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| number = ML030580136
| number = ML030580136
| issue date = 03/17/2003
| issue date = 03/17/2003
| title = 01/29/2003 - Meeting with NEI Regarding ESP Issues
| title = Meeting with NEI Regarding ESP Issues
| author name = Jenkins R V
| author name = Jenkins R
| author affiliation = NRC/NRR/NRLPO
| author affiliation = NRC/NRR/NRLPO
| addressee name =  
| addressee name =  
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| docket = PROJ0689
| docket = PROJ0689
| license number =  
| license number =  
| contact person = Jenkins R V,  NRR/NRLPO 415-2985
| contact person = Jenkins R,  NRR/NRLPO 415-2985
| package number = ML030580114
| package number = ML030580114
| document type = Meeting Summary
| document type = Meeting Summary
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=Text=
=Text=
{{#Wiki_filter:March 17, 2003ORGANIZATION:Nuclear Energy Institute (NEI)
{{#Wiki_filter:March 17, 2003 ORGANIZATION:           Nuclear Energy Institute (NEI)


==SUBJECT:==
==SUBJECT:==


==SUMMARY==
==SUMMARY==
OF MEETING WITH THE NUCLEAR ENERGY INSTITUTE REGARDING EARLY SITE PERMIT (ESP) ISSUESOn January 29, 2003, representatives from the Nuclear Energy Institute (NEI) met with theNuclear Regulatory 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.
OF MEETING WITH THE NUCLEAR ENERGY INSTITUTE REGARDING EARLY SITE PERMIT (ESP) ISSUES On January 29, 2003, representatives from the Nuclear Energy Institute (NEI) met with the Nuclear Regulatory 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.
(Entergy) were in attendance. is a list of the meeting attendees. NRC and NEI provided handouts during the meeting which can be accessed through the Agencywide Documents Access and Management System (ADAMS). This system provides text and image files of NRCs public documents. The handouts mentioned above may be accessed through the ADAMS system under Accession No. ML030300448. 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.
ML030300448. 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 December 5th Meeting The staff deferred until later the following action items: (1) consideration of NEI comments on Inspection Manual Chapter (IMC) 2501, Nuclear Reactor Inspection Program Early Site Permit, (NEI will provide specific comments on IMC 2501 at the next meeting) and (2) additional comments on the ESP-8 presentation given during the December meeting (Staff will respond to the NEI issue resolution letter for ESP-8). Russell Bell of NEI noted that the Plant Parameter Envelope (PPE) Worksheet will be transmitted to the staff by February 7, 2003. NEI ESP Task Force (ESPTF) addressed an action item to respond to staff questions and comments on the environmental impact mitigation alternatives issue with Enclosure 1 (PPE White Paper) of the NEI Letter titled Resolution of Generic Topic ESP-6 (PPE Approach for ESP) dated December 20, 2002.
.Follow-up Items from the December 5 th MeetingThe staff deferred until later the following action items: (1) consideration of NEI comments onInspection Manual Chapter (IMC) 2501, "Nuclear Reactor Inspection Program Early Site Permit," (NEI will provide specific comments on IMC 2501 at the next meeting) and (2) additional comments on the ESP-8 presentation given during the December meeting (Staff will respond to the NEI issue resolution letter for ESP-8). Russell Bell of NEI noted that the Plant Parameter Envelope (PPE) Worksheet will be transmitted to the staff by February 7, 2003. NEI ESP Task Force (ESPTF) addressed an action item to respond to staff questions and comments on the environmental impact mitigation alternatives issue with Enclosure 1 (PPE White Paper) of the NEI Letter titled "Resolution of Generic Topic ESP-6 (PPE Approach for ESP)" dated December 20, 2002. Topics for Next MeetingNEI ESPTF proposed the following topics to be discussed at the next meeting:
Topics for Next Meeting NEI ESPTF proposed the following topics to be discussed at the next meeting:
ESP-2ESP inspection guidance - NEI to provide specific comments on IMC 2501;Staff to discuss future inspection proceduresESP-4Nominal NRC review timeline - NEI to provide specific commentsESP-9Criteria for assuring control of the site by the ESP HolderESP-13Guidance for ESP seismic evaluations - Follow up by NEI ESP-19Addressing effects of potential new units at existing siteESP-21Understanding the interface of ESP with the COL processESP-22Form and Content of an ESP - Additional NEI commentsIndustry Comments on RS-002, Draft ESP Review StandardThe staff responded to comments (See handouts) which were transmitted via e-mail on January16, 2003 on RS-002. 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 end of the comment period on March 31, 2003.ESP-4 (NRC nominal review timeline
 ESP-2        ESP inspection guidance - NEI to provide specific comments on IMC 2501; Staff to discuss future inspection procedures
)The NRC staff provided a presentation (see handouts) on the Draft ESP Review Scheduledetailing the steps needed to complete the Final Safety Evaluation Report and the Final Environmental Impact Statement for ESP applications. The staff estimates a 12-month period for the mandatory ESP hearing assuming there are no contentions. The subject schedule milestone dates represent bounding time intervals. For example, the time interval for Requests for Additional Information (RAIs) is intended to allow sufficient interaction time to clearly identify issues and concerns with the applicant given that this filing would be the first time use of the ESP process. Any reduction in the time period for RAIs would result in a corresponding reduction in the overall schedule. The staff noted that there may be up to three inspections which will be scheduled based upon an applicant specific timetable. Although the Advisory Committee for Reactor Safeguards (ACRS) milestones on the subject ESP Review Schedule will be subject to the available ACRS meeting time it was felt that the staff can plan around the multiple applications (i.e., Exelon and Entergy ESP applications) to be filed in June 2003.ESP-18x (Alternative sources review under 10 CFR Part 52)The NEI ESPTF discussed their e-mail note (See handouts) on the alternative sources reviewrequirement which was transmitted to the staff on January 16, 2003. Although the staff indicated that both Title 10 of the Code of Federal Regulations (10 CFR) Part 52 and theapplicable section of the Draft ESP Review Standard called for all alternatives to be addressed including alternative power sources, there may be some flexibility in how that requirement is addressed by the ESP applicant. NEI stated that they will submit their position on alternative sources as a comment to RS-002. 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
 ESP-4        Nominal NRC review timeline - NEI to provide specific comments
)The NEI ESPTF provided a follow up presentation (See handouts) which was transmitted to thestaff via e-mail on January 16, 2003. The NEI ESPTF seeks agreement with the staff that mitigating factors are adequate for the fuel cycle and transportation impacts using Tables S-3 and S-4 and that the subject methodology is applicable for any reactor technology. The methodology is limited to the uranium fuel cycle. The staff noted that the final results shouldfactor in previous information from the Pebble Bed Modular Reactor discussions and any application of the methodology should include justification regarding any assumptions (e.g., amount of yellow cake, centrifuge technology).ESP-16 (Guidance for ESP approval of emergency plans)The NEI ESPTF discussed a briefing sheet (See handouts) on Topic ESP-16 which wastransmitted to the staff via e-mail on January 16, 2003. The staff had the following comments/observations: (1) reference to an existing emergency preparedness plan should be discussed in the ESP application; (2) the term "significant
 ESP-9        Criteria for assuring control of the site by the ESP Holder
" implies the same level of importancethat is consistent with past licensing decisions in this area; (3) the staff expects ESP applicants to address all of the planning standards and evaluation criteria identified in NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans andPreparedness in Support of Nuclear Power Plants," Revision 1, Supplement 2; (4) the staffprefers written letters establishing the arrangements between the ESP applicant and state and local officials; and (5) SECY-91-041, "Early Site Permit Readiness," provides additionalinformation on this subject to assist the ESP applicant. The staff stated that NRC interactions with the Federal Emergency Management Agency (FEMA) are managed through the memorandum of understanding between FEMA and the NRC and the staff meets with FEMA representatives on a quarterly basis. There were no concerns expressed regarding future performance of the joint emergency preparedness review by FEMA and NRC. Status/Plans for the balance of generic ESP topicsNEI discussed and distributed the Table of Generic ESP Interactions (See handouts) listing thestatus and future plans for the balance of those ESP topics which had not yet been discussed or resolved with the staff. The table also provides target dates as to when NEI expects to transmit resolution letters to the staff. The staff took an action item to consider the development of a Regulatory Guide (RG) to provide staff guidance on the form and content of ESP applications.Public CommentsA representative from Greenpeace commented that the industry only wants to talk about thebenefits of nuclear power and did not want to address the impacts. He hopes the NRC staff will force the industry to address the impacts. He noted that it is inappropriate for the applicants to ask for finality on the Tables S-3 & S-4 (ESP-8) issue when the results of their analysis will not bound all of the designs they are considering and he hopes the finality of an ESP will be carefully considered such that issues won't be closed out prematurely. He also hopes that an ESP is not made so broad as to be useless. He requested that the Table of ESP Generic Interactions (See handouts) be put on the NRC website and that there be links to the correspondence associated with each ESP issues. The staff committed to place more information regarding the ESP issues on the NRC website. The Entergy representative announced that the Grand Gulf ESP application will be filed duringthe last week of June 2003. The handouts also contained transmittals from NEI entitled "Industry Comments on PreliminaryNRC Identification of SRP & ESRP Applicability to ESP
 ESP-13        Guidance for ESP seismic evaluations - Follow up by NEI
" and "Industry Response to NRCQuestions on ESP applications Using the Plant Parameter Envelope (PPE) Approach
 
" whichwere e-mailed to the staff on November 11 and December 20, 2002, respectively./RA/Ronaldo V. Jenkins, Senior Project ManagerNew Reactor Licensing Project Office Office of Nuclear Reactor RegulationProject No. 689
                                                 ESP-19        Addressing effects of potential new units at existing site
 ESP-21        Understanding the interface of ESP with the COL process
 ESP-22        Form and Content of an ESP - Additional NEI comments Industry Comments on RS-002, Draft ESP Review Standard The staff responded to comments (See handouts) which were transmitted via e-mail on January 16, 2003 on RS-002. 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 end of the comment period on March 31, 2003.
ESP-4 (NRC nominal review timeline)
The NRC staff provided a presentation (see handouts) on the Draft ESP Review Schedule detailing the steps needed to complete the Final Safety Evaluation Report and the Final Environmental Impact Statement for ESP applications. The staff estimates a 12-month period for the mandatory ESP hearing assuming there are no contentions. The subject schedule milestone dates represent bounding time intervals. For example, the time interval for Requests for Additional Information (RAIs) is intended to allow sufficient interaction time to clearly identify issues and concerns with the applicant given that this filing would be the first time use of the ESP process. Any reduction in the time period for RAIs would result in a corresponding reduction in the overall schedule. The staff noted that there may be up to three inspections which will be scheduled based upon an applicant specific timetable. Although the Advisory Committee for Reactor Safeguards (ACRS) milestones on the subject ESP Review Schedule will be subject to the available ACRS meeting time it was felt that the staff can plan around the multiple applications (i.e., Exelon and Entergy ESP applications) to be filed in June 2003.
ESP-18x (Alternative sources review under 10 CFR Part 52)
The NEI ESPTF discussed their e-mail note (See handouts) on the alternative sources review requirement which was transmitted to the staff on January 16, 2003. Although the staff indicated that both Title 10 of the Code of Federal Regulations (10 CFR) Part 52 and the applicable section of the Draft ESP Review Standard called for all alternatives to be addressed including alternative power sources, there may be some flexibility in how that requirement is addressed by the ESP applicant. NEI stated that they will submit their position on alternative sources as a comment to RS-002.
ESP-8 (Use of a bounding approach for providing fuel cycle and transportation info required by the National Environmental Policy Act (NEPA) (Table S-3 and S-4)
The NEI ESPTF provided a follow up presentation (See handouts) which was transmitted to the staff via e-mail on January 16, 2003. The NEI ESPTF seeks agreement with the staff that mitigating factors are adequate for the fuel cycle and transportation impacts using Tables S-3 and S-4 and that the subject methodology is applicable for any reactor technology. The
 
methodology is limited to the uranium fuel cycle. The staff noted that the final results should factor in previous information from the Pebble Bed Modular Reactor discussions and any application of the methodology should include justification regarding any assumptions (e.g., amount of yellow cake, centrifuge technology).
ESP-16 (Guidance for ESP approval of emergency plans)
The NEI ESPTF discussed a briefing sheet (See handouts) on Topic ESP-16 which was transmitted to the staff via e-mail on January 16, 2003. The staff had the following comments/observations: (1) reference to an existing emergency preparedness plan should be discussed in the ESP application; (2) the term significant implies the same level of importance that is consistent with past licensing decisions in this area; (3) the staff expects ESP applicants to address all of the planning standards and evaluation criteria identified in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, Supplement 2; (4) the staff prefers written letters establishing the arrangements between the ESP applicant and state and local officials; and (5) SECY-91-041, Early Site Permit Readiness, provides additional information on this subject to assist the ESP applicant. The staff stated that NRC interactions with the Federal Emergency Management Agency (FEMA) are managed through the memorandum of understanding between FEMA and the NRC and the staff meets with FEMA representatives on a quarterly basis. There were no concerns expressed regarding future performance of the joint emergency preparedness review by FEMA and NRC.
Status/Plans for the balance of generic ESP topics NEI discussed and distributed the Table of Generic ESP Interactions (See handouts) listing the status and future plans for the balance of those ESP topics which had not yet been discussed or resolved with the staff. The table also provides target dates as to when NEI expects to transmit resolution letters to the staff. The staff took an action item to consider the development of a Regulatory Guide (RG) to provide staff guidance on the form and content of ESP applications.
Public Comments A representative from Greenpeace commented that the industry only wants to talk about the benefits of nuclear power and did not want to address the impacts. He hopes the NRC staff will force the industry to address the impacts. He noted that it is inappropriate for the applicants to ask for finality on the Tables S-3 & S-4 (ESP-8) issue when the results of their analysis will not bound all of the designs they are considering and he hopes the finality of an ESP will be carefully considered such that issues won't be closed out prematurely. He also hopes that an ESP is not made so broad as to be useless. He requested that the Table of ESP Generic Interactions (See handouts) be put on the NRC website and that there be links to the correspondence associated with each ESP issues. The staff committed to place more information regarding the ESP issues on the NRC website.
The Entergy representative announced that the Grand Gulf ESP application will be filed during the last week of June 2003.
 
The handouts also contained transmittals from NEI entitled Industry Comments on Preliminary NRC Identification of SRP & ESRP Applicability to ESP and Industry Response to NRC Questions on ESP applications Using the Plant Parameter Envelope (PPE) Approach which were e-mailed to the staff on November 11 and December 20, 2002, respectively.
                                  /RA/
Ronaldo V. Jenkins, Senior Project Manager New Reactor Licensing Project Office Office of Nuclear Reactor Regulation Project No. 689


==Enclosure:==
==Enclosure:==
As stated cc w/encl: See next page The handouts also contained transmittals from NEI entitled "Industry Comments on PreliminaryNRC Identification of SRP & ESRP Applicability to ESP
As stated cc w/encl: See next page
" and "Industry Response to NRCQuestions on ESP applications Using the Plant Parameter Envelope (PPE) Approach
 
" whichwere e-mailed to the staff on November 11 and December 20, 2002, respectively./RA/Ronaldo V. Jenkins, Senior Project ManagerNew Reactor Licensing Project Office Office of Nuclear Reactor RegulationProject No. 689
The handouts also contained transmittals from NEI entitled Industry Comments on Preliminary NRC Identification of SRP & ESRP Applicability to ESP and Industry Response to NRC Questions on ESP applications Using the Plant Parameter Envelope (PPE) Approach which were e-mailed to the staff on November 11 and December 20, 2002, respectively.
                                    /RA/
Ronaldo V. Jenkins, Senior Project Manager New Reactor Licensing Project Office Office of Nuclear Reactor Regulation Project No. 689


==Enclosure:==
==Enclosure:==
As stated cc w/encl: See next pageACCESSION NUMBER: ML030580114-Pkg.OFFICEPM:NRLPODD:NRLPONAMERJenkinsMGamberoniDATE03/14/0303/14/03Document Name: C:\ORPCheckout\FileNET\ML030580136.wpd OFFICIAL RECORD COPY Distribution for Meeting Summary Dated March 17, 2003Hard CopyNRLPO Rdg.RJenkins MGamberoni (original)E-mailPUBLICRidsNrrOD (SCollins)
As stated cc w/encl: See next page ACCESSION NUMBER: ML030580114-Pkg.
OFFICE PM:NRLPO                DD:NRLPO NAME RJenkins                  MGamberoni DATE      03/14/03              03/14/03 Document Name: C:\ORPCheckout\FileNET\ML030580136.wpd
 
OFFICIAL RECORD COPY
 
Distribution for Meeting Summary Dated March 17, 2003 Hard Copy NRLPO Rdg.
RJenkins MGamberoni (original)
E-mail PUBLIC RidsNrrOD (SCollins)
RidsNrrAdip (WBorchardt)
RidsNrrAdip (WBorchardt)
NRLPO Group FEltawila TBergman JTappert BZalcman TKenyon AKugler KManoly TFoley MEvans JBlake RGardner CPaulk CMunson GBagchi KCoyne CHinson SKlementowicz EThrom RMcIntyre PPrescott JMitchell AMurphy RKaras CGrimes AFernandez JMoore JLee AGill MKotzalas (NRR Communication Coord)
NRLPO Group FEltawila TBergman JTappert BZalcman TKenyon AKugler KManoly TFoley MEvans JBlake RGardner CPaulk CMunson GBagchi KCoyne CHinson SKlementowicz EThrom RMcIntyre PPrescott JMitchell AMurphy RKaras CGrimes AFernandez JMoore JLee AGill MKotzalas (NRR Communication Coord)
MEL-Zeftawy CAbbott SWeerakkody
MEL-Zeftawy CAbbott SWeerakkody KGibson EImbro DThatcher DBarss BMusico LBanic
 
Meeting With the Nuclear Energy Institute January 29, 2003 Attendance List NRC                                Nuclear Energy Institute Marsha Gamberoni, NRR              Russell Bell Ronaldo Jenkins, NRR                Ronald Simard Joe Williams, NRR                  Robert Bishop Belkys Sosa, NRR                    Ellen Anderson Charles Hinson, NRR Michael Scott, NRR                  Other Attendees James Lyons, NRR                    Roger Huston, Licensing Support Services Nanette Gilles, NRR                Stefan Doerffer, AECL Jim Wilson, NRR                    Jim Riccio, Greenpeace Stephen Koenick, NRR                Mike Bourgeois, Entergy Barry Zalcman, NRR                  George Zinke, Entergy Bruce Musico, NRR                  Eddie Grant, Exelon Jay Lee, NRR                        Thomas P. Mundy, Exelon Kevin Coyne, NRR                    Bill Maher, Exelon Gene Imbro, NRR                    Marvin Smith, Dominion Thomas Kenyon, NRR                  Jenny Weil, McGraw-Hill John Tappert, NRR                  Robert Nitschke, INEEL Rebecca Karas, NRR                  Guy Cesare, Enercon Lee Banic, NRR                      Bill McNutt, FEMA Dan Barss, NRR                      James H. Purvis, FEMA Jocelyn Mitchell, RES              Mike Cambia, Parsons E & C Antonio Fernandez, OGC              Patricia Campbell, Winston & Strawn Enclosure 1


KGibson EImbro DThatcher DBarss BMusico LBanic MeetingWith the Nuclear Energy InstituteJanuary 29, 2003Attendance List NRC Nuclear Energy InstituteMarsha Gamberoni, NRRRussell BellRonaldo Jenkins, NRR Ronald Simard Joe Williams, NRRRobert Bishop Belkys Sosa, NRREllen Anderson Charles Hinson, NRRMichael Scott, NRROther  AttendeesJames Lyons, NRRRoger Huston, Licensing Support ServicesNanette Gilles, NRRStefan Doerffer, AECL Jim Wilson, NRRJim Riccio, Greenpeace 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, NRRMarvin Smith, Dominion Thomas Kenyon, NRRJenny Weil, McGraw-Hill John Tappert, NRRRobert Nitschke, INEEL Rebecca Karas, NRRGuy Cesare, Enercon Lee Banic, NRRBill McNutt, FEMA Dan Barss, NRRJames H. Purvis, FEMA Jocelyn Mitchell, RESMike Cambia, Parsons E & C Antonio Fernandez, OGCPatricia Campbell, Winston & StrawnEnclosure 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
ESP-Generic                              Mr. Eddie Grant Exelon Generation cc:                                      200 Exelon Way, KSA3-E Kennett Square, PA 19348 Mr. David Lochbaum Union of Concerned Scientists            Mr. James F. Mallay, Director 1707 H Street, NW                        Regulatory Affairs Suite 600                                FRAMATOME, ANP Washington, DC 20006-3919                3315 Old Forest Road Lynchburg, VA 24501 Mr. Paul Gunter Director of the Reactor Watchdog Project Mr. Ernie H. Kennedy Nuclear Information & Resource Service  Vice President New Plants 1424 16th Street, NW, Suite 404          Nuclear Plant Projects Washington, DC 20036                    Westinghouse Electric Company 2000 Day Hill Road Mr. Ron Simard                          Windsor, CT 06095-0500 Nuclear Energy Institute Suite 400                                Dr. Regis A. Matzie 1776 I Street, NW                        Senior Vice President and Washington, DC 20006-3708                Chief Technology Officer Westinghouse Electric Company Mr. Russell Bell                        2000 Day Hill Road Nuclear Energy Institute                Windsor, CT 06095-0500 Suite 400 1776 I Street, NW                        Mr. Gary Wright, Manager Washington, DC 20006-3708                Office of Nuclear Facility Safety Illinois Department of Nuclear Safety Mr. Thomas P. Miller                    1035 Outer Park Drive U.S. Department of Energy                Springfield, IL 62704 Headquarters - Germantown 19901 Germantown Road                    Mr. Vince Langman Germantown, MD 20874-1290                Licensing Manager Atomic Energy of Canada Limited Mr. James Riccio                        2251 Speakman Drive Greenpeace                              Mississauga, Ontario 702 H Street, NW, Suite 300              Canada L5K 1B2 Washington, DC 20001 Mr. David Ritter Rod Krich                                Research Associate on Nuclear Energy Vice President, Licensing Projects      Public Citizens Critical Mass Energy Exelon Nuclear                            and Environmental Program 4300 Winfield Road                      215 Pennsylvania Avenue, SE Warrenville, IL 60555                    Washington, DC 20003 Patricia Campbell                       Mr. Tom Clements Winston & Strawn                        6703 Guide Avenue 1400 L Street, NW                       Takoma Park, MD 20912 Washington, DC 20005


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.
Mr. Edwin Lyman                      Dr. Glenn R. George Nuclear Control Institute           PA Consulting Group 1000 Connecticut Avenue, NW         130 Potter Street Suite 410                           Haddonfield, NJ 08033 Washington, DC 20036 Arthur R. Woods Mr. Jack W. Roe                      Enercon Services, 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.
SCIENTECH, INC.                     500 TownPark Lane 910 Clopper Road                     Kennesaw, GA 30144 Gaithersburg, MD 20878 Mr. Thomas Mundy Dr. Gail H. Marcus                  Director, Project Development U.S. Department of Energy           Exelon Generation Room 5A-143                         200 Exelon Way, KSA3-E 1000 Independence Ave., SW           Kennett Square, PA 19348 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 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.
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}}
500 TownPark Lane Kennesaw, GA 30144Mr. Thomas MundyDirector, Project Development Exelon Generation 200 Exelon Way, KSA3-E Kennett Square, PA  19348}}

Latest revision as of 22:07, 23 March 2020

Meeting with NEI Regarding ESP Issues
ML030580136
Person / Time
Site: Nuclear Energy Institute
Issue date: 03/17/2003
From: Ronaldo Jenkins
NRC/NRR/NRLPO
To:
Nuclear Energy Institute
Jenkins R, NRR/NRLPO 415-2985
Shared Package
ML030580114 List:
References
Download: ML030580136 (10)
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Text

March 17, 2003 ORGANIZATION: Nuclear Energy Institute (NEI)

SUBJECT:

SUMMARY

OF MEETING WITH THE NUCLEAR ENERGY INSTITUTE REGARDING EARLY SITE PERMIT (ESP) ISSUES On January 29, 2003, representatives from the Nuclear Energy Institute (NEI) met with the Nuclear Regulatory 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. is a list of the meeting attendees. NRC and NEI provided handouts during the meeting which can be accessed through the Agencywide Documents Access and Management System (ADAMS). This system provides text and image files of NRCs public documents. The handouts mentioned above may be accessed through the ADAMS system under Accession No. ML030300448. 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 December 5th Meeting The staff deferred until later the following action items: (1) consideration of NEI comments on Inspection Manual Chapter (IMC) 2501, Nuclear Reactor Inspection Program Early Site Permit, (NEI will provide specific comments on IMC 2501 at the next meeting) and (2) additional comments on the ESP-8 presentation given during the December meeting (Staff will respond to the NEI issue resolution letter for ESP-8). Russell Bell of NEI noted that the Plant Parameter Envelope (PPE) Worksheet will be transmitted to the staff by February 7, 2003. NEI ESP Task Force (ESPTF) addressed an action item to respond to staff questions and comments on the environmental impact mitigation alternatives issue with Enclosure 1 (PPE White Paper) of the NEI Letter titled Resolution of Generic Topic ESP-6 (PPE Approach for ESP) dated December 20, 2002.

Topics for Next Meeting NEI ESPTF proposed the following topics to be discussed at the next meeting:

 ESP-2 ESP inspection guidance - NEI to provide specific comments on IMC 2501; Staff to discuss future inspection procedures

 ESP-4 Nominal NRC review timeline - NEI to provide specific comments

 ESP-9 Criteria for assuring control of the site by the ESP Holder

 ESP-13 Guidance for ESP seismic evaluations - Follow up by NEI

 ESP-19 Addressing effects of potential new units at existing site

 ESP-21 Understanding the interface of ESP with the COL process

 ESP-22 Form and Content of an ESP - Additional NEI comments Industry Comments on RS-002, Draft ESP Review Standard The staff responded to comments (See handouts) which were transmitted via e-mail on January 16, 2003 on RS-002. 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 end of the comment period on March 31, 2003.

ESP-4 (NRC nominal review timeline)

The NRC staff provided a presentation (see handouts) on the Draft ESP Review Schedule detailing the steps needed to complete the Final Safety Evaluation Report and the Final Environmental Impact Statement for ESP applications. The staff estimates a 12-month period for the mandatory ESP hearing assuming there are no contentions. The subject schedule milestone dates represent bounding time intervals. For example, the time interval for Requests for Additional Information (RAIs) is intended to allow sufficient interaction time to clearly identify issues and concerns with the applicant given that this filing would be the first time use of the ESP process. Any reduction in the time period for RAIs would result in a corresponding reduction in the overall schedule. The staff noted that there may be up to three inspections which will be scheduled based upon an applicant specific timetable. Although the Advisory Committee for Reactor Safeguards (ACRS) milestones on the subject ESP Review Schedule will be subject to the available ACRS meeting time it was felt that the staff can plan around the multiple applications (i.e., Exelon and Entergy ESP applications) to be filed in June 2003.

ESP-18x (Alternative sources review under 10 CFR Part 52)

The NEI ESPTF discussed their e-mail note (See handouts) on the alternative sources review requirement which was transmitted to the staff on January 16, 2003. Although the staff indicated that both Title 10 of the Code of Federal Regulations (10 CFR) Part 52 and the applicable section of the Draft ESP Review Standard called for all alternatives to be addressed including alternative power sources, there may be some flexibility in how that requirement is addressed by the ESP applicant. NEI stated that they will submit their position on alternative sources as a comment to RS-002.

ESP-8 (Use of a bounding approach for providing fuel cycle and transportation info required by the National Environmental Policy Act (NEPA) (Table S-3 and S-4)

The NEI ESPTF provided a follow up presentation (See handouts) which was transmitted to the staff via e-mail on January 16, 2003. The NEI ESPTF seeks agreement with the staff that mitigating factors are adequate for the fuel cycle and transportation impacts using Tables S-3 and S-4 and that the subject methodology is applicable for any reactor technology. The

methodology is limited to the uranium fuel cycle. The staff noted that the final results should factor in previous information from the Pebble Bed Modular Reactor discussions and any application of the methodology should include justification regarding any assumptions (e.g., amount of yellow cake, centrifuge technology).

ESP-16 (Guidance for ESP approval of emergency plans)

The NEI ESPTF discussed a briefing sheet (See handouts) on Topic ESP-16 which was transmitted to the staff via e-mail on January 16, 2003. The staff had the following comments/observations: (1) reference to an existing emergency preparedness plan should be discussed in the ESP application; (2) the term significant implies the same level of importance that is consistent with past licensing decisions in this area; (3) the staff expects ESP applicants to address all of the planning standards and evaluation criteria identified in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, Supplement 2; (4) the staff prefers written letters establishing the arrangements between the ESP applicant and state and local officials; and (5) SECY-91-041, Early Site Permit Readiness, provides additional information on this subject to assist the ESP applicant. The staff stated that NRC interactions with the Federal Emergency Management Agency (FEMA) are managed through the memorandum of understanding between FEMA and the NRC and the staff meets with FEMA representatives on a quarterly basis. There were no concerns expressed regarding future performance of the joint emergency preparedness review by FEMA and NRC.

Status/Plans for the balance of generic ESP topics NEI discussed and distributed the Table of Generic ESP Interactions (See handouts) listing the status and future plans for the balance of those ESP topics which had not yet been discussed or resolved with the staff. The table also provides target dates as to when NEI expects to transmit resolution letters to the staff. The staff took an action item to consider the development of a Regulatory Guide (RG) to provide staff guidance on the form and content of ESP applications.

Public Comments A representative from Greenpeace commented that the industry only wants to talk about the benefits of nuclear power and did not want to address the impacts. He hopes the NRC staff will force the industry to address the impacts. He noted that it is inappropriate for the applicants to ask for finality on the Tables S-3 & S-4 (ESP-8) issue when the results of their analysis will not bound all of the designs they are considering and he hopes the finality of an ESP will be carefully considered such that issues won't be closed out prematurely. He also hopes that an ESP is not made so broad as to be useless. He requested that the Table of ESP Generic Interactions (See handouts) be put on the NRC website and that there be links to the correspondence associated with each ESP issues. The staff committed to place more information regarding the ESP issues on the NRC website.

The Entergy representative announced that the Grand Gulf ESP application will be filed during the last week of June 2003.

The handouts also contained transmittals from NEI entitled Industry Comments on Preliminary NRC Identification of SRP & ESRP Applicability to ESP and Industry Response to NRC Questions on ESP applications Using the Plant Parameter Envelope (PPE) Approach which were e-mailed to the staff on November 11 and December 20, 2002, respectively.

/RA/

Ronaldo V. Jenkins, Senior Project Manager New Reactor Licensing Project Office Office of Nuclear Reactor Regulation Project No. 689

Enclosure:

As stated cc w/encl: See next page

The handouts also contained transmittals from NEI entitled Industry Comments on Preliminary NRC Identification of SRP & ESRP Applicability to ESP and Industry Response to NRC Questions on ESP applications Using the Plant Parameter Envelope (PPE) Approach which were e-mailed to the staff on November 11 and December 20, 2002, respectively.

/RA/

Ronaldo V. Jenkins, Senior Project Manager New Reactor Licensing Project Office Office of Nuclear Reactor Regulation Project No. 689

Enclosure:

As stated cc w/encl: See next page ACCESSION NUMBER: ML030580114-Pkg.

OFFICE PM:NRLPO DD:NRLPO NAME RJenkins MGamberoni DATE 03/14/03 03/14/03 Document Name: C:\ORPCheckout\FileNET\ML030580136.wpd

OFFICIAL RECORD COPY

Distribution for Meeting Summary Dated March 17, 2003 Hard Copy NRLPO Rdg.

RJenkins MGamberoni (original)

E-mail PUBLIC RidsNrrOD (SCollins)

RidsNrrAdip (WBorchardt)

NRLPO Group FEltawila TBergman JTappert BZalcman TKenyon AKugler KManoly TFoley MEvans JBlake RGardner CPaulk CMunson GBagchi KCoyne CHinson SKlementowicz EThrom RMcIntyre PPrescott JMitchell AMurphy RKaras CGrimes AFernandez JMoore JLee AGill MKotzalas (NRR Communication Coord)

MEL-Zeftawy CAbbott SWeerakkody KGibson EImbro DThatcher DBarss BMusico LBanic

Meeting With the Nuclear Energy Institute January 29, 2003 Attendance List NRC Nuclear Energy Institute Marsha Gamberoni, NRR Russell Bell Ronaldo Jenkins, NRR Ronald Simard Joe Williams, NRR Robert Bishop Belkys Sosa, NRR Ellen Anderson Charles Hinson, NRR Michael Scott, NRR Other Attendees James Lyons, NRR Roger Huston, Licensing Support Services Nanette Gilles, NRR Stefan Doerffer, AECL Jim Wilson, NRR Jim Riccio, Greenpeace Stephen Koenick, NRR Mike Bourgeois, Entergy Barry Zalcman, NRR George Zinke, Entergy Bruce Musico, NRR Eddie Grant, Exelon Jay Lee, NRR Thomas P. Mundy, Exelon Kevin Coyne, NRR Bill Maher, Exelon Gene Imbro, NRR Marvin Smith, Dominion Thomas Kenyon, NRR Jenny Weil, McGraw-Hill John Tappert, NRR Robert Nitschke, INEEL Rebecca Karas, NRR Guy Cesare, Enercon Lee Banic, NRR Bill McNutt, FEMA Dan Barss, NRR James H. Purvis, FEMA Jocelyn Mitchell, RES Mike Cambia, Parsons E & C Antonio Fernandez, OGC Patricia Campbell, Winston & Strawn Enclosure 1

ESP-Generic Mr. Eddie Grant Exelon Generation cc: 200 Exelon Way, KSA3-E Kennett Square, PA 19348 Mr. David Lochbaum Union of Concerned Scientists Mr. James F. Mallay, Director 1707 H Street, NW Regulatory Affairs Suite 600 FRAMATOME, ANP Washington, DC 20006-3919 3315 Old Forest Road Lynchburg, VA 24501 Mr. Paul Gunter Director of the Reactor Watchdog Project Mr. Ernie H. Kennedy Nuclear Information & Resource Service Vice President New Plants 1424 16th Street, NW, Suite 404 Nuclear Plant Projects Washington, DC 20036 Westinghouse Electric Company 2000 Day Hill Road Mr. Ron Simard Windsor, CT 06095-0500 Nuclear Energy Institute Suite 400 Dr. Regis A. Matzie 1776 I Street, NW Senior Vice President and Washington, DC 20006-3708 Chief Technology Officer Westinghouse Electric Company Mr. Russell Bell 2000 Day Hill Road Nuclear Energy Institute Windsor, CT 06095-0500 Suite 400 1776 I Street, NW Mr. Gary Wright, Manager Washington, DC 20006-3708 Office of Nuclear Facility Safety Illinois Department of Nuclear Safety Mr. Thomas P. Miller 1035 Outer Park Drive U.S. Department of Energy Springfield, IL 62704 Headquarters - Germantown 19901 Germantown Road Mr. Vince Langman Germantown, MD 20874-1290 Licensing Manager Atomic Energy of Canada Limited Mr. James Riccio 2251 Speakman Drive Greenpeace Mississauga, Ontario 702 H Street, NW, Suite 300 Canada L5K 1B2 Washington, DC 20001 Mr. David Ritter Rod Krich Research Associate on Nuclear Energy Vice President, Licensing Projects Public Citizens Critical Mass Energy Exelon Nuclear and Environmental Program 4300 Winfield Road 215 Pennsylvania Avenue, SE Warrenville, IL 60555 Washington, DC 20003 Patricia Campbell Mr. Tom Clements Winston & Strawn 6703 Guide Avenue 1400 L Street, NW Takoma Park, MD 20912 Washington, DC 20005

Mr. Edwin Lyman Dr. Glenn R. George Nuclear Control Institute PA Consulting Group 1000 Connecticut Avenue, NW 130 Potter Street Suite 410 Haddonfield, NJ 08033 Washington, DC 20036 Arthur R. Woods Mr. Jack W. Roe Enercon Services, Inc.

SCIENTECH, INC. 500 TownPark Lane 910 Clopper Road Kennesaw, GA 30144 Gaithersburg, MD 20878 Mr. Thomas Mundy Dr. Gail H. Marcus Director, Project Development U.S. Department of Energy Exelon Generation Room 5A-143 200 Exelon Way, KSA3-E 1000 Independence Ave., SW Kennett Square, PA 19348 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

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