Report on Lessons Learned from the NP 2010 Early Site Permit Program FINAL REPORT
This report provides a summary of lessons learned from the demonstration of the licensing process for three Early Site Permit (ESP) applications supported as part of the Department of Energy’s (DOE) Nuclear Power 2010 (NP 2010) program. The ESP process was established by the Nuclear Regulatory Commission (NRC) to enable completion of the site evaluation component of nuclear power plant licensing under 10 CFR Part 52 before a utility makes a decision to build a plant. Early Site Permits are valid for 10 to 20 years and can be renewed for an additional 10 to 20 years. NRC review of an ESP application addresses site safety issues, environmental protection issues, and plans for coping with emergencies. Successful completion of the ESP process will establish that a site is suitable for possible future construction and operation of a nuclear power plant. Most importantly, an ESP resolves significant site-related safety and environmental issues early in the decision process and helps achieve acceptance by the public. DOE competitively selected Dominion Nuclear Energy North Anna, LLC (Dominion); System Energy Resources, Inc. (an Entergy subsidiary); and Exelon Generation Company, LLC (Exelon) in 2002 to demonstrate the ESP process and provided cost-shared support through the NP 2010 program. Dominion pursued an ESP for the North Anna site in Virginia; System Energy Resources, Inc. pursued an ESP for the Grand Gulf site in Mississippi; and Exelon pursued an ESP for the Clinton site in Illinois. After successfully demonstrating the process, the NRC issued an ESP for Clinton on March 17, 2007; Grand Gulf on April 5, 2007; and North Anna on November 27, 2007. As with all successful projects, there are lessons to be learned from the NP 2010 early site permitting demonstration that can help improve future implementation guidance documents and regulatory review standards. In general, these lessons pertain to the effectiveness of the regulatory process, experience related to guidance for developing and reviewing ESP applications, issues involving ESP plant parameters, and suggestions for future ESP applicants. The development, submittal, and issuance of these first ESPs under DOE’s NP 2010 program started the momentum to exercise NRC’s new 10 CFR Part 52 licensing process. Several key questions that define critical issues regarding the effectiveness of regulations pertaining to ESPs have been identified and summarized in this report. However, the final resolution of whether the ESP component of the Part 52 process significantly contributes to the predictability in nuclear power plant licensing requires more experience and time, such as the completion of the ongoing combined Construction and Operating License (COL) process for the North Anna and Grand Gulf sites. The three ESP project participants prepared and submitted to DOE lessons learned reports from their experience in developing, submitting, and receiving an ESP. This document summarizes these reports, which are appended hereto. The Nuclear Energy Institute (http://www.nei.org/) and NRC (http://www.nrc.gov/) have also prepared reports regarding their perspectives on lessons learned during the ESP process. Their documents can be accessed on their respective web sites. Following is a summary of the lessons learned from the NP 2010 ESP projects. Effectiveness of the ESP Process: In general, the ESP process is expected (subject to demonstration of the ESP finality provisions in the North Anna and Grand Gulf ESPs) to provide high value for applicants as a site banking and risk mitigation strategy. However, several aspects of the initial process, such as NRC hearings and determining an acceptable approach to the NRC’s Emergency Planning requirements, proved challenging for the applicants. Project Execution: Initial regulatory and industry guidance for planning and executing an ESP application program proved to be insufficient to address NRC’s document review expectations. However, continuous communication between NRC and the applicants helped establish an acceptable framework for the applications and resulted in the successful issuance of three ESPs. Still, formal guidance from both NRC and industry is needed for issues involving merchant plants; data collection issues; and interactions between NRC, the public, and the applicants. Specific Plant Parameter Issues: The use of the Plant Parameter Envelope (PPE) approach, when the applicant has not yet chosen a reactor technology, proved to be a major source of confusion between applicants and NRC. This issue had also been a topic of discussion during the NRC ESP hearings. Based upon North Anna and Grand Gulf COLA experiences, the need should be evaluated for future NRC guidance pertaining to the PPE approach to clarify these issues. In addition, NRC, applicants, and industry spent considerable time and resources deciding how to employ new seismic analysis approaches. Future guidance in this area would also be very useful. Best Project Practices: A variety of good practices were identified, such as using specific project tracking and milestone items, handling very large documents electronically, employing a formal and rigorous document review process, and sharing large files across organizational sites. This report also includes a set of general recommendations to assist future ESP applicants. Several recommendations highlight the need for NRC and industry to continue to work together to improve the ESP process.
- Research Organization:
- USDOE Office of Nuclear Energy, Science and Technology (NE) (United States)
- Sponsoring Organization:
- USDOE NE Office of Nuclear Reactor Technologies (NE-7)
- OSTI ID:
- 1121311
- Country of Publication:
- United States
- Language:
- English
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