ML030230071
| ML030230071 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 02/05/2003 |
| From: | Lyons J E NRC/NRR/NRLPO |
| To: | Simard R L Nuclear Energy Institute |
| Jenkins R V, NRR/NRLPO 415-2985 | |
| References | |
| Download: ML030230071 (7) | |
Text
February 5, 2003Dr. Ronald L. Simard Nuclear Energy Institute (NEI) 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
RESOLUTION OF EARLY SITE PERMIT TOPIC 6 (ESP-6), USE OF PLANTPARAMETER ENVELOPE (PPE) APPROACH
Dear Dr. Simard:
The purpose of this letter is to inform you of the Nuclear Regulatory Commission's (NRC)understandings and expectations regarding the use of the plant parameter envelope (PPE) approach for the preparation and review of early site permit (ESP) applications. This topic, which is identified as ESP-6 on the list of Nuclear Energy Institute (NEI) generic ESP issues, was discussed during public meetings between July 17 and December 5, 2002. Subsequently, NEI documented its position on this topic in a letter dated December 20, 2002. The NRC staff agrees with NEI's position that ESP applicants may use the PPE approach as a surrogate for facility information to support required safety and environmental review subject to the observations and clarifications below. However, the staff does not concur with all of the statements and assumptions in the NEI white paper (Enclosure 1 to the subject letter).1.ESP applicants may use the PPE approach as a surrogate for actual facility information tosupport required safety and environmental reviews. In NEI's August 1, 2002, letter, NEI indicated that the information listed in 10 CFR 52.17(a)(1)(i)-(viii) is not required. Should this information not be provided, it may complicate the staff review (i.e., resulting in increased review time) and have a bearing on the staff assumptions and associated staff findings.2.The ESP application information that contains PPE values along with site investigationefforts (i.e., data and analyses) and existing information (i.e., data and analyses) must adequately address three areas - site safety, environmental impacts, and emergency preparedness.3.No comment on Item 3 of the subject NEI letter.
4.The staff understands that PPE values may differ among the ESP applicants. It is thestaff's expectation that margins applied to account for uncertainties in PPE values will be identified in the subject application in order to avoid any ambiguity or confusion with the NEI PPE worksheet information.5.NEI has indicated that the PPE values will represent composite parameters that are notindicative of any specific reactor design or type. Although the bounding PPE values are intended for future use (i.e., during the combined license (COL) application), issuing an R. Simard-2-ESP is an independent licensing action. As such, the NRC staff review will determinewhether the PPE values are sufficient to enable the NRC staff to conduct its required review and that the PPE values are not unreasonable for consideration in the staff findings to comply with 10 CFR Part 52, Subpart A. 6.Given that PPE values do not reflect a specific design and will not be reviewed by the NRCstaff for correctness, the granting of an ESP by the NRC does not indicate NRC approval of the site for any specific plant or type of plant. In addition to the emergency preparedness and environmental impact findings, site approval will be contingent on the staff's ability to make a finding, taking into consideration the site criteria contained in10 CFR Part 100, that a reactor or reactors having characteristics that fall within the parameters for the site can be constructed and operated without undue risk to the health and safety of the public. This finding may result in conditions or limitations on the ESP in specific areas, as set forth in 10 CFR Section 52.24. 7.No comment on Item 7 of the subject NEI letter.
8.COL applicants who reference an ESP bear the risk that the design ultimately selected forthe approved site might fall outside of the terms and conditions of the ESP.9.The NRC review will be conducted using the review guidance cited in the Draft ESPReview Standard (ML023530045). The NRC review will result in safety and environmental impact determinations based upon the NRC
's independent evaluation of the informationprovided in the ESP application, assumptions or limitations or both as established by the staff, as well as independent information developed by the staff. We agree that a combination of site characteristics and PPE values will comprise the ESP bases that will be the focus for comparison at COL with the design of the actual plant proposed for the site. 10.NEI's position regarding compliance with 10 CFR 52.17(a)(1) (Topic ESP-7) will beaddressed in a separate staff response.11.NEI's position regarding alternative site reviews (Topic ESP-18a) will be addressed in aseparate staff response.Please contact Ronaldo Jenkins, the ESP Senior Project Manager, at 301-415-2985 if you haveany questions on this matter.Sincerely, /RA/James E. Lyons, DirectorNew Reactor Licensing Project Office Office of Nuclear Reactor RegulationProject No. 689 cc: See next page R. Simard-2-ESP is an independent licensing action. As such, the NRC staff review will determinewhether the PPE values are sufficient to enable the NRC staff to conduct its required review and that the PPE values are not unreasonable for consideration in the staff findings to comply with 10 CFR Part 52, Subpart A. 6.Given that PPE values do not reflect a specific design and will not be reviewed by the NRCstaff for correctness, the granting of an ESP by the NRC does not indicate NRC approval of the site for any specific plant or type of plant. In addition to the emergency preparedness and environmental impact findings, site approval will be contingent on the staff's ability to make a finding, taking into consideration the site criteria contained in10 CFR Part 100, that a reactor or reactors having characteristics that fall within the parameters for the site can be constructed and operated without undue risk to the health and safety of the public. This finding may result in conditions or limitations on the ESP in specific areas, as set forth in 10 CFR Section 52.24. 7.No comment on Item 7 of the subject NEI letter.
8.COL applicants who reference an ESP bear the risk that the design ultimately selected forthe approved site might fall outside of the terms and conditions of the ESP.9.The NRC review will be conducted using the review guidance cited in the Draft ESPReview Standard (ML023530045). The NRC review will result in safety and environmental impact determinations based upon the NRC
's independent evaluation of the informationprovided in the ESP application, assumptions or limitations or both as established by the staff, as well as independent information developed by the staff. We agree that a combination of site characteristics and PPE values will comprise the ESP bases that will be the focus for comparison at COL with the design of the actual plant proposed for the site. 10.NEI's position regarding compliance with 10 CFR 52.17(a)(1) (Topic ESP-7) will beaddressed in a separate staff response.11.NEI's position regarding alternative site reviews (Topic ESP-18a) will be addressed in aseparate staff response.Please contact Ronaldo Jenkins, the ESP Senior Project Manager, at 301-415-2985 if you haveany questions on this matter.Sincerely, /RA/James E. Lyons, DirectorNew Reactor Licensing Project Office Office of Nuclear Reactor RegulationProject No. 689 cc: See next pageACCESSION NO. ML030230071 *See previous concurrence OFCPM:NRLPOSPA:NRLPODD:NRLPO*D:NRLPOSPSB:BCNAMERJenkinsJWilsonMGamberoni JLyons MJohnson DATE2/3/031/23/03 1/24/03 2/4/03 2/3/03 OFCRLEP:SCOGCEMEB:BC*SPLB:SC NAMEJTappert JMooreGImbroSWeerakkody DATE 2/3/03 1/31/03 1/31/03 1/30/03OFFICIAL RECORD COPY Distribution for letter to R. Simard dated February 5, 2003Hard CopyNRLPO Rdg.RJenkins MGamberoni JLyonsE-mailPUBLICACRS/ACNW RidsNrrAdip (RBorchardt)
RidsNrrAdpt (BSheron)
RidsOgcRp NRLPO Group RidsNrrOD (SCollins)
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 20912Mr. Edwin LymanNuclear Control Institute 1000 Connecticut Avenue, NW Suite 410 Washington, DC 20036Mr. Jack W. RoeSCIENTECH, INC.
910 Clopper Road Gaithersburg, MD 20878 Dr. 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.
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