Letter Sequence RAI |
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EPID:L-2017-LLA-0406, Response to Request for Additional Information for Acceptance of License Amendment Request (LAR) for One-Time Extension of the Containment Type a Leak Rate Testing Frequency from 15 to 16 Years (Approved, Closed) |
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Category:E-Mail
MONTHYEARML23341A2002023-12-0707 December 2023 Email - Indian Point Energy Center Generating Units 1, 2, and 3 Implementation Notice of Amendment No. 67, 300 and 276 to Independent Spent Fuel Storage Installation Only Emergency Plan (Ioep) ML23332A0802023-11-0808 November 2023 Email from State of New York on the Revised License Amendment for Indian Point Energy Center ISFSI Only Emergency Plan ML23325A1632023-11-0808 November 2023 State of New York Comments on the Revised License Amendment for Indian Point Unit 2 and 3 Technical Specification Changes Reflecting Permanent Removal of Spent Fuel ML23331A9542023-11-0808 November 2023 Email - State of New York Comments on the Revised License Amendment for Indian Point Unit 2 and 3 Technical Specification Changes Reflecting Permanent Removal of Spent Fuel ML23144A3452023-05-25025 May 2023 Adam Kahn of Monsey, New York Email Against Treated Water Release from Indian Point Site ML23144A3442023-05-25025 May 2023 Peggy Kurtz of Rockland County, New York Email Against Treated Water Release from Indian Point Site ML23144A3392023-05-25025 May 2023 David Morris of New City, New York Email Against Treated Water Release from Indian Point Site ML23144A3502023-05-25025 May 2023 Dan Kwilecki of Montebello, New York Email Against Treated Water Release from Indian Point Site ML23144A3422023-05-25025 May 2023 Peter Duda of Pearl River, New York Email Against Treated Water Release from Indian Point Site ML23144A3382023-05-25025 May 2023 Dawn Giambalvo of Jersey City, New Jersey Email Against Treated Water Release from Indian Point Site ML23136B1622023-05-15015 May 2023 Town of North Salem, County of Westchester, New York Board Resolution Letter Regarding Treated Water Release from Indian Point Site ML23109A0632023-04-17017 April 2023 Email Acceptance Review for IP2 and IP3 Amended Facility License and Technical Specification to Reflect Permanent Removal of Spent Fuel from Spent Fuel Pits ML23055A1112023-02-23023 February 2023 Alyse Peterson Email- NYSERDA No Comments on Indian Point Unit 2 - Regarding Holtec License Amendment Request to Revise Permanently Defueled Technical Specifications and Staffing Requirements with Spent Fuel Transfer to ISFSI (Dockets 50-24 ML23049A0032023-02-14014 February 2023 NRC Acceptance Email to Holtec for License Amendment Request for Approval of New ISFSI-Only Emergency Plan and Associated EAL Scheme ML22313A1682022-11-0909 November 2022 NRC Response to Updates to the Proposed Amended IP2 Master Trust ML22308A0912022-11-0303 November 2022 Email Acknowledgement for IP2 and IP3 Amended Facility License and Technical Specification to Reflect Permanent Removal of Spent Fuel from Spent Fuel Pits ML22276A1642022-09-29029 September 2022 New York State Revised Draft EA Response E-Mail ML22271A8492022-09-28028 September 2022 E-Mail Transmitting Revised Indian Point Exemption Draft EA ML22269A3452022-09-22022 September 2022 Email Objection to Holtec IP2 Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Facility Unit 1 and 2, EPID L-2022-LLA-0072 ML22259A1992022-09-0202 September 2022 Acceptance for License Amendment Request to Modify Staffing Requirements Following SFP Transfer to Dry Storage ML22265A0142022-08-31031 August 2022 Email Acknowledgement for Amended and Restated Holtec IP3 Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Facility Unit 3 ML22242A2592022-08-19019 August 2022 E-mail from K. Sturzebecher, NRC, to B. Noval, HDI, Acknowledgement for Amended and Restated Holtec IP2 Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Facility Unit 1 and 2 ML22228A1332022-08-0909 August 2022 Acknowledgement for License Amendment Request to Modify Staffing Requirements Following SFP Transfer to Dry Storage ML22215A0432022-08-0101 August 2022 E-Mail Transmitting NYS NSA Exemption Comments & Draft EA Review Completion ML22208A0292022-07-19019 July 2022 E-Mail Transmitting Indian Point Exemption Draft EA ML22168A0072022-06-16016 June 2022 Acceptance Review for License Amendment Request to Revise License Condition to Eliminate Cyber Security Plan Requirements ML22112A0102022-04-21021 April 2022 Acceptance Review: Request for Exemption from 10 CFR 50.54(w)(1) Concerning Indian Point Energy Center Onsite Property Damage Insurance ML22112A0122022-04-21021 April 2022 Acceptance Review: Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance for Indian Point Energy Center ML22103A2432022-04-13013 April 2022 E-mail - Request for Additional Information - License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme for Permanently Defueled Condition for Indian Point Energy Center ML22104A0342022-04-13013 April 2022 E-mail from Z. Cruz, NRC to J. Fleming, Holtec - Request for Additional Information Related to Request for Exemption from Portions of 10 CFR 50.47 and Part 50 Appendix E for Indian Point Energy Center ML22038A2572022-02-0707 February 2022 E-mail from Z. Cruz, NRC, to J. Fleming, HDI - Acceptance Review: License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme to Address Permanently Defueled Condition for Indian Point Energy Center ML22035A1862022-02-0404 February 2022 E-mail to J. Fleming, Holtec, from Z. Cruz Perez, NRC - Acceptance Review: Exemption Requests from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E, Section IV for Indian Point Energy Center ML22028A1032022-01-28028 January 2022 E-mail Dated 1/28/2022, Transmittal of Draft Safety Evaluation for Proposed License Amendment Revision to Licensing Basis to Incorporate the Installation and Use of of New Auxiliary Lifting Device ML22038A1592022-01-24024 January 2022 NRR E-mail Capture - (External_Sender) 2021 IPEC Annual Sturgeon Impingement Report ML22006A0442022-01-0505 January 2022 Email from Z Cruz to J Fleming Request for Additional Information - HDI Indian Point Post-Shutdown Decommissioning Activities Report ML21337A2952021-12-0303 December 2021 Subsequent Request for Additional Information License Amendment Request to Revise Licensing Basis for New Auxiliary Lifting Device (E-mail Dated 12/3/2021) ML21335A3692021-12-0101 December 2021 Acceptance Review: Indian Point Energy Center - Exemption Request from 10 CFR Part 20 App G Section Iii.E ML21266A2972021-08-18018 August 2021 8/18/2021 E-mail from H. Specter to R. Guzman Public Comments to NRC, Indian Point Post-Shutdown Decommissioning Activities Report Public Meeting on July 29, 2021 ML21225A6142021-08-0909 August 2021 Email from NRC to the Tuscarora Nation Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A5682021-08-0909 August 2021 Email from NRC to the Stockbridge-Munsee Community Band of Mohican Indians Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A5012021-08-0909 August 2021 Email from NRC to the Shinnecock Indian Nation Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21224A3032021-08-0909 August 2021 Email from NRC to the Mashantucket Pequot Tribe of Connecticut Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A4252021-08-0909 August 2021 Email from NRC to the Oneida Nation of Wisconsin Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A3142021-08-0606 August 2021 Email from NRC to the Oneida Indian Nation Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A4402021-08-0606 August 2021 Email from NRC to the Onondaga Nation of Wisconsin Announcing the IPEC PSDAR Meeting on August 18, 2021 ML21225A5462021-08-0606 August 2021 Email from NRC to the St. Regis Mohawk Tribe Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A5352021-08-0606 August 2021 Email from NRC to the Tonawanda Band of Seneca Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21266A2942021-07-25025 July 2021 E-mail from Paul Blanch to NRC (N. Sheehan, D. Screnci) Public Comments to NRC, Indian Point Post-Shutdown Decommissioning Activities Report Public Meeting, July 29, 2021 ML21197A2002021-07-16016 July 2021 (E-mail 7/16/2021) NRC Staff Assessment and RAI Closeout HDI Fleet Decommissioning Quality Assurance Program and Indian Point Energy Center Quality Assurance Program Manual ML21194A4082021-07-13013 July 2021 (7-13-2021) E-mail NRR Review Hour Estimate Change Supporting the Hi-Lift Crane Proposed License Amendment Request Review 2023-05-25
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23171B0442023-06-23023 June 2023 Enclosure - Indian Point Energy Center - Request for Additional Information for Independent Spent Fuel Storage Installation Facility-Only Emergency Plan License Amendment ML22292A2402022-10-21021 October 2022 RAIs for Master Dtf Agreement on IP1 IP2 10 18 2022 ML22103A2442022-04-13013 April 2022 Attachment - Request for Additional Information - License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme for Permanently Defueled Condition for Indian Point Energy Center ML22104A0352022-04-13013 April 2022 Request for Additional Information Related to Exemption Request from Emergency Planning Holtec Decommissioning International, LLC Indian Point Energy Center ML22006A0452022-01-0505 January 2022 PSDAR RAIs Final ML21337A2952021-12-0303 December 2021 Subsequent Request for Additional Information License Amendment Request to Revise Licensing Basis for New Auxiliary Lifting Device (E-mail Dated 12/3/2021) ML21183A1602021-06-30030 June 2021 Update Request for Additional Information - Indian Point Energy Center Quality Assurance Program Manual (06/30/2021 E-mail) ML21138A9412021-05-18018 May 2021 Request for Additional Information - Indian Point Energy Center Quality Assurance Program Manual (05/18/2021 E-mail) ML21112A2672021-04-22022 April 2021 Subsequent Request for Additional Information License Amendment Request to Revise Licensing Basis for New Auxiliary Lifting Device (Public Redacted Version) ML21019A5672021-01-19019 January 2021 Second Round Request for Additional Information License Amendment Request to Revise Licensing Basis for New Auxiliary Lifting Device ML21013A0152021-01-12012 January 2021 Draft Request for Additional Information (E-mail Dated 1/12/2021) License Amendment Request to Revise Licensing Basis for New Auxiliary Lifting Device ML20268C2352020-09-24024 September 2020 Request for Additional Information (E-mail Dated 9/24/20) License Amendment Request to Revise Licensing Basis for New Auxiliary Lifting Device ML20233B0152020-08-20020 August 2020 Request for Additional Information (E-mail Dated 8/20/20) License Amendment Request to Revise Licensing Basis for New Auxiliary Lifting Device ML20190A2342020-07-0808 July 2020 Request for Additional Information - Application for Order Consenting to Transfers of Control of Licenses (07/08/2020 E-mail) ML20190A1502020-06-25025 June 2020 (06/25/2020 E-mail) Draft Request for Additional Information Application for Order Consenting to Transfers of Control of Licenses ML20106F2492020-04-15015 April 2020 E-mail (04/15/2020) Request for Additional Information Exemption Request from 10 CFR Appendix R, Section Iii.H Due to COVID-19 Pandemic ML20070J7902020-03-10010 March 2020 Request for Information to Support Triennial Baseline Design-Basis Capability of Power-Operated Valves Inspection; Inspection Report 05000286/2020012 ML19045A6252019-02-14014 February 2019 Request for Additional Information - Proposed License Amendment Request Regarding Storage of Fresh and Spent Nuclear Fuel in the Spent Fuel Pool - 2/14/19 E-mail from R.Guzman to M.Mirzai NL-18-053, Response to Request for Additional Information Regarding Relief Request IP3-ISI-RR-11 for Reactor Vessel Weld Inservice Inspection Frequency Extension2018-07-18018 July 2018 Response to Request for Additional Information Regarding Relief Request IP3-ISI-RR-11 for Reactor Vessel Weld Inservice Inspection Frequency Extension ML18155A4842018-06-0404 June 2018 Request for Additional Information Regarding Relief Request IP3-ISI-RR-11, E-mail from R.Guzman to C.Mackaman ML18143B6792018-05-23023 May 2018 Request for Additional Information Regarding LAR for One-Time Extension of the Containment Leakage Rate Test - Email from R.Guzman to M.Mirzai ML18094B0922018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to B. S. Ford RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for ISFSI Docket Nos.: 72-43, 72-51, 72-1044, 72-07, 72-12, and 72-59) ML17296A2352017-10-23023 October 2017 Request for Additional Information -10/23/17 E-mail from R.Guzman to R.Louie Cyber Security Plan Milestone 8 Implementation Schedule (CAC Nos. MF9656, MF9657, MF9658; EPID: L-2017-LLA-0217) ML17277B5482017-10-0303 October 2017 Request for Additional Information - Relief Request IP2-ISI-RR-20 Regarding Weld Examination ML17219A1062017-08-10010 August 2017 Request for Additional Information Regarding Inter-Unit Transfer of Spent Fuel - Shielded Transfer Canister Requests for Additional Information ML17200A0852017-07-19019 July 2017 Request for Additional Information Regarding the Connection of Non-Seismic Boric Acid Recovery System to RWST Seismic Piping ML17197A0002017-07-17017 July 2017 Request for Additional Information Regarding Inter-Unit Transfer of Spent Fuel ML17170A2862017-06-27027 June 2017 RAI Set 2017-06 ML17103A4182017-04-25025 April 2017 Baffle Bolt Rais. Requests for Additional Information for the Review of the Indian Point License Renewal Application (TAC Nos. MD5407 and MD5408) ML17088A4052017-04-20020 April 2017 Requests for Additional Information for the Review of the Indian Point License Renewal Application RAI Set 2017-3 (CAC Nos. MD5407 and MD5408) ML17088A3272017-04-19019 April 2017 Requests for Additional Information for the Review of the Indian Point License Renewal Application RAI Set 2017-02 (CAC Nos. MD5407 and MD5408) ML17100A1282017-04-11011 April 2017 Supplemental Information Needed for Acceptance of Requested Licensing Action Amendment of Inter Unit Transfer of Spent Fuel ML17046A2312017-03-0808 March 2017 Request for Additional Information for the Review of the Indian Point License Renewal - Set 2017-01 ML16232A1192016-09-12012 September 2016 Request for Additional Information for the Review of the Indian Point Nuclear Generating Units Nos. 2 and 3, License Renewal Application Environmental Review - Severe Accident Mitigation Alternatives (CAC Nos. MD5411 and MD5412) ML16138A1942016-07-25025 July 2016 Request for Additional Information for the Review of License Renewal Application, Set 2016-01 ML16139A0302016-06-10010 June 2016 Request for Additional Information Regarding Conditional Exemption from End-of-Line Moderator Temperature Coefficient Measurement ML16112A2262016-04-26026 April 2016 Request for Additional Information Regarding Relief Request IP2-ISI-RR-02 Alternative Examination Volume Required by Code Case N-729-1 ML16041A5782016-02-18018 February 2016 Request for Additional Information Related to License Amendment Request Regarding Moderator Temperature Coefficient Measurement Change ML16005A6292016-01-14014 January 2016 Request for Additional Information Regarding Relief Request IP2-RR-19 ML16013A0642016-01-13013 January 2016 NRR E-mail Capture - Request for Additional Information Entergy CNRO-2015-00023 - Revision to Entergy Quality Assurance Program Manual (Fleet Submittal CAC Nos. MF7086-MF7097) ML15341A1662015-12-0707 December 2015 NRR E-mail Capture - Entergy Fleet RR-EN-15-1, Request for Additional Information (CACs MF6341-MF6349) ML15148A4032015-06-29029 June 2015 Request for Additional Information Regarding the Spent Fuel Pool Criticality Analysis ML15156B2742015-06-16016 June 2015 Request for Additional Information Regarding Request to Permanently Extend the Frequency of the Containment Integrated Leak Rate Test ML15125A0972015-05-0606 May 2015 Request for Additional Information Regarding License Amendment to Permanently Extend the Frequency of the Containment Integrated Leak Rate Test ML15071A1012015-05-0404 May 2015 Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, Set 2015-01 (TAC Nos. MD5407 and MD5408) ML15103A2592015-04-28028 April 2015 Request for Additional Information Regarding the Proposed License Amendment to Extend the Containment Type a Leak Rate Testing Frequency to 15 Years ML15104A5412015-04-22022 April 2015 Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application Environmental Review (TAC Nos. MD5411 and MD5412) ML15072A4172015-03-17017 March 2015 Request for Additional Information Regarding Extension of the Containment Type a Leak Rate Testing Frequency to 15 Years ML14329B2452015-02-18018 February 2015 Request for Additional Information for the Review of the Indian Point Nuclear Generating Units 2 and 3, License Renewal Application Environmental Review (TAC Nos. MD5411 and MD5412) CNRO-2015-00008, Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company2015-02-18018 February 2015 Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company 2023-06-23
[Table view] |
Text
From:Guzman, RichardTo:"Mirzai, Mahvash"Cc:Walpole, Robert W
Subject:
Indian Point, Unit 3 - Request for Additional Information regarding LAR for One-Time Extension of theContainment Leakage Rate Test (EPID: L-2017-LLA-0406)Date:Wednesday, May 23, 2018 2:14:07 PMMahvash, On May 15, 2018, the U.S. Nuclear Regulatory Commission (NRC) staff sent EntergyNuclear Operations, Inc. (Entergy or the licensee) the subject Request for AdditionalInformation (RAI) as a draft (via e-mail shown below). This RAI relates to a licenseamendment request submitted by Entergy that requests a one-time extension to the IndianPoint Unit No. 3 Containment Integrated Leakage Rate Test (from the current 15-year to a16-year frequency). This test is required by Technical Specification 5.5.15 "ContainmentLeakage Rate Testing Program." On May 23, 2018, the NRC staff conducted a conference call with the licensee staff toclarify the request. Following the discussion, you indicated that Entergy will provide aresponse to this RAI by July 6, 2018 (approximately 45 days from the date of thiscorrespondence). Updated below is the official (final) RAI. A publicly available version ofthis e-mail and RAI will be placed in the NRC's ADAMS system. Please contact me shouldyou have any questions in regard to this request. Thanks,~~~~~~~~~Rich GuzmanSr. PM, Division of Operating Reactor LicensingOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionOffice: O-9C07 l Phone: 301-415-1030 From: Guzman, Richard [1] Sent: Tuesday, May 15, 2018 12:33 PMTo: Walpole, Robert WCc: Mirzai, Mahvash
Subject:
Indian Point, Unit 3 - LAR for One-Time Extension of the Containment Leakage Rate Test -DRAFT Request for Additional Information (EPID: L-2017-LLA-0406)Mahvash,By letter dated December 8, 2017 (Agencywide Documents Access and ManagementSystem (ADAMS) Accession No. ML17349A131), Entergy Nuclear Operations, Inc.(Entergy, licensee) submitted a license amendment request (LAR) requesting one-timeextension from 15 years to 16 years frequency for the Indian Point Unit No. 3 (IP3)containment Integrated Leakage Rate Test (ILRT). The Nuclear Regulatory Commission(NRC) staff has determined that additional information is needed to complete its review, asdescribed in the request for additional information (RAI) shown below. This RAI is identified as draft at this time to confirm your understanding of the informationthat the NRC staff needs to complete the evaluation. Please contact me if you would like toset up a conference call to clarify this request for information.
Thanks,~~~~~~~~~Rich GuzmanSr. PM, Division of Operating Reactor LicensingOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionOffice: O-9C07 l Phone: 301-415-1030 REQUEST FOR ADDITIONAL INFORMATIONLICENSE AMENDMENT REQUEST (LAR)FOR ONE-TIME EXTENSION OF THECONTAINMENT TYPE A LEAK RATE TESTING FREQUENCY FROM 15 TO 16 YEARSINDIAN POINT UNIT NO. 3DOCKET NO. 50-286By letter dated December 8, 2017 (Agencywide Documents Access and ManagementSystem (ADAMS) Accession No. ML17349A131), Entergy Nuclear Operations, Inc.(Entergy, licensee) submitted a license amendment request (LAR) requesting one-timeextension from 15 years to 16 years frequency for the Indian Point Unit No. 3 (IP3)containment Integrated Leakage Rate Test (ILRT). This test is required by TS 5.5.15"Containment Leakage Rate Testing Program." The following requests for additionalinformation (RAIs) outline the information needed for the NRC staff to complete its review:RAI External Events ScreeningElectric Power Research Institute (EPRI) Technical Report No. 1009325, Revision 2-A(ADAMS Accession No. ML14024A045) states that "[w]here possible, the analysis shouldinclude a quantitative assessment of the contribution of external events (for example, fireand seismic) in the risk impact assessment for extended ILRT intervals. For example,where a licensee possesses a quantitative fire analysis and that analysis is of sufficientquality and detail to assess the impact, the methods used to obtain the impact from internalevents should be applied for the external event." EPRI TR-1009325, Revision 2-A furtherstates that the "assessment can be taken from existing, previously submitted and approvedanalyses or another alternate method of assessing an order of magnitude estimate forcontribution of the external event to the impact of the changed interval."In Section 5.7 of Attachment 1 to the LAR, the licensee performed an assessment ofexternal event contribution. The licensee's analysis reflected the contribution from internalfire and seismic event. The licensee stated that high winds, external floods and "Other"external events were considered negligible in estimation of the external events impact onthe ILRT extension application. This conclusion appears to be reached based on the IP3Individual Plant Examination for External Events (IPEEE) analysis performed in 1997.Consistent with the Regulatory Guide (RG) 1.174 guidance that the probabilistic risk assessment (PRA) scope, level of detail and technical acceptability be based on the as-built and as-operated plant, and maintained to reflect the current operating experience atthe plant, provide justification for the applicability of the IPEEE conclusions to the currentplant and its environs, considering each of the external hazards screened from thisapplication and taking into account any updated risk studies and insights. The analysisshould include all hazard groups (i.e., high winds, external flooding, transportation events,aircraft, industrial facilities, and other external hazards)RAI Assumptions used for Alternative Approach for External Events ImpactSection 2.5.3 of RG 1.174, Revision 3, states, "[t]he impact of using alternativeassumptions or models may be addressed by performing appropriate sensitivity studies orby using qualitative arguments, based on an understanding of the contributors to the resultsand how they are impacted by the change in assumptions or models." In addition, Section2.5.5 of RG 1.174 states, "[i]n general, the results of the sensitivity studies should confirmthat the guidelines are still met even under the alternative assumptions (i.e., changegenerally remains in the appropriate region)." In Section 5.7 of Attachment 1 to the LAR, the licensee performed an assessment ofexternal event contribution. The licensee used two approaches: the multiplier approach,which applies a multiplier to the internal events results (the multiplier is derived from theratio of external events core damage frequency (CDF) to the internal events CDF) and an"alternative" approach where each EPRI accident class frequency is re-examined. Thelicensee calculated an increase in population dose risk from changing the ILRT frequencyfrom three in 10 years to once in 16 years as 3.67 person-rem/year or 1.00% (when usingthe multiplier approach) and 3.84 person-rem/year or 0.69% when using the alternativeapproach. The reported increase in total population dose is close to the acceptance criteriavalues of 1 person-rem/year or 1% provided in EPRI TR-1009325, Revision 2-A, anddefined in Section 3.2.4.6 of the NRC safety evaluation for NEI 94-01, Revision 2 (ADAMSAccession No. ML081140105). It appears that the reduction in the % population dose change obtained through the use ofthe "alternative" approach included in Section 5.7.5 of Attachment 1 to the LAR relies onincreasing the total estimated population dose due to external hazards for the base case,corresponding to the three in 10 year frequency. Two assumptions appears to be key tothis reduction in population dose change: ~ The frequency for the EPRI accident Class 7 sequences (accidents involvingcontainment failure induced by severe accident phenomena) is increased byassuming that 50% of the CDF is due to late Class 7 sequences, as compared tothe internal events value of 15%, with the justification that "the external eventscontributors are dominated by unrecoverable SBO-like scenarios". ~ The frequency of the EPRI accident Class 2 sequences (containment isolationfailures) is increased by assuming that 0.1% of the external events CDF is due tolarge containment isolation failures, as opposed to the internal events contribution of0.03%, with the justification that "seismic and fire initiated events would likely be more susceptible" to large containment isolation failures. In accordance with the guidance in RG 1.174, provide a detailed justification for assumingthe value of 50% for the external events contribution to the Class 7 late sequences and thevalue of 0.1% for the Class 2 sequences. The explanation should include the conceptsused to identify the assumptions made for the contributors which ultimately resulted in doserisk change to less than 1.0%. Include a discussion of the conservatisms in the analysisand the risk significance of these conservatisms.