20878 Mr. Thomas Mundy Dr. Gail H. Marcus Director, Project Development U.S. Department of Energy Exelon Generation Room 5A-143 200 Exelon Way, KSA3-E 1000 Independence Ave., SW Kennett Square, PA 19348 Washington, DC 20585 Ms. Marilyn Kray Vice President, Special Projects Exelon Generation 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.
Washington Operations 12300 Twinbrook Pkwy., Suite 330 Rockville, MD 20852 Mr. Ralph Beedle Senior Vice President and Chief Nuclear Officer Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708