ML20217B933

Responds to from D Modeen to M Reinhart of NRC Staff Requesting Feedback on Draft NEI Rept 99-03 & Staff Identified Several Areas of Concern with Rept

ML20217B933
Person / Time
Issue date:	10/06/1999
From:	Collins S NRC (Affiliation Not Assigned)
To:	Ralph Beedle NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
NUDOCS 9910130117
Download: ML20217B933 (3)

Text

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• WASHINGTON, D.C. 20066-0001

\*****/ October 6,1999 l Mr. Ralph E. Beedle <

Senior Vice President and Chief NuclearOfficer Nuclear Energy Institute 1776 i Street, NW, Suite 400 ,

1 Washington, DC 20006-3708 ,

Dear Mr. Beedle' i in response to the letter dated August 5,1999, from Mr. David Modeen to Mr. Mark Reinhart of the NRC staff requesting NRC feedback on draft NEl Report 99-03, the staff identified several areas of concem with the report. This letter will briefly discuss four of these areas and their treatment in NEl Report 99-03.

The first area deals with control room operator radiological dose assessment. The report focuses on the conservatism in current analyses, including more liberal use of total effective dose equivalent provisions. The staff recognizes that the revision of the design basis for the radiological dose assessments may be justified based on more realistic recent technical insights. However, adaption of such insights necessitates a more balanced treatment of both conservative and non-conservative effects.

The second area involves the description of ventilation system configurations, operational modes and susceptibility to inleakage. As written, the report does not incorporate the full experience of those plants that performed tracer gas tests of their control room envelope it is necessary to ensure that the report disseminate this experience to NRC licensees.

The third area concems the demonstration of the control room envelope integrity. The report l does not address the staff's concem about periodic verification of conformance with the design basis. Recent history with tracer gas testing revealed that actual inteakage at several plants exceeded their design basis and raised questions as to the capability of these plants to meet General Design Criteria (GDC) 19 of Appendix A to Part 50 of Title 10 of the Code of Federal Reoulations. In my letter of November 18,1998, I indicated that periodic tracer gas testing of the control room envelope would provide a valuable tool for assessing control room integrity.

This was reiterated in meetings between the NEl and NRC staffs on September 24,1998, j April 28 and June 2,1999. In light of the recent testing history, periodic verification of the l O

design basis provides a clear pathway to the acceptance of NEl-99-03 and the industry initiative. .

The fourth area is that we disagree with the statement that the issues identified with control room habitability are more a matter of compliance than safety. The ability of the control room operators to perform their duties unimpeded by challenges arising from control room integrity is C(CM%

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, , October 6, 1999

'Mr. Ralph E. Beedle ,

t. 1 necessary for safety. While the low probability of challenges to control room operations and appropriate compensatory actions allow continued reactor operation, the control room habitability issue requires timely resolution.

Therefore, I am writing to obtain an industry commitment that NEl 99-03 will address our concerns about control room envelope integrity. Whether you adopt periodic testing of existing i design basis assumptions or propose another approach should be decided in the near future.

1 request that you respond within 60 days to provide a plan and schedule to resolve this matter in a timely manner.

Sincerely, Samuel J. Collins, Director Office of Nuclear Reactor Regulation l

l Distribution:

File Center PDR SPSB R/F CHRON File Regional Administrators - H. Miller, R-1 L. Reyes, R-il J. Dyer, R-ill E. Mershcoff, R-IV DOCUMENT NAME: A:\BEEDLE72.WPD Log No.: 99-195 To r;ceive a copy of this document, indicate in the box: "C" = Copy without attachment /e sure "E" = Copy with r.,ttachment/ enclosure "N" = No copy A/ >

OFFICE - SPSB/DSSA lE SPSB/DSSA lE TECH ED l SPSB/DSSf V D/DSSA/N l NAME JJHayes:pmm:rmc* FMReinhart* RJBarrettf ID4 11 GpdfTolahanh DATE 09/01 /99 10/06/99 09/01/99* 09/02 /99 /)9/ 02)p9 /

OFFICE DE/EMCB DRCH/HOHB SPLB/DSSA l ADPT/NRR 1 DOPfR ,

NAME WHBateman* RMGallo

• JNHannon

• BWSheron* WCoV DATE 09/01 /99 09/01 /99 09/01 /99 09/14/99 10fo /99 OFFICIAL DOCUMENT COPY

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i , October 6, 1999 Mr. Ralph E. Beedle .

1 necessary for safety. While the low probability of challenges to control room operations and appropriate compensatory actions allow continued reactor operation, the control room habitability issue requires timely resolution.

Therefore, I am writing to obtain an industry commitment that NEl 99-03 will address our concems about control room envelope integrity. Whether you adopt periodic testing of existing j design basis assumptions or propose another approach should be decided in the near future. '

I request that you respond within 60 days to provide a plan and schedule to resolve this matter in a timely manner.

Sincerely, Samuel J. Collins, Director Office of Nuclear Reactor Regulation Distribution:

File Center PDR SPSB R/F CHRON File Regional Administrators - H. Miller, R-l L. Reyes, R-Il J. Dyer, R-Ill E. Mershcoff, R-IV DOCUMENT NAME: A:\BEEDLE72.WPD Log No.: 99-195 To r:ceive a copy of this document, indicate in the box: "C" = Copy without attachment /e sure "E" = Copy with cttachment/ enclosure "N" = No copy A/

OFFICE SPSB/DSSA lE SPSB/DSSA lE TECH ED l SPSB/DS'SA V l D/DSSA/fi l NAME JJHayes:pmm:rmc* FMReinhart* RJBarrettf pl il CiMfTolahanh DATE 09/01 /99 10/06/99 09/01/99* 09/02 /99 49/ 02)p9 /

OFFICE DE/EMCB DRCH/HOHB l SPLB/DSSA ADPT/NRR l DONR ,

NAME WHBateman* RMGallo

• JNHannon

• BWSheron* %JCo #

DATE 09/01 /99 09/01 /99 09/01 /99 09/14 /99 10G /99 r OFFICIAL DOCUMENT COPY 1

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