ML112020105

Enclosure 2: E-mail, NRC to NEI

ML112020105
Person / Time
Issue date:	07/14/2011
From:	Dante Johnson NRC/NSIR/DPR/DDIR/OB
To:	Young D Nuclear Energy Institute
Johnson Don A. DPR/NSIR, 301-415-4040
References
Download: ML112020105 (2)

Text

From:

Johnson, Don To:

"YOUNG, David" Cc:

Norris, Michael; Anderson, Joseph

Subject:

NEI 99-01 R6 Meeting Prep - 7/26-7/27 Date:

Thursday, July 14, 2011 11:52:00 AM Good morning, David.

As we discussed the other day, I am sending you a list of items I will want to discuss during our next meeting based upon my review of the draft of the Risk Informed EAL Study. While the study will probably not be published for awhile, certainly not by our meeting date, I do want to capture as much as we can during this R6 initiative, at least based upon my review of it. As of right now I do not see any issues that may pop up that would not be addressed somehow with the R6 project, but we will have to see when the study is published.

Many of these issues were put on the table during our last R6 meeting, but I want to reiterate them as they were also commented on in the study, somewhat.

1. Toxic Gas EALs

a. As discussed before, we really need to shore up the development of the listed areas and make sure the EALs are developed appropriately to capture the intent of this EAL set.

b. I also asked the task force to consider elimination of the NOUE if supported by analyses, well discuss during the meeting.

2. Control Room Annunciation/Indication EALs

a. As discussed during the last meeting, I want to get this EAL to reflect more of the intent to capture issues related to a darkened CR rather than the somewhat arbitrary 75% thresholds we have now. This may lead to elimination of the NOUE and a significant revision, but capturing the actual intent and clarifying a development strategy is what we need to strive for.

b. May want to consider separating the annunciation component from the indication component due to the vastly different failure mechanisms each have.

3. The 1-source SBO EALs may need to be revised to ensure that licensees that need multiple sources available, as a minimum, do not inadvertently develop an EAL(s) that fails to recognize that. We, again, need to capture the actual intent and clarify a development strategy.

4. ATWS EALs

a. As we discussed at the last meeting, we may want to consider removing the NOUE and dropping the other EALs in this set down one notch.

5. Please have the task force look into whether we have captured total loss of DC events at the appropriate classification level. The preliminary results from the study show that we may have the classification level(s) a little too low. Please be prepared to discuss whether we are at the right levels, and that the EALs are

written to capture the intent, risk, and have a clear development strategy.

6. Please have the task force look into whether or not we should have an EAL, or EAL set, based upon a total loss of AC and DC power. I know we bound these, but they are specific to AC or DC separately, we may want to see if it would be prudent to capture AC and DC power loss in the same EAL (which would drive the appropriate classification level).

7. Please have the task force look at the Fukushima Near Term Task Force Report, ML111861807, and be prepared to discuss any potential improvements/enhancements we can make to NEI 99-01. Any resultant Commission decisions as a result of this report will need to be addressed later, but we can start to look at the data now and see if we can proactively take some action(s), if we see anything related to EALs, in advance of whatever may come from these studies and/or reports.

Please feel free to call me if you have any questions.

Thank you.

Don A. Johnson

Senior Emergency Preparedness Specialist Operating Reactor Licensing Team Operating Reactor Licensing and Outreach Branch Division of Preparedness and Response Office of Nuclear Security & Incident Response U.S. Nuclear Regulatory Commission

Mail Stop: T-3B46M Washington, DC 20555-0001 Telephone: 301.415.4040 E-mail: don.johnson@nrc.gov

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