ML083220276
| ML083220276 | |
| Person / Time | |
|---|---|
| Issue date: | 12/02/2008 |
| From: | Chris Miller NRC/NSIR/DPR |
| To: | Alexis Nelson Nuclear Energy Institute |
| Johnson D, NSIR/DPR 301-415-4040 | |
| References | |
| Download: ML083220276 (3) | |
Text
December 2, 2008 Mr. Alan Nelson Director, Emergency Preparedness Nuclear Generation Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION REVIEW OF EMERGENCY ACTION LEVELS FOR NEW REACTOR APPLICATIONS
Dear Mr. Nelson:
The purpose of this letter is to inform the Nuclear Energy Institute (NEI) of the NRC staffs approach for reviewing emergency action levels (EALs) in new reactor applications. Specifically, this letter addresses how finality will be given regarding an applicants EAL scheme. EALs are required by 10 CFR 50.47(b)(4) and App. E.IV.B of 10 CFR Part 50. EALs are required to be approved by the NRC. Current new reactor applications have been submitted that do not address certain aspects of the EAL scheme. This is due to actual set points that cannot be derived until actual as-built information is available (head corrections, radiation shine issues, equipment tolerances and calculations being finalized, etc.), and certain Technical Specifications are finalized. My staff has been evaluating possible options that existing and future applicants could consider when developing EALs. These options are as follows:
Option 1 - Submit an entire EAL scheme, which contains all site-specific information, including set points. Until this information is finalized, EALs would remain an open item.
Option 2 - Submit emergency plan Section D, Emergency Classification System, which addresses the four critical elements of an EAL scheme (listed below). The NRC will determine the acceptability of the EAL scheme.
Critical Element 1 - Applicant proposes an overview of its emergency action level scheme including defining the four emergency classification levels, (i.e., Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency), as stated in NEI 99-01, Revision 5, with a general list of licensee actions at each emergency classification level.
Critical Element 2 - Applicant proposes to develop the remainder of its EAL scheme by using a specified NRC endorsed guidance document. In the development of its EALs, the proposed EALs should be developed with few or no deviations or differences, other than those attributable to the specific reactor design. NEI 07-01, if endorsed, will be applicable to the AP1000 and ESBWR (passive) reactor designs, and NEI 99-01 is applicable to all (non-passive) reactor designs. If applicable, EALs related to digital instrumentation and control must be included. The NRC must find in the Safety Evaluation Report that this approach is acceptable for each site.
2 Critical Element 3 - Applicant proposes a License Condition (LC) that the applicant will create a fully developed set of EALs in accordance with the specified guidance document. These fully developed EALs must be submitted to the NRC for confirmation at least 180 days prior to fuel load.
Critical Element 4 - The EALs must be kept in a document controlled by 10 CFR 50.54(q), such as the emergency plan; or a lower tier document, such as the Emergency Plan Implementing Procedures.
The NRC has sent a request for additional information to all the current applicants to inform them of these two options and for them to inform the NRC of which option they choose to pursue. We will also develop an Interim Staff Guidance for this issue to ensure future applications are given the options they could consider for EALs.
Sincerely,
/RA/
Christopher G. Miller, Deputy Director Emergency Preparedness Division of Preparedness and Response Office of Nuclear Security and Incident Response
2 Critical Element 3 - Applicant proposes a License Condition (LC) that the applicant will create a fully developed set of EALs in accordance with the specified guidance document. These fully developed EALs must be submitted to the NRC for confirmation at least 180 days prior to fuel load.
Critical Element 4 - The EALs must be kept in a document controlled by 10 CFR 50.54(q) such as the emergency plan or a lower tier document, such as the Emergency Plan Implementing Procedures.
The NRC has sent a request for additional information to all the current applicants to inform them of these two options and for them to inform us of which option they choose to pursue. We will also develop an Interim Staff Guidance for this issue to ensure future applications are given the options they could consider for EALs.
Sincerely,
/RA/
Christopher G. Miller, Deputy Director Emergency Preparedness Division of Preparedness and Response Office of Nuclear Security and Incident Response Distribution:
DPR Reading File D. Johnson M. Norris K. Williams ADAMS Accession Number: ML083220276 OFFICE NSIR:DPR TL:NSIR:DPR ADMIN:NSIR BC:NSIR:DPR OGC DD:NSIR:DPR NAME D.JOHNSON D. BARSS STucker K. WILLIAMS J. MARTIN C. MILLER DATE 11/17/08 11/17/08 11/20/08 11/20/08 11/26/08 12/02/08 OFFICIAL RECORD COPY