ML20206M818

Responds to 990407 Ltr Informing That NEI Provided Draft Rev 4 of NEI 99-01, Methodology for Development of Emergency Action Levels, to NEI Utility Members & NRC for Review & Comment

ML20206M818
Person / Time
Issue date:	05/11/1999
From:	Essig T NRC (Affiliation Not Assigned)
To:	Alexis Nelson NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
PROJECT-689 NUDOCS 9905170058
Download: ML20206M818 (12)

Text

y Alin Nilson May 11, 1999

.. a, Nuclier Entrgy Instituts 1776 Eya Strat, NW, Suits 400 Washington, DC 20006-3708

Dear Mr. Nelson:

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In a letter dated April 7,1999, the Nuclear Energy Institute (NEI) provided Draft Revision 4 of NEl 99-01 " Methodology for Development of Emergency Action Levels," to NEl utility members and the NRC for review and comment. Our comments on this document are provided in Attachment 1.

We look forward to meeting with you on May 13,1999, to discuss our comments. Furthermore, we believe it will be beneficial to spend some time during the May 13* meeting to consider the interrelationship of each of the emergency action levels (EALs) with each other and with the existing EALs contained in industry and NRC EAL guidance documents. 1 i

NEl 99-01 represents a significant undertaking by the industry to develop EAL guidance which I will help ensure the consistent and proper classification of events at operating plants,  !

permanently shutdown reactors and dry cask storage facilities. We are pleased with the l progress made to complete this guidance and believe that NRC's endorsemera of it in a draft guide can be accomplished in the near term upon resolution of a few remaining open items.

1 If you have any questions on this matter, please contact Jim O'Brien of my staff at (301) 415-2919.

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Sincerely, or;ninal signcd by Timn 03 H.14.

Thomas H. Essig, Chief Emergency Preparedness and Health Physics Section Operating Licensing, Human Factors and 9905170058 990511 Plant Support Branch PDR REVQP ERONUMRC PDR Division of Inspection Program Management Office of Nuclear Reactor Regulation

' Project No. 689

Attachment:

As stated cc: See next page DISTRIBUTION:

SRoudier DBarss LLois Project File BBoger RHall RSullivan ~ PMilligan Public ACRS RHasselberg JGiitter- SMagruder BSheron GTracy SCollins/RZimmerman 9 fo3.

DISK / DOCUMENT NAME: C:\EALS\s\NEl99-01\May 10 letter \5-10 letter.wpd To receive a copy of this document, indicate in the box: "C" = Copy w/o attach., "E" = Copy w/ attach.. "N' = No copy

'OpC EP&HP;DIPM E EP&HP:DIPM E. E lNAME JO'Brih TEssig [k lDATE f #/99V / $/H/99 / / _

/ / / /

OFFICIAL RECORD COPY

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p Altn Nelson May 11, 1999

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Er ' Nucinr EnIrgy Institut2-

- 1776 Eye Street, NW, Suite 400 k Washington, DC 20006-3708

Dear Mr. Nelon:

In a letter dated April 7,1999, the Nuclear Energy Institute (NEI) provided Draft Revision 4 of NEl 99-01 " Methodology for Development of Emergency Action Levels," to NEl utility members and the NRC for review and comment. Our comments on this document are provided in Attachment 1.

We look fonward to meeting with you on May 13,1999, to discuss our comments. Furthermore,

, we believe it will be beneficial to spend some time during the May 13* meeting to consider the interrelationship of each of the emergency action levels (EALs) with each other and with the i existing EALs contained in industry and NRC EAL guidance documents.

NEl 99-01 represents'a significant undertaking by the industry to develop EAL guidance which I will help ensure the consistent and proper classification of events at operating plants, permanently shutdown reactors and dry cask storage facilities. We are pleased with the i progress made to complete this guidance and believe that NRC's endorsement of it in a draft guide can be accomplished in the near term upon resolution of a few remaining open items.

If you have any questions on this matter, please contact Jim O'Brien of my staff at (301)415-2919.

Sincere;y, 4 Orkisi EigntdTibf ms H. M Thomas H. Essig, Chief Emergency Preparedness and Health Physics Section >

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

- Project No. 689

Attachment:

As stated cc: See next page DISTRIBUTION:

SRoudier DBarss LLois Project File BBoger RHall RSullivan PMilligan Public ACRS RHasselberg JGlitter SMagruder BSheron GTracy SCollins/RZimmerman DISK / DOCUMENT NAME: C:\EALS\s\NEl99-01\May 10 letter \5-10 letter.wpd To receive a copy of this document, indicate in the box "C" = Copy w/o attach., 'E' = Copy w/ attach., 'N' = No copy OFC EP&HP@8PM E EP&HP;DIPM, E E NAME JO'Bri TEssig [k DATE f /4/9! $/ H /99 / / / / //

OFFICIAL RECORD COPY

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UNITED STATES

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NUCLEAR HEGULATORY COMMISSION 2 WASHINGTON, D.C. mass m -

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• May 11, 1999 )

Alan Nelson Nuclear Energy Institute 4 1776 Eye Street, NW, Suite 400 Washington, DC 20006-3708

Dear Mr. Nelson:

In a letter dated April 7,1999, the Nuclear Energy Institute (NEI) provided Draft Revision 4 of NEl 99-01 " Methodology for Development of Emergency Action Levels," to NEl utility members and the NRC for review and comment. Our comments on this document are provided in Attachment 1.

We look forward to meeting with you on May 13,1999, to discuss our comments. Furthermore, we believe it will be beneficial to spend some time during the May 13* meeting to consider the interrelationship of each of the emergency action levels (EALs) with each other and with the existing EALs contained in industry and NRC EAL guidance documents.

NEl 99-01 represents a significant undertaking by the industry to develop EAL guidance which will help ensure the consistent and proper classification of events at operating plants, permanently shutdown reactors and dry cask storage facilities. We are pleased with the progress made to complete this guidance and believe that NRC's endorsement of it in a draft guide can be accomplished 61 the near term upon resolution of a few remaining open items.

If you have any qucrt. ions on this matter, please contact Jim O'Brien of my. staff at (301) 415-2919.

Sincerely, T mas H. Essig, Chi Emergency Preparedness and Health Physics Section Operating Licensing, Human Factors and Plant Support Branch Division of Inspection Program Management Office of Nucisar Reactor Regulation Project No. 689

Attachment:

As stated cc: See next page

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'4 Nuclear Energy Institute Project No. 689 cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support arid Chief Nuclear Officer Nuclear Energy Institute i Nuclear Energy Institute Suite 400 Suite 400 1776 l Street, NW 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, Mary!and 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 Licensing ,

Nuclear Energy Institute Suite 400 1776 l 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 Suite 400 1776 i Street, NW Washington, DC 20006-3708

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, Attachment 1 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 Ooeration EALs

1. CU2 -

UNPLANNED Loss of RCS Inventory with Irradiated Fuel in the RPV Sianificant Issue 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-specific) indication of uncontrolled waterlevel decrease in the reactor refueling cavity, spent fuelpool, or fuel transfer canal with allirradiated fuel assemblies remaining coveredby 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 guidance in order to ease site-specific implementation of this guidance.

Minor issue 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.

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.

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

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

2. CU4 - Loss of Decay Heat Removal l

Minor lasue I 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 not accurate.

3. CU5 --

Fuel Clad Degradation Minor issue it is not clear why this IC is not applicable in the defueled mode.

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4. CU7 -

Loss of DC Power i 1

Minor issue '

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.

5. CA1 and CA2 Loss of inventory (Alert) i Minor issues l A. These EALs are identical. Therefore, it seems as though they should be combined. l 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.

B. In the 2"8 to last sentence in the basis the statement is:

This EAL is not applicable to decreases in flooded reactor cavity level (covered by CU2 EAL2 and AU2 EAL1) until such tirne as the level decreases to the level of the vessel flange.

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.

6. CS1 and CS2 Loss of Inventory (SAE)

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

Minor lasue A. _ 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.

B. It seems that at the bottom ID of the RCS loop that suction to decay heat removal would undoubtly be lost. It may be appropriate te modify the sentence in the basis to reflect this.

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

s D. 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.

7. CG1 -- General Emergency Slanificant 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.

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.

Permanentiv Defueled Plant EALs

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

2. D-AU1 Sianificant 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

l be modified to make it consistent with the operating plant EAL. It is not clear how EAL #3 will I be implemented.- '

Minor lasue It is not clear why the terms " unplanned" and " sustained" are defined in this section rather than in the definitions section.

2. D-AU2 Sionificant lasue it is not clear why a different setpoint is appropriate for this EAL as compared to the corresponding operating plant EAL Minor lasue it does not seem necessary to specifically define " uncontrolled" in this section.

3. D-SU1 Sianificant lasues A. It does not seem necessary to include the condition of having no makeup capability in this EAL B. 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 .

would exist.

C. 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.

Minor lasue it is not clear why the term " makeup capability" is defined in this section.

4. D-HU1 Minor lasue 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.

5. D-HU2 Minor lasue 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.

6. D-HU3 Significant lasue 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.

Minor lasue ,

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.

7. D-HA3 (January 261999 revision)

Sianificant Issue The January 16,1999 revision of NEl 99-01 included an Alett 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.

8. D-AA2 Minor Issues A. It is inappropriate to reference NUREG/CR-4982. The potential release discussed in that document are well above the Alert classification level.

B. The EALs should have consistent wording (to the extent possible) with the corresponding operating plant EALs.

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

9. Appendix D Minor issue 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."

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indeoendent Soent Fuel Storaos Instdlation (ISFSI) EALs

1. General Minor lasue it should be stated that in the guidance document that these EA1.s only apply to ISFSI which do not process or repackage spent fuel.

2. E-AU1 El )

la there any area radiation monitors in the area of dry cast storage? If so could these be l referred to for classifying this event?

3. E-HU1 The EAL under this IC is:

Other conditions exist which in the judgment of the Shift Supervisor / Emergency Director \

indicate a potential degradation in the level of safety of the ISFSt. No releases of 1 radioactive material requiring offsite response or monitoring are expected unless further l degradation of safety systems occurs.

Minor lasues A. It does not seem that the last part of this EAL, i.e., "unless further degradation of safety systems occurs," is appropriate. i B. 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) l i

C. 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.  ;

D. It me.y 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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4. E-HU2 jAinor lasue I It would be beneficial to provide more detall as to the type of security events which may be classified under this IC.

5. E-HU3 Sianificant Issue The basis for this EAL states: "A NOUE in this IC is categorized on the basis of the occurrence i of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated. The results of the ISFSI Safety Analysis Report (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-spec 4ic or whether specific conditions may be listed as is done under the natural phenomena EALs for plant operations.

6. Criticality Hazard l

Sianificant lasue 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 corresponding entry for the NUREG-1567 Appendix C event for the " discovery of a condition that couldlead to a ,

criticality hazard." Explain how this initiating condition (IC) is accounted forin the NEI '

guidance.

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 i 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. Alternatively the basis for the radiological EALs may be modified to identify increases in radiation levels as an Indication of a potential criticality event.

7. Onsite Fire Sianificant issue in the NRC letter dated February 19,1999, the following issue was identified:

"Further analysis to establish whether the level of the emergency class should be an Unusual Event (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 shows that the fire will not result in a release of radioactive material warranting an Alert classification.

8. Severe phenomenon have occurred without assessment:

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

"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"

Sianificant Issue 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 material warranting an Alert classification.

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9. Appendix E Minor Page E.2, lines 37 to 39, 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 associated Part 50.47 emergency plan.

Editorial Page E.2, line 36, it is unclear what the wording "no Electrical Technical Support' is referring to. This needs to be clarified.

Page E.1, line 41, remove the word "is."

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