ML071640133

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Letter to James Riley, NEI, Regarding Final License Renewal Interim Staff Guidance LR-ISG-2006-03: Staff Guidance for Preparing Severe Accident Mitigation Alternatives Analyses
ML071640133
Person / Time
Site: PROJ0690
Issue date: 08/02/2007
From: Kuo P
NRC/NRR/ADRO/DLR
To: Jeffrey Riley
Nuclear Energy Institute
Emch R, NRR/DLR/REBB, 415-1590
References
LR-ISG-2006-03
Download: ML071640133 (7)


Text

August 2, 2007Mr. James H. RileyNuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

FINAL LICENSE RENEWAL INTERIM STAFF GUIDANCE LR-ISG-2006-03: STAFF GUIDANCE FOR PREPARING SEVERE ACCIDENT MITIGATION ALTERNATIVES ANALYSES

Dear Mr. Riley:

By letter dated August 10, 2006, we issued our proposed License Renewal Interim StaffGuidance, LR-ISG-2006-03, for public comments. By letter dated September 15, 2006, Dr. Jill Lipoti, State of New Jersey, Department of Environmental Protection, provided comments and requested that the staff take this opportunity to include a review of the impacts of terrorist attacks on nuclear facilities as part of the National Environmental Policy Act in the interim staff guidance. The staff reviewed Dr. Lipoti's comments and provided responses in a letter dated July 31, 2007, which can be found in the Agencywide Document Access and Management System (ADAMS) under Accession Number ML071380307. No changes were incorporated in the Final LR-ISG-2006-03 based on these comments. Enclosure 1 is our Final LR-ISG-2006-03. A notice relating to this Final LR-ISG will bepublished in the Federal Register. If you have any questions regarding this matter, pleasecontact 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.Sincerely,/RA/Pao-Tsin Kuo, DirectorDivision of License Renewal Office of Nuclear Reactor RegulationProject No. 690

Enclosure:

Final LR-ISG-2006-03cc w/encl: See next page August 2, 2007Mr. David LochbaumUnion of Concerned Scientists 1707 H Street, NW, Suite 600 Washington, DC 20006-3919

SUBJECT:

FINAL LICENSE RENEWAL INTERIM STAFF GUIDANCE LR-ISG-2006-03: STAFF GUIDANCE FOR PREPARING SEVERE ACCIDENT MITIGATION ALTERNATIVES ANALYSES

Dear Mr. Lochbaum:

By letter dated August 10, 2006, we issued our proposed License Renewal Interim StaffGuidance, LR-ISG-2006-03, for public comments. By letter dated September 15, 2006, Dr. Jill Lipoti, State of New Jersey, Department of Environmental Protection, provided comments and requested that the staff take this opportunity to include a review of the impacts of terrorist attacks on nuclear facilities as part of the National Environmental Policy Act in the interim staff guidance. The staff reviewed Dr. Lipoti's comments and provided responses in a letter dated July 31, 2007, which can be found in the Agencywide Document Access and Management System (ADAMS) under Accession Number ML071380307. No changes were incorporated in the Final LR-ISG-2006-03 based on these comments. Enclosure 1 is our Final LR-ISG-2006-03. A notice relating to this Final LR-ISG will bepublished in the Federal Register. If you have any questions regarding this matter, pleasecontact 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. James H. Riley at the Nuclear Energy Institute.Sincerely,/RA/Pao-Tsin Kuo, DirectorDivision of License Renewal Office of Nuclear Reactor RegulationProject No. 690

Enclosure:

Final LR-ISG-2006-03cc w/encl: See next page August 2, 2007Mr. James H. RileyNuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

FINAL LICENSE RENEWAL INTERIM STAFF GUIDANCE LR-ISG-2006-03: STAFF GUIDANCE FOR PREPARING SEVERE ACCIDENT MITIGATION ALTERNATIVES ANALYSES

Dear Mr. Riley:

By letter dated August 10, 2006, we issued our proposed License Renewal Interim StaffGuidance, LR-ISG-2006-03, for public comments. By letter dated September 15, 2006, Dr. Jill Lipoti, State of New Jersey, Department of Environmental Protection, provided comments and requested that the staff take this opportunity to include a review of the impacts of terrorist attacks on nuclear facilities as part of the National Environmental Policy Act in the interim staff guidance. The staff reviewed Dr. Lipoti's comments and provided responses in a letter dated July 31, 2007, which can be found in the Agencywide Document Access and Management System (ADAMS) under Accession Number ML071380307. No changes were incorporated in the Final LR-ISG-2006-03 based on these comments. Enclosure 1 is our Final LR-ISG-2006-03. A notice relating to this Final LR-ISG will bepublished in the Federal Register. If you have any questions regarding this matter, pleasecontact 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.Sincerely,/RA/Pao-Tsin Kuo, DirectorDivision of License Renewal Office of Nuclear Reactor RegulationProject No. 690

Enclosure:

Final LR-ISG-2006-03cc w/encl: See next page DISTRIBUTION: See next page Adams Accession No. ML071640133OFFICEPM:DLR:REBBLA:DLRPM:DLR:RLRBOGC NAMEREmchYEdmondsLTranSUttal (NLO w/comments)DATE06/15/0706/26/0707/3/0707/13/07OFFICEBC:DLR:REBBBC:DLR:RRLRBD:DLRNAMERFranovichRAuluck PTKuoDATE07/23/0707/27/0708/2/07OFFICIAL RECORD COPY Letter to: James H. Riley, David Lochbaum, from: Pao-Tsin Kuo, dated: August 2, 2007

SUBJECT:

FINAL LICENSE RENEWAL INTERIM STAFF GUIDANCELR-ISG-2006-03: STAFF GUIDANCE FOR PREPARING SEVERE ACCIDENT MITIGATION ALTERNATIVES ANALYSESHARD COPY DLR RFREmch LTranE-MAIL:PUBLICMRubin RPalla RidsNrrOd RidsNrrAdro RidsNrrAdra RidsNrrAdes RidsNrrDlr RidsNrrDra RidsNrrDnrl RidsNrrDlrRebb RidsNrrDlrReba DLR Staff EnclosureFINAL LICENSE RENEWAL INTERIM STAFF GUIDANCE LR-ISG-2006-03: STAFF GUIDANCE FOR PREPARING SEVERE ACCIDENT MITIGATIONALTERNATIVES ANALYSESIntroductionA Severe Accident Mitigation Alternatives (SAMA) analysis is required as part of a licenserenewal 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 for all applications for license renewal received by the staff thus far. Therefore, this LR-ISG is being recommended as guidance consistent with our goal to more effectively and efficiently resolve license renewal issues identified by the staff or the industry.Background and DiscussionAfter 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 theNRC staff's expectations regarding the information that should 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 staff's 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, Revision A, dated November 2005. TheNRC staff reviewed and concluded that this version fully resolved the NRC staff's comments. In addition, the NRC staff concluded that NEI 05-01, Revision A, describes existing NRC regulations and facilitates complete preparation of SAMA analysis submittals. Some applicants for license renewal have submitted SAMA analyses using the guidanceprovided in NEI 05-01, Revision 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, Revision A.Recommended ActionThe staff is recommending that applicants for license renewal follow the guidance provided inNEI 05-01, Revision A, when preparing their SAMA analyses. The staff finds that NEI 05-01, Revision A, describes existing NRC regulations, and facilitates complete preparation of SAMA analysis submittals. Although this final LR-ISG does not convey a change in the NRC's regulations or how they areinterpreted, 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, Revision 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." This LR-ISG provides a clarification ofexisting guidance with no additional requirements. For those that are interested in reviewing NEI 05-01, Revision A, the Agencywide Documents Access and Management System (ADAMS)

Accession Number is ML060530203.

Nuclear Energy Institute Project No. 690

cc:Ms. Christine S. Salembier, Commissioner State Liaison Officer Department of Public Service 112 State St., Drawer 20 Montipelier, VT 05620-2601Mr. Gordon A. CleftonNuclear Energy Institute 1776 I St., N.W., Suite 400 Washington, DC 20006-3708Mr. Frederick W. PolaskiManager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348Mr. Clifford I. CusterProject Manager, License Renewal FirstEnergy Nuclear Operating Company P.O. Box 4 Route 168 (Mail Stop SIM-2)

Shippingport, PA 15077Mr. Paul Gunter, DirectorReactor Watchdog Project Nuclear Information & Resource Service 6930 Carroll Avenue, Suite 340 Takoma Park, MD 20912Mr. Hugh JacksonPublic Citizen's Critical Mass Energy &

Environment Program 215 Pennsylvania Ave., SE Washington, DC 20003Mary OlsonNuclear Information & Resource Service Southeast Office P.O. Box 7586 Asheville, NC 28802 Mr. Garry G. YoungManager, License Renewal Services 1448 SR 333, N-GSB-45 Russellville, AR 72802Robert A. VincentLicensing Lead - License Renewal Project Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043Lorrie Bell, Project ManagerWolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839Roger StewartProgress Energy Carolinas, Inc.

3581 West Entrance Road RNP A9 Hartsville, SC 29550Michael H. Crowthers, Supervisor Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street (GENPL4)

Allentown, PA 18101-1179