ML031540694
| ML031540694 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 07/21/2003 |
| From: | Lyons J Office of Nuclear Reactor Regulation |
| To: | Simard R Nuclear Energy Institute |
| Scott M L, NRR/ADIP/NRLPO, 301-415-1421 | |
| References | |
| ESP-8 | |
| Download: ML031540694 (6) | |
Text
July 21, 2003 Dr. Ronald L. Simard Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
EARLY SITE PERMIT TOPIC 8 (ESP-8), FUEL CYCLE AND TRANSPORTATION IMPACTS
Dear Dr. Simard:
This is in response to your letter dated May 7, 2003, regarding analysis of fuel cycle and transportation impacts for early site permit (ESP) applications. This topic, which is identified as ESP-8 on the list of Nuclear Energy Institute (NEI) generic ESP issues, was discussed at several public meetings between September 2002 and March 2003. Your letter describes the lead ESP applicants planned approach to addressing these impacts. While your letter states that no response is necessary, the staff believes a response is appropriate to provide and document the staffs positions on certain aspects of this issue.
The staff agrees that the approach to addressing fuel cycle and transportation impacts will differ for light-water reactors (LWRs) and non-light water reactors. Should an applicant choose to submit an ESP application that references one or more LWR designs (or that includes a plant parameter envelope [PPE] intended to represent only LWRs), such applicants must use Table S-3 in 10 CFR 51.51 as the basis for evaluating fuel cycle impacts. Use of Table S-4 in 10 CFR 51.52 for transportation impacts may require additional analysis by the applicant. In accordance with 10 CFR 51.52, detailed analysis is required if the requirements of 10 CFR 51.52(a), with reference to limitations on enrichment, burnup, and power level, are exceeded. In accordance with 10 CFR 51.52(b), the applicant would need to provide a full description and detailed analysis of the environmental effects of transportation of spent fuel and wastes to and from the reactor, including values for the environmental impact under normal conditions of transport and for the environmental risk from accidents in transport.
With regard to an ESP application that references one or more non-LWR designs, the staff notes that the criteria for applicability of 10 CFR 51.51 and 51.52 are not met, because both rules pertain only to LWRs. Therefore, Tables S-3 and S-4 are not appropriate reference sources for analyzing fuel cycle and transportation impacts for ESP applications that reference non-LWRs.
To support final NRC review of fuel cycle and transportation impacts of non-LWRs at the ESP stage, ESP applicants considering non-LWRs will need to fully address fuel cycle and transportation impacts of such reactors using appropriate references. Technical reports WASH-1238 and WASH-1248, which are source documents for Tables S-3 and S-4 and cited in 10 CFR 51.51 and 51.52, may be good references in determining the impacts. However, an ESP applicant referencing non-LWRs who uses impacts from these documents bears the burden of demonstrating that the impacts, and the methods used to determine those impacts,
R. Simard are accurate and appropriate for the reactors (or PPE intended to represent the reactors) proposed by the applicant.
We would like to emphasize, as we have in several meetings with NEI and the prospective ESP applicants, that all identified fuel cycle and transportation impacts should be addressed in proportion to their significance. Finally, when discussing impacts of a new technology (e.g.,
enrichment or mining technologies), applicants should comprehensively address impacts of that technology, and should not just address impacts of earlier technology that are lessened by the new technology.
Please contact Mike Scott, ESP Project Manager, at 301-415-1421 or mls3@nrc.gov if you have any questions on this matter.
Sincerely,
/RA/
James E. Lyons, Director New, Research and Test Reactors Program Office of Nuclear Reactor Regulation Project No. 689 cc: See next page
R. Simard are accurate and appropriate for the reactors (or PPE intended to represent the reactors) proposed by the applicant.
We would like to emphasize, as we have in several meetings with NEI and the prospective ESP applicants, that all identified fuel cycle and transportation impacts should be addressed in proportion to their significance. Finally, when discussing impacts of a new technology (e.g.,
enrichment or mining technologies), applicants should comprehensively address impacts of that technology, and should not just address impacts of earlier technology that are lessened by the new technology.
Please contact Mike Scott, ESP Project Manager, at 301-415-1421 or mls3@nrc.gov if you have any questions on this matter.
Sincerely,
/RA/
James E. Lyons, Director New, Research and Test Reactors Program Office of Nuclear Reactor Regulation Project No. 689 cc: See next page Distribution: See next page ACCESSION NO: ML031540694 *See previous concurrence OFFICE NRLPO NRLPO*
RLEP*
RPRP*
NAME MScott MGamberoni JTappert DSkeen DATE 7/8/03 6/4/03 6/12/03 6/5/03 OFFICE SFPO*
OGC NRLPO NAME RLewis AFernandez JLyons DATE 6/6/03 7/16/03 7/18/03 OFFICIAL RECORD COPY
Distribution for letter to R. Simard dated July 21, 2003 Hard Copy NRLPO Rdg.
MScott MGamberoni JLyons JTappert E-mail PUBLIC ACRS/ACNW RidsNrrOD (SCollins)
RidsNrrAdip (RBorchardt)
JLyons/MGamberoni RidsNrrAdpt (BSheron)
RidsOgcRp NRLPO Group JMitchell JCook BZalcman TKenyon RKaras DSkeen RLewis
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