ML19233A293
| ML19233A293 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 08/21/2019 |
| From: | Annette Vietti-Cook NRC/SECY |
| To: | NRC/OGC, Tennessee Valley Authority |
| SECY RAS | |
| References | |
| 52-047-ESP, ASLBP 17-954-01-ESP-BD02, RAS 55188 | |
| Download: ML19233A293 (7) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of TENNESSEE VALLEY AUTHORITY Docket No. 52-047-ESP (Clinch River Nuclear Site Early Site Permit Application)
ORDER (Transmitting Post-Hearing Questions)
The Commission held an evidentiary hearing on August 14, 2019, at its Rockville, Maryland headquarters to receive testimony and exhibits in the uncontested portion of the captioned proceeding. The Tennessee Valley Authority (TVA) and the NRC Staff (Staff) should file written responses to the post-hearing questions listed in the table below no later than August 28, 2019. The responses should be filed as exhibits, using the previously established numbering scheme. The parties should consult prior to filing their responses and indicate whether there are any objections to admitting the new exhibits into the record. Absent objection, the new exhibits will be admitted. This order is issued pursuant to my authority under 10 C.F.R. § 2.346(a) and (j).
No. Category Reference Directed Question To 1 Safety Ex. NRC-002, Draft Early Staff Could the Commission dispense with Permit Condition 5 and Site Permit for the Clinch instead rely on the Staff to review whether the emergency planning River Nuclear Site (June zone (EPZ) sizing methodology, when applied to a design-specific 21, 2019) (public), at ¶ 5 source term at a later stage of licensing, justifies a plume exposure (ML19219A045) (Draft pathway (PEP) EPZ smaller than that generally described in the ESP) regulations? If so, why should Permit Condition 5 be imposed? If not, why not?
2 Safety 10 C.F.R. § 50.33(g) Staff 10 C.F.R. § 50.33(g) requires an early site permit (ESP) applicant that proposes major features of the emergency plans to meet the Ex. NRC-002, Draft ESP, requirements of that paragraph, which states that the PEP EPZ will at ¶ 4.A.(1)(i) generally be 10 miles, while the ingestion pathway will generally be 50 miles. In this case, exemption is sought from the 10-mile EPZ.
Has the Staff previously granted exemptions to the general requirement of a 10-mile EPZ? Under what circumstances? How were those circumstances similar to (or different from) this case?
3 Safety Ex. NRC-008, Clinch Staff TVAs response to electronic request for information (eRAI) 9206 River Nuclear Site Early provides an example of screening out an accident scenario for the Site Permit Application, purposes of the PEP EPZ sizing methodology. Please explain the Rev. 2Part 2, Site basis of the Staffs conclusion that it is appropriate for the PEP EPZ Safety Analysis Report sizing methodology to not account for the unique beyond design (Jan. 18, 2019), ch. 13 basis event with the highest risk, which accounts for 99% of the (ML19227A256) (SSAR) total core damage frequency for the example provided.
Ex. NRC-014A, Final Safety Evaluation Report for the Early Site Permit Application for the Clinch River Nuclear Site (June 2019) (public), ch. 13 (ML19227A216) (FSER)
No. Category Reference Directed Question To Letter from J.W. Shea, TVA, to NRC Document Control Desk (Mar. 9, 2018), Encl. at E-7 (ML18068A732) 4 Safety Proposed Rule: Staff Please describe any differences in methodology between the PEP Emergency EPZ sizing methodology contained in this ESP and the Preparedness for Small methodology contained in SECY-18-0103 and its associated Modular Reactors and guidance.
Other New Technologies, Commission Paper SECY-18-0103 (Oct. 12, 2018) (ML18134A076)
(SECY-18-0103) 5 Safety Tr. at 128-29 (Mr. Scott)1 Staff After the events of September 11, 2001, the Staff examined its emergency planning requirements to determine if they were adequate or whether they needed to be updated for potential hostile actions, and the Staff concluded that the requirements did not need to be updated. Was that conclusion based, in part, on a ten-mile EPZ with dedicated radiological emergency planning?
6 Safety Tr. at 135-36 (Mr. Scott) Staff Is the Staff finding that the proposed PEP EPZ sizing methodology maintains the same level of protection as a 10-mile EPZ necessary for the issuance of the EPZ exemptions?
7 Safety Ex. NRC-005, NRC Staff Staff In its response to Pre-Hearing Question 18, the Staff stated:
Responses to Depending on the plant design, multiple reactor accidents for multi-1 Transcript references in this table of questions are to the line-numbered copy of the official transcript provided by the Secretary of the Commission to the parties on August 20, 2019. See Memorandum from Annette L. Vietti-Cook, Secretary of the Commission, to Counsel for TVA and the Staff (Aug. 20, 2019) (ML19232A230).
No. Category Reference Directed Question To Commission Prehearing module designs may or may not be included in the spectrum of Questions (June 26, accidents used for the PEP EPZ size determination. Ex. NRC-005, 2019) (Staff Pre-Hearing Staff Pre-Hearing Responses, at 18. Please explain the basis of Responses) the Staffs conclusion that it may be appropriate to not consider the cumulative risks of multiple modules when determining an EPZ size.
Tr. at 142 (Ms. Hart) 8 Safety Tr. at 130-34 (Mr. Scott, Staff Is it the Staffs position that all-hazards planning would be just as Ms. Milligan) effective as dedicated radiological emergency planning in an actual radiological emergency?
9 Safety Tr. at 142-44 (Mr. Scott, Staff Please clarify whether there is any legal barrier to the Commission Ms. Sutton) approving only the exemptions for a two-mile EPZ at this stage and not the exemptions for a site boundary EPZ. Could the record of Tr. at 181-82 (Mr. Brown) decision and the permit specify which requested exemptions were being granted and which were being denied?
During the hearing, the Staff stated that the Commission could issue an ESP that specifically identifies the portions of the application that are not being approved but that such an undertaking would be complex. Please describe what this effort would involve.
10 Safety Staff Pre-Hearing Staff If a combined license (COL) or construction permit (CP) applicant Responses, Question 15 referencing the ESP cannot demonstrate that a site boundary PEP EPZ is justified, will a formal offsite radiological plan for the facility Tr. at 129-34 (Mr. Scott, be required?
Ms. Milligan) 11 Safety Tr. at 129-31 (Mr. Scott) Staff What is the probability of a scenario where an all-hazards approach would need to be relied upon?
12 Environmental Ex. NRC-015A, Staff In Section 1.3 of Final EIS, the Staff states that [t]he NRCs Environmental Impact purpose and need is informed by the applicants objective to use the
No. Category Reference Directed Question To Statement for an Early power generated by [small modular reactors (SMRs)] to address Site Permit (ESP) at the critical energy security issues for TVA Federal direct-served Clinch River Nuclear customers (which included only [U.S. Department of Defense] or Site (Final Report), [U.S. Department of Energy] facilities). Ex. NRC-015A, Final EIS, NUREG-2226, vol. 1 at 1-10.
(Apr. 2019), §§ 1.3, 10.2 (ML19227A213) (Final In Section 10.2 of the Final EIS, the Staff assesses the relationship EIS) between short-term uses and long-term productivity of the Clinch River Nuclear (CRN) Site. The Staff states that it is expected that National Environmental the enhancement of regional productivity resulting from the Policy Act of 1969 electrical energy produced by two or more SMRs would lead to a (NEPA) § 102(2)(C)(iv) correspondingly large increase in regional long-term productivity that would not be equaled by any other long-term use of the site.
10 C.F.R. Ex. NRC-015A, Final EIS, at 10-19. The Staff concludes that the
§ 51.105(a)(1), (4) negative impacts of constructing and operating two or more SMRs at the CRN Site would be outweighed by the positive long-term System Energy enhancement of regional productivity resulting from the production Resources, Inc. (Early of electrical energy by such SMRs.
Site Permit for Grand Gulf ESP Site), 1. Is the projected increase in productivity described in CLI-07-14, 65 NRC 216, Section 10.2 of the Final EIS based on the maximum 218-19 (2007) electrical output of the bounding plant parameter envelope (PPE), i.e. 800 MW(e)?
- 2. Is the projected increase in productivity described in Section 10.2 of the Final EIS based on the power generated by SMRs to address critical energy security issues for TVA Federal direct-served customers (which included only [U.S.
Department of Defense] or [U.S. Department of Energy]
facilities)?
- 3. What is the region the Staff considered for the purposes of its analysis and conclusions regarding regional productivity in Section 10.2 of the Final EIS?
For the Commission NRC SEAL /RA/
Annette L. Vietti-Cook Secretary of the Commission Dated at Rockville, Maryland, this 21st day of August, 2019.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
TENNESSEE VALLEY AUTHORITY )
) Docket No. 52-047-ESP (Early Site Permit Application )
for Clinch River Nuclear Site) )
)
(Mandatory Hearing) )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing ORDER (Transmitting Post-Hearing Questions) have been served upon the following persons by Electronic Information Exchange.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Office of the General Counsel Mail Stop O-16B33 Mail Stop O-14A44 Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: ocaamail@nrc.gov Marcia Carpentier, Esq.
Ann Hove, Esq.
U.S. Nuclear Regulatory Commission Jody Martin, Esq.
Office of the Secretary of the Commission Ann Paisner, Esq.
Mail Stop O-16B33 Kevin Roach, Esq.
Washington, DC 20555-0001 David Roth, Esq.
E-mail: hearingdocket@nrc.gov Maxine Segarnick, Esq.
Michael Spencer, Esq.
Susan Vrahoretis, Esq.
Counsel for Licensee, Tennessee Valley Anthony Wilson, Esq.
Authority: Megan Wright, Esq.
Christopher Chandler, Esq. E-mail: marcia.carpentier@nrc.gov David A. Codevilla, Esq.. ann.hove@nrc.gov Ryan Dreke, Esq jody.martin@nrc.gov Tennessee Valley Authority ann.paisner@nrc.gov 400 W. Summit Hill Drive, WT 6A-K kevin.roach@nrc.gov Knoxville, TN 37902 david.roth@nrc.gov E-mail: ccchandler0@tva.gov maxine.segarnick@nrc.gov dacodevilla@tva.gov michael.spencer@nrc.gov rcdreke@tva.gov susan.vrahoretis@nrc.gov anthony.wilson@nrc.gov megan.wright@nrc.gov
[Original signed by Herald M. Speiser ]
Dated at Rockville, Maryland, Office of the Secretary of the Commission this 21st day of August, 2019