ML031430282
| ML031430282 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 06/25/2003 |
| From: | Lyons J NRC/NRR/NRLPO |
| To: | Simard R Nuclear Energy Institute |
| Koenick S, NRR, 301-415-1239 | |
| References | |
| Download: ML031430282 (7) | |
Text
June 25, 2003 Dr. Ronald L. Simard Nuclear Energy Institute (NEI) 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
RESPONSE TO LETTER ON EARLY SITE PERMIT TOPIC 12 (ESP-12), NEPA CONSIDERATIONS OF SEVERE ACCIDENT ISSUES
Dear Dr. Simard:
The purpose of this letter is to respond to your second letter on the subject early site permit (ESP) topic dated April 28, 2003. In this letter, NEI outlined the approach that the prospective ESP applicants are going to use in preparation of their respective applications. NEI states that the approach was based on the March 26, 2003, public meeting to discuss the issue and is consistent with the staff position contained in the February 12, 2003 letter and SECY-91-041.
This letter does not change any of the understandings and expectations stated in our letter dated February 12, 2003 regarding consideration of severe accidents. We confirm the understandings and expectations cited in your letter for the prospective ESP applicants with the clarifications as listed below:
Understandings and expectations:
1.
The staff agrees. With respect to severe accident mitigation alternatives, the staff recognizes that if sufficient design information is not available at the ESP stage, then the NRC review and findings will be deferred to the COL stage.
2.
The staff agrees. The staff expects the ESP applicants to include a discussion of severe accident impacts in their environmental reports.
3.
The staff agrees. Draft ESP Review Standard RS-002 references ESRP Section 7.2 as one acceptable methodology for reviewing an applicants severe accident impacts assessment.
4.
The prospective ESP applicants have proposed to address the environmental impacts of severe accidents through a "comparative discussion" of the candidate sites with the evaluations and conclusions contained in generic NRC severe accident studies, and to demonstrate that the site-specific populations and meteorological characteristics are consistent with sites considered in the generic studies. Although a comparative discussion may provide insights into population and meteorological differences relative to previous studies, based on the level of information provided in the NEI letter it is not clear that this discussion will provide an adequate basis for concluding that the site contains no characteristics which make it unsuitable for construction and operation of a nuclear power plant.
R. Simard The staff analyses of severe accident impacts would be similar in scope and content to the site-specific analyses of environmental impacts typically addressed in more recent site-specific final environmental impact statements and generic environmental impact statements (such as NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants). These studies typically considered multiple exposure pathways (i.e., airborne releases, releases to groundwater, and fallout onto open bodies of water) and assessed impacts in terms of population exposure, early and latent fatalities, and economic costs. If the staff needs additional information to perform these analyses, then the staff will request that ESP applicants provide supplementary information as described above.
5.
NEI states that the NRC will base its finding related to severe accident environmental impacts on the expectation that severe accident impacts of future nuclear plants will be bounded by those of existing plants, which have been determined to be small. This expectation would be based on the Commissions 1985 Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants.
The NRC will perform its review on severe accident environmental impacts in accordance with ESRP Section 7.2. If specific plant design information is available (e.g., a detailed design with a Level 3 PRA), then this information would be used in the evaluation. However, even in the absence of a detailed plant design (e.g., the specific reactor type or technology is undecided), a severe accident impacts analysis is technically feasible at the ESP stage using a PPE approach and the existing guidance in ESRP Section 7.2. Such an approach could involve characterizing the spectrum of credible releases from candidate future plant designs, in terms of representative source terms and their respective frequencies, and using these release characteristics in conjunction with site-specific population and meteorology to determine site-specific risk impacts for the surrogate design. Release characteristics could be developed through a survey of severe accident analyses for previously certified ALWRs and/or operating reactors. Risk impacts could be assessed using the same metrics as in previous plant-specific and generic EISs, such as NUREG-0974, Limerick 1 and 2 Operating License and NUREG-1437. These metrics include population dose, early and latent fatalities, and economic costs. The metrics would be used to determine the acceptability of the proposed site at the ESP stage.
6.
With respect to the provisions of 10 CFR 52.39, the staff expects that the COL application would demonstrate that the severe accident analysis performed for the ESP is bounding for the proposed facility. If a COL applicant adequately makes such a demonstration, then the applicant may avail themselves of 10 CFR 52.39.
R. Simard Please contact Stephen Koenick 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 Please contact Stephen Koenick 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 Distribution: See next page ACCESSION NO. ML031430282 OFC PM:NRLPO DD:NRLPO RLEP:SC SPSB:BC OGC NAME SKoenick MGamberoni JTappert MTschiltz JMoore DATE 6/12/03 5/27/03 6/16/03 6/18/03 6/25/03 OFC D:NRLPO NAME JLyons DATE 6/25/03 OFFICIAL RECORD COPY
Distribution:
June 25, 2003 Hard Copy NRLPO R/F SKoenick MGamberoni JLyons E-mail PUBLIC ACRS/ACNW RidsNrrAdip (RBorchardt)
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RidsOgcRp NRLPO Group JTappert MRubin JLee RPalla BZalcman TKenyon AFernandez
ESP-Generic cc:
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. 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 Mr. Thomas P. Miller U.S. Department of Energy Headquarters - Germantown 19901 Germantown Road Germantown, MD 20874-1290 Mr. James Riccio Greenpeace 702 H Street, NW, Suite 300 Washington, DC 20001 Rod Krich Vice President, Licensing Projects Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Patricia Campbell Winston & Strawn 1400 L Street, NW Washington, DC 20005 Mr. Eddie Grant Exelon Generation 200 Exelon Way, KSA3-E Kennett Square, PA 19348 Mr. James F. Mallay, Director Regulatory Affairs FRAMATOME, ANP 3315 Old Forest Road Lynchburg, VA 24501 Mr. Ernie H. Kennedy Vice President New Plants Nuclear Plant Projects Westinghouse Electric Company 2000 Day Hill Road Windsor, CT 06095-0500 Dr. Regis A. Matzie Senior Vice President and Chief Technology Officer Westinghouse Electric Company 2000 Day Hill Road Windsor, CT 06095-0500 Mr. Gary Wright, Manager Office of Nuclear Facility Safety Illinois Department of Nuclear Safety 1035 Outer Park Drive Springfield, IL 62704 Mr. Vince Langman Licensing Manager Atomic Energy of Canada Limited 2251 Speakman Drive Mississauga, Ontario Canada L5K 1B2 Mr. David Ritter Research Associate on Nuclear Energy Public Citizens Critical Mass Energy and Environmental Program 215 Pennsylvania Avenue, SE Washington, DC 20003
Mr. Tom Clements 6703 Guide Avenue Takoma Park, MD 20912 Mr. Edwin Lyman Nuclear Control Institute 1000 Connecticut Avenue, NW Suite 410 Washington, DC 20036 Mr. Jack W. Roe SCIENTECH, INC.
910 Clopper Road Gaithersburg, MD 20878 Dr. Gail H. Marcus U.S. Department of Energy Room 5A-143 1000 Independence Ave., SW 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 Dr. Glenn R. George PA Consulting Group 130 Potter Street Haddonfield, NJ 08033 Arthur R. Woods Enercon Services, Inc.
500 TownPark Lane Kennesaw, GA 30144 Mr. Thomas Mundy Director, Project Development Exelon Generation 200 Exelon Way, KSA3-E Kennett Square, PA 19348