ML031320110

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Letter to R. Simard USNRC Responses to NEI Comments on Draft RS-002, Processing Applications for Early Site Permits
ML031320110
Person / Time
Site: Nuclear Energy Institute
Issue date: 06/23/2003
From: Lyons J
NRC/NRR/NRLPO
To: Simard R
Nuclear Energy Institute
Scott M L, NRR/ADIP/NRLPO, 301-415-1421
References
RS-002
Download: ML031320110 (6)


Text

June 23, 2003 Dr. Ronald L. Simard Senior Director, New Plant Development Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW Suite 400 Washington, DC 20006-3708

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION RESPONSES TO NUCLEAR ENERGY INSTITUTE (NEI) COMMENTS ON DRAFT RS-002, PROCESSING APPLICATIONS FOR EARLY SITE PERMITS

Dear Dr. Simard:

This letter provides the responses of the U.S. Nuclear Regulatory Commission (NRC) staff to the comments on the subject document provided in your letter to James E. Lyons dated March 31, 2003. Enclosed with this letter are item-by-item NRC staff responses to the comments provided in the enclosure to your letter. The responses reflect the staffs positions on your comments, and they will be addressed as appropriate in the development of the final RS-002 scheduled for completion by the end of 2003.

The staff believes that the combination of the following will constitute sufficient guidance to the staff to allow rigorous, consistent, and efficient NRC staff reviews of any early site permit (ESP) applications received prior to release of the final RS-002:

Staff guidance on ESP reviews in draft RS-002 The staffs positions on ESP-related issues raised by the Nuclear Energy Institute (NEI) as documented in various letters from the staff to NEI in 2002 and 2003 The staffs responses to public comments on draft RS-002 Additional guidance to be made available to the NRC staff reviewers of potential ESP applications as needed We also believe that draft RS-002, the staffs responses to public comments on draft RS-002, and the letters the staff has provided to NEI collectively provide sufficient information to enable ESP applicants to understand the staffs expectations for the content of an ESP application.

Your letter also expressed concerns regarding NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants. The staff continues to believe that the document, with the clarifications noted in Attachment 3 to draft RS-002 and as noted in the enclosure to this letter, provides appropriate guidance to the staff for its review of an ESP

R. Simard applicants environmental report and for the staffs development of the environmental impact statement. We do not believe that the clarifications warrant markups of NUREG-1555 as suggested in your letter. Please see the staffs response to NEI comment J.1 for additional discussion on the staffs reasoning for this position.

Your letter also notes that several sections of RS-002 have not yet been released for public comment and interim use. Since the date of your letter, the staff has issued additional sections of the document on the subjects of quality assurance and accident analysis. The staff has decided that the appropriate method of providing guidance to the three potential ESP applicants on the subject of physical security is by letter. Letters providing this guidance were sent to all three potential ESP applicants on May 8, 2003. The staff may supplement this guidance in the future. The other subjects noted in your letter as missing from the draft RS-002 (emergency planning, site missiles, and aircraft hazards) are, in fact, already addressed in draft RS-002 (in Sections 13.3, 2.2.1, and 3.5.1.6, respectively).

If you have any questions regarding this letter or the staffs responses to your comments, please contact Mr. Michael L. Scott at (301) 415-1421.

Sincerely,

/RA/

James E. Lyons, Director New Reactor Licensing Project Office Office of Nuclear Reactor Regulation Project No. 689

Enclosure:

As stated cc w/encl: See next page

R. Simard applicants environmental report and for the staffs development of the environmental impact statement. We do not believe that the clarifications warrant markups of NUREG-1555 as suggested in your letter. Please see the staffs response to NEI comment J.1 for additional discussion on the staffs reasoning for this position.

Your letter also notes that several sections of RS-002 have not yet been released for public comment and interim use. Since the date of your letter, the staff has issued additional sections of the document on the subjects of quality assurance and accident analysis. The staff has decided that the appropriate method of providing guidance to the three potential ESP applicants on the subject of physical security is by letter. Letters providing this guidance were sent to all three potential ESP applicants on May 8, 2003. The staff may supplement this guidance in the future. The other subjects noted in your letter as missing from the draft RS-002 (emergency planning, site missiles, and aircraft hazards) are, in fact, already addressed in draft RS-002 (in Sections 13.3, 2.2.1, and 3.5.1.6, respectively).

If you have any questions regarding this letter or the staffs responses to your comments, please contact Mr. Michael L. Scott at (301) 415-1421.

Sincerely,

/RA/

James E. Lyons, Director New Reactor Licensing Project Office Office of Nuclear Reactor Regulation Project No. 689

Enclosure:

As stated cc w/encl: See next page ACCESSION NO.: ML031320110-ML031710698-Pkg. *See previous concurrence OFFICE NRR/NRLPO*

NRR/NRLPO*

NRR/IEHB*

NRR/SPSB*

NAME MLScott MGamberoni TQuay MTschiltz DATE 5/29/03 5/31/03 6/12/03 6/6/03 OFFICE NRR/RLEP*

NRR/IIPB*

NRR/EMEB*

NSIR*

NAME PKuo SRichards GImbro VOrdaz DATE 6/13/03 6/10/03 6/3/03 6/5/03 OFFICE OGC-NLO*

NRR/NRLPO NAME AFernandez JLyons DATE 6/19/03 6/20/03 OFFICIAL RECORD COPY

Distribution for Letter to R. Simard dated June 23, 2003 Hard Copy NRLPO Reading MScott NGilles SKoenick RWeisman KCoyne PPrescott CMunson JLee LBrown KCampe RPalla TKenyon SKlementowicz CHinson BMusico DBarss AKugler EThrom JWilliams JLyons E-mail PUBLIC NRR Division Directors NRR Branch Chiefs NRR Section Chiefs ACRS/ACNW RidsNrrAdip (RBorchardt)

RidsNrrOD (SCollins)

RidsOgcRp NRLPO Group VOrdaz SStein

Nuclear Energy Institute cc:

Mr. Marvin Fertel Senior Vice President and Chief Nuclear Officer Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708 Mr. David Lochbaum Union of Concerned Scientists 1707 H Street, NW Suite 600 Washington, DC 20006-3919 Mr. Paul Gunter Director of the Reactor Watchdog Project Nuclear Information & Resource Service 1424 16th Street, NW, Suite 404 Washington, DC 20036 Mr. James Riccio Greenpeace 702 H Street, NW, Suite 300 Washington, DC 20001 Dr. Edwin Lyman Nuclear Control Institute 1000 Connecticut Avenue, NW Suite 410 Washington, DC 20036 Mr. Gary Wright, Manager Office of Nuclear Facility Safety Illinois Department of Nuclear Safety 1035 Outer Park Drive Springfield, IL 62704 Mr. Tom Clements 6703 Gude Avenue Takoma Park, MD 20912 Mr. Vince Langman Licensing Manager Atomic Energy of Canada Limited 2251 Speakman Drive Mississauga, Ontario Canada L5K 1B2 Patricia Campbell Winston & Strawn 1400 L St., NW Washington, DC 20005 Mr. Jack W. Roe SCIENTECH, INC.

910 Clopper Road Gaithersburg, MD 20878 Mr. David Ritter Research Associate on Nuclear Energy Public Citizens Critical Mass Energy and Environmental Program 215 Pennsylvania Avenue, SE Washington, DC 20003 Mr. Thomas P. Miller U.S. Department of Energy NE-20, Rm. A286 Headquarters-Germantown 19901 Germantown Road Germantown, MD 20874-1290 Mr. Ed Rodwell, Manager PWR Design Certification Electric Power Research Institute 3412 Hillview Avenue Palo Alto, CA 94304-1395 Mr. James F. Mallay, Director Regulatory Affairs FRAMATOME, ANP 3315 Old Forest Road Lynchburg, VA 24501 J. Alan Beard GE Nuclear Energy 13113 Chestnut Oak Drive Darnestown, MD 20878-3554 Dr. Gail H. Marcus U.S. Department of Energy Office of Nuclear Energy, Science

& Technology NE-1, Room 5A-143 1000 Independence Avenue, SW Washington, DC 20585 Mr. Ron Simard Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708 Mr. Russell Bell Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708