ML102810390

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Proposed Changes for Consideration to NEI 99-01, Methodology for the Development of Emergency Action Levels
ML102810390
Person / Time
Site: Nuclear Energy Institute
Issue date: 10/12/2010
From: James Anderson
NRC/NSIR/DPR
To: Perkins-Grew S
Nuclear Energy Institute
Anderson, Joseph, NSIR/DPR, 301-415-4114
References
NEI 99-01
Download: ML102810390 (3)


Text

October 12, 2010 Susan Perkins-Grew Director, Emergency Preparedness Nuclear Energy Institute 1776 I Street, NW Suite 400 Washington, DC 20006-3708

SUBJECT:

PROPOSED CHANGES FOR CONSIDERATION TO THE NUCLEAR ENERGY INSTITUTE (NEI) REPORT, NEI 99-01, METHODOLOGY FOR THE DEVELOPMENT OF EMERGENCY ACTION LEVELS

Dear Ms. Perkins-Grew:

Based on the review of recent emergency action level (EAL) scheme change submittals adopting Revision 5 to NEI 99-01, the staff has identified below proposed enhancements to NEI 99-01 EAL Methodology (for consideration by the NEI EAL Task Force.

1. Revise EAL Basis format (Sections 5.5 through 5.11) to separate Developer Notes from Technical Basis Information.
2. Revise EAL Basis (under proposed Developer Notes) to clarify on how specific instrumentation, alarms or readings should be developed, where.
3. Clarify where site-specific definitions are required (e.g., CONTAINMENT CLOSURE).
4. Clarify or propose alternatives on the seismic and fire EALs for licensees may do not have adequate instrumentation to ensure timely classification from within the Control Room.
5. Revise to include a section for development of EALs applicable to new non-passive designs (digital Instrument & Controls, etc.).
6. Clarify meaning of terms: freshly loaded fuel (HG1) and non-routine pathways (Abnormal Rad levels / Radiological Effluent EALs).
7. Revise the front sections of document to eliminate redundancy and inconsistency, and clearly differentiate between information that is useful for understanding how the document was put together and information that is expected to be carried over into a licensees technical basis document.

S. Perkins-Grew

8. Conduct a review of all Unusual Events to determine if they should be revised/eliminated or added to, include in this review a discussion of any revision proposals for the corresponding Alerts. (Note: this is primarily for events that are based upon situations where emergency response organization activation is the goal rather than a precursor to escalated EALs.)

These proposed enhancements are being provided at this time only to facilitate discussion at the Category 2 public meeting on October 14, 2010 (ADAMS Accession No.: ML102510699),

were industry is planning to discuss the scope of EAL changes being considered as part of a proposed Revision 6 to NEI 99-01. As such, this letter does not infer staff endorsement of any changes to the NEI 99-01 EAL Methodology.

Any questions pertaining to the enclosure may be directed to either Michael Norris (301) 415-4098 or Don Johnson (301) 415-4040.

Sincerely,

/RA/

Joseph D. Anderson, Chief Operating Reactor Licensing Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response

As stated

S. Perkins-Grew

8. Conduct a review of all Unusual Events to determine if they should be revised/eliminated or added to, include in this review a discussion of any revision proposals for the corresponding Alerts. (Note: this is primarily for events that are based upon situations where emergency response organization activation is the goal rather than a precursor to escalated EALs.)

These proposed enhancements are being provided at this time only to facilitate discussion at the Category 2 public meeting on October 14, 2010 (ADAMS Accession No.: ML102510699),

were industry is planning to discuss the scope of EAL changes being considered as part of a proposed Revision 6 to NEI 99-01. As such, this letter does not infer staff endorsement of any changes to the NEI 99-01 EAL Methodology.

Any questions pertaining to the enclosure may be directed to either Michael Norris (301) 415-4098 or Don Johnson (301) 415-4040.

Sincerely,

/RA/

Joseph D. Anderson, Chief Operating Reactor Licensing Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response

As stated DISTRIBUTION:

C. Miller, NSIR M. Norris, NSIR D. Johnson, NSIR ADAMS ACCESSION NUMBER: ML102810405 Office NSIR/DPR:BC NSIR/DPR BSIR/DPR:DD Name JAnderson STucker KWilliams*JAnderson for Date 10/06/2010 10/08/2010 10/12/2010 OFFICIAL USE ONLY