ML062220367
| ML062220367 | |
| Person / Time | |
|---|---|
| Site: | PROJ0690 |
| Issue date: | 08/10/2006 |
| From: | Gillespie F NRC/NRR/ADRO/DLR |
| To: | Marion A Nuclear Energy Institute |
| Ellis, Twana, NRR/DLR/RLRA 301-415-3134 | |
| References | |
| LR-ISG-2006-03 | |
| Download: ML062220367 (10) | |
Text
August 10, 2006 Mr. Alexander Marion Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
PROPOSED LICENSE RENEWAL INTERIM STAFF GUIDANCE LR-ISG-2006-03: STAFF GUIDANCE FOR PREPARING SEVERE ACCIDENT MITIGATION ALTERNATIVES (SAMA) ANALYSES
Dear Mr. Marion:
The purpose of this letter is to provide you with the opportunity to comment on the enclosed License Renewal Interim Staff Guidance LR-ISG-2006-03 (LR-ISG) for severe accident mitigation alternatives (SAMA) analyses (Enclosure). This LR-ISG recommends that applicants for license renewal use the Guidance Document NEI 05-01, Rev. A when preparing SAMA analyses. This LR-ISG is being proposed consistent with our goal to more efficiently resolve license renewal issues identified by the staff or the industry. Your response to this letter will assist the staff in deciding how to finalize and implement the license renewal interim staff guidance.
After receiving extensive requests for additional information regarding the SAMA analyses, several applicants for license renewal concluded that they did not fully understand the kind of information that the NRC staff was expecting to see in SAMA analyses. The Nuclear Energy Institute (NEI) decided to develop a generic guidance document to help clarify the NRC staffs expectations regarding the information that needs to be submitted in SAMA analyses. On April 8, 2005, the NEI submitted Guidance Document NEI 05-01, ?Severe Accident Mitigation Alternatives (SAMA). In an effort to develop a shared understanding of the staffs expectations and make the staffs reviews more efficient, the NRC staff reviewed the document. In a letter dated July 12, 2005, NRC provided comments on NEI 05-01. NRCs comments were discussed during a public license renewal meeting between NEI and NRC on July 21, 2005. The NEI subsequently submitted revisions to NEI 05-01 on December 16, 2005, and February 17, 2006.
The NRC staff has concluded that the final version of Rev. A to NEI 05-01, submitted on February 17, 2006, fully resolves the NRCs comments.
Although this proposed LR-ISG does not convey a change in the NRCs regulations or how they are being interpreted, it is being provided to facilitate complete preparation of future SAMA analysis submittals in support of applications for license renewal and other license amendment applications. As such, we are interested in receiving comments on the proposed LR-ISG as well as an indication of when comments can be provided to ensure its timely release. The staff plans to incorporate this guidance into a future update of Supplement 1 to Regulatory Guide 4.2,
?Preparation of Supplemental Environmental Reports for Applications To Renew Nuclear Power Plant Operating Licenses. Because this LR-ISG provides a clarification of existing guidance with no additional requirements, the staff did not perform a backfit evaluation.
A. Marion Recent SAMA analyses submitted as part of the license renewal applications have begun to use the guidance in NEI 05-01. Use of the guidance has already led to improved quality in the submitted SAMA analyses and to a reduction in the number of requests for additional information by the NRC staff.
A notice relating to this proposed LR-ISG will be published in the Federal Register. The staff is requesting your comments on the proposed LR-ISG as indicated in the Federal Register notice.
If you have any questions regarding this matter, please contact Mr. Richard L. Emch, Jr., by telephone at 301-415-1590 or by e-mail at RLE@nrc.gov.
An identical letter was sent to Mr. David Lochbaum at the Union of Concerned Scientists for comment.
Sincerely,
/RA/ Pao-Tsin Kuo for Frank P. Gillespie, Director Division of License Renewal Office of Nuclear Reactor Regulation Project No. 690
Enclosure:
Proposed LR-ISG-2006-03 cc w/encl: See next page
August 10, 2006 Mr. David Lochbaum Union of Concerned Scientists 1707 H Street, NW, Suite 600 Washington, DC 20006-3919
SUBJECT:
PROPOSED LICENSE RENEWAL INTERIM STAFF GUIDANCE LR-ISG-2006-03: STAFF GUIDANCE FOR PREPARING SEVERE ACCIDENT MITIGATION ALTERNATIVES (SAMA) ANALYSES
Dear Mr. Lochbaum:
The purpose of this letter is to provide you with the opportunity to comment on the enclosed License Renewal Interim Staff Guidance LR-ISG-2006-03 (LR-ISG) for severe accident mitigation alternatives (SAMA) analyses (Enclosure). This LR-ISG recommends that applicants for license renewal use the Guidance Document NEI 05-01, Rev. A when preparing SAMA analyses. This LR-ISG is being proposed consistent with our goal to more efficiently resolve license renewal issues identified by the staff or the industry. Your response to this letter will assist the staff in deciding how to finalize and implement the license renewal interim staff guidance.
After receiving extensive requests for additional information regarding the SAMA analyses, several applicants for license renewal concluded that they did not fully understand the kind of information that the NRC staff was expecting to see in SAMA analyses. The Nuclear Energy Institute (NEI) decided to develop a generic guidance document to help clarify the NRC staffs expectations regarding the information that needs to be submitted in SAMA analyses. On April 8, 2005, the NEI submitted Guidance Document NEI 05-01, ?Severe Accident Mitigation Alternatives (SAMA). In an effort to develop a shared understanding of the staffs expectations and make the staffs reviews more efficient, the NRC staff reviewed the document. In a letter dated July 12, 2005, NRC provided comments on NEI 05-01. NRCs comments were discussed during a public license renewal meeting between NEI and NRC on July 21, 2005. The NEI subsequently submitted revisions to NEI 05-01 on December 16, 2005, and February 17, 2006.
The NRC staff has concluded that the final version of Rev. A to NEI 05-01, submitted on February 17, 2006, fully resolves the NRCs comments.
Although this proposed LR-ISG does not convey a change in the NRCs regulations or how they are being interpreted, it is being provided to facilitate complete preparation of future SAMA analysis submittals in support of applications for license renewal and other license amendment applications. As such, we are interested in receiving comments on the proposed LR-ISG as well as an indication of when comments can be provided to ensure its timely release. The staff plans to incorporate this guidance into a future update of Supplement 1 to Regulatory Guide 4.2,
?Preparation of Supplemental Environmental Reports for Applications To Renew Nuclear Power Plant Operating Licenses. Because this LR-ISG provides a clarification of existing guidance with no additional requirements, the staff did not perform a backfit evaluation.
D. Lochbaum Recent SAMA analyses submitted as part of the license renewal applications have begun to use the guidance in NEI 05-01. Use of the guidance has already led to improved quality in the submitted SAMA analyses and to a reduction in the number of requests for additional information by the NRC staff.
A notice relating to this proposed LR-ISG will be published in the Federal Register. The staff is requesting your comments on the proposed LR-ISG as indicated in the Federal Register notice.
If you have any questions regarding this matter, please contact Mr. Richard L. Emch, Jr., by telephone at 301-415-1590 or by e-mail at RLE@nrc.gov.
An identical letter was sent to Mr. Alexander Marion at the Nuclear Energy Institute for industry comment.
Sincerely,
/RA/ Pao-Tsin Kuo for Frank P. Gillespie, Director Division of License Renewal Office of Nuclear Reactor Regulation Project No. 690
Enclosure:
Proposed LR-ISG-2006-03 cc w/encl: See next page
D. Lochbaum Recent SAMA analyses submitted as part of license renewal applications have begun to use the guidance in NEI 05-01. Use of the guidance has already led to improved quality in the submitted SAMA analyses and to a reduction in the number of requests for additional information by the NRC staff.
A notice relating to this proposed LR-ISG will be published in the Federal Register. The staff is requesting your comments on the proposed LR-ISG as indicated in the Federal Register notice.
If you have any questions regarding this matter, please contact Mr. Richard L. Emch, Jr., by telephone at 301-415-1590 or by e-mail at RLE@nrc.gov.
An identical letter was sent to Mr. Alexander Marion at the Nuclear Energy Institute for industry comment.
Sincerely,
/RA/ Pao-Tsin Kuo for Frank P. Gillespie, Director Division of License Renewal Office of Nuclear Reactor Regulation Project No. 690
Enclosure:
Proposed LR-ISG-2006-03 cc w/encl: See next page Adams Accession No. ML062220367 OFFICE LA:DLR PM:DLR:RLRB PM:DLR:REBB PM:DLR:REBB NAME Y. Edmonds L. Tran J. Davis R. Emch (RGS for)
DATE 07/14/06 07/21/06 07/14 /06 07/14/06 OFFICE OGC (NLO)
BC:DLR:REBB BC:DLR:RLRB D:DLR NAME S. Uttal R. Franovich (Jdavis for)
J. Zimmerman F. Gillespie DATE 08/04/06 08/07/06 08/08/06 08/10/06 OFFICIAL RECORD COPY
Letter to: Alexander Marion, David Lochbaum, from: Frank Gillespie, dated: August 10, 2006
SUBJECT:
PROPOSED LICENSE RENEWAL INTERIM STAFF GUIDANCE LR-ISG-2006-03: STAFF GUIDANCE FOR PREPARING SEVERE ACCIDENT MITIGATION ALTERNATIVES (SAMA) ANALYSES HARD COPY DLR RF REmch E-MAIL:
PUBLIC MRubin RPalla RidsNrrOd RidsNrrAdro RidsNrrAdra RidsNrrAdes RidsNrrDlr RidsNrrDra RidsNrrDnrl RidsNrrDlrRebb RidsNrrDlrReba DLR Staff
ENCLOSURE PROPOSED LICENSE RENEWAL INTERIM STAFF GUIDANCE LR-ISG-2006-03:
STAFF GUIDANCE FOR PREPARING SEVERE ACCIDENT MITIGATION ALTERNATIVES (SAMA) ANALYSES Introduction A Severe Accident Mitigation Alternatives (SAMA) analysis is required as part of a license renewal application, if a SAMA analysis has not already been performed for the plant and reviewed by the NRC staff. SAMA analyses have been performed and submitted to the NRC as part of all the applications for license renewal received by the staff thus far. Therefore, this LR-ISG is being proposed consistent with our goal to more efficiently resolve license renewal issues identified by the staff or the industry.
Background and Discussion After receiving extensive requests for additional information regarding the SAMA analyses, several applicants for license renewal concluded that they did not fully understand the kind of information that the NRC staff was expecting to see in SAMA analyses.
The Nuclear Energy Institute (NEI) developed a generic guidance document to help clarify the NRC staffs expectations regarding the information that needs to be submitted in SAMA analyses.
On April 8, 2005, NEI submitted NEI 05-01, ?Severe Accident Mitigation Alternatives (SAMA)
Analysis - Guidance Document. The NRC staff reviewed this guidance document, and by letter, dated July 12, 2005, provided comments on NEI 05-01. The NRC staffs comments were discussed during a public meeting between NEI and NRC on July 21, 2005.
On February 17, 2006, NEI submitted its NEI 05-01, Rev. A, dated November 2005. The NRC staff reviewed and concluded that this version fully resolved the NRC staffs comments. In addition, the NRC staff concluded that NEI 05-01, Rev. A, describes existing NRC regulations, and facilitates complete preparation of SAMA analysis submittals.
Some applicants for license renewal have submitted SAMA analyses using the guidance provided in NEI 05-01, Rev A. The NRC staff found improved quality in the submitted SAMA analyses and a reduction in the number of requests for additional information for those applications that followed the guidance provided in NEI 05-01, Rev. A.
Proposed Action The staff is proposing that applicants for license renewal follow the guidance provided in NEI 05-01, Rev. A, when preparing their SAMA analyses. The staff finds that NEI 05-01, Rev. A, describes existing NRC regulations, and facilitates complete preparation of SAMA analysis submittals.
Although this proposed LR-ISG does not convey a change in the NRCs regulations or how they are being interpreted, it is being provided to facilitate complete preparation of future SAMA analysis submittals in support of applications for license renewal. The NRC staff plans to incorporate the guidance provided in NEI 05-01, Rev. A, into a future update of Supplement 1 to Regulatory Guide 4.2, ?Preparation of Supplemental Environmental Reports for Applications to Renew Nuclear Power Plant Operating Licenses. Because this LR-ISG provides a clarification of existing guidance with no additional requirements, the staff did not perform a backfit evaluation.
For those that are interested in reviewing NEI 05-01, Rev. A, the Agencywide Documents Access and Management System (ADAMS) Accession Number is ML060530203.
NUCLEAR ENERGY INSTITUTE Project No. 690 cc:
Mr. Joe Bartell U.S. Department of Energy NE-42 Washington, DC 20585 Ms. Christine S. Salembier, Commissioner State Liaison Officer Department of Public Service 112 State St., Drawer 20 Montipelier, VT 05620-2601 Mr. James Ross Nuclear Energy Institute 1776 I St., N.W., Suite 400 Washington, DC 20006-3708 Mr. Frederick W. Polaski Manager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348 Peter A. Mazzaferro Site Project Manager - License Renewal Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093 Mr. David Lochbaum Union of Concerned Scientists 1707 H St., NW, Suite 600 Washington, DC 20006-3919 Mark Ackerman Project Manager, License Renewal FirstEnergy Nuclear Operating Company P.O. Box 4 Route 168 (Mail Stop BV-SGRP)
Shippingport, PA 15077 Mr. Paul Gunter, Director Reactor Watchdog Project Nuclear Information & Resource Service 6930 Carroll Avenue, Suite 340 Takoma Park, MD 20912 Mr. Hugh Jackson Public Citizen's Critical Mass Energy &
Environment Program 215 Pennsylvania Ave., SE Washington, DC 20003 Mary Olson Nuclear Information & Resource Service Southeast Office P.O. Box 7586 Asheville, NC 28802 Talmage B. Clements Manager - License Renewal Progress Energy P.O. Box 1551 Raleigh, NC 27602 Mr. Garry G. Young Manager, License Renewal Services 1448 SR 333, N-GSB-45 Russellville, AR 72802 Mr. William Crough, Manager Licensing and Regulatory Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 NUCLEAR ENERGY INSTITUTE Project No. 690 cc:
Patrick Burke License Renewal Project Manager Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637 Robert A. Vincent Licensing Lead - License Renewal Project Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043