ML15068A328

ACRS Pre-Decisional DG-1319 Integrated Response Capabilities for Beyond-Design-Basis Events

ML15068A328
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Issue date:	03/10/2015
From:	Kolb T Office of Nuclear Reactor Regulation
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U.S. NUCLEAR REGULATORY COMMISSION March 2015 OFFICE OF NUCLEAR REGULATORY RESEARCH Division 1 DRAFT REGULATORY GUIDE

Contact:

Timothy Kolb 301-415-1428 Charles Murray 301-287-9246 DRAFT REGULATORY GUIDE DG-1319 (Proposed New Regulatory Guide 1.228)

INTEGRATED RESPONSE CAPABILITIES FOR BEYOND-DESIGN-BASIS EVENTS A. INTRODUCTION Purpose This regulatory guide (RG) identifies methods and procedures the staff of the U.S. Nuclear Regulatory Commission (NRC) considers acceptable for nuclear power reactor applicants and licensees to demonstrate compliance with NRC regulations covering integrated planning and preparedness for beyond-design-basis events as required by Section 50.155, Mitigation of Beyond-Design-Basis Events, of Title 10 of the Code of Federal Regulations (10 CFR 50.155) (Ref. 1) and Section VII, Communications and Staffing Requirements for the Mitigation of Beyond Design Basis Events, to Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50.

This RG endorses, with clarifications, the methods and procedures promulgated by the Nuclear Energy Institute (NEI) in the following documents as methods the NRC staff considers acceptable for meeting portions of the regulations in 10 CFR 50.155 and 10 CFR Part 50, Appendix E, Section VII:

• NEI 12-01, Guidelines for Assessing Beyond-Design-Basis Accident Response Staffing and Communication Capabilities, Revision 0, dated May 2012 (Ref. 2). This NEI document was previously endorsed by the NRC in a letter from Mr. David Skeen to Ms. Susan Perkins-Grew dated May 15, 2012 (Ref. 3).

This RG is being issued in draft form to involve the public in the early stages of the development of a regulatory position in this area. It has not received final staff review or approval and does not represent an official NRC final staff position. Public comments are being solicited on this draft guide (including any implementation schedule) and its associated regulatory analysis or value/impact statement. Comments should be accompanied by appropriate supporting data. Written comments may be submitted to the Rules, Announcements, and Directives Branch, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; submitted through the NRCs interactive rulemaking Web page at http://www.nrc.gov; or faxed to (301) 492-3446. Copies of comments received may be examined at the NRCs Public Document Room, 11555 Rockville Pike, Rockville, MD. Comments will be most helpful if received by [insert date - 75 days from issuance].

Electronic copies of this draft regulatory guide are available through the NRCs interactive rulemaking Web page (see above); the NRCs public Web site under Draft Regulatory Guides in the Regulatory Guides document collection of the NRC Library at http://www.nrc.gov/reading-rm/doc-collections/; and the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML14265A070. The regulatory analysis may be found in ADAMS under Accession No. ML15049A212.

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• NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond-Design-Basis Accidents and Events, Revision 0, dated September 2014 (Ref. 4), and

• NEI 14-01, Emergency Response Procedures and Guidelines for Beyond-Design-Basis Events and Severe Accidents. Revision 0, dated September 2014 (Ref. 5)

Applicable Orders and Regulations

• NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, issued March 12, 2012 (Ref. 6). This order requires nuclear power reactor licensees and construction permit holders to develop, implement, and maintain strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities following a beyond-design-basis external event. Additionally, the order requires the licensee to develop all needed procedures, guidance, and training and be able to implement the requirements in all modes of operation.

• 10 CFR 50.155(b) requires licensees to develop, implement, and maintain an integrated response capability that includes 1) mitigation strategies for beyond-design-basis external events, 2) extensive damage mitigation guidelines, 3) severe accident management guidelines. Section 50.155 also requires nuclear power reactor licensees to integrate these strategies and guidelines with existing Emergency Operating Procedures (EOPs), provide sufficient staffing and a supporting organizational structure with defined roles, responsibilities, and authorities to support implementation of the integrated response capability.

• 10 CFR 50.155(e) "Training requirements" requires licensees to provide training and qualification of personnel that perform activities in accordance with the strategies and guidelines required by 10 CFR 50.155(b).

• 10 CFR 50.155(f) "Drills and Exercises" requires licensees to perform drills or exercises to demonstrate the capability to use the strategies and guidelines required by10 CFR 50.155(b).

• 10 CFR Appendix E - Emergency Planning and Preparedness for Production and Utilization Facilities;Section IV requires licensees to have the means to determine the magnitude of, and continually assess the impact of, the release of radioactive materials from all reactor core and spent fuel.

• 10 CFR Appendix E - Emergency Planning and Preparedness for Production and Utilization Facilities;Section VII.1 requires applicants or licensees to perform a detailed analysis demonstrating sufficient staff is available to respond to a beyond-design-basis external event affecting all units on a site.

• 10 CFR Appendix E - Emergency Planning and Preparedness for Production and Utilization Facilities;Section VII.2 requires applicants or licensees to make and describe adequate provisions for at least one on-site and one off-site communications system capable of remaining functional during an extended loss of alternating current (ac) power to include effects of the loss of local communications infrastructure.

Related Guidance DG-1319, Page 2 BEING PROVIDED TO SUPPORT THE MEETING WITH ACRS AND NOT TO SOLICIT EXTERNAL STAKEHOLDER FEEDBACK

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• JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Ref. 7).

This interim staff guidance (ISG) endorses, with exceptions and clarifications, the methodologies described in NEI guidance document NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide (Ref. 8) as one method of demonstrating compliance with NRC Order EA-12-049. JLD-ISG-2012-01 is superseded and replaced by draft regulatory guide (DG)-1301 (proposed RG 1.226), Flexible Mitigation Strategies for Beyond-Design-Basis Events (Ref. 9).

Purpose of Regulatory Guides The NRC issues RGs to describe to the public methods that the staff considers acceptable for use in implementing specific parts of the agencys regulations, to explain techniques that the staff uses in evaluating specific problems or postulated accidents, and to provide guidance to applicants. Regulatory guides are not substitutes for regulations and compliance with them is not required. Methods and solutions that differ from those set forth in RGs will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license by the Commission.

Paperwork Reduction Act This RG contains information collection requirements covered by 10 CFR Part 50 that the Office of Management and Budget (OMB) approved under OMB control number 3150-0011. The NRC may neither conduct nor sponsor, and a person is not required to respond to, an information collection request or requirement unless the requesting document displays a currently valid OMB control number.

B. DISCUSSION Reason for Issuance One of the primary lessons learned from the events at Fukushima Dai-ichi was the significance of the challenge presented by a loss of safety-related systems following the occurrence of a beyond-design-basis external event. In the case of Fukushima Dai-ichi, the extended loss of alternating current (ac) power condition caused by the tsunami led to loss of core cooling and a significant challenge to containment. The design basis for U.S. nuclear power plants includes bounding analyses with margin for external events expected at each site. Extreme external events (e.g., seismic events, external flooding) beyond those accounted for in the design basis are highly unlikely but could present challenges to nuclear power plants.

The regulations in 10 CFR Part 50, Appendix E require each nuclear power plant licensee to have enhanced on-site emergency response capabilities to address the impact of beyond-design-basis external events affecting multiple units and source terms on a site, where applicable.

This RG addresses these challenges by endorsing, with clarifications, the processes in 3 NEI documents, NEI 12-02, 13-06, and 14-01. The NRC staff believes that the strategies and methods in these 3 NEI documents will enhance a licensees ability to implement their on-site emergency response capability to respond to such events.

Background

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BEING PROVIDED TO SUPPORT THE MEETING WITH ACRS AND NOT TO SOLICIT EXTERNAL STAKEHOLDER FEEDBACK Following the March 11, 2011 events at the Fukushima Dai-ichi nuclear power plant, the NRC established a senior-level agency task force referred to as the Near-Term Task Force (NTTF). The NTTF conducted a systematic and methodical review of the NRC regulations and processes to determine if the agency should make additional improvements to these programs in light of the events at Fukushima Dai-ichi. As a result of this review, the NTTF developed a comprehensive set of recommendations, documented in SECY-11-0093, Near-Term Report and Recommendations for Agency Actions Following the Events in Japan, dated July 12, 2011 (Ref. 10). As directed in staff requirements memorandum (SRM) for SECY-11-0093, (Ref. 11) the NRC staff reviewed the NTTF recommendations within the context of the NRCs existing regulatory framework and considered the various regulatory vehicles available to the NRC to implement the recommendations. The NRC staff also considered the input obtained from interactions with stakeholders. Documentation of the staffs efforts is contained in SECY-11-0124, Recommended Actions to be Taken without Delay from the Near-Term Task Force Report, dated September 9, 2011 (Ref. 12) and SECY-11-0137, Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned, dated October 3, 2012 (Ref. 13).

After receiving the Commissions direction in SRM-SECY-11-0124 (Ref. 14) and SRM-SECY-11-0137 (Ref. 15), the NRC staff issued a request for information (RFI) (Ref. 16) asking each licensee to assess its current communications system and equipment under conditions of on-site and off-site damage and prolonged loss of all ac power and perform a staffing study to determine the number and qualifications of staff required to fill all necessary positions in response to a multi-unit event on a single site. The NRC staff provided the order and RFI to the Commission in SECY-12-0025 (Ref. 17).

Following receipt of the Commissions direction in SRM-SECY-12-0025 (Ref. 18), the NRC issued the order and RFI on March 12, 2012. The NRC staff also conducted a series of public meetings (Ref. 19) to discuss the implementation guidance for enhanced emergency response capabilities for beyond-design-basis events.

The NRC staff is issuing 10 CFR 50.155 to, among other things, make the requirements in Order EA-12-049 generically applicable. The NRC is also amending the regulations in 10 CFR Part 50, Appendix E to require enhanced on-site emergency response capabilities. This RG provides implementation guidance for a portion of the regulations in 10 CFR 50.155 and Part 50, Appendix E by endorsing, with clarifications, NEI 12-01, 13-06, and 14-01 as acceptable methods for licensees to demonstrate compliance with these regulatory requirements.

External Documents Endorsed in This Guide This RG endorses, in part, the use of one or more codes, standards, or guidance documents developed by external organizations. These codes, standards, and third party guidance documents may contain references to other codes, standards, or third party guidance documents (secondary references).

If a secondary reference has itself been incorporated by reference into NRC regulations as a requirement, then licensees and applicants must comply with that standard as set forth in the regulation. If the secondary reference has been endorsed in an RG as an acceptable approach for meeting an NRC requirement, then the standard constitutes a method acceptable to the NRC staff for meeting that regulatory requirement as described in the specific RG. If the secondary reference has neither been incorporated into NRC regulations nor endorsed in an RG, the secondary reference is neither a legally-binding requirement nor a generic NRC approved acceptable approach for meeting an NRC requirement. However, licensees and applicants may consider and use the information in the secondary reference, if appropriately justified, consistent with current regulatory practice, and consistent with applicable NRC requirements.

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BEING PROVIDED TO SUPPORT THE MEETING WITH ACRS AND NOT TO SOLICIT EXTERNAL STAKEHOLDER FEEDBACK The International Atomic Energy Agency (IAEA) has established a series of technical reports, safety guides and standards constituting a high level of safety for protecting people and the environment.

IAEA guides present international good practices and identify best practices to help users striving to achieve high levels of safety. As part of their response to the events at Fukushima Dai-ichi the IAEA prepared a technical report titled Accident Monitoring Systems for Nuclear Power Plants dated February 2015 (Ref. 20). This RG and the NEI documents endorsed by it contain guidance about accident and emergency response staffing, capabilities, and programs similar to the guidance in the IAEA technical report.

C. STAFF REGULATORY GUIDANCE The NRC staff considers the following NEI technical reports acceptable for use subject to the staff position comments below.

NEI 12-01 Guidelines for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Rev. 0, dated May 2012 The regulations in 10 CFR Part 50, Appendix E, Section VII require a power reactor applicant or licensee to perform a detailed analysis demonstrating sufficient staff is available to response to a beyond-design-basis external event affecting all units on a site. This section also requires a power reactor applicant or licensee to make and describe adequate provisions for at least one on-site and one off-site communications system capable of remaining functional during an extended loss of alternating current (ac) power to include effects of the loss of local communications infrastructure.

NRC Staff Position: NEI 12-01 provides an acceptable method to assess staffing and communication capabilities and needs when responding to a beyond-design-basis event.

NEI 13-06 Enhancement to Emergency Response Capabilities for Beyond Design Basis Accidents and Events, Rev. 0, dated April 2014 The regulations in 10 CFR 50.155(e) require licensees to provide training and qualification of personnel that perform activities in accordance with the strategies and guidelines required by 10 CFR 50.155(b). The regulations in 10 CFR 50.155(f) requires licensees to perform drills or exercises to demonstrate the capability to use the strategies and guidelines required by10 CFR 50.155(b).

1. A licensee should provide the training, drills, and exercises (i.e., performance enhancing experiences) needed to assure that the staff understands their duties and responsibilities when responding to a beyond-design-basis event.

2. The licensee should develop guidance that clearly delineates the command and control structure and identifies the qualifications and training needed for decision makers during emergencies.

3. Licensees at multi-unit sites should establish methodologies and capabilities to perform multi-unit dose assessments during an event involving concurrent radiological releases from multiple on-site sources.

NRC Staff Position: NEI 13-06 provides an acceptable methodology for enhancing the on-site emergency response capabilities for beyond-design-basis events.

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BEING PROVIDED TO SUPPORT THE MEETING WITH ACRS AND NOT TO SOLICIT EXTERNAL STAKEHOLDER FEEDBACK NEI 14-01 Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Rev. 0, dated April 2014 The regulations in 10 CFR 50.155(b), in part, require each applicant and licensee to develop, implement, and maintain an integrated response capability that includes: 1) the beyond-design-basis event mitigation strategies in 10 CFR 50.155(b)(1); 2) extensive damage mitigation guidelines in 10 CFR 50.155(b)(2); and 3) severe accident management guidelines in 10 CFR 50.155(b)(3). The regulations also require, in part, integration of these guideline sets with existing EOPs under 10 CFR 50.155(b)(4) and a supporting command and control structure under 10 CFR 50.155(b)(6).

NEI 14-01 provides guidance for: 1) the integration of guideline sets required by 10 CFR 50.155(b)(1)-(3) with EOPs as required by 10 CFR 50.155(b)(4); 2) SAMGs (required by 10 CFR 50.155(b)(3)); and 3) command and control for beyond design basis events and severe accidents (addressed by 10 CFR 50.155(b)(6)).

NRC Staff Position: NEI 14-01 provides an acceptable method for implementing those elements of an integrated response capability under the above identified portions of 10 CFR 50.155(b) with the following clarifications:

1. NEI 14-01 section 2 provides guidance to licensees intended to result in a set of integrated guidelines (with existing EOPs). The guidance identifies considerations in section 2.4 that provide appropriate elements licensees should consider to achieve compliance with 10 CFR 50.155(b), with regard to integration.

2. NEI 14-01, section 3 provides guidance for the development and implementation of SAMGs. The guidance in NEI 14-01, section 3 regarding the SAMG principles (section 3.2.2) and the considerations for site-specific SAMGs (section 3.2.3) provides an acceptable means for the development and implementation of SAMGs.

3. NEI 14-01 section 4 provides guidance to licensees intended to result in command and control structures capable of directing a response to beyond-design-basis events and severe accidents.

The NRC staff finds the guidance in section 4 acceptable for implementing 10 CFR 50.155(b)(6).

D. IMPLEMENTATION.

The purpose of this section is to provide information on how applicants and licensees1 may use this guide and information regarding the NRCs plans for using this RG. In addition, it describes how the NRC staff complies with the Backfit Rule found in 10 CFR 50.109(a)(1) or any applicable finality provisions in 10 CFR Part 52.

Use by Applicants and Licensees 1 In this section, licensees refers to holders of, and applicants refers to applicants for, the following: (1) licenses for nuclear power plants under 10 CFR Parts 50 and 52; and (2) construction permits for nuclear power plants under 10 CFR Part 50.

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BEING PROVIDED TO SUPPORT THE MEETING WITH ACRS AND NOT TO SOLICIT EXTERNAL STAKEHOLDER FEEDBACK Applicants and licensees may voluntarily2 use the guidance in this document to demonstrate compliance with the underlying NRC regulations. Methods or solutions that differ from those described in this RG may be deemed acceptable if they provide sufficient basis and information for the NRC staff to verify that the proposed alternative demonstrates compliance with the appropriate NRC regulations.

Current licensees may continue to use guidance the NRC found acceptable for complying with the identified requirements as long as their current licensing basis remains unchanged.

Licensees may use the information in this RG for actions that do not require NRC review and approval. Licensees may use the information in this RG or applicable parts to resolve regulatory or inspection issues.

Use by NRC Staff The NRC staff does not intend or approve any imposition or backfitting of the guidance in this RG. The NRC staff does not expect any existing licensee to use or commit to using the guidance in this RG, unless the licensee makes a change to its licensing basis. The NRC staff does not expect or plan to request licensees to voluntarily adopt this RG to resolve a generic regulatory issue. The NRC staff does not expect or plan to initiate NRC regulatory action that would require the use of this RG. Examples of such unplanned NRC regulatory actions include issuance of an order requiring the use of the RG, generic communication, or promulgation of a rule requiring the use of this RG without further backfit consideration.

During regulatory discussions on plant specific operational issues, the staff may discuss with licensees various actions consistent with staff positions in this RG, as one acceptable means of meeting the underlying NRC regulatory requirement. Such discussions would not ordinarily be considered backfitting. However, unless this RG is part of the licensing basis for a facility, the staff may not represent to the licensee that the licensees failure to comply with the positions in this RG constitutes a violation.

If an existing licensee voluntarily seeks a license amendment or change and (1) the NRC staffs consideration of the request involves a regulatory issue directly relevant to this RG and (2) the specific subject matter of this RG is an essential consideration in the staffs determination of the acceptability of the licensees request, then the staff may request that the licensee either follow the guidance in this RG or provide an equivalent alternative process that demonstrates compliance with the underlying NRC regulatory requirements. This is not considered backfitting as defined in 10 CFR 50.109(a)(1) or a violation of any applicable finality provisions in 10 CFR Part 52.

If a licensee believes that the NRC is either using this RG or requesting or requiring the licensee to implement the methods or processes in this RG in a manner inconsistent with the discussion in this Implementation section, then the licensee may file a backfit appeal with the NRC in accordance with the guidance in NUREG-1409, Backfitting Guidelines, (Ref. 21) and the NRC Management Directive 8.4, Management of Facility-Specific Backfitting and Information Collection (Ref. 22).

2 In this section, voluntary and voluntarily means that the licensee is seeking the action of its own accord, without the force of a legally binding requirement or an NRC representation of further licensing or enforcement action.

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BEING PROVIDED TO SUPPORT THE MEETING WITH ACRS AND NOT TO SOLICIT EXTERNAL STAKEHOLDER FEEDBACK REFERENCES3

1. U.S. Code of Federal Regulations (CFR), Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter 1, Title 10, Energy.

2. Nuclear Energy Institute (NEI) technical report NEI 12-01, Guidelines for Assessing Beyond-Design-Basis Accident Response Staffing and Communication Capabilities, Revision 0, dated May 2012, Washington, DC. (ADAMS Accession No. ML12125A412)4

3. Skeen, David L., U.S. Nuclear Regulatory Commission, letter to Susan Perkins-Grew, Nuclear Energy Institute, May 15, 2012, endorsement of NEI 12-01, Revision 0, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, May 2012.

(ADAMS Accession No. ML12131A043)

4. NEI, technical report NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond-Design-Basis Accidents and Events, Revision 0, dated September 2014, Washington, DC. (ADAMS Accession No. ML14269A230)

5. NEI, technical report NEI 14-01, Emergency Response Procedures and Guidelines for Beyond-Design-Basis Events and Severe Accidents, Revision 0, dated September 2014, Washington, D.C. (ADAMS Accession No. ML14049A005)

6. U.S. Nuclear Regulatory Commission (NRC) Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, Washington, DC. (ADAMS Accession No. ML12054A736).

7. NRC, JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events, Revision 0, Issued August 29, 2013, NRC, Washington, DC. (ADAMS Accession No. ML12229A174)

8. NEI, technical report NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, August 21, 2012 (ADAMS Accession No. ML12242A378)

9. NRC, Draft Regulatory Guide (DG)-1301 (proposed RG 1.226) Flexible Mitigation Strategies for Beyond-Design-Basis Events, Washington, DC.

10. NRC, SECY-11-0093, Recommendations for Enhancing Reactor Safety in the 21st Century, the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated July 12, 2011, Washington, DC. (ADAMS Accession No. ML11186A950) 3 Publicly available documents from the U.S. Nuclear Regulatory Commission (NRC) are available electronically through the NRC Library on the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/. The documents can also be viewed on-line for free or printed for a fee in the NRCs Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD; the mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415 3548; and e-mail pdr.resource@nrc.gov.

4 Publications from the Nuclear Energy Institute (NEI) are available at their Web site: http://www.nei.org/ or by contacting the headquarters at Nuclear Energy Institute, 1201 F Street NW, Ste. 1100, Washington DC 20004-1218, Phone: 202-739-8000, Fax 202-785-4019.

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11. NRC, SMR-SECY-11-0093, Staff Requirements - SECY-11-0093 - Near-Term Report and Recommendations for Agency Actions Following the Events in Japan, dated August 19, 2011, Washington, D.C. (ADAMS Accession No. ML112310021)

12. NRC, SECY-11-0124, Recommended Actions to be Taken without Delay from the Near-Term Task Force Report, dated September 9, 2011, Washington, DC. (ADAMS Accession No. ML11245A158)

13. NRC, SECY-11-0137, Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned, dated October 3, 2011, Washington, DC. (ADAMS Accession No. ML11272A111)

14. NRC, SRM-SECY-11-0124, Staff Requirements - SECY-11-0124 - Recommended Actions to be Take without Delay from the Near-Term Task Force Report, dated October 18, 2011, Washington, DC. (ADAMS Accession No. ML112911571)

15. NRC, SRM-SECY-11-0137, Staff Requirements - SECY-11-0137 - Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned, dated December 15, 2011, Washington, DC. (ADAMS Accession No. ML113490055)

16. NRC, Request for Information (RFI) pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights From the Fukushima Dai-Ichi Accident, March 12, 2012. (ML12053A340)

17. NRC, SECY-12-0025, Proposed Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami, dated February 17, 2012, Washington, D.C. (ADAMS Accession No. ML12039A111)

18. NRC, SMR-SECY-12-0025, Staff Requirements - SECY-12-0025 - Proposed Orders and Requests For Information in Response to Lessons Learned From Japans March 11, 2011, Great Tohoku Earthquake and Tsunami, dated March 9, 2012, (ADAMS Accession No. ML120690A347)

19. NRC, Public Meetings, Review of NRC Order EA-12-051, Washington, DC

--- December 12, 2011, (ADAMS Accession No. ML11343A050)

--- January 19, 2012, (ADAMS Accession No. ML11361A036)

--- February 7, 2012, (ADAMS Accession No. ML12025A046)

--- March 5, 2012, (ADAMS Accession No. ML12082A006)

--- January 3, 2013, (ADAMS Accession No. (ML12354A483)

20. International Atomic Energy Agency (IAEA), IAEA Technical Report No. NP-T-3.6, Accident Monitoring Systems for Nuclear Power Plants, dated February 2015, IAEA, Vienna, Austria5

21. NRC, NUREG 1409, "Backfitting Guidelines," July 1990, Washington, DC. (ADAMS Accession No. ML032230247) 5 Copies of International Atomic Energy Agency (IAEA) documents may be obtained through their Web site:

WWW.IAEA.Org/ or by writing the International Atomic Energy Agency P.O. Box 100 Wagramer Strasse 5, A-1400 Vienna, Austria. Telephone (+431) 2600-0, Fax (+431) 2600-7, or E-Mail at Official.Mail@IAEA.Org DG-1319, Page 9 BEING PROVIDED TO SUPPORT THE MEETING WITH ACRS AND NOT TO SOLICIT EXTERNAL STAKEHOLDER FEEDBACK

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22. NRC, Management Directive 8.4, "Management of Facility specific Backfitting and Information Collection," Washington, DC.

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