ML24166A091

NEI 99-01 R7 Meeting Summary March 15 and April 16, 2024

ML24166A091
Person / Time
Site:	99902037
Issue date:	07/16/2024
From:	Leslie Fields Licensing Processes Branch
To:	Gerond George Licensing Processes Branch
Shared Package
ML24166A090	List: ML24166A091
References
EPID L-2023-TOP-0045
Download: ML24166A091 (8)

Text

July 16, 2024 MEMORANDUM TO:

Gerond A. George, Chief Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:

Leslie C. Fields, Senior Project Manager /RA/

Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUMMARY

OF PUBLIC MEETINGS BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE NUCLEAR ENERGY INSTITUTE TO DISCUSS REVISIONS TO DRAFT GUIDANCE NEI 99-01 REVISION 7, DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS (EPID L-2023-TOP-0045)

On March 15 and April 16, 2024, the U.S. Nuclear Commission (NRC) staff met with Nuclear Energy Institute (NEI) representatives to discuss Revision 7 of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactor. The meeting summary is available in and the list of attendees is listed in Enclosure 2.

If you have any questions or comments, please contact me via e-mail at Leslie.Fields@nrc.gov.

Docket No. 99902037

Enclosures:

1. Meeting Summary

2. List of Attendees CONTACT: Leslie Fields, NRR/DORL/LLPB 301-415-1186

U.S. NUCLEAR REGULATORY COMMISSION PUBLIC MEETING

SUMMARY

OF PUBLIC MEETINGS BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE NUCLEAR ENERGY INSTITUTE TO DISCUSS REVISIONS TO DRAFT GUIDANCE NEI 99-01 REVISION 7, DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS (EPID L-2023-TOP-0045)

Meeting Dates: March 15, 2024, 9:00 am - 11:00 am and April 16, 2024, 10:00 am - 12:00 pm Location: Hybrid Meeting Type: These were observation meetings where attendees had the opportunity to observe the U.S. Nuclear Regulatory Commission (NRC) staff and industry representatives engage in discussion on regulatory issues. Members of the public had an opportunity to ask questions of the NRC staff and make comments about the issues discussed following the business portion of the meeting; however, the NRC was not actively soliciting comments toward regulatory decisions at this meeting.

Meeting

Purpose:

The purpose of the meetings was to discuss NRCs comments on the latest version of Nuclear Energy Institute (NEI) draft guidance document entitled, NEI 99-01, Revision 7, "Development of Emergency Action Levels for Non-Passive Reactors.

Meeting Summary:

For the March 15, 2024, meeting, the NRC staff presented slides for discussion which provided details on how the updates were implemented to the review guidance.

Discussion topics focused on emergency action levels (EALs) associated with:

Site-specific effluent releases Site-specific effluent monitor readings and threshold values Analysis of a liquid effluent sample Primary containment radiation monitor reading For the April 16, 2024, meeting, the NEI representatives provided responses to the NRC staff presentation at the March 15, 2024, meeting regarding NEI 99-01, Revision 7. The NEI representatives comments focused on three categories:

1) NEI provides additional basis to support proposed changes associated with NRC comment Nos. 1, 3, 7, 9, 10, 11, and 12;

2) NEIs proposed alternatives addressing staff comments on the retention of EALs using precalculated effluent radiation monitor readings and Fission Product Barrier thresholds based on containment radiation monitor readings associated with NRC comment Nos. 2, 4, 5, 6, and 8; and

3) NEIs proposed changes addressing two items that were discovered after the January 2023 submittal of Revision 7 associated with NRC comment Nos. 14 and 15 (one change corrects an error and the other change improves the wording of an EAL).

No regulatory decisions or commitments were made at the meeting.

Public Participation Themes: No public comments or public meeting feedback forms were received during the public comment period at the conclusion of the meetings.

Action Items/Next Steps: NEI representatives stated that they would provide an updated summary based on the discussion at the March 15, 2024, meeting. At the end of the March meeting, the NEI representatives requested a follow-up meeting to finalize comments which was held on April 16, 2024.

At the end of the April 16, 2024, meeting, the NRC staff agreed to caucus and discuss the presentation slides with respect to its impact on the completion review of the technical guidance.

The NRC staff has provided additional feedback to help identify the best path forward in to this meeting summary.

Attachments:

1. March 15, 2024, Meeting Notice - ADAMS Accession No. ML24072A523

2. April 16, 2024, Meeting Notice - ADAMS Accession No. ML24095A350

3. March 15, 2024, NRC Presentation - ADAMS Accession No. ML24072A351

4. April 16, 2024, NEI Presentation - ADAMS Accession No. ML24095A353

5. NRC Feedback and Proposed Resolution to NEIs April 16, 2024, presentation - ADAMS Accession No. ML24164A219

U.S. NUCLEAR REGULATORY COMMISSION PUBLIC MEETING TO DISCUSS NUCLEAR ENERGY INSTITUTE DRAFT GUIDANCE, NEI 99-01, REVISION 7, ATTENDEES LIST MARCH 15, 2024 Nuclear Regulatory Commission (NRC)

Name Leslie Fields NRC Eric Schrader NRC Caty Nolan NRC Gerond George NRC Jeffrey Herrera NRC Steven Garry NRC Todd Smith NRC Jonathan Fiske NRC Don Johnson NRC Michael Waters NRC Kathryn Brock NRC Nuclear Energy Institute (NEI) and Industry Representatives Name Organization David Young NEI Bill Gross NEI Scott Odom Tennessee Valley Authority (TVA)

Walter Lee TVA Marcus Hofmann Dominion Energy Tyran Tharp Dominion Energy Cynthia Cashwell Florida Power and Light (FPL)

Peter Polfleit FPL Michael Williams FPL Noah Narut FPL Steve Catron FPL Adam Abrams FPL Anthony Daniels FPL Marty Vonk Xcelenergy Michael Finnegan Nextera Energy Denny Smith Nextera Energy Sophia Bartels Nextera Energy David Thompson Duke Energy Eric White Duke Energy R. Keith Brown Southern Nuclear Ricky Collings Southern Nuclear Timothy Barton Constellation Sherrie Grant Constellation William Revelle Constellation Sukjoon Kim Argonne National Laboratory Christopher Salz Ohio Department of Safety Kami Miller Holtec Kelly Walker Operations Support Services Inc.

Members of the Public Jana Bergman Curtiss-Wright John Conly Certrec Corporation Melissa Milstrey Member of the Public Ed Bates Member of the Public

U.S. NUCLEAR REGULATORY COMMISSION PUBLIC MEETING TO DISCUSS NUCLEAR ENERGY INSTITUTE DRAFT GUIDANCE, NEI 99-01 REVISION 7, ATTENDEES LIST APRIL 16, 2024 Nuclear Regulatory Commission (NRC)

Name Leslie Fields NRC Eric Schrader NRC Caty Nolan NRC Steven Garry NRC Don Johnson NRC Keith Compton NRC Kathryn Brock NRC Charles Murray NRC Jeffrey Herrera NRC Robert Fisher NRC Jessie Quichocho NRC Michael Norris NRC Keith Miller NRC William Rautzen NRC David Garmon NRC Sean Meighan NRC Nuclear Energy Institute (NEI) and Industry Representatives Name Organization David Young NEI Susan Perkins NEI Danielle Page Blair Framatome Kevin Simpson Constellation Tim Barton Constellation Sherrie Grant Constellation Phil Couture Entergy Peter Polfleit Florida Power and Light (FPL)

Cynthia Cashwell FPL Adam Abrams FPL Michael Williams FPL Jerry Phillabaum FPL Noah Narut FPL Scott Myers Odom Tennessee Valley Authority (TVA)

Walter Lee TVA Eric White Duke Energy David Thompson Duke Energy Richard Mothena Arizona Public Service (APS)

Chadwick Vinje APS Shaun Bernat APS Andrew Radosevic APS Steven Kadatz APS Shawn Wagner APS

R. Keith Brown Southern Nuclear David Simmons Southern Nuclear William Evans Southern Nuclear Ernest Bates Southern Nuclear Tyran Tharp Dominion Energy Alex Markivich Dominion Energy Brian L Mount Dominion Energy Currier, David Nextera Energy Finnegan, Michael Nextera Energy Smith, Denny Nextera Energy Faver, Kelly Luminant Kenneth L. Fossum Idaho National Laboratory Webster, Jay Vistracorp Robert Harrsch Energy Compliance Consultants, LLC Monica Ray Energy Compliance Consultants, LLC Kelly Walker Operations Support Services Inc.

Members of the Public Bergman, Jana Curtiss-Wright Fred Madden Certrec Corporation John Egdorf

ML24166A090 (Package)

ML24072A523 (3-15-24 Meeting Notice)

ML24095A350 (4-16-24 Meeting Notice)

ML22195A169 (NEI Draft Guidance Document)

ML22277A444 (NRC Presentation)

ML24095A353 (NEI Presentation)

ML24164A219 (NRC Feedback from 4/16/24 Meeting)

ML24166A091 (Meeting Summary) via *email OFFICE NRR/DORL/LLPB/PM*

NRR/DORL/LLPB/LA*

NSIR/DPR/RLB/BC*

NRR/DORL/LLPB/BC NAME LFields DHarrison CNolan GGeorge DATE 6/14/2024 6/21/2024 7/15/2024 7/16/2024