ML030990608

03/05/2003, Summary of Meeting with NEI Regarding ESP Issues

ML030990608
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/14/2003
From:	Ronaldo Jenkins NRC/NRR/NRLPO
To:	Nuclear Energy Institute
Jenkins R, NRR/NRLPO 415-2985
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ML030990583	List: ML030990608
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April 14, 2003ORGANIZATION:Nuclear Energy Institute (NEI)

SUMMARY

OF MEETING WITH THE NUCLEAR ENERGY INSTITUTE REGARDING EARLY SITE PERMIT (ESP) ISSUESOn March 5, 2003, representatives from the Nuclear Energy Institute (NEI) met with the NuclearRegulatory Commission (NRC) staff. The meeting was requested by NEI in order to discuss issues related to ESP applications and reviews. Representatives from Dominion Generation (Dominion), Exelon Generating Company (Exelon) and Entergy Operations, Inc. (Entergy) were in attendance. Enclosure 1 is a list of the meeting attendees. NRC and NEI provided handouts during themeeting which can be accessed through the Agencywide Documents Access and Management System (ADAMS). This system provides text and image files of NRC's public documents. The handouts mentioned above may be accessed through the ADAMS system under Accession No.

ML030660056. If you do not have access to ADAMS or if there are problems in accessing the handouts located in ADAMS, contact the NRC Public Document Room (PDR) reference staff at 1-800-397-4209, 301-415-4737, or by e-mail to pdr@nrc.gov

.Follow-up Items from the January 29 th MeetingIn response to the action item to consider the development of a Regulatory Guide on the formand content of ESP applications, the staff noted that the appropriate time to develop further regulatory guidance would be after any lessons learned gained by the review of the first ESP applications. Russell Bell of NEI noted that Document NEI-01-02, "Industry Guideline for Preparing An Early Site Permit Application - 10 CFR Part 52, Subpart A," will be updated later this year. The staff noted in response to comments from a representative of Greenpeace that more information regarding the ESP generic issues has been placed on the NRC website. Topics for Next MeetingNo meeting is planned between the NRC and the NEI Early Site Permit Task Force (ESPTF) inthe near future. The staff discussed other future public meetings in the ESP area. ESP-2 (ESP Inspection Guidance)The staff responded to the document "Industry Comments on IMC-2501 Nuclear ReactorInspection Guidance, ESP Phase" (See Handouts) which were transmitted via e-mail on February 21, 2003. The staff informed the NEI ESPTF that the inspection procedures will reflect the current and future staff guidance regarding quality assurance as stated in Review Standard (RS)-002, "Processing Applications for Early Site Permits." The staff noted that a formal response to the subject comments requires that those comments be submitted in writing in accordance with the public comment procedure for RS-002. NEI stated that applicable comments will be submitted in accordance with the public comment procedure before the endof the comment period on March 31, 2003.ESP-4 (NRC nominal review timeline

)NEI questioned the timing of the mandatory hearing process associated with an ESPapplication and offered to explore, at a later date, methods to reduce the one year assumed in the ESP Review Schedule. The Entergy representative noted that by the first week in May the applicant will know whether there will be any changes in its filing date. The Exelon representative reconfirmed that the Clinton ESP application will be filed in June 2003. The Dominion representative announced that the North Anna ESP application will be filed on September 26, 2003. ESP-8 (Use of a bounding approach for providing fuel cycle and transportation info required bythe National Environmental Policy Act (NEPA) (Table S-3 and S-4

)The NEI ESPTF submitted a draft issue resolution letter (See Handouts) which was transmittedto the staff via e-mail on February 21, 2003. Due to the agency information protocols, the staff declined to discussed the subject draft letter. NEI agreed to submit a white paper for staff review and further stated that a telephone conference with the staff would be scheduled at a later date to address any further questions or clarifications.ESP-9 (Criteria for assuring control of the site by ESP Holder)The NEI ESPTF provided and discussed a briefing sheet (See Handouts) on Topic ESP-9which was transmitted to the staff via e-mail on February 21, 2003. The staff had no comments on the subject material. ESP-13 (Guidance for ESP seismic evaluations)The NEI ESPTF provided and discussed their status update sheet (See Handouts) on theseismic and geotechnical work performed to-date for Topic ESP-13 which was transmitted to the staff on February 26, 2003. It was noted that some areas were not covered in the probabilistic seismic hazards analysis. The staff noted that further discussion on this item should be deferred until after specific ESP application details were available for review. ESP-19 (Addressing effects of potential new units at an existing site)The NEI ESPTF provided and discussed a briefing sheet (See Handouts) on Topic ESP-19which was transmitted to the staff via e-mail on February 21, 2003. The staff had the following comments/observations: (1) existing regulatory requirements for the existing unit must be examined to ascertain the impacts on previous licensing assumptions and commitments (e.g., aircraft hazard analyses assume a given area of risk which becomes larger given the additional unit); and (2) new threats or vulnerabilities to the existing unit may be introduced due to the presence of the new unit (e.g., turbine missiles, intakes interference for control room habitability). ESP-21 (Understanding the interface of ESP with the COL process)Both the NEI ESPTF and the staff agreed that the subject ESP Topic would be betteraddressed by the recently formed Combined License (COL) Task Force. NEI will document this transfer via a letter to the staff at a later date.ESP-22 (Form and Content of an ESP)The NEI ESPTF again requested staff feedback on the revised August 21, 2002, Form andContent of an ESP document that was presented at the August 22, 2002, public meeting. The staff responded that it was premature at this time to discuss specifics on the permit structure without consulting the Commission regarding some of the policy-related ESP issues. The staff intends to develop a SECY paper on these ESP policy issues after the receipt of the key NEI resolution letters. Follow-up Discussion on NRC responses to NEI Issue Resolution LettersThe NEI ESPTF provided and discussed briefing sheets (See Handouts) posing furtherquestions and comments on the staff responses to the NEI Issue Resolution Letters for Topics ESP-3, ESP-6, ESP-7, ESP-11 and ESP-12 which were transmitted to the staff via e-mail dated February 21 to March 4, 2003. The staff responded to the NEI questions and comments with a written presentation (See Handouts). Due to the short time frame associated with the e-mail transmittal of applicable briefing sheet, NEI agreed to participate in a future telephone conference with the staff to address any questions or clarifications for Topic ESP-12./RA/Ronaldo V. Jenkins, Senior Project ManagerNew Reactor Licensing Project Office Office of Nuclear Reactor RegulationProject No. 689

Enclosures:

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KGibson EImbro DThatcher DBarss BMusico LBanic MeetingWith the Nuclear Energy InstituteMarch 5, 2003Attendance List NRC Nuclear Energy InstituteMarsha Gamberoni, NRRRussell BellRonaldo Jenkins, NRR Ronald Simard Tom Foley, NRREllen Anderson Kaz Campe, NRR Charles Hinson, NRRGoutam Bagchi, NRROther AttendeesJames Lyons, NRRJoe Hegner, DominionJennifer Davis, NRRStefan Doerffer, AECL Ken Heck, NRRStephen Routh, Bechtel Stephen Koenick, NRRMike Bourgeois, Entergy Barry Zalcman, NRRGeorge Zinke, Entergy Bruce Musico, NRREddie Grant, Exelon Jay Lee, NRRThomas P. Mundy, Exelon Kevin Coyne, NRRBill Maher, Exelon Gene Imbro, NRRMike Case, Framatome/ ANP Thomas Kenyon, NRRMike Schoppman, Framatome/ Rockville Jerry Wilson, NRRHerbert Feinroth, Gamma Engineering Rebecca Karas, NRRGuy Cesare, Enercon Doug Pickett, NRRMike Cambia, Parsons E & C Cliff Munson, NRRPatricia Campbell, Winston & Strawn Paul F. Prescott, NRR Andrew J. Murphy, RES Jocelyn Mitchell, RES Antonio Fernandez, OGC Janice Moore, OGC Cassie Bray, OGC Brooke G. Smith, OGCEnclosure 1 ESP-Generic cc:Mr. David LochbaumUnion of Concerned Scientists 1707 H Street, NW Suite 600 Washington, DC 20006-3919Mr. Paul GunterDirector of the Reactor Watchdog Project Nuclear Information & Resource Service

1424 16 th Street, NW, Suite 404Washington, DC 20036Mr. Ron SimardNuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708Mr. Russell BellNuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708Mr. Thomas P. MillerU.S. Department of Energy Headquarters - Germantown 19901 Germantown Road Germantown, MD 20874-1290Mr. James RiccioGreenpeace 702 H Street, NW, Suite 300 Washington, DC 20001Rod KrichVice President, Licensing Projects Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555Patricia CampbellWinston & Strawn 1400 L Street, NW Washington, DC 20005Mr. Eddie GrantExelon Generation 200 Exelon Way, KSA3-E Kennett Square, PA 19348Mr. James F. Mallay, DirectorRegulatory Affairs FRAMATOME, ANP 3315 Old Forest Road Lynchburg, VA 24501Mr. Ernie H. KennedyVice President New Plants Nuclear Plant Projects Westinghouse Electric Company 2000 Day Hill Road Windsor, CT 06095-0500Dr. Regis A. MatzieSenior Vice President and Chief Technology Officer Westinghouse Electric Company 2000 Day Hill Road Windsor, CT 06095-0500Mr. Gary Wright, ManagerOffice of Nuclear Facility Safety Illinois Department of Nuclear Safety 1035 Outer Park Drive Springfield, IL 62704Mr. Vince LangmanLicensing Manager Atomic Energy of Canada Limited 2251 Speakman Drive Mississauga, Ontario Canada L5K 1B2Mr. David RitterResearch Associate on Nuclear Energy Public Citizens Critical Mass Energy and Environmental Program 215 Pennsylvania Avenue, SE Washington, DC 20003Mr. Tom Clements6703 Guide Avenue Takoma Park, MD 20912 Mr. Edwin LymanNuclear Control Institute 1000 Connecticut Avenue, NW Suite 410 Washington, DC 20036Mr. Jack W. RoeSCIENTECH, INC.

910 Clopper Road Gaithersburg, MD 20878Dr. Gail H. MarcusU.S. Department of Energy Room 5A-143 1000 Independence Ave., SW Washington, DC 20585Ms. Marilyn KrayVice President, Special Projects Exelon Generation 200 Exelon Way, KSA3-E Kennett Square, PA 19348Mr. Joseph D. HegnerLead Engineer - Licensing Dominion Generation Early Site Permitting Project 5000 Dominion Boulevard Glen Allen, VA 23060Mr. George Alan ZinkeProject Manager Nuclear Business Development Entergy Nuclear M-ECH-683 1340 Echelon Parkway Jackson, MS 39213Mr. Charles BrinkmanWestinghouse Electric Co.

Washington Operations 12300 Twinbrook Pkwy., Suite 330 Rockville, MD 20852Mr. Ralph BeedleSenior Vice President and Chief Nuclear Officer Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708Dr. Glenn R. GeorgePA Consulting Group 130 Potter Street Haddonfield, NJ 08033Arthur R. WoodsEnercon Services, Inc.

500 TownPark Lane Kennesaw, GA 30144Mr. Thomas MundyDirector, Project Development Exelon Generation 200 Exelon Way, KSA3-E Kennett Square, PA 19348