ML20207E845

Summary of 990513 Meeting with NEI Re NRC Comments on industry-proposed Emergency Action Level Guidance Contained in NEI 99-01, Methodology for Development of Emergency Action Levels

ML20207E845
Person / Time
Issue date:	05/21/1999
From:	Obrien J NRC (Affiliation Not Assigned)
To:	Essig T NRC (Affiliation Not Assigned)
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ML20207E850	List: ML20207E845 ML20207E870
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PROJECT-689 NUDOCS 9906070183
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May 21; 1999 MEMORANDUM TO: Thomm H. Estig, Chilf Emergency Preparedness and Health Physics Section Operating Licensing, Human Performance and Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation FROM:

James B. O'Brien, Emergency Preparedness Specialist original signed by Emergency Preparedness and Health Physics Section Thomas Essig for:

Operating Licensing, Human Perforrnance and Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF MAY 13,1999, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING PROPOSED REVISION TO EMERGENCY ACTION LEVEL GUIDANCE On May 13,1999, representatives of the Nuclear Energy Institute (NEI) met with representatives of the Nuclear Regulatory Commission (NRC) to discuss NRC comments on industry-proposed emergency action level (EAL) guidance contained in NEl 99-01,

• Methodology for Development of Emergency Action Levels." NEl 99-01 incorporates new guidance for development of EALs applicable to the shutdown mode of plant operations, permanently shutdown reactors and dry storage independent spent fuel storage installations. provides a list of meeting attendees.

In'a letter dated April 7,1999, NEl submitted NEl 99-01 for NRC review and comment. In a letter dated May 11,1999, NRC provided its comments to NEl. The purpose of this meeting was to discuss these comments and NEl's proposed resolution of them. NEl provided a document describing a proposed resolution for each of the NRC comments (Attachment 2) and a mark-up of NEl 99-01 identifying where changes would be made to address the NRC concerns (Attachment 3).

Each of the NRC comments and NEl's proposed resolutions were discussed. Following these discussions, NRC stated that no major issues appeared to remain which would prevent NRC's endorsement of the NEl document. NEl indicated it would revise the document and provide it to the NRC and nuclear power plant industry for discussion at NEl's Emergency Preparedness information Forum on June 8,1999. Following this meeting, NEl would submit NEl 99-01 for NRC endorsement.

In addition to discussions related to NEl 99-01, NEl requested the NRC to continue actions to endorse a related EAL guidance document (NEl 97-03) which contains refinements to the current industry-developed EAL guidance. The NRC informed NEl that it intended to continue its efforts to endorse this document.

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o May 21',

1999 MEMORANDUM TO: Thomas H. Essig, Chief Emergency Preparedness and Health Physics Section Operating Licensing, Human Performance and Plant Support Branch l

Division of Inspection Program Management l

Office of Nuclear Reactor Regulation FROM:

James B. O'Brien, Emergency Preparedness Specialist original signed by i l

Emergency Preparedness and Health Physics Section Thomas Essig for:

i Operating Licensing, Human Performance and Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF M AY 13,1999, MEETING WITH THE NUCLEAR ENERGY INSTl'e UTE (NEI) REGARDING PROPOSED REVISION TO EMERGENCY LCT!ON LEVEL GUIDANCE l

On May 13,1999, representatives of the Nuclear Energy Institute (NEI) met with representatives of the Nuclear Regulatory Commission (NRC) to discuss NRC comments on industry-proposed emergency action level (EAL) guidance contained in NEl 99-01,

" Methodology for Development of Emergency Action Levels." NEl 99-01 incorporates new guidance for development of EALs applicable to the shutdown mode of plant operations, permanently shutdown reactors and dry storage independent spent fuel storage installations. provides a list of meeting attendees.

In a letter dated April 7,1999, NEl submitted NEl 99-01 for NRC review and comment. In a letter dated May 11,1999, NRC provided its comments to NEl. The purpose of this meeting was to discuss these comments and NEl's proposed resolution of them. NEl provided a document describing a proposed resolution for each of the NRC comments (Attachment 2) and a mark-up of NEl 99-01 identifying where changes would be made to address the NRC concerns (Attachment 3).

Each of the NRC comments and NEl's proposed resolutions were discussed. Following these discussions, NRC stated that no major issues appeared to remain which would prevent NRC's endorsement of the NEl document. NEl indicated it would revise the document and provide it to l

the NRC and nuclear power plant industry for discussion at NEl's Emergency Preparedness Information Forum on June 8,1999. Following this meeting, NEl would submit NEl 99-01 for NRC endorsement.

in addition to discussions related to NEl 99-01, NEl requested the NRC to continue actions to endorse a related EAL guidance document (NEl 97-03) which contains refinements to the current industry-developed EAL guidance. The NRC informed NEl that it intended to continue its efforts to endorse this document.

Project' No. ' 89 6

Attachments: As stated cc w/att: See next page DISTRIBUTION: See attached page OFFICE EPp EP&HP SC:EP&W,

NAME JOJM TEssig lk IM/99 E/1A /99

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DATE

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UNITED STATES s

j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001

'<4 g g,o May 21, 1999 MEMORANDUM TO: Thomas H. Essig, Chief Emergency Preparedness and Health Physics Section

' Operating Licensing, Human Performance and Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation -

FRO.M:

James B. O'Brien, Emergency Preparedness Specialist Emergency Preparedness and Health Physics Section Operating Licensing, Human Performance and Plant Support Branch s

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Division of Inspection Program Management 1

Office of Nuclear Reactor Regulation-

SUMMARY

OF MAY 13,1999, MEETING WITH THE NUCLEAR I

ENERGY INSTITl'TE (NEI) REGARDING PROPOSED REVISION TO l

EMERGENCY ACTION LEVEL GUIDANCE l

i On May 13,1999, representatives of the Nuclear Energy Institute (NEI) met with representatives of the Nuclear Regulatory Commission (NRC) to discuss NRC comments on industry-proposed emergency action level (EAL) guidance contained in NEl 99-01,

" Methodology for Development of Emergency Action Levels." NEl 99-01 incorporates new guidance for development of EALs applicable to the shutdown mode of plant operations, permanently shutdown reactors and dry storage independent spent fuel storage installations.

J provides a list of meeting attendees.

In a letter dated April 7,1999, NEl submitted NEl 99-01 for NRC review and comment. In a letter dated May 11,1999, NRC provided its comments to NEl. The purpose of this meeting was to discuss these comments and NEl's proposed resolution of them. NEl provided a document describing a proposed resolution for each of the NRC comments (Attachment 2) and j

a mark-up of NEl 99-01 identifying where changes would be made to address the NRC j

concems (Attachment 3).

4 Each of the NRC comments and NEl's proposed resolutions were discussed. Following these discussions, NRC stated that no major issues appeared to remain which would prevent NRC's endorsement of the NEl document. NEl indicated it would revise the document and provide it to the NRC and nuclear power plant industry for discussion at NEl's Emergency Preparedness Information Forum on June 8,1999. Following this meeting, NEl would submit NEl 99-01 for 1

NRC endorsement.

'In addition to discussions related to NEl 99-01, NEl requested the NRC to continue actions to

- endorse a related EAL guidance document (NEl 97-03) which contains refinements to the current industry-developed EAL guidance. The NRC informed NEl that it intended to continue its efforts to endorse this document.

Project No. 689 Attachmentsi As stated cc w/att: See next page

7 1

Nuclear Energy Institute Project No. 689 cc:

Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer -

Nuclear Energy institute Nuclear Energy Institute -

Suite 400 Suite 400 1776 l Street, NW i

1776 i Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineering, Inc.

Suite 400 12300 Twinbrook Parkway, Suite 330 1776 l Street, NW -

Rockville, Maryland 20852 Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director-

.j Licensing i

Nuclear Energy institute

. Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation

^

P.O. Box 355 Pittsburgh, Pennsylvania 15230

. Mr. Jim Davis, Director Operations Nuclear Energy Institute -

i

.. Suite 400 1776 l Street, NW -

" Washington, DC 20006-3708 i

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l ATTACHMENT 1 NRC/NE! MEETING ON NEl's PROPOSED EAL GUIDANCE NEl 99-01 LIST OF ATTENDEES May 13,1999 NAME ORGANIZATION Alan Nelson NEl Martin Hug Southern California Edison Dave Stobaugh Commonwealth Edison Walter Lee Southern Nuclear John Costello Dominion Generation Rodney Brown Duke Power Company John Kaminski Niagara Mohawk Jim O'Brien NRC/NRR Thomas Essig NRC/NRR Daniel Barss NRC/NRR Lambros Lois NRC/NRR Edwin Fox NRC/NRR e

ATTACHMENT 2 9

RESPONSE TO NRC ISSUES IDENTIFIED IN NRC'S MAY 11,1999 LETTER TO NEl 6

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NEl ITF

RESPONSE

TO NRC STAFF COMMENTS IN LETTER DATED 05/11/99 ON NEl 99-01 Final Draft Revision 4 (Dated 04/04/99)

Forward This document is a preliminary response to NRC staff comments providedin a letterfrom T. Essig to A. Nelson did 05/w99. This document provides the staff comment and a preliminary response and/oraction statement.

This document was prepared by the NEl staff and industry representatives. We have provided a response to each comment.

Thus, our response should not be taken as firm commitments.

i i

h' NEl RESPONSE TO NRC COMMENTS ON NEl 99-01 (Final Draft Revision 4)

Emergency Action Level (EAL) Guidance The comments have been grouped under the recognition categories specified in NEl 99-01,

" Methodology for Development of Emergency Action Levels." Furthermore the comments have been categorized as (1) significant issues (concems related to the adequacy of the EAL to correctly classify events), (2) minor issues (issues of lesser significance, usually related to the basis of EALs), and (3) editorial. Fourteen of the approximately fifty comments have been categorized as significant issues.

Shutdown and Refuelina Mode of Operation EALs CU2 UNPLANNED Loss of RCS Inventory with irradiated Fuel in the RPV i

1. Sionificant issue l

In the NRC letter dated February 19,1999, the following comment was provided on NEl 99-01:

"It would be beneficial for NEl 99-01 to include a discussion of the relationship of this EAL to AU2-1, i.e.:

VALID (site-speciRc) indication of uncontrolled waterlevel decrease in the reactor refueling cavity, spent fuelpool, or fuel transfer canal with allirradiated fuel assemblies remaining covered by water.'

. NEl's response (included in its letter dated April 7,1999) did not fully resolve this issue.

It is not clear that CU2 and AU2-1 do not have some overlap. It seems that it would be beneficial to modify AU2 or further explain what is appropriate implementation of this L

guidance in order to ease site-specific implementation of this guidance.

l l

NEIITF Comment (051299): Added text to the basis AU2to clarify the difference l

between CU2 and AU2 usage and implementation. AU2 EALs were changed to include

" unplanned" to preclude unwarranted declarations of non-events. Added a "B" part to EAL 1 to insure that a decrease in water level in this EAL did not result in a NOUE declaration unless it was accompanied by increased radiation levels.

J 4 )

2. MinorIssue The basis states that escalation to an Alert would be based on calculation of mass loss rate via either CA2..." However, CA2 does not consider a calculation of mass loss rate.

This basis statement should be corrected.

NEI ITF Comment (051299): Wording change made to clarify per the comment.

i

3. Editorial The basis includes the following statement:

The difference between CU1 and CU2 deals with the RCS conditions that exist between cold shutdown and refueling mode applicability.

It appears that the last part of this sentence should read " refueling modes" instead of

" refueling mode applicability." This comment applies to the basis for other shutdown mode ICs.

NEI ITF Comment (051299): Wording change made to clarify per the comment.

CU4 -Loss of Decay Heat Removal

4. Minorissue 1

The statement in the basis that " escalation to the Alert level via CA4 is therefore provided should the RCS approach a temperature that would allow boiling to occur" is i

not ac: urate.

NEIITF Comment (051299): Wording change made to clarify per the comment.

CUS Fuel Clad Degradation

5. Minorissue It is not clear why this IC is not applicable in the defueled mode.

i NEIITF Comment (051299): Per telephone conversations between the ITF and Jim O'Brien on 5/12/99, no action is required on this comment because concerns over clad 1

damage to fuel in the Spent Fuel Pool are covered by AU2.

I CU7 Loss of DC Power

6. Minorlasue 3

I It is not clear why this is not applicable in the defueled mode while loss of AC power IC (CA3) is. Furthermore, it is not clear why a loss of vital DC power is not as significant as a loss of vital AC power.

NEIITF Comment (051299): In the defueled mode, all fuel is in the Spent Fuel Pool and the need for vital DC power is minimal. The ITF believes that loss of vital DC power should remain as a NOUE for the Cold Shutdown and Refueling modes because components (such as RHR pumps, Charging pumps, and RCS instrumentation not available without vital AC power.) which require DC power to operate can be locally started without DC power or monitored locally as required.

CA1 and CA2 Loss of Inventory (Alert) -

7. Minorlasue These EALs are identical. Therefore, it seems as though they should be combined.

The basis states that the need for two separate EALs is related to several factors.

However, at the Alert level, these factors do not seem to affect the criteria in the EAL.

NEI ITF Comment (051299): 'Ihe ITF disagrees. CA1 addresses loss of RCS inventory.

CA2 addresses loss of RPV inventory with Irradiated fuel in the RPV. Although the differences are slight the ITF believes the separation in ICs need to be maintained for human factor engineered clarity and ease of use.

8 Minorissue in the 2"' to last sentence in the basis the statement is:

This EAL is not applicable to decreases in Hooded reactor cavity level (covered by CU2 EAL2 and AU2 EAL1) until such time as the level decreases to the level of the vesse!.

Range.

It seems that this conflicts with the statement in CU2 regarding its escalation when there is a loss of water level indication. - In the case of water indication loss, CA2 does escalate CU2.

NEIITF Comment (051299): ITF agrees that the wording conflicts and is not needed.

Wording has been removed.

. CS1 and CS2 Loss of Inventory (SAE)

9. Sionificant issue.

Need to discuss the definition of containment closure. In particular it is necessary to discuss use of the secondary containment in BWR as indication of a closed containment.

NEI ITF Comment (051299): Per telephone conversations between the ITF and Jim O'Brien on 5/12/99, no action is required on this comment. Concem was the potential for a BWR never getting to an SAE if CONTAINMENT CLOSURE was established and an RCS leak was in progress. Worked thru several scenarios that indicated that escalation from Alert to Site Area would occur. CONTAINMENT CLOSURE is a defined term for both PWRs and BWRs.

10. Minorissue As stated in our letter of February 19,1999, we consider it unnecessary to have two EALs. Furthermore we believe that it would be better to have a single IC to minimize the number of ICs and EALs. However we do not consider the separation of this into two EALs to be a impetus to proper classification.

NEIITF Comment (051299): The ITF disagrees. Although the differences are slight the ITF believes the separation in ICs need to be maintained for human factor engineered clarity and case of use.

11. Minorlasue it seems that at the bottom ID of the RCS loop that suction to decay heat removal would undoubtedly be lost. It may be appropriate to modify the sentence in the basis to reflect this.

NEI ITF Comment (051299): Per telephone conversations between the ITF and Jim O'Brien on 5/12/99, no action is required on this comment. CA2 discusses the loss of RHR pump suction once the RCS inventory has lowered to the bottom ID of the RCS loops. The discussion in CS2 is considered to not be necessary because the entry point to CS2 is 6" below the bottom ID of the RCS loops and entry into CA2 would have already occurred.

12. Minor lasue.

The RPV is part of the pressure boundary therefore it is not appropriate to speedy that pressure boundary leakage is only a concem for BWRs for this EAL.

NEIITF Comment (051299): ITF agrees and PWR and BWR specific references have been removed. -

m

13. Minorissue The basis discusses the setpoint for the containment monitor. There should be guidance for a setpoint for EAlib and EAL 2b. For EAL 1b the setpoint should correspond to a given amount of water shielding. For EAL 2b it should correspond to core uncovery.

NEI ITF Comment (051299): ITF agrees and the CS2 basis has been changed to indicate that the radiation monitor setpoint for both the EAL 1 and EAL 2 should be indicative of core uncovery (ie... level at TOAF).

CG1 -General Emergency

14. Sianificant issue in the NRC letter dated February 19,1999, the NRC commented that it considered EAL 1 under this IC to be unnecessary. We still consider that EAL 1 should be deleted.

EALs 2 and 3, in and of themselves, are sufficient to classify this event. It is not appropriate to include conditions which are not needed to support classification.

NEI ITF Comment (051299): ITF disagrees. EAL 1 provides indication of the RCS barrier failure, EAL 2 provides indication of the fuel barrier failure, and EAL3 provides indication of containment barrier failure. Inclusion of all three EALs allows the user to truly compare the EALs against the definition of the General Emergency (eg. Loss of 2 barriers with the potential or actual loss of the third barrier). The inclusion of EAL 1 ensures that an unwarranted General Emergency is not declared due to an instrument failure. An example of such a scenario is: CONTAINMENT CLOSURE is not established due to refueling operations and the source range instrumentation fails high due to welding in the Containment Building. Without EAL 1, a General Emergency would be required to be declared even though no threat to the RCS inventory exists.

ji Minor Issue in the NRC letter dated February 19,1999, the NRC commented that it considered the use of one-half of the containment pressure to be unfounded as an indication of the potentialloss of containment. We still consider use of one-half of the containment pressure to be unfounded. This is inconsistent with the use of the containment pressure in the fission product barrier EALs.

NEIITF Comment (051299): ITF agrees and basis wording has been changed to indicate that the setpoint should be the Containment design pressure.

Permanently Defueled Plant EALs -

r 3

General

16. Mingt it would be beneficial to describe how this EAL guidance applies to permanently defueled plante which have not received exemption from offsite EP and where the potential for significant releases warrants maintaining offsite EP.

NEIITF Comment (051299): Until exemptions are recieved the operating Unit EALs Would remain in effect. Appendix D introduction, clearly defines the intended users of these EALs.

D AU1 17.' Sienlficent issue The first EAL under this IC repeats the IC without specifying a site-specific radiation effluent monitor setpoint as is done in the corresponding operating plant EAL (AU1).

This EAL should be modified to make it consistent with the operating plant EAL. It is not clear how EAL #3 will be implemented.

NEIITF Comment (051299): Reworded for consistency. Revised wording to clarify EAL 3 for ease ofimplementation.

18 Minorissue

it is not clear why the terms " unplanned" and " sustained" are defined in this section rather than in the defmitions section.

NEI ITF Comment (051299): Unplanned will be deleted fmm the basis as it is already contained within the definitions section. Sustained must be. included here as it is specific to this EAL only.

D-AU2

19. Sionificant lasue it is not clear why a different setpoint is appropriate for this EAL as compared to the <

corre'sponding operating plant EAL NEIITF Comment (051299): The use of 25 mr/hr is considered significant in a defueled plant whereas an increase of 1000 times normal values may still be insignificant.

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20. Minorissue

. It does not seem necessary to specifically define ' uncontrolled" in this section.

j NEIITF Comment (051299): Will be deleted from the basis.

d D-SU1 1

21. Sionificantlasue i

it does not seem necessary to include the condition of having no makeup capability in this EAL i

i NEIITF Comment (051299): Will be deleted from the basis.

22. Sionificantissue The basis for setting the spent fuel pool level does not seem to be appropriate. The technical specification level is set at a higher level than where prohibitive radiation levels l

would exist.

l NEIITF Comment (051299): The setpoint will be changed to that level which if decreased to will result in prohibitive radiation levels in the fuel building.

23 SiantficantIssue it is not clear what the temperatures referred to in the EAL are. More importantly it does not appear appropriate that the temperature correspond to the onset of fuel damage.

j 1

NEIITF Comment (051299): The EAL basis will be revised to more clearly state the

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basis used for the initial temperature used in the SAR calculations i

' 24. - Minor issue It is not clear why the term " makeup capability" is defined in this section.

NEIITF Comment (051299): Deleted the definition and deleted the wording from the EAL',

l-D-HU1,

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25. Minorlasue Further information is needed to determine how this EAL would be implemented on a site-specific basis. Examples of potential EALs for this IC would be beneficial in making this determination.

NElITF Comment (051299): The basis permits the developer to reference the individual plants Security plan during the development process.

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D-HU2

26. Minorissue The last sentence in the EAL may not be appropriate for a permanently shutdown facility since no release requiring offsite response would be expected even with further degradation of safety systems.

NEIITF Comment (051299): Will be deleted from the EAL.

D-HU3

27. Sionificant issue i

it is not clear that the first EAL (i.e. earthquake) should include the condition "has the potential to affect equipment needed to maintain spent fuel integrity. Whereas the other natural or destructive phenomena have localized impacts, the impacts from an earthquake is not localized. Therefore only the magnitude of the earthquake needs to be of concem.

NEIITF Comment (051299): Will revise EAL to delete the affects from the earthquake as a concern.

28. Minorissue The basis states that

' Escalation to the ALERT level will be via D-AA2 if any of the above events has caused damage that results in radiation levels exceeding 100 mr/h" As discussed below under D-HA3, it is not clear that appropriate to escalate the event solely on indication of elevated radiation levels.

NEIITF Comment (051299): Wording in basis will be revised to reflect D-AA2 EAL requirements l l

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)

D-HA3 (January 261999 revision)

29. Sionificant Issue The January 16,1999 revision of NEl 99-01 included an Alert level EAL for Seismic event and a tomado striking the fuel building. These EALs were eliminated in the current NEl 99-01 revision. It seems that an EAL should be included for these conditions.

NEIITF Comment (051299): The task force determined that escalation to an Alert through D-AA2 would be more appropriate in situations in which either of these events were to occur and resulted in damage. In situations where no damage were to occur,

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escalation would not be appropriate.

l D-AA2 l

30. Minorissue it is inappropriate to reference NUREG/CR-4982. The potential release discussed in that document are well above the Alert classification level.

i NEIITF Comment (051299): Will delete reference to NUREG/CR-4982

31. Minorissue The EALs should have consistent wording (to the extent possible) with the corresponding operating pisint EALs NEIITF Comment (051299): Wording was revised to accommodate permanently defueled plant operations.

32. Minorissue The basis section reads, in part, " evolution that results in operations necessary." This should be changed to read " evolution that impedes operations necessary."

i NEIITF Comment (051299): Wording will be revised as stated.

Appendix D

33. Minorlasue Page D.1, line 19, reads " licensee receives approval for specific emergency planning requirements negotiated with.. " This statement is not accurate. An accurate statement

)

is "the licensee receives approval for exemption from specific NRC emergency planning requirements."

(

NEIITF Comment (051299): The wordirig v;ill be revised as stated.

l Independent Spent Fuel Storage Installation (ISFSI) EALs l

General

34. Minorissue it should be stated that in the guidance document that these EALs only apply to ISFSI which do not process or repackage spent fuel.

NEI ITF Comment (051299): Section 3.16, ISFSI EALs, was revised to specifically exclude ISFSis which do not process or repackage spent fuel.

E-AU1

35. Minorissue is there any area radiation monitors in the area of dry cast storage? If so could these be referred to for classifying this event?

NElITF Comment (051299): No area radiation monitors are required for ISFSIs. If a licensee chooses to install area radiation monitors, these monitors could be utilized for this EAL. Dry cask storage modules are routinely monitored by site Radiation Protection /

Health Physics as stated in the basis for E-AUI.

1 E-HU1

36. Minorissue l

The EAL under this IC is:

Other conditions exist which in theJudgment of the Shift SupervisorEmergency Director indicate a potential degradation in the level of safety of the ISFSI. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

It does no: seem that the last part of this EAL, i.e., "unless further degradation of safety systems occurs," is appropriate.

l I

I'..

)

NEI ITF Comment (051299): The ITF concurs. Deleted "unless further degradation of safety systems occurs".

j

37. Minorissue it would be beneficial for the basis to discuss whether this emergency director judgement EAL must be included or whether the ED judgement EAL contained in the plant EALs would suffice (if a licensee choose to format its EALs in that manner)

NEIITF Comment (051299): Section 3.16, ISFSI EALs, was revised to indicate that the licensee has the flexibility to keep Category E EALs separate or integrate them into the existing EAL scheme as they see fit.

38. Minor lasue in the operating plant and permanently shutdown mode ICs, the emergency director IC is the last in the H category. To be consistent it may be appropriate to include the emergency director judgement EAL last in this category also.

NEIITF Comment (051299): The impact of renumbering throughout the document to incorporate this comment is under consideration by the ITF. This comment does not present a technical problem with the EAL as written.

3g.' Minor lasue

. It may be appropriate to modify the statement in the EAL regarding " degradation of safety systems" to " degradation of safety systems or structures."

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NEIITF Comment (051299): See item 36 4

E-HU2

40. Minor.laggt It would be beneficial to provide more detail as to the type of security events which may be classified under this IC.

NElITF Comment (051299): See item 25

E-HU3 j

41. Sianificantissue

- The basis for this EAL states: *A NOUE in this IC is categorized on the basis of the j

occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT j

BOUNDARY is damaged or violated. The results of the ISFSI Safety Analysis P.eport (SAR) should be used to develop the site-specific list of natural phenomena events and accident conditions."

Further information is needed to determine whether this list is site-specific or whether 1

specific conditions may be listed as is done under the natural phenomena EALs for plant I

operations.

NEIITF Comment (051299): The example EALs were modified to reflect a listing of site specific natural phenomena events and accident conditions. The basis was revised to indicate that these lists should be developed based on NUREG 1536..

42. Sionificant issue - Criticality Hazard in the NRC letter dated February 19,1999, the following issue was identified:

The table in Appendix E of NEl 99-01 does not include a conssponding entry for the NUREG-1567 Appendix C event for the ' discovery of a condition that could lead to a criticality hazard.' Explain how this initiating condition (IC) is accounted forin the NElguidance.

The NEl response to this issue (contained in NEl's letter dated April 7,1999) stated that the appropriate conditions are addressed. It is not clear how the conditions are addressed.~ Since a criticality event can be postulated to occur (even though it is

' unlikely) it seems that an EAL should be included for this type of event. Altematively the basis for the radiological EALs may be modified to identify increases in radiation levels as an indication of a potential criticality event.

NEIITF Comment (051299): The basis of E-AUl was revised to reflect that increases in.

radiation levels may indicate a potential criticality event; however, classification will be j

based on increased radiation readings rather than criticality itself.

43. Sionificant Issue - Onsite Fire i

in the NRC letter dated February 19,1999, the following issue was identified:

I i

"Further analysis to establish whether the level of the emergency class should be l

an Unusual Event (UE) rather than Alert' 1

1,

i Further information is needed as to why this event is classified as an UE rather than as an Alert. This discussion'should describe the analysis performed which shows that the l

fire will not result in a release of radioactive material warranting an Alert classification.

l NEIITF Comment (051299): Classification of an Alert under provisions of NUREG-

)

1567 Appendix C is based on the requirements of 10 CFR 72.32(a), which provides for classification of all emergency events at a simple ISFSI, i.e., one that does not process and/or repackage spent fuel, as Alerts. The emergency classifications used for Recognition Category E events are those provided by 10 CFR 72.32(c), i.e., the emergency classifications prescribed in 10 CFR 50 Appendix E and as described in NUREG 0654/ FEMA Rep.l. These differences are described in great detail in NEI 99-01 Appendix E. NOUE classifications provide an increased awareness for aonormal conditions. Due to the robust nature of the dry cask storage systems design criteria, the source term and motive force available at a simple ISFSI is insufficient to warrant classifications above the l

NOUE level using the 10 CFR 50 emergency classification scheme. The ISFSI SAR includes analysis of accident conditions and natural phenomena as required by NUREG-1536.

l

44. Significant Issue - Severe phenomenon have occurred without assessment:

In the NRC letter dated February 19,1999, the following issue was identified:

L "This is an appropriate EAL for an ISFSI but need further analysis to establish whether the level of the emergency class should be an UE rather than Alert" Further information is needed as to why this event is classified as an UE rather than as an Alert. This discussion should describe the analysis performed which show that the fire will not result in a release of radioactive matenal warranting an Alert classification.

NEIITF Comment (051299): See item 43.

Appendix E

45. Minor Page E.2, lines 37 to 3g, the classification of ISFSI events as an NOUE instead of an ALERT as proposed here is only acceptable under the special circumstance of a licensee that is maintaining a Part 50.47 emergency plan structure. This should be more clearly stated to avoid confusion with those ISFSI that do not have an assocMid j

Part 50.47 emergency plan.

NEIITF Comment (051299): ITF agrees, change will be made as indicated i 1 l

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p

'46.' Editorial Page E.2, line 36, it is unclear what the wording "no Electrical Technical Support"is

' referring to. This needs to be clarified.

NEI ITF Comment (051299): 1TF agrees, change will be made as indicated 47.' Editorial Page E.1, line 41, remove the word "is."

NEIITF Comment (051299): ITF agrees, change will be made as indicated v

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ATTACHMENT 3 MARK UP OF NEl 99-01