ML16068A252

Mitigation Beyond-Design-Basis Events Proposed Rule Comment (9) - NEI (Annotated) Original Submission Dated February 9, 2016 (ML16041A445)

ML16068A252
Person / Time
Site:	Nuclear Energy Institute
Issue date:	07/30/2019
From:	Jeffrey Riley Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
Reed T
References
80 FR 70609, NRC-2014-0240, RIN 3150-AJ49
Download: ML16068A252 (256)

Text

Page 1 of 2 10 CFR Parts 50 and 52 80FR70609 9 As of: 2/10/16 1:35 PM Received: February 09, 2016 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 1k0-8nv8-izsv Comments Due: February 11, 2016 Submission Type: Web Docket: NRC-2014-0240 Mitigation Strategies for Beyond Design Basis Events Comment On: NRC-2014-0240-0003 Mitigation of Beyond-Design-Basis Events Document: NRC-2014-0240-DRAFT-0015 Comment on FR Doc # 2015-28589 Submitter Information Name: Jim Riley General Comment See attached file(s)

Attachments 02-09-16_NEI_Industry Comments on Draft Mitigating Beyond Design Basis Events Rulemaking Package 02-09-16_NEI_Industry Comments on Draft Mitigating Beyond Design Basis Events Rulemaking Package_Attachment 1 02-09-16_NEI_Industry Comments on Draft Mitigating Beyond Design Basis Events Rulemaking Package_Attachment 2 02-09-16_NEI_Industry Comments on Draft Mitigating Beyond Design Basis Events Rulemaking Package_Attachment 3 02-09-16_NEI_Industry Comments on Draft Mitigating Beyond Design Basis Events Rulemaking Package_Attachment 4 02-09-16_NEI_Industry Comments on Draft Mitigating Beyond Design Basis Events Rulemaking Package_Attachment 5 https://www.fdms.gov/fdms/getcontent?objectId=0900006481e5ec0a&format=xml&showorig=false 02/10/2016

Page 2 of 2 02-09-16_NEI_Industry Comments on Draft Mitigating Beyond Design Basis Events Rulemaking Package_Attachment 6 2-9-16 _NEI_Industry Comments on Draft Mitigating Beyond Design Basis Events Rulemaking Package_Attachment 7 https://www.fdms.gov/fdms/getcontent?objectId=0900006481e5ec0a&format=xml&showorig=false 02/10/2016

JAMES H. RILEY Sr. Technical Advisor 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8130 jhr@nei.org nei.org February 9, 2016 Secretary, US Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Rulemakings and Adjudications Staff

Subject:

Industry Comments on Draft Mitigation of Beyond Design Basis Events Rulemaking Package (Docket ID NRC-2014-0240)

Project Number: 689 On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) is providing comments on the NRC draft Mitigation of Beyond Design Basis Events Rulemaking Package (Docket ID NRC-2014-0240).

We appreciate the opportunity to comment on this draft rulemaking package which incorporates most of the important actions that the industry and the NRC have taken in response to the 2011 accident at the Fukushima Dai-ichi Nuclear Power Plant. NEI supports issuance of the proposed rule and is largely in agreement with the requirements it contains. We do have some suggestions on modified rule language, comments on some parts of the rulemaking package, and responses to the questions it contains; these details are included in the attachments to this letter. We would like to emphasize several of our comments as described below.

• [Implementation Time: The proposed rule would require that each holder of an operating license comply with its provisions no later than 2 years following the effective date of the rule. This timeframe is not adequate. The degree to which the reevaluated seismic or flooding hazard(s) may impact the implementation of mitigating strategies varies widely across the operating reactor fleet, and the effort required to address them varies widely too. In addition, the various evaluations necessary to prepare for any necessary changes are in different stages of completion. As a result, the industry recommends that the proposed rule allow licensees to submit site specific schedules for achieving full compliance with the rule. Our response to the question on Equipment Protection Implementation Deadline in Section VI of the rulemaking package provides our proposed rule language to address this concern (Attachment 3). NEI CL-1]

• [Application of Other Change Control Processes: Section 50.155(f) should explicitly and clearly address the application of Other Change Control Processes given that facility changes can impact multiple aspects of the plant having different applicable requirements, and be subject to different change control requirements. The rule and associated guidance should consistently differentiate between design basis conditions and beyond-design-basis conditions, i.e., clarify that existing change control

Secretary, US NRC February 9, 2016 Page 2 processes such as § 50.59, § 50.54(p), § 50.54(q) and fire protection change controls are not applied to beyond-design-basis requirements. Our response to the Change Control questions in Section VI of the rulemaking package propose changes to the rule to address this concern (Attachment 3). NEI CL-2]

• [Methodology for Addressing the Reevaluated Hazards: The need for a licensees strategies and guidelines to be capable of execution in the context of the reevaluated flooding and seismic hazards should be addressed in § 50.155(b)(1) rather than § 50.155(c)(2) for several reasons.

1) We believe that the intent is to mitigate the effects of the reevaluated hazards in a manner similar to the strategies that have been developed by the industry for FLEX. The inclusion of the reevaluated hazards requirement into § 50.155(c)(2)(i) applies reasonable protection to all the equipment covered by the proposed rule (both plant equipment and FLEX equipment), however, reasonable protection should only apply to FLEX equipment.

2) Including the reevaluated hazard requirement in § 50.155(c)(2)(i) only applies the reevaluated hazard requirement to equipment, it does not achieve the intended objective of applying the reevaluated flood and seismic hazards to mitigating strategies in general. NEI CL-3]

[Furthermore, in addressing mitigating strategies for the reevaluated hazards, section 50.155(b)(1) should allow further flexibility in the licensees strategies and guidelines by:

1) establishing an alternative means of compliance that does not include the surrogate conditions of an extended loss of all alternating current power and loss of normal access to the ultimate heat sink, and

2) providing different success criteria for targeted or scenario-specific mitigating strategies (i.e.,

requiring core cooling and spent fuel pool cooling but not the containment capability to be maintained). NEI CL-4]

Finally, [the rule should also allow for utilization of risk insights or other approaches to demonstrate reasonable protection for mitigation of beyond design basis external events. NEI CL-5]

Our response to the Methodology for Addressing the Reevaluated Hazard question in Section VI of the rulemaking package proposes changes to the rule to address these concerns (Attachment 3).

• Use of Adequate Protection: [The proposed rule and regulatory analysis properly recognizes that the new requirement to monitor and assess multiple source terms constitutes a backfit, but rather than perform a systematic and documented analysis demonstrating that this new requirement will result in a cost-justified substantial increase in safety, the NRC has invoked backfit exception in 10 C.F.R.

§ 50.109(a)(4)(ii) for regulatory actions that are necessary to ensure that the facility provides adequate protection to the health and safety of the public. The draft regulatory analysis fails to overcome the presumption that current regulations and orders currently ensure adequate protection because it identifies no significant safety issue that is going unaddressed. On top of the extensive required actions that licensees are already taking, the industry is voluntarily implementing multiple source term dose assessment capabilities to assist in the mitigation of remote, yet potentially serious

Secretary, US NRC February 9, 2016 Page 3 beyond-design-basis external events. Rather than place these actions in their proper context, the draft regulatory analysis offers generic statements about meeting existing emergency preparedness regulatory objectives. Accordingly, the NRC has not justified using the adequate protection exception and should not impose this new requirement absent an analysis demonstrating that it will result in a cost-justified substantial increase in safety. We provide additional information relative to this concern in response to Question 5 in Section XI of the rulemaking package (Attachment 3). NEI CL-6]

• Spent Fuel Pool Instrumentation (SFPI): [The rule language, regulatory guides and related supporting information must keep the requirements for SFPI separate and distinct from the requirements for mitigating strategies. The requirement for SFPI was promulgated by NRC Order EA-12-051, while the requirement for mitigating strategies was promulgated by NRC Order EA-12-049. While the two Orders were in response to lessons-learned from the Fukushima accident, they are distinctly different in underlying purpose and character. EA-12-049 requires guidance and strategies to maintain core and spent fuel cooling and the containment function in the face of certain events, and requires the ability to take action under the circumstances specified in the Order. EA-12-051, requires the installation of reliable spent fuel pool instrumentation to provide decision makers with information about the amount of water in the spent fuel such that resources can be allocated. EA-12-051 does not require the ability to take action; it only provides information. The fact that industry Flex program implemented in response to EA-12-49 uses this information to indicate the need to add water to the pools does not change the underlying SFPI requirement and does not justify including SFPI as part of mitigating strategies as appears to have been done in the draft of proposed 10CFR50.155(c)(4). We provide suggested changes to the rule language to address this concern in our detailed comments (Attachment 1). NEI CL-7]

We look forward to engaging the Staff to discuss or clarify any of our comments. If you have questions or require additional information, please contact me at 202-739-8137; jhr@nei.org.

Sincerely, James H. Riley Attachments:

1. MBDBE Rulemaking Package Comment Table

2. Comment Table Text Changes

3. Responses to Questions in Sections VI and XI

4. NEI 13-06 Revision 1

5. NEI 13-06 Revision 1 / Revision 0 Comparison

6. NEI 14-01 Revision 1

Secretary, US NRC February 9, 2016 Page 4

7. NEI 14-01 Revision 1 / Revision 0 Comparison c: Fukushima Points of Contact Administrative Points of Contact

Attachment 1: MBDBE Rulemaking Comment Table

[The NRC reviewed this table and agreed with NEIs identification of individual comments. These comments are identified as NEI TC-# in the NRCs comment response document. The numbering corresponds to the same comment number in the table below. Each comment includes the text, the concern, and the suggestion for change. The table is not marked-up to reflect this.]

Comment Tech Area Document Page Text Concern Suggestion for Change 1 FLEX DG-1301 1 The last sentence of the Presumably this is Industry guidance has second paragraph states, referring to the been added in Appendix H Additionally, this RG provides guidance for of NEI 12-06 so this guidance in areas that are not performing a sentence should be covered in NEI 12-06, for mitigating strategies deleted.

meeting the regulations in 10 assessment for the CFR 50.155. reevaluated seismic hazard.

1

2 General DG-1301 2 Related Guidance, states: Clarification is needed Describe the process for JLD-ISG-2012-01 is regarding the rescinding Orders EA superseded and replaced by following aspects of 049 and EA-12-051 this RG. However the stated the transition from following the issuance of purpose of JLD-ISG-2012-01 is Orders EA-12-049 the final rule to provide an acceptable and EA-12-051 to 10 approach for compliance with CFR 50.155: Some EA-12-049, and the stated licensees have purpose of DG-1301 is to already achieved provide an acceptable compliance with approach for compliance with Orders EA-12-049 10 CFR 50.155. It is not clear and EA-12-051 in how DG-1301 can supersede accordance with JLD-JLD-ISG-2012-01 when JLD- ISG-2012-01 Rev. 0, ISG-2012-01 has a different and JLD-ISG-2012-03 purpose than DG-1301. Rev. 0, and their associated NEI guidance documents.

It is recognized that 10 CFR 50.155 and 2

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change the R.G.s associated with DG-1301, and DG-1317 may specify actions that are additional to, and/or different from, the actions required by the ISGs to achieve to compliance with the NRC Orders. It is also recognized that 10 CFR 50.155 and the associated R.G.s may specify actions that are less restrictive than the corresponding actions needed for compliance with the orders. It is not clear if and when compliance with Orders EA-12-049 and EA-12-051 will no longer be required following issuance of 10 CFR 50.155 and the associated R.G.s.

3

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change 3 FLEX DG-1301 4 The word determine in the second sentence of the first paragraph should be determined.

4 FLEX DG-1301 4 The reference to Revision 1A The reference is Suggest rewording the of NEI 12-06 in the last referring to NEI 12- sentence as follows:

sentence of the fourth 06 in general not to a paragraph should be removed. specific revision. The strategies and guidance described in NEI 12-06 expand on those developed.

5 FLEX DG-1301 5 Background , Last paragraph In Revision 2 of NEI Modify the language to use 12-06 the description the current terminology.

of Phase 2 was changed to Augment or transition from plant equipment to on-site FLEX equipment and consumables to maintain or restore key functions. The description of Phase 2 in the Background of the DG retains the previous language for Phase 2.

4

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change 6 FLEX DG-1301 7 Staff Position a) Initial and Staff Position a) and The language in § boundary conditions do not 1.2 are not needed 50.155(b)(1) should be accurately reflect a loss of all since the rule changed to eliminate the ac power condition. addresses an word all from extended extended loss of ac loss of ac power in order Staff Position 1.2 power as opposed to maintain consistent Contingencies for Loss of All a loss of all ac power. terminology.

Alternating Current Power Eliminate Staff Position a) and Section 1.2.

The resolution of the same comment for JLD-ISG-2012-01, Rev. 1 is not necessary since the rule address mitigation of an extended loss of ac power as opposed to a loss of all ac power.

7 FLEX DG-1301 7 Staff Position b) .However, It is not clear what is The change made in maintenance of the guidance being clarified that is response to this comment and strategies requires that not already in JLD-ISG-2012-01, Rev. 1 the estimate of capability be addressed by Section is appropriate.

kept current to reflect plant 11.8 Configuration conditions following facility Control of NEI 12-06.

changes such as modification This section or equipment outages. addresses assessing 5

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change the impact of facility changes to ensure FLEX strategies are not adversely impacted.

Additionally, the guidance addresses the unavailability of equipment. The industry does not believe this clarification is necessary, but rather, 6

that it creates a lack of clarity in that it implies something in addition to Section 11.8 is needed.

8 FLEX DG-1301 8 Staff Position d).1 The use of It does not appear The change made in Level C validation methods that a clarification is response to this comment should be limited to those needed as Level C in JLD-ISG-2012-01, Rev. 1 tasks, manual actions and validation is limited in is appropriate.

decisions that do not have a the guidance to those time constraint for the tasks, manual actions strategy to be successful. and decisions that do not have a time constraint for the strategy to be 7

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change successful.

Clarification has been added to the description of Level C validation in Section E.5.1.2 of Appendix E to NEI 12-06.

9 FLEX DG-1301 8 Staff Position d).2 Level B vs Footnote 17 on page The change made in Level A validation 97 of NEI 12-06, response to this comment Revision 1A in JLD-ISG-2012-01, Rev. 1 erroneously is appropriate.

establishes the basis of using a Level B 8

validation for time-sensitive actions started between 6 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> solely on the availability of additional personnel.

This is not the case and, as such, the footnote has been deleted. Validation is performed based on the nature of the task to determine if it can be performed within the time constraint 9

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change with reasonable confidence. If the validation did not provide reasonable confidence, then applying additional resources to the task is one option that can be considered to establish reasonable confidence if additional personnel would effectively 1

improve task performance.

With this change, the industry does not believe the clarification is needed.

10 FLEX DG-1301 8 Staff Position d).2 Integrated The last sentence of The change made in Reviews the staff position response to this comment provides a in JLD-ISG-2012-01, Rev. 1 clarification that is appropriate.

would imply the guidance in Appendix E for performing the integrated review is 1

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change not sufficient. The guidance as written does address adjusting procedures and revalidating tasks if there is not reasonable confidence that the task, manual action or decision can be completed within the time constraint. The industry does not see 1

the need for clarification and the clarification only creates a lack of clarity as it implies that something in addition to the guidance is needed but does not provide clarifying guidance.

11 General DG-1301 8 Staff position d. required Typographical error. Should be NEI 12-06.

human actions. NEI 12006, Rev. 1A, Appendix E neither proposes nor is endorsed as a method to assess whether 1

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change required human actions are reliable.

12 FLEX DG-1301 9 Sections 1.1.1.1, 1.1.1.2 and The language in The language in these 1.1.1.3 these sections refers sections should refer to to installed and plant equipment and portable equipment. FLEX equipment vs installed equipment and portable equipment, respectively.

1

13 FLEX DG-1301 11 Section 3 first sentence In accordance with the changes proposed to § 50.155(c) and § 50.155(b)(1) in Attachment 3.in response to the question on Methodology for Addressing Reevaluated Hazards, the word reasonably should be deleted from the first sentence.

14 FLEX DG-1301 13 Programmatic Controls for Unavailability is Unavailability, Staff Position: addressed in Section Section 11.5.3 of NEI 12-06, 11.5.4 not 11.5.3.

1

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change Revision 1A..

15 FLEX DG-1301 13 Equipment Maintenance, In accordance with Section 4 first sentence Attachment 3 Question on Equipment Requirements, the word adequate should be eliminated.

16 FLEX DG-1301 13 Treatment of Reevaluated In accordance with Hazards , Section 6 first the changes sentence proposed to § 50.155(c) and § 50.155(b)(1) in Attachment 3 in response to the question on Methodology for Addressing Reevaluated Hazards, the first paragraph of Section 6 should be revised accordingly.

10

17 FLEX DG-1301 14 Section 6.1 NEI 12-06 revision 2 The Regulatory Guide and was endorsed by JLD- ISG will need to reflect the ISG-2012-01 revision a revision to NEI 12-06 1 which has now when Path 5 is been issued with a 11

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change pending effective incorporated.

date. The industry intends to further revise NEI 12-06 to address a Path 5 for plants performing seismic PRAs and intends to submit revision 3 for endorsement. This will necessitate a further revision to NRC guidance.

12

18 FLEX DG-1301 14 Section 6.1- The ISG provides Revision 2 to NEI 12- The change made in the guidance for performing 06 includes Appendix response to this comment the mitigating strategy H which provides in JLD-ISG-2012-01, Rev. 1 assessment for the guidance for is appropriate.

reevaluated seismic hazard. performing the mitigating strategies assessments for the reevaluated seismic hazard. The guidance in Appendix H has been endorsed in ISG-JLD-2012-01 Rev. 1 and should similarly be endorsed in the Regulatory 13

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change Guide, which would replace the guidance provided in Section 6.1.

19 FLEX DG-1301 15 Section 6.1.2.b Second The second sentence The change made in sentence addresses the response to this comment flooding mechanism in JLD-ISG-2012-01, Rev. 1 when it should is appropriate.

address seismic.

14

20 FLEX DG-1301 20 Sections 6.2.1, 6.2.2, and See the changes In Section 6.2.1 in JLD-6.2.3- Reference to proposed to § ISG-2012-01, Rev. 1, the

§ 50.155(c)(2)(i) 50.155(c) and § wording provide 50.155(b)(1) and in reasonable protection the response to from should be replaced Methodology for with mitigate.

Addressing Reevaluated Hazards in Attachment 3, These paragraphs should be revised accordingly.

Also in Section 6.2.1 in JLD-ISG-2012-01, Rev. 1 the wording provide reasonable protection from was used when it should 15

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change say mitigate.

21 FLEX DG-1301 20 6.2.2 and 6.2.3 Staff Positions For the AMS and The language in the same The staff positions state that THMS an ELAP does sections in JLD-ISG-2012-strategy developed must not need to be 01, Rev 1 would resolve provide a capability to considered to occur this comment.

mitigate the BDBEE by unless it is caused by mitigating or preventing an the reevaluated ELAP that would occur as a hazard. The staff result of the BDBEE through position appears to exhaustion of fuel for be requiring the operating emergency power mitigation or sources prevention of an ELAP condition even though it is not necessarily assumed to occur.

16

22 General DG-1301 2 JLD-ISG-2012-01, JLD-ISG-2012-01, Compliance with Order EA- Rev 1 is published.12-049, Order Modifying These citations Licenses with Regard to should be updated Requirements for Mitigation when the ISG revision Strategies for Beyond-Design- is issued.

Basis External Events, Rev. 0 Also, Reference 4 on page 23 still cites rev 0 of JLD-ISG-2012-01 17

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change 23 General DG-1317 2 Related Guidance, states: Clarification is needed Describe the process for JLD-ISG-2012-03 is regarding the rescinding Orders EA superseded and replaced by following aspects of 049 and EA-12-051 this RG. However the stated the transition from following the issuance of purpose of JLD-ISG-2012-03 is Orders EA-12-049 the final rule to provide an acceptable and EA-12-051 to 10 approach for compliance with CFR 50.155: Some EA-12-051, and the stated licensees have purpose of DG-1317 is to already achieved provide an acceptable compliance with approach for compliance with Orders EA-12-049 10 CFR 50.155. It is not clear and EA-12-051 in how DG-1317 can supersede accordance with JLD-JLD-ISG-2012-03 when JLD- ISG-2012-01 Rev. 0, ISG-2012-03 has a different and JLD-ISG-2012-03 purpose than DG-1317. Rev. 0, and their associated NEI Related Guidance, also guidance documents.

states: Draft regulatory guide It is recognized that (DG)-1301 (proposed RG 10 CFR 50.155 and 1.226), Flexible Mitigation the R.G.s associated Strategies for Beyond-Design- with DG-1301, and Basis Events (Ref. 7) is DG-1317 may specify planned to supersede and actions that are replace JLD-ISG-2012-01. As additional to, and/or noted in the first bulleted different from, the paragraph above, it is not actions required by clear how DG-1301 can the JLDs to achieve supersede JLD-ISG-2012-01 to compliance with 18

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change when JLD-ISG-2012-01 has a the NRC Orders. It is different purpose than DG- also recognized that 1301. 10 CFR 50.155 and the associated R.G.s may specify actions that are less restrictive than the corresponding actions needed for compliance with the orders. It is not clear 19

if and when compliance with Orders EA-12-049 and EA-12-051 will no longer be required following issuance of 10 CFR 50.155 and the associated R.G.s.

24 SFPI DG-1317 3 The wide-range spent fuel Confusion created by The wide-range spent fuel pool level instrumentation referring to order not pool level instrumentation required by Order EA-12-051 rule required by 10CFR50.155(c)(40 (originally required by Order EA-12-051) 25 SFPI DG-1317 4 These regulations require that These regulations require licensees install reliable means that licensees install 20

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change of remotely monitoring wide- reliable means of remotely range SFP levels to support monitoring wide-range SFP effective prioritization of event levels to support the mitigation and recovery mitigation strategies required by 10CFR50.155(b)(1) and effective prioritization of event mitigation and recovery 26 SFPI DG-1317 6 This exception is needed to designed as hand- This exception is needed 21

strengthen the guidance in held devices or to strengthen the guidance NEI 12-02, Rev. 1 by similar rugged in NEI 12-02, Rev. 1 by recommending that portable components. Needs recommending that instrument channel further definition. portable instrument components should be The analogy with channel components designed as hand-held devices commercially should be designed as or similar rugged components. available hand-held devices (e.g.,

smartphones was commercially available used during several smartphones) or similar meetings with NRC rugged components.

staff in 2012 during development of NEI 12-02.

27 FLEX FRN 70611 Section: Supplementary The changes being Suggest the following Information: Executive made to the wording:

Summary, C. Costs and mitigation strategies Benefits: to address the Although the draft However, this regulatory information from regulatory analysis did not analysis does not estimate the the reevaluated estimate the impacts impacts that may occur as a flooding and seismic that may occur as a result of licensees needing to hazards is not for result of licensees make changes to mitigation the purpose of needing to make strategies including potential reasonably changes to mitigation plant modifications as a result protecting the FLEX strategies including of the need to address equipment but is for potential plant to the purpose of mitigation strategies ensuring that the including potential 22

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change the seismic and flooding reevaluated hazards plant modifications as a reevaluated hazards for can be mitigated. result of the need to reasonable protection of Furthermore, address the seismic and the FLEX equipment. reasonably protecting flooding reevaluated information. the FLEX equipment hazards, the NRC is not the only requested information acceptable method of on this issue and these addressing the costs are now reflected in hazard. the final regulatory analysis.

28 FLEX FRN 70615 Section IV.A.1: In making the The changes being Suggest the following SFPI requirements of Order EA made to the wording:

049 generically-applicable, this mitigation strategies In making the requirements of proposed rule would also to address the Order EA- 12-049 generically-consider the reevaluated information from the applicable, this rule would hazard information developed reevaluated flooding also require that licensees in response to the March 12, and seismic hazards consider the reevaluated 23

2012, NRC letter issued under is not for the purpose hazard information

§ 50.54(f) as part of providing of reasonably developed in response to reasonable protection for protecting the FLEX the March 12, 2012, NRC mitigation strategies equipment is not the letter issued under § equipment against external only acceptable 50.54(f) in development of flooding or seismic hazards. method of addressing the mitigation strategies.

the hazard.

29 General FRN 70617 The discussion on SAMG This section should Add this information (or Implementation concludes be revised to state similar) to the SAMG with, The Commission notes that the strengthened Implementation section -

that the industry indicated it voluntary industry The NEI Nuclear Strategic would strengthen its voluntary initiative was Issues Advisory Committee initiative for SAMGs in its approved by the NEI (NSIAC) approved a letter dated May 11, 2015. NSIAC on October 15, strengthened voluntary 2015, and will be initiative for SAMGs on implemented per site- October 15, 2015. This specific initiative requires timely commitments. Refer updates of site-specific to NEI letter, SAMGs based on revisions Pietrangelo to to Owners Group generic Johnson, dated severe accident technical October 26, 2015. guidelines. In addition, SAMGs will be considered 24

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change within plant configuration management processes, integrated with other emergency response guideline sets and symptom-based EOPs, and validated. Each licensee has sent a letter to the NRC docketing site-specific commitments related to these actions.

25

30 Proc Integ FRN 70617 Section IV.B Scope of It is not clear what The NRC should clarify that Procedure and Guideline would be required by it is not expanding the Integration this expansion of the requirements currently set term EDMGs. Per forth in § 50.54(hh)(2).

2. EDMGs the rule language the EDMGs must address The NRC proposes to expand firefighting, the scope of the generic term operations to mitigate EDMGs to include all of the fuel damage, and strategies and guidelines used actions to minimize to implement § 50.54(hh)(2).

radiological release.

31 Applicability FRN 70620 Section IV.D Applicability While explained well In the final rule, in the supplementary § 50.155(a)(3) should be However, the resulting rule information, clarified as follows:

was written to remove the § 50.155(a)(3) can be EDMG requirements once the clarified to address (3)(i) After the NRC has certifications of permanent docketed the certifications 26

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change cessation of operations and the applicability of of permanent cessation of removal of fuel from the plants undergoing operations and permanent reactor vessel were submitted decommissioning. removal of fuel from the rather than upon removal of reactor vessel described in fuel from the SFP. The NRC The proposed § 50.82(a)(1) or § proposes to correct this error changes to paragraph 52.110(a) of this chapter, from the 2009 final rule in this (3)(i) eliminates the licensee shall comply proposed rule as explained in unnecessary with the following the EDMGs portion of this language and clarifies provisions until all section. that § 50.155 applies irradiated fuel has been until all irradiated fuel permanently removed from has been removed the spent fuel pool(s):

from the spent fuel pool(s). (A) If the reactor design employs secondary Paragraphs (3)(i)(A) containment as a fission and (B) are added to product barrier for the clarify when the spent fuel pool source requirements of § term, then the licensee 50.155(b)-(e) shall comply with the associated with requirements of § maintaining and 50.155(b) through (e) restoring secondary associated with maintaining containment or restoring secondary capabilities would be containment capabilities, applicable to plants and spent fuel pool cooling undergoing capabilities, except that decommissioning. such licensees need not The Supplementary comply with § 20

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change Information published 50.155(c)(4); or with the proposed rule states: This (B) If the reactor design proposed rule would does not employ secondary require secondary containment as a fission containment for product barrier for the reactor designs that spent fuel pool source employ this feature term, then the licensee as a fission product shall comply with the barrier for the spent requirements of § fuel pool source 50.155(b) through (e) term. See pg. associated with spent fuel 70,619, Col. II. pool cooling capabilities, Thus, use secondary except that such licensees containment as a need not comply with § fission product barrier 50.155(c)(4).

for the spent fuel (ii) Holders of operating pool source term was licenses or combined used to define when licenses for which the NRC the proposed has docketed the requirements certifications described in § associated with 50.82(a)(1) or § 52.110(a) maintaining and of this chapter need not restoring secondary meet the requirements of containment this section except for capabilities would be paragraph (b)(2) of this applicable to plants section once the decay undergoing heat of the fuel in the 21

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change decommissioning. spent fuel pool can be removed solely by heating Paragraph (3)(iv) was and boiling of water within added to clarify that the spent fuel pool and the the requirements of § boil-off period provides 50.155 do not apply sufficient time for the once the certifications licensee to obtain off-site of permanent resources to sustain the cessation of spent fuel pool cooling operations and function indefinitely, as permanent removal demonstrated by an of fuel from the analysis performed and reactor vessel have retained by the licensee.

been docketed and all irradiated fuel is (iii) Dominion Nuclear permanently removed Connecticut, Inc. (Millstone from the spent fuel Power Station Unit 1) is not pool(s). subject to the requirements of this section.

Under no circumstances would (iv) Holders of operating

§50.155(c)4 remain licenses or combined in effect once all licenses for which the NRC spent fuel in the pool has docketed the was removed from certifications of permanent the reactor vessel five cessation of operations and or more years earlier. permanent removal of fuel from the reactor vessel described in § 50.82(a)(1) 22

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change or § 52.110(a) are not subject to the requirements of this section once all irradiated fuel has been permanently removed from the spent fuel pool(s).

(4) §50.155(c)(4) is not applicable if the spent fuel pool contains no fuel used in a reactor vessel for power generation within the past five years or the conditions in

§50.155(a)(3)(i),(ii),(iii),(iv) are met, whichever comes sooner.

32 General FRN 70621 First paragraph, fifth sentence Revise this sentence For example, functional

- For example, functional to better clarify the integration of the integration of the strategies, expectations for strategies, guidelines and guidelines and procedures procedure and procedures would ensure would ensure that transition guideline integration. that transition points are points are explicitly identified Given the unbounded explicitly identified and and conflicts between nature of BDB event readily apparent conflicts strategies are eliminated to sequences, there between strategies are the extent practical. should be some eliminated to the extent reasonable limit on practicable.

the expected work 23

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change directed at eliminating conflicts. Replace practical with practicable to better characterize the scope of effort (i.e.,

feasible, or able to be done or put into practice successfully).

33 FLEX FRN 70622 Section IV.D Integrated The wording of this Revise the statements to Response Capability section and others clarify the explanation.

can easily lead to the Suggested wording:

Specifically, this damage conclusion that the Nevertheless, in In this state was implemented mitigating strategies proposed rule the NRC is through the assumption of the implemented by the requiring that the ELAP to the onsite emergency industry did not strategies and guidelines ac buses, but did allow for ac properly consider a be capable of power from the inverters to be loss of all ac power in implementation during an assumed available in order to that the assumptions ELAP with contingencies to establish event sequence and and initial conditions address actions during a the associated times for when allowed for the loss of all ac power.

mitigation actions would be availability of ac assumed to be required. To power from batteries The language in § address the Order EA-12-049 through inverters. 50.155(b)(1) should be requirement for an actual loss Even though the changed to eliminate the of all ac power, including ac paragraph in question word all from extended power from the batteries expressly states there loss of ac power in order 24

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change (through inverters), is no intent to either maintain consistent contingencies are included in relax or impose new terminology.

the mitigation strategies to requirements, the enable actions to be taken overall message of under those the paragraph is that circumstances..Nevertheless, a loss of all ac power in this proposed rule the NRC includes the loss of ac is requiring that the strategies power from batteries and guidelines be capable of through inverters.

implementation during a loss This is inconsistent of all ac power. with the definition of ELAP from the NRC-The paragraph on page 70623 endorsed industry in this same section that starts guidance in NEI 12-with the principal regulatory 06 which defines an objective of § 50.63 was.. ELAP as a loss of off-also states that an ELAP is a site power, loss of all ac power (including emergency diesel ac from inverters) which generators and any similarly is not consistent with alternate ac source the approved and but not the loss of ac implemented definition of an power from buses fed ELAP. by station batteries through inverters. To even infer anything different from this definition will create the potential for improper 25

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change interpretation of the required capabilities by future inspectors.

The last sentence of the paragraph clearly implies that the rule is requiring something different than what was implemented under the Order.

The mitigating strategies do provide contingencies for the loss of ac power from inverters but those contingencies are not the same as assuming a loss of ac power from inverters at the start of the event.

34 Editorial FRN 70623 Section IV.D Integrated The apostrophe after Response Capability containment should be a comma.

The paragraph that starts with The proposed mitigation strategies requirements are 26

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change both performance-based and functionally-based. has a sentence in it that says, Maintaining or restoring three key safety functions (core cooling, containment and spent fuel pool cooling).

35 FLEX FRN 70623 Section IV.D Integrated The paragraph The NRC should clarify that Response Capability implies that the the timeline for the spent timelines for strategy fuel pool strategies for the The paragraph that starts with deployment for spent at-power case may assume The mitigation strategies and fuel pool cooling and a heat load that is less than guidelines implemented under core cooling both the full core offload heat NRC Order EA-12-049. must assume the load.

concludes with, The NRC maximum heat load considers the development of simultaneously. This timelines for the proposed is not what the mitigating strategies using the guidance requires.

maximum heat load for either The timeline for the the reactor core or the spent spent fuel pool fuel pool to be appropriate. strategy is not While establishing the required to use the capability to mitigate the maximum heat load maximum heat load for both in the spent fuel pool simultaneously would be for the at power compliant with the proposed condition. NEI 12-06 requirement, it would not be in Section 3.2.2.14 necessary. states, The sizing of 27

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change FLEX equipment used to cool the SFP should be based on the maximum design basis heat load for the site. For the purposes of determining the response time for the SFP strategies when fuel is in the reactor vessel, the rate of inventory loss of the SFP should be calculated based on the worst case conditions for SFP heat load assuming the plant is at power. (Emphasis added)

The timeline for the spent fuel pool strategies for the at-power case may assume a heat load that is less than the full core offload heat 28

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change load.

36 EP FRN 70625 Under Staffing The FRN does not Add a reference to include a reference to ML13065A048.

ML13065A048, Summary of February 19, 2013, Public Meeting to Discuss Framework of Phase 1 Staffing Submittals Related to Issues Associated with Near-Term Task Force Recommendation 9.3, and the associated information regarding considerations for a BDB event staffing analysis that utilizes security personnel.

This information was the basis for creating the NEI White Paper, Generic Basis for Responses to Staffing Assessment Questions Related to Use of Security Personnel During a 29

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change BDB Event Response, included in the comment below (see EP Text Change 1 in Attachment 2).

37 EP FRN 70625 Under Staffing - see In reference to EROs, See attached EP Text attached EP Text Change 1 the term expanded Change 1 in Attachment 2 in Attachment 2 is used incorrectly; should revise to align with usage in NEI 12-01 which is the source document (i.e., the term applies only to EROs at multi-unit sites). The description of the staffing analyses performed to respond to the 50.54(f) letter is not entirely accurate; revise language to better reflect analysis purpose and methodology. There is no reference to the NEI white paper on use of security 30

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change personnel in a staffing analysis; one should be included.

38 General FRN 70625 4. Licensees identify and Revise this sentence 4. Licensees identify and resolve conflicts between the to better clarify the resolve readily apparent strategies, guidelines and expectations for conflicts between the procedures. procedure and strategies, guidelines and guideline integration. procedures to the extent Given the unbounded practicable.

nature of BDB event sequences, there should be some reasonable limit on the expected work directed at identifying and resolving conflicts. Replace practical with practicable to better characterize the scope of effort (i.e.,

feasible, or able to be done or put into practice successfully).

39 General FRN 70625 5. Licensees identify Revise this sentence 5. Licensees identify competing considerations to better clarify the readily apparent competing when using the strategies, expectations for considerations when using 31

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change guidelines and procedures and procedure and the strategies, guidelines eliminate or address them in guideline integration. and procedures and guidance. Given the unbounded eliminate or address them nature of BDB event in guidance.

sequences, there should be some reasonable limit on the expected work directed at addressing competing considerations.

40 FLEX FRN 70627 Section IV.D Equipment The equipment being Suggest rewording the addressed in this sentence as follows:

The paragraph that starts paragraph is plant with, The underlying equipment, as This proposed rule would proposed requirements. opposed to FLEX require plant equipment includes a sentence that says equipment, and it relied on for the mitigation This proposed rule would should be so strategies to meet the require reasonable protection specified. In current design basis for a for the equipment relied on accordance with the hazard level as severe as for the mitigation strategies to NRC endorsed that originally determined a hazard level as severe as implementing for the facility under GDC-2 that originally determined for guidance, reasonable or the applicable PDC the facility under GDC-2 or the protection only unless the reevaluated applicable PDC unless the applies to FLEX hazards stemming from the reevaluated hazards stemming equipment. For plant March 12, 2012, NRC letter from the March 12, 2012, NRC equipment to be issue under § 50.54(f), as 32

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change letter issue under § 50.54(f), considered for use in assessed by the NRC show as assessed by the NRC show a mitigating strategy that a greater hazard is that increased protection is it must meet the necessary.

necessary. current plant design basis for the applicable external hazard(s) or the reevaluated seismic and flooding hazards.

The paragraph should use this terminology for plant equipment.

41 FLEX FRN 70627 Section IV.D Equipment These two To correctly reflect how the paragraphs do not reevaluated flooding and The two paragraphs referring correctly capture the seismic hazards came to be to COMSECY-14-0037. sequence of events in included in the rulemaking, the development of this section should be the mitigation revised to remove strategies. These statements suggesting that paragraphs imply that NEI 12-06 contained a NEI 12-06 always requirement to reasonably reflected the intent to protect equipment from the update the mitigating reevaluated hazards.

strategies based on the reevaluated hazards. The mitigation strategies were developed 33

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change based on the design basis hazards that had been documented at the time of Order EA 049. The first paragraph says that as a result of COMSECY-14-0037 Order EA-12-049 included a requirement to reasonably protect equipment from the reevaluated hazards.

and that these principles are reflected in NEI 12-06.

The use of the term most recent flood analysis in NEI 12-06 did not mean what is implied in these two paragraphs. It meant to select the most recent design basis flood analysis 34

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change applicable to the site in question and use that for developing the strategies. It was not referring to the ongoing activities under NTTF 2.1 because otherwise the licensees could not have complied with the Order in the time required.

It is agreed that the COMSECY did direct addressing the reevaluated flood and seismic hazards through a mitigating strategies approach.

That is, in fact, what is being done through the inclusion of Appendices G and H into NEI 12-06.

42 Training FRN 70628 Section IV.D Training This statement is See attached Training made at the end of Text Change 1 in The last sentence of the the discussion Attachment 2 second paragraph in this 35

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change section states, Licensees regarding other would be required to use the training programs SAT process for newly that do not use the identified training SAT process. The requirements supporting the NRC concludes that effective use of the strategies such programs do not and guidelines that would be need to be revised to required by this proposed use the SAT process.

rule. However, the sentence in question would imply that new training requirements that would be implemented under such programs would need to be developed using the SAT process. The penultimate sentence in this paragraph would then only grandfather existing elements of these programs as not needing to use the SAT process. Since this training will in large part have been completed prior to 36

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change the rule becoming effective, the rule should not impose a new requirement (i.e., for newly identified training to use the SAT process) retroactively.

43 Training FRN 70628 Under Training - see The Training See attached Training attached Training Text description should be Text Change 1 in Change 1 in Attachment 2 revised to better Attachment 2 reflect how licensees would implement the new training requirement. A licensee would first need to assess all job tasks necessary to perform mitigating strategies in order to identify training gaps or future modifications. These gaps or modifications would then be addressed in the 37

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change appropriate training program - a SAT-based program or, for common elements, a non-SAT program currently acceptable for meeting regulatory required training. Also, this section should address expectations for initial training that was delivered prior to the effective date of the rule training requirements.

44 EP FRN 70629 Under Onsite and offsite There is no reference This section of the FRN communications capability to the licensee should recognize the communications communications assessments that assessments (similar to were performed in what was done with response to the § staffing) and that 50.54(f) request for implementation of NRC-information of March reviewed proposed 12, 2012. These changes are sufficient to assessments provided meet the intent of the the bases for changes proposed requirement in implemented by 10 CFR 50, Appendix E, 38

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change licensees to add Section VII.

communications capabilities for events that result in extended loss of ac power onsite, or potential destruction of offsite communications infrastructure. Each facilitys assessment was the subject of a Safety Assessment performed by the NRC staff; the Safety Assessments typically concluded that the assessment for communications was reasonable, and the interim measures, analyzed existing systems, and proposed enhancements would help to ensure that communications are maintained.

39

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change 45 EP FRN 70629 Under Staffing assessment - As used here, See attached EP Text see attached EP Text Change EDMGs are Change 2 in Attachment 2 2 in Attachment 2 improperly conflated with the staffing assessment conducted under the March 12, 2012 request for information that was developed to align with the requirements included in Order EA-12-049, and the proposed new staffing assessment requirement in 10 CFR 50, Appendix E, Section VII. The reference to EDMGs should be deleted from this paragraph.

46 FLEX FRN 70632 V. Section-by-Section Analysis Reasonable Suggest rewording the protection only sentence as follows:

Proposed §50.155(b), applies to FLEX Integrated Response equipment and not to This provision also results Capability plant equipment. This in the need to have section is referring to mitigation equipment Paragraph starting with, The withstand the effects of both sets of proposed § 50.155(b)(1) 40

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change would limit the requirements equipment; therefore, external natural for mitigation strategies to reasonable protection phenomena as discussed in is the incorrect later portions of this The last sentence refers to terminology. notice.

equipment being reasonably protected.

47 General FRN 70632 V. Section-by-Section Analysis First column, third The citation at the end of Proposed §50.155(b), paragraph: The the paragraph should be to Integrated Response citation at the end of § 50.155(f) not § Capability the paragraph is 50.155(g).

incorrect.

48 EP FRN 70633 Under Proposed § 50.155(b), Revise wording to See attached EP Text Integrated response clarify the application Change 3 in Attachment 2 capability - see attached EP of § 50.155 (b)(1)

Text Change 3 in Attachment and (b)(2) 2 requirements, i.e.,

(b)(1) applies to all on-site units consistent with Order EA-12-049 and, for the current 50.54(hh)(2) requirement, the affected unit consistent with industry implementation of 41

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change NRC-endorsed guidance in NEI 06-12.

49 FLEX FRN 70633 V. Section-by-Section Analysis The guidance for Rather than state that all implementation of equipment needs to be Proposed § 50.155(c), mitigation strategies reasonably protected, the Equipment Requirements uses two concepts for final rule should reflect the ensuring equipment approach allowed by is available to guidance, which ensures perform its mitigation that the equipment is function(s). For plant available to perform its equipment the specified function.

guidance provides that the equipment For example, § must meet the 50.155(c)(2) should be current design basis worded (2) The (including the equipment relied on for the reevaluated flooding mitigation strategies and seismic hazards if required by paragraph they are greater). For (b)(1) of this section must FLEX equipment the withstand the effects of concept of reasonable natural phenomena protection is applied applicable to the facility to provide reasonable (including the reevaluated assurance that the seismic and flooding FLEX equipment will hazards). Or in place of be available to withstand the phrase perform its function. remain available could be 42

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change The rulemaking used.

proposes to combine these two concepts The phrase at the end of under the term this section that are reasonable equivalent to the design protection. This will basis of the facility cannot create confusion and, be used as it is contrary to in some cases, the guidance for creates a conflict reasonable protection of between the rule and FLEX equipment in NEI 12-the guidance. For 06. This language would example, the section- also allow § 50.155(c)(2)(i) by-section analysis to be eliminated. (See the states that § comments in Attachment 3 50.155(c)(2) sets the under the question hazard level for Methodology for reasonable protection Addressing Reevaluated at the design basis or Hazards) the reevaluated flood or seismic hazard whichever is greater.

But the analysis also recognizes that the guidance allows ASCE 7-10 to be used for reasonable protection. These two are in conflict.

43

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change Hazard protection requirements for SFPI are limited to the NRC endorsed guidance NEI 12-02, Rev 1, which cites the hazard protection requirements in NEI 12-06 Rev 0

{emphasis added}.

SFPI would be subject to a new requirement for evaluation against the re-evaluated hazards (the intent of proposed

§50.155(c)(2)(i) -

which is lost in this proposed change).

As indicated above, this does not necessarily mean that the SFPI equipment must be altered in any way to account for the re-evaluated hazards. Other 44

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change actions might be available to provide the needed information contemplated by the original Order EA 051 or to support FLEX operations. With regard to support for FLEX operations, SFPI shall be treated no differently than any other existing plant instruments providing information for FLEX operations.

50 EP FRN 70634 First paragraph, first sentence Recommend Proposed § 50.155(e)

- Proposed § 50.155(e) changing second would require that each would require that each and to or to align licensee and applicant licensee and applicant this sentence with the specified in § 50.155(a) specified in § 50.155(a) rest of the description conduct drills or exercises conduct drills and exercises contained in this for personnel that would for personnel that would section, and the perform activities in perform activities in proposed rule accordance with the accordance with the strategies wording in 10 CFR strategies and guidelines and guidelines identified in § 50.155(e). identified in § 50.155(b)(1) 45

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change 50.155(b)(1) and (2). and (2).

51 EP FRN 70634 First paragraph, third The term integrated These drills or exercises sentence - Integrated is is not used in should demonstrate usage used to describe the licensees proposed 10 CFR of the procedures, or applicants approach to 50.155(e), so it is guidelines, staffing and using all tools, spaces, unclear how it can be supporting organizational qualified personnel and introduced here in structure during a resources during a the Section-by- performance enhancing performance enhancing Section Analysis to experience to the extent experience to the furthest describe a drill or practicable given a set of extent practical given a set of exercise. The initiating conditions and initiating conditions and within sentence should be within the bounds of a drill the bounds of a drill or reworded such that it or exercise scenario.

exercise scenario. is stating the expected attributes (scope) of a drill or exercise demonstrating the integrated use of strategies or guidelines in § 50.155(b)(1) and (2).

Revised wording is suggested to improve clarity of expected drill/exercise scope, and practical with practicable to better 46

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change characterize the scope of effort (i.e.,

feasible, or able to be done or put into practice successfully).

Note - the concept of integrated, as it pertains to capabilities, procedures and guidelines demonstrated in a drill or exercise, is correctly addressed in the second and fourth sentences of this paragraph.

47

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change 52 EP FRN 70634 Second paragraph, first Recommend This proposed rule uses sentence - This proposed rule changing the words drill and uses the words drill and appropriate centers, exercise as they are exercise as they are defined work groups, strike defined in NUREG-in NUREG-0654/FEMA-REP-1, teams, or individuals 0654/FEMA-REP-1, Revision 1,9 meaning an to the appropriate Revision 1,9 meaning an evaluated performance- emergency facilities, evaluated performance-enhancing experience that teams and support enhancing experience that reasonably simulates the groups to align with reasonably simulates the interactions between standard industry interactions between the appropriate centers, work terminology (e.g., in appropriate emergency groups, strike teams, or emergency plans and facilities, teams and individuals that would be NEI 99-02). This will support groups that would expected to occur during the improve be expected to occur event. understanding of rule during the event.

expectations.

53 EP FRN 70635 First paragraph, second Recommend This would require that sentence - This would require changing first and the drills or exercises that the drills and exercises to or to align this performed to demonstrate performed to demonstrate this sentence with the this capability include capability include transitions rest of the description transitions from other from other procedures and contained in this procedures and guidelines, guidelines, as applicable, and section, and the as applicable, and the use the use of communications proposed rule of communications equipment that would be wording in 10 CFR equipment that would be required by proposed 10 CFR 50.155(e). required by proposed 10 part 50, appendix E, section CFR part 50, appendix E, 48

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change VII. section VII.

54 New Plants FRN 70644 ELAP concurrent with 10 CFR 50.155(b)(1) In order to avoid having to either a loss of normal access does not address the make a rule change when to the ultimate heat sink possibility that some additional new plant (LUHS) or, for nuclear power new plant designs designs progress, the plants with passive reactor may use an ultimate language in section designs, a loss of normal or normal heat sink. 155(b)(1) regarding heat access to the normal heat sinks should be revised to sink. accommodate new designs as they become available.

55 EDMGs FRN 70644 The rule language in § The requirement in § To avoid backfit concerns 50.155(b)(2). 50.155(b)(1) regarding a potential addresses strategies unanalyzed expansion of and guidelines that what is now required by must be capable of § 50.54(hh)(2), it is being implemented recommended that § site-wide. § 50.155(b)(2) be reworded 50.155(b)(2) does as follows:

not specify that it is (2) Extensive Damage only intended to Mitigation Guidelines apply to the affected (EDMGs). Strategies and unit. guidelines to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of 49

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change the plant due to explosions or fire. These strategies and guidelines must be capable of being implemented in the affected unit and must address the following areas:

56 SFPI FRN 70645 §50.155(c) Sweeps up SFPI into (4) The mitigation (4) The equipment relied on the requirements for strategies required in for the mitigation strategies in mitigating strategies. paragraph (b)(1) must be paragraph (b)(1) of this Order EA-12-051 was supported by spent fuel section must include reliable separate and distinct pool level information from means to remotely monitor from the mitigating wide-range level wide-range spent fuel pool strategies order with instruments capable of levels to support effective different purposes meeting the conditions prioritization of event and characteristics. specified in paragraph mitigation and recovery The strategies (b)(1) and to provide referred in information to support actions.

effective prioritization of

§50.155(b)(1) do not event mitigation and attach to SFPI, which recovery actions.

is only intended to provide information (i) The imposition of the for prioritization of paragraph (c)(2)(i) to the actions. The wide-range level proposed rule instrumentation does not language could lead invoke imposition of any to inadvertent other mitigation strategy application of 50

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change unnecessary and requirement on the wide-unintended range level requirements for instrumentation, SFPI.

57 SFPI FRN 70645 §50.155(c)(2): See comment above on (i) Each licensee that received section-by-section analysis the March 12, 2012, NRC at FRN page 70633 letter issued under § 50.54(f) concerning reevaluations of seismic and flooding hazard levels, shall provide reasonable protection against that reevaluated seismic or flooding hazard(s) if it exceeds the design basis of its facility.

58 FLEX FRN 70645 10 CFR 50.65, The proposed regulation Requirements for should state that the SFPI monitoring the Maintenance Rule (10 CFR effectiveness of 50.65) is not applicable to maintenance at FLEX equipment or SFPI nuclear power level instrumentation plants, does not required by § 50.155(c) .

apply to FLEX equipment or SFP level instrumentation whose primary design 51

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change function is to support strategies developed to comply with this rule. The Maintenance Rule is intended to apply to SSCs whose failure impacts safety related functions, are relied upon for the mitigation of design basis events, and required for an EOP mitigating function.

The failure of FLEX equipment or SFP level instrumentation with the primary design function of supporting this rule does not impact any safety related function nor is this equipment relied upon or required for a design basis or an EOP mitigating 52

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change function.

59 FLEX FRN 70645 The NRCs cyber The proposed regulation security rule codified should state that the Cyber SFPI in 10 CFR 73.54 Security Rule (10 CFR would not apply to 73.54) is not applicable to FLEX equipment or FLEX equipment or SFPI SFP level level instrumentation instrumentation. The required by § 50.155(c).

cyber rule provides the programmatic The proposed regulation requirements to should also state that the defend against the wide-range level design basis threat of instruments are not subject radiological sabotage to the requirements of the cyber attack. The cybersecurity rule regulation applies to regardless of the use of the digital SSCs within information provided by the nuclear power the instruments for any plant that, if emergency action level(s).

compromised, could directly or indirectly result in radiological sabotage (i.e.,

significant core damage or spent fuel sabotage). The FLEX equipment and SFPI level instrumentation 53

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change do not provide safety-related or important-to-safety functions.

Nor do the FLEX equipment and SFPIlevel instrumentation constitute support systems or equipment necessary for safety-related systems to perform their intended safety functions.

Accordingly, the NRCs cyber security regulations do not apply. Additionally, given the FLEX equipment would be covered by a maintenance program, imposing the cyber security requirements would not provide a significant safety benefit.

54

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change 60 EP FRN 70646 Proposed 10 CFR 50, The wording in this Recommend relocating the Appendix E,Section VII section contents/requirements of notwithstanding, proposed 10 CFR 50, future readers may Appendix E,Section VII, to interpret that these proposed 10 CFR 50.155 as requirements must be section (f), and re-described in a site designate Change Control emergency plan. as section (g) and Since 10 CFR Implementation as (h).

50.155(b)(4) Also make conforming addresses staffing changes throughout the and (e)(1 through 4) FRN.

address communications, the clarity of MBDBE requirements would be improved if the related staffing and communications aspects were consolidated in 10 CFR 50.155.

Recommendations on change control are contained in our responses to the 55

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change rulemaking questions (see Attachment 3 questions 1 and 2)

Change control is described in NEI 12-02 App. 1 (QA).

61 New Plants FRN 70646 Proposed Part 50, Appendix E, Some COL holders Suggest revising proposed VII. Communications and are on schedule to Part 50, Appendix E, Staffing Requirements for the complete all their VII.1.b as follows:

Mitigation of Beyond Design ITAAC less than 2 Basis Events, requires holders years from the rules b. A holder of a combined of combined licenses (COLs) expected effective license issued under 10 issued under Part 52, where date (i.e., a Jan. CFR part 52 before the the Commission has not yet 2019 fuel load date Commission has made the made the finding under with a Jan. 2017 rule finding under § 52.103(g) 52.103(g) to perform a effective date). Under of this chapter shall detailed analysis and submit it the proposed rule, perform this analysis and to the NRC at least 2 years such a licensee could submit it to the NRC under before the date specified for not comply with the § 52.3 of this chapter at completion of the last implementation least 2 years before the inspections, tests, and schedule in the date specified for analyses in the inspections, proposed rule. As a completion of the last tests, analyses, and practical matter, a inspections, tests, and acceptance criteria (ITAAC) licensee in that analyses in the inspections, completion schedule required situation may have to tests, analyses, and by § 52.99(a) of this chapter complete and submit acceptance criteria (ITAAC) for the plant. the required analysis completion schedule before the rule even required by § 52.99(a) of 56

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change becomes effective to this chapter for the plant avoid the need for an OR [DATE 365 DAYS exemption. To give AFTER EFFECTIVE DATE licensees a OF THE FINAL RULE],

reasonable amount of whichever is later.

time to comply with this rule, COL holders who are already within 2 years of the specified date for their last ITAAC completion when the rule becomes effective should be given the same submittal schedule as operating plants.

62 EP NEI 13-06 --- Various - see attached Since the submittal of Various - see attached redline/strikeout version and revision 0 of NEI 13- redline/strikeout version clean version of NEI 13-06, 06 in September of and clean version of NEI Revision 1 that are included in 2014, additional NRC 13-06, Revision 1 in Attachments 4 and 5. documents have been Attachments 4 and 5.

issued that should be Includes editorial/minor referenced in the changes to improve clarity; document. Section these are non-intent 3.3.1 should be changes.

revised to reflect that training on common 57

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change elements may be addressed by a non-SAT training program acceptable for meeting regulatory required training, and non-SAT training programs that meet the needs for common elements do not need to be revised to use the SAT process (both these points will bring the guidance into better alignment with Training discussion in the rule FRN). Section 3.3.2, Plant-Referenced Simulator, should be revised to better align the wording with related guidance in NEI 12-06. Consistent with SRM-SECY 0065, clarify that SAMG drills are not a regulatory 58

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change requirement and are conducted on a voluntary basis.

Section 5.3.7, Drills Demonstrating the Use of Strategy-Related Equipment, should address expected action if placement of portable equipment during a drill is not practicable (e.g., due to plant safety or configuration control issues). Replace Regional Response Center with correct title - National SAFER Response Center.

63 EP NEI 14-01 --- Various - see attached Since the submittal of Various - see attached redline/strikeout version and revision 0 of NEI 14- redline/strikeout version clean version of NEI 14-01, 01 in September of and clean version of NEI Revision 1 that are included in 2014, additional NRC 14-01, Revision 1in Attachments 6 and 7. documents have been attachments 6 and 7.

issued that should be Includes editorial/minor referenced in the changes to improve clarity; 59

Attachment 1: MBDBE Rulemaking Comment Table Comment Tech Area Document Page Text Concern Suggestion for Change document. A these are non-intent reference to the changes.

strengthened industry initiative on maintenance of SAMGs (approved by the NEI NSIAC) should also be included.

60

Attachment 2: Comment Table Text Changes EP Text Change 1 [These text changes are addressed with NEI TC-36 and 37 in comment responses to SOC comment 14 and 15]

FRN, starting on page 58 Staffing Staffing The NRC proposes to require licensees to provide the staffing necessary for having an integrated response capability to support implementation of the FSGs and EDMGs. To be effective, staffing for an expanded response capability should include the trained and qualified individuals who would be relied upon to analyze, recommend, authorize, and implement the mitigating strategies. The staffing must directly support the assessment and implementation of a range of mitigation strategies intended to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling.

The staffing analyses required by proposed appendix E, section VII, should determine the required staff necessary for responding to a beyond design basis external event that affects all units on a site. A staffing analysis must confirm that sufficient personel are available to implement FSGs within the timeframes necessary to when personnel performing expanded response functions should report to the site, within a timeframe sufficient to support implementation of the strategies that are not assigned to the on- shift staff. This would ensure that the functions of core cooling, containment, and spent fuel pool cooling are continuously maintained or are promptly restored. The analysis will consider the availability of both on-shift and augmenting responders and, for multi-unit sites, an expanded emergency response organization that enables performance of unit-specific accident assessment and mitigation functions.

The NRC has endorsed the industry guidance for conducting staffing analyses, NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Revision 0, and NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, and the NRC has issued Interim Staff Guidance (ISG),

NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants, that provides the requisite details for determining the staffing levels and for which positions, as well as which beyond design basis external events, the applicants and licensees should evaluate. The NRC has also reviewed and concurred with related guidance presented in NEI White Paper, Generic Basis for Responses to Staffing Assessment Questions Related to Use of Security Personnel During a BDB Event Response.

The recommended minimum positions and staffing levels for emergency plans were initially provided in NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. Following the September 11, 2001, events, the NRC issued Enhancements to Emergency Preparedness Regulations (EP final rule) (76 FR 72560) to amend 10 CFR part 50, appendix E, to address, in part, concerns about the assignment of tasks or responsibilities to on-shift emergency response organization (ERO) personnel that would potentially overburden them and prevent the timely performance of their functions under the emergency plan. Licensees must have enough on-shift staff to perform specified tasks in various functional areas of emergency response 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week. This proposed rule would address the staffing requirements for the expanded response 1

Attachment 2: Comment Table Text Changes capabilities for on-shift response and the ERO, including an expanded response capability for multi-unit sites.

This proposed rule would require adequate staffing to implement the FSGs and EDMGs with the EOPs without requiring further analysis to supplement analyses that were completed as a result of post-Fukushima orders, responses to the § 50.54(f) request for information of March 12, 2012, or the EP final rule. Staffing levels should be established to ensure that if strategies are executed there would be no delays in completing them caused by the lack of qualified personnel. The NRC expects that the use of drills, existing training analyses and other methods would verify sufficient staffing levels.

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Attachment 2: Comment Table Text Changes Training Text Change 1 [Addressed with NEI TC-42 and 43]

FRN, starting on page 67 The NRC acknowledges that licensee training programs, such as those required for licensed operators under 10 CFR part 55, Operators Licenses, the programs for plant personnel specified under § 50.120, "Training and Qualification of Nuclear Power Plant Personnel, and the training for emergency response personnel required by 10 CFR part 50, appendix E, section IV.F, Training, would likely provide for many of the knowledge and abilities required for performing activities in accordance with the strategies and guidelines that would be required by this proposed rule. The NRC also recognizes that while each of these programs is currently acceptable for meeting regulatory required training, some there are other training programs are based on a Systems Approach to Training (SAT) process as defined in § 55.4 while others that are currently acceptable for meeting other regulatory required training (e.g., 10 CFR part 50, appendix E, section IV.F) that do not use the SAT process. 7 Training programs that do not use a SAT approach have been found acceptable for more frequently occurring design-basis events; therefore, the NRC has determined that these training programs can meet the needs for common elements with beyond-design-basis mitigation and would not require licensees to revise these training programs to use the SAT process to meet the proposed requirements. Nevertheless, as noted previously, the NRC anticipates that mitigating these strategies and guidelines may use new methods or equipment that require knowledge and abilities not currently addressed under existing training programs and, as a result, there may be gaps in these training programs that must be addressed to support effective use of the strategies and guidelines. Accordingly, this proposed rule would further require that licensees provide for the training of personnel using a SAT process systems approach to training as defined in

§ 55.4 (the Systems Approach to Training (SAT) process), except for elements already covered under other NRC regulations.7 Licensees would assess the jobs to be performed in order to The SAT process, which is acceptable for meeting training requirements under 10 CFR part 55 and § 50.120, would also be appropriate for licensee identify ication and resolution of any current gaps or future modifications to personnel training that may be necessary to provide for the training of personnel performing activities in accordance with the mitigating strategies and guidelines that would be required by this proposed rule. The licensee would then address the identified training needs in a SAT-based training program or, for common elements, in a program acceptable for meeting other regulatory required training. The NRC recognizes that there are other training programs that are currently acceptable for meeting other regulatory required training (e.g., 10 CFR part 50, appendix E, section IV.F) that do not use the SAT process. In light of the existence of these training programs, which have been found acceptable for more frequently occurring design-basis events, the NRC has determined that these training programs can meet the needs for common elements with beyond-design basis event mitigation. Therefore, the NRC would not require licensees to revise these training programs to use the SAT process to meet the proposed requirements. Licensees would be required to use the SAT process for newly identified training requirements supporting the effective use of the strategies and guidelines that would be required by this proposed rule By identifying training needs and then using the SAT process or another process within an approved training program, licensees would identify and will train on any additional tasks that would be necessary to implement the strategies and guidelines for the mitigation of beyond design-basis 3

Attachment 2: Comment Table Text Changes events as defined in this proposed rule. The additional tasks identified would be incorporated into the training program to ensure appropriate training would be administered for each qualified individual designated to implement the strategies and guidelines required by this proposed rule.

The NRC is not requiring that initial training provided to personnel to achieve compliance with post-Fukushima NRC Orders be re-delivered to those personnel if the training was not developed using a SAT-based process.

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Attachment 2: Comment Table Text Changes EP Text Change 2 [Addressed with NEI TC-45]

FRN, starting on page 73

2. Staffing assessment This proposed rule would require an assessment that is considered essential for effective implementation of the FSGs. This assessment matches the one that was conducted under the March 12, 2012, request for information that was developed to align with the requirements included in Order EA-12-049 (i.e., the staffing analysis specifically considered the staffing needs for implementing Order EA-12-049); licensees would not be required to repeat the staffing analysis. A lesson-learned from the Fukushima event is that there are increased staffing demands following a beyond-design-basis external event, and this coupled with the subsequent NRC requirements issued in Order EA-12-049 required the staffing analysis to provide a level of assurance that the FSGs can be implemented. This provision would then support the proposed requirements of the rule to have sufficient staffing to implement the FSGs and EDMGs in conjunction with the EOPs.

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Attachment 2: Comment Table Text Changes EP Text Change 3 [Addressed with NEI TC-48]

FRN, starting on page 85 Proposed § 50.155(b)(4) would establish requirements for licensees to provide the staffing necessary for having an integrated response capability to support implementation of the strategies and guidelines in proposed (b)(1) and (2). The number and composition of the response staff should be sufficient to implement (b)(1) mitigation strategies and guidelines intended to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling for all on-site affected units and (b)(2) mitigation strategies and guidelines for the affected unit. The word sufficient is used in the proposed paragraph to reflect its meaning adequate.

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Attachment 3: Responses to Questions in Sections VI and XI Specific Requests for Comments (FRN Section VI) 1.) Change Control

[We understand the intent of proposed 10 CFR 50.155(f) is to allow the licensee to make changes in the implementation of the requirements in § 50.155 and 10 CFR part 50, appendix E, section VII, without NRC approval as long as the licensee continues to meet the provisions of § 50.155 and 10 CFR part 50, appendix E, section VII. This is an appropriate change control standard for these beyond-design-basis event requirements. We propose the following minor clarification to § 50.155(f)(1):

(f) Change Control. (1) A licensee may make changes in the implementation of the requirements in this section and 10 CFR part 50, appendix E, section VII, without NRC approval, provided that before implementing each such change, the licensee performs an evaluation demonstrating demonstrates that the provisions of this section and 10 CFR part 50, appendix E, section VII, continue to be met. NEI SR-1]

[The associated guidance for the proposed regulation will be key to understanding that the proposed change control provision is intended to allow such changes without NRC approval. In accordance with the endorsed change control guidance in NEI 12-06, the licensee need not obtain prior NRC approval to make a change, provided that the licensees assessment determines that the provisions of § 50.155 and 10 CFR part 50, appendix E, section VII continue to be met. The supplementary information seems to contradict this by stating that the proposed change control provisions may result in licensees seeking NRC review and approval of proposed changes that do not follow current regulatory guidance for this proposed rulemaking potentially through a license amendment.1 Under the plain language of both proposed § 50.155(f) and NEI 12-06, a licensee would not need a license amendment to implement strategies that are not approved in regulatory guidance if the licensee performs a documented assessment demonstrating that the change continues to meet applicable regulatory requirements. NEI SR-2]

[Current paragraph (f)(2) would be renumbered as (f)(3) as follows:

(f)(3) Documentation of all changes, including those required by paragraph (f)(1) of this section, shall be maintained until the requirements of this section and section VII of appendix E to 10 CFR part 50 no longer apply. NEI SR-3]

1 80 Fed. Reg. at 70,628 (emphasis added).

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Attachment 3: Responses to Questions in Sections VI and XI 2.) Application of Other Change Control Processes

[Section 50.155(f)(2) should explicitly and clearly address the application of Other Change Control Processes given that facility changes can impact multiple aspects of the plant having different applicable requirements, and being subject to different change control requirements. The rule and associated guidance should consistently differentiate between design basis conditions and beyond-design-basis conditions by clarifying that other change control processes such as § 50.59, § 50.54(p), § 50.54(q), and fire protection change controls are not applied to changes affecting only implementation of the strategies and guidelines required by 10 CFR 50.155(b). This would reflect the NRC staff position stated in an NRC letter from Dean to Pollock, dated April 17, 2015 (see ML14147A073). Specifically, Provided that such changes do not also involve changes to the plant or procedures as described in the UFSAR, the associated guidance in NRC endorsed documents such as NEI 96-07, Guidelines for 10 CFR 50.59 [Title 10 of the Code of Federal Regulations (10 CFR), Section 50.59] Implementation, and NEI 97-04, Design Basis Program Guidelines, would support screening out those changes and not needing to evaluate them in accordance with the regulatory processes associated with the UFSAR (i.e., 10 CFR 50.59 and 50.71). The same is true for other key licensing basis documents such as the security plan and emergency plan, and their related change control and reporting requirements, provided the changes being evaluated impact only mitigating strategies for BDBEEs and do not affect the content of the other licensing basis documents.

As noted, NRC endorsed documents allow the determination that 10 CFR 50.59 does not apply to changes that are determined to be beyond-design-basis (i.e., changes to the plant or procedures that are not described in the UFSAR). In the same manner and based on the applicability determination made under 10 CFR 50.59, other change control processes for the security plan, emergency plan and fire protection plan would not be applicable to changes affecting only implementation of the strategies and guidelines required by 10 CFR 50.155(b).

In this regard, the following is the suggested change control language for § 50.155(f)(2):

(f)(2) Changes in implementation of requirements in this section and 10 CFR part 50, appendix E, section VII are not subject to change control processes other than paragraph (f)(1) provided the changes being evaluated impact only mitigation of beyond-design-basis events.

Alternatively, the regulation could contain a provision that allows licensees to deem acceptable a change evaluated through these other change processes provided the change affects only the implementation of the strategies and guidelines required by this section. The suggested provisions would be particularly relevant to streamlining the assessment of potential change impacts on programmatic requirements associated with Security, Emergency Preparedness, and Fire Protection that would only be implemented during an actual beyond-design-basis event. NEI SR-4]

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Attachment 3: Responses to Questions in Sections VI and XI 3.) Reasonable Protection

Background

The Mitigating Beyond Design Basis Events rulemaking package asked for feedback on the cost to licensees of implementing the proposed requirement that equipment supporting mitigating strategies be protected from the effects of natural phenomenon including both those in the current plant design basis as well as the reevaluated hazard under the March 12, 2012 section 50.54(f) request concerning the flooding and seismic hazards.

[The estimates provided in response to this question are based on the guidance for Mitigating Strategies Assessment (MSA) contained in NEI 12-06, a document that has been endorsed by the NRC. Our interpretation of the proposed rules requirements for a MSA differs from the guidance in NEI 12-06. Specifically, the language in section 50.155(c)(2) seems to focus the assessment on the protection of mitigating strategies equipment, whereas the guidance allows the use of alternate mitigating strategies to cope with the hazards. We propose changes to the rule language to address this discrepancy in our response to question VI.9. If the final rule precludes these alternate mitigating strategies, industry compliance costs would be significantly greater than reflected here, without any corresponding safety benefit. With that caveat, NEI offers the following feedback on the costs and impacts licensees expect occur because of a new requirement to address the reevaluated hazards within their mitigation strategies for beyond-design-basis external events.

Survey In December 2015, NEI surveyed the utilities to obtain information related to the NRCs request.

Our survey characterized its questions as follows.

The purpose of this survey is to collect cost and implementation information that may support some of the industry comments on the rulemaking package and allow NEI to submit a response to these questions that summarizes industry input.

The questions below provide some task details that will help answer the NRCs questions. The cost or implementation schedule estimates provided should be based on the evaluations and changes that will be necessary under the new rule, the estimates should not include the costs or time associated with implementing the existing Orders or any previous rulemaking but may include costs associated with response to the NRC 50.54(f) letter to the extent they are being used in support of mitigating strategies.

With respect to estimating mitigating strategies changes to address the reevaluated seismic and flooding hazards, we recognize that Mitigating Strategies Assessments (MSAs) have not been completed, but the guidance has been issued (see NEI 12-06 rev 2) and you probably know the difference between the FLEX DB hazard and the reevaluated hazard results. As a result, you may have an idea of what changes you need to make to accommodate these differences. Your best estimate of the cost and implementation schedule is all that is requested.

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Attachment 3: Responses to Questions in Sections VI and XI The questions asked in the survey were the following.

A. Please provide man-hour or cost estimates for the following (indicate which is provided):

1. Completion of a flooding MSA per NEI 12-06 rev 1 Appendix G

2. Indicate what strategy will be used for the flooding MSA (FLEX OK, mod FLEX, AMS, or THMS)

3. Completion of a seismic MSA per NEI 12-06 rev 1 Appendix H

4. Indicate what path will be used in the seismic MSA (Path 1, 2, 3, 4, or 5)

5. Complete NRC submittal of flooding and seismic MSA results

6. Revise FLEX program and OIP or FIP documents to reflect MSA results

7. Revise FLEX Support Guidelines, if necessary, to reflect MSA results

8. Train staff on revised FLEX Support Guidelines

9. Completed plant modifications, if necessary, to address results of MSA B. Please provide a brief summary of the modifications to mitigating strategies and the plant that you expect to have to make, and how long (in terms of years or RFOs) it will take to design and implement the changes. Also briefly indicate what is driving the schedule.

There are several key assumptions and observations related to interpreting the results of the survey.

• All costs are on a per site basis.

• The guidance for completing Mitigating Strategies Assessments (MSA) was not final at the time of the survey. The survey referred to revision 1 of NEI 12-06. Revision 2 had just been completed at the time of the survey; the utilities may not have been fully aware of its contents or the changes since revision 1, especially in the seismic area.

• MSA guidance may be affected by NRC comments during the endorsement process.

• No utility had actually completed a MSA at the time of the survey. As a result:

o The effort required to complete a MSA is a best estimate.

o The effort required to implement any changes to plant programs and procedures and complete any necessary training is dependent on the results of the MSA. Since these results are not known, estimates have a large uncertainty.

o The extent of any plant modifications is dependent on both the mitigating strategy used and the results of the evaluation as compared to existing plant design. Both of these factors have a very large effect on estimate uncertainty.

• One of available seismic strategies uses a probabilistic approach. The cost of developing the underlying seismic PRA is not included in the estimates.

• Costs of maintaining configuration control for the resulting programs, procedures and modifications were not included in the estimates.

• NRC review fees are not included in the estimates. Experience indicates that the review fees for some submittals can be close to the development costs for the information.

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Attachment 3: Responses to Questions in Sections VI and XI

• Some utilities responded with manhour estimates, some with cost. An assumption of $100 per manhour was used to consolidate the information.

Because of all of these uncertainties, the information provided below will use averages or ranges.

Survey Results NEI received responses from approximately 60% of the sites. For those that responded:

MSA Cost The average effort necessary to complete a flooding MSA may be approximately:

• 690 manhours if the existing FLEX strategy is OK (~two-thirds of responding sites)

• 2,450 manhours if the FLEX strategy needs to be modified (~one-third of responding sites)

• 1,550 manhours if an AMS strategy is used (~one-tenth of responding sites)

• 2,500 manhours if a THMS strategy is used The average effort necessary to complete a seismic MSA may be approximately:

• 60 manhours for path 1 (~one-third of responding sites)

• 450 manhours for path 2 (~one-seventh of responding sites)

• 3,800 manhours for path 3 (~one-seventh of responding sites)

• 7,300 manhours for path 4 (~one-fifth of responding sites)

• 10,000 manhours for path 5 (~one-fifth of responding sites)

Implementation Cost Implementation costs depend on the combination of flooding and seismic strategies adopted, and, of course, how much the existing FLEX implementation plans would need to change. For the reasons mentioned above, the estimates varied widely. The information below is presented in manhour ranges per site for those that expect to perform implementation tasks. Note that some sites expect zero costs for programs, procedures, or training efforts if no changes are expected.

• MSA submittal costs ranged from approximately 400 to 1000 manhours

• Program revision costs ranged from approximately 100 to 700 manhours

• Procedure development and revision costs ranged from approximately 50 to 1,500 manhours

• Training costs ranged from approximately 50 to 1,500 manhours Modification Cost The estimates of plant modification costs varied tremendously between sites; in fact many respondents submitted a very broad range for the potential modification efforts at a given site. This is due to the fact that licensees do not yet have a good picture of what plant changes will be necessary. Individual plant estimates ranged from zero (no modifications expected) to tens of millions of dollars for sites that may need to enhance their flood protection features. The average 5

Attachment 3: Responses to Questions in Sections VI and XI anticipated potential modification cost for the respondents was 4.5 million dollars. This cost is in addition to the other implementation costs discussed above. NEI SR-5]

Implementation Time

[The expected time necessary to achieve full compliance with the proposed rule varied widely due to site specific differences in the status of evaluations and the effects of the evaluation on the plant, but as a rule, many of those that had to make changes considered the time allowed in the draft rulemaking package (2 years from the effective date of the rule),insufficient. This observation, and our recommendation to deal with this fact, is provided in our response to the rulemaking package question in Section VI on Implementation Deadline. NEI SR-6]

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Attachment 3: Responses to Questions in Sections VI and XI 4.) Mitigation of Beyond-Design-Basis Events Staffing Analysis

[The industry prefers that the two staffing analyses - one for Proposed 10 CFR part 50, appendix E, section VII and the other for 10 CFR part 50, appendix E, section IV - and their corresponding requirements not be combined. In general, we believe that there should be a clear demarcation between response planning and capabilities described in a site emergency plan, associated with the requirements of 10 CFR 50 Appendix E, and those for beyond design basis events governed by proposed 10 CFR 50.155. This separation facilitates better understanding of the underlying requirements and planning bases for various program elements, and the application of change control processes. NEI SR-7]

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Attachment 3: Responses to Questions in Sections VI and XI 5.) Training Requirements Industry has provided proposed changes to address any potential unintended consequences of the proposed rule language for programs not currently required to be SAT-based, see Attachment 2.

8

Attachment 3: Responses to Questions in Sections VI and XI 6.) Drill or Exercise Frequency

[The industry believes that the drill or exercise frequency proposed by § 50.155(e)(3) and (4) is appropriate. Personnel performing activities in accordance with FLEX and EDMG strategies and guidelines will receive training developed by the SAT process or other processes used by training programs that are acceptable for meeting regulatory required training (e.g., 10 CFR part 50, appendix E, section IV.F, Training.) These processes and training programs have proven effective in preparing individuals for job performance. In addition, many of the job tasks/skills that emergency response personnel would perform during a BDB event response drill are the same as, or similar to, those performed during EP Program drills and exercises conducted to meet the requirements of 10 CFR 50, Appendix E. The proposed BDB drill or exercise frequency provides sufficient performance enhancing opportunities in light of the new training requirements, and responder participation in more frequent EP Program drills and exercises. NEI SR-8]

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Attachment 3: Responses to Questions in Sections VI and XI 7.) Equipment Requirements

[The NRC requested comments on the need for a separate maintenance provision. The industry does not see a need for a separate provision in the rule addressing maintenance of the equipment addressed in § 50.155(c). The more general requirement of § 50.155(b)(1) is sufficient, and, along with the guidance in NEI 12-06, as endorsed by DG-1301, adequately addresses equipment maintenance. NEI SR-9]

[However, if § 50.155(c)(3) is retained, it is not seen to be inconsistent with the guidance in Section 11.5 of NEI 12-06. The proposed rule language states that the equipment must receive adequate maintenance. Adequate is a subjective term that would be open to wide variation in its interpretation. For this reason, the word adequate should be eliminated. The remainder of the proposed rule language more appropriately and specifically addresses the intent of adequate in saying that the maintenance is performed such that the equipment is capable of fulfilling its intended function. NEI SR-10]

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Attachment 3: Responses to Questions in Sections VI and XI 8.) Equipment Protection Implementation Deadline

[Section 50.155(g)(1) would require that each holder of an operating license comply with all provisions of this section no later than 2 years following the effective date of the rule. As explained below, this timeframe is not adequate.

The degree to which the reevaluated seismic or flooding hazard(s) may impact the implementation of mitigating strategies varies widely across the operating reactor fleet, and the various evaluations necessary to prepare for any necessary modifications are in different stages of completion, for example:

• Some sites have not yet finished their flooding hazard reevaluations: These situations are due to work that must be completed by the US Army Corps of Engineers.

• Some sites have simple evaluations: A number of sites have reevaluated hazards that are bounded by the design basis of the facility and the level of effort to demonstrate compliance with the proposed rule may be complete in advance of the effective date of the rule.

• Some sites will need to complete additional evaluations: These sites have reevaluated hazards that exceed the design basis of the facility. They must perform detailed Mitigating Strategies Assessments or MSAs in order to evaluate the effect of the external hazard on their mitigating strategies.

• Some sites still must develop the methodology needed to perform their MSAs: For example, the input for Seismic MSAs that use Path 5 (SSE greater than 2xSSE) may be risk-informed based upon a seismic PRA, which is currently in progress. A two year implementation timeline would not provide adequate time for review of the SPRA results by the NRC Staff prior to completion of modifications under the Rule.

Completion of the engineering, design, planning and installation of any identified modifications or other plant changes is a complex process; sufficient time should be provided to completed the work efficiently, for example:

• Utilities will not start the modification process until their MSAs have been approved by the NRC (note that utilities will not start this process when their hazard report results have been approved as stated on page 70634 of the FRN because it is the MSA that will determine the results of the hazard on mitigating strategies, not the hazard report.) At this point they will need to prepare, plan, and implement the necessary modifications or procedure changes and train their staff. Some of the plant modifications will require access to plant equipment or spaces that are not available except during outages.

• If greater than minor modifications are indicated, a two year implementation window would tend to require that the modifications be performed at risk or fast-tracked, where engineering/design would be performed in parallel with installation of the change. This is inefficient and increases the risk for errors and rework.

By allowing each licensee to develop and submit to NRC a unit-specific implementation schedule, the NRC would allow for more precise implementation schedules that could account for this variation.

Under this approach, some licensees would accelerate their implementation quicker than required by 11

Attachment 3: Responses to Questions in Sections VI and XI the proposed rule when, for example, their reevaluated hazards are bounded by the design basis of the facility. On the other hand, this approach would accommodate other licensees that cannot address their reevaluated hazards within the time required by the proposed rule because, for example, they are still awaiting input from other government agencies. Therefore, the industry suggests that each holder of an operating license submit a schedule for achieving full compliance with the requirements of 50.155 within 90 days from the effective date of the rule. We propose the following:

50.155(g)(1) - Each holder of an operating license under this part on [EFFECTIVE DATE OF FINAL RULE] shall submit to the U.S. Nuclear Regulatory Commission a schedule for achieving full compliance with the requirements of 50.155 no later than 90 days following

[EFFECTIVE DATE IF THE FINAL RULE]. NEI SR-11] .

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Attachment 3: Responses to Questions in Sections VI and XI 9.) Methodology for Addressing Reevaluated Hazards The NRC is requesting comments on the following statement: The NRC is proposing to require licensees for operating nuclear power plants to address the reevaluated flooding hazard levels by reasonably protecting the mitigating strategies equipment to those levels if they exceed the design-basis flood level for the facility.

[The need for a licensees strategies and guidelines to be capable of execution in the context of the reevaluated flooding and seismic hazards information should be addressed in § 50.155(b)(1) rather than § 50.155(c)(2). Consistent with NRC-endorsed guidance, the reasonable protection concept only applies to FLEX equipment and is an element of a viable mitigating strategy but is not, in itself, a mitigating strategy. As proposed, the incorporation of the reevaluated hazards into § 50.155(c)(2)(i) would expand the reasonable protection concept beyond FLEX equipment and yet still not achieve the intended objective of developing mitigating strategies for the reevaluated flood and seismic hazards.

Rather than focus narrowly on the reevaluated hazards in § 50.155(c)(2), the NRC should place this requirement in § 50.155(b)(1). Doing so would require that licensees consider the reevaluated hazards more broadly in the context of developing mitigation strategies as directed by the Commission in the Staff Requirements Memorandum issued on March 30, 2015 for COMSECY 14-0037. This would allow further flexibility in the licensees strategies and guidelines for addressing the reevaluated hazards by 1) establishing an alternative means of compliance that does not include the surrogate conditions of a loss of all alternating current power and loss of normal access to the ultimate heat sink, and 2) providing different success criteria for targeted or scenario-specific mitigating strategies (i.e., namely requiring core cooling and spent fuel pool cooling but not the containment capability to be maintained).

Order EA-12-049 required maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities. Allowing the containment capability to not be maintained for targeted hazard strategies when addressing the reevaluated hazard is acceptable because the reevaluated hazards were not considered by the Order. Rather, the Staff Requirements Memorandum issued on March 30, 2015 for COMSECY 14-0037 addressed the use of a mitigating strategies approach when the Commission approved the staff recommendation to address the reevaluated flooding hazards within their mitigating strategies for beyond-design-basis external events.

As such, § 50.155(b) and (c) should be modified as follows:

(b) Integrated response capability. Each applicant or licensee shall develop, implement, and maintain an integrated response capability that includes:

(1) Mitigation Strategies for Beyond-Design-Basis External Events. Strategies and guidelines to mitigate beyond-design-basis external events from natural phenomena that result in an extended loss of all ac power concurrent with either a loss of normal access to the ultimate heat sink or, for passive reactor designs, a loss of normal access to the normal heat sink.

(i) Each licensee that received the March 12, 2012, NRC letter issued under § 50.54(f) concerning reevaluations of seismic and flooding hazard levels and determined that the 13

Attachment 3: Responses to Questions in Sections VI and XI reevaluated flooding or seismic hazard level exceeded the design basis of its facility must:

(A) Demonstrate the adequacy of the strategies and guidelines required by paragraph (b)(1) to mitigate the effects of the reevaluated hazard; (B) Modify the strategies and guidelines required by (b)(1) to mitigate the effects of the reevaluated hazard; (C) Develop event-specific strategies and guidelines, which need not assume the consequences in paragraph (b)(1), to mitigate the effects of the reevaluated hazard; NEI SR-12]

(D) [Develop strategies and guidelines, or demonstrate the adequacy of the strategies and guidelines required by paragraphs (b)(1), (b)(1)(i)(B), or (b)(1)(i)(C), using risk insights from a probabilistic risk assessment; or NEI SR-13]

(E) [Develop an alternate approach or assessment that provides, as determined by the NRC upon its evaluation of the specific circumstances of each licensee, reasonable assurance that the licensee has adequately addressed the reevaluated hazard. NEI SR-14]

(ii) [These strategies and guidelines must be capable of being implemented site-wide and must include:

(A) Maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities except that the containment capability does not need to be maintained or restored in the case of targeted hazard mitigating strategies and guidelines under paragraph (b)(1)(i)(C); and (B) The acquisition and use of offsite assistance and resources to support the functions required by paragraph (b)(1)(ii)(A) indefinitely, or until sufficient site functional capabilities can be maintained without the need for the mitigation strategies. Goes with NEI SR-12]

(c) Equipment.

(1) [The capacity and capability of the equipment relied on for the mitigation strategies required by paragraph (b)(1) of this section must be have sufficient capacity and capability to simultaneously respond to the event described in paragraph b(1) atmaintain or restore core cooling, containment, and spent fuel pool cooling capabilities for all the power reactor units within the site boundary. NEI SR-15]

(2) [The equipment relied on for the mitigation strategies required by paragraph (b)(1) of this section must be reasonably protected from the effects of natural phenomena that are equivalent to the design basis of the facility.

(i)Each licensee that received the March 12, 2012, NRC letter issued under § 50.54(f) concerning reevaluations of seismic and flooding hazard levels, shall provide reasonable 14

Attachment 3: Responses to Questions in Sections VI and XI protection against that reevaluated seismic or flooding hazard(s) if it exceeds the design basis of its facility. NEI SR-16]

[The above proposed changes to the rule include a section (b)(1)(i)(E) to allow the use of other approaches, including the use of risk insights. The rule should allow for the use of risk insights to demonstrate that licensees can reasonably address the mitigation of beyond design basis seismic events. The seismic safety of a facility involves both the site seismic hazard and the capacity of individual SSCs. The seismic probabilistic risk assessment (SPRA) is the best tool to use to make an overall assessment of the level of protection provided by the as-built plant. The NRC has requested that SPRAs be performed for plants with the greatest potential for the design capacity to be exceeded, (i.e., those plants with the greatest GMRS to SSE ratio). The results of the SPRA can be used to identify the areas of greatest potential for safety enhancement.

The MBDBE rulemaking codifies the requirements for providing reasonable assurance of adequate protection in mitigating the consequences of beyond-design-basis external events. One such requirement involves providing protection of the mitigation strategies equipment. For the reevaluated seismic hazards, the SPRAs provide an appropriate tool for demonstrating reasonable protection of this equipment because the SPRAs are helpful in focusing on the most safety significant aspects of a licensees strategies.

A long standing position of the Commission has been that reasonable assurance of adequate protection does not equate to zero risk. This position is also important in considering the level of risk acceptable for demonstrating reasonable protection of mitigating strategies equipment as the SPRA considers a spectrum of earthquakes that exceed the re-evaluated seismic hazards developed in response to the NRC 50.54(f) request for information.

Plants performing SPRAs are investing significant resources in the evaluation of plant seismic capabilities in the performance of detailed plant specific SPRAs. The industry is developing guidance in NEI 12-06 that will build upon this significant investment in order to maximize safety effectiveness.

Plants that are developing an SPRA should be permitted to utilize a risk informed process to assess whether the mitigating strategies are reasonably protected against the re-evaluated seismic hazard.

Using the fragility calculations of SSCs and the logic models developed for the SPRAs, the risk-informed process can be used to determine reasonable protection for mitigation. A total of 35 operating reactors with a broad spectrum of seismic hazards and plant capacities have been requested to develop SPRAs. Consequently, the seismic safety insights are expected to be very plant-specific.

Based on insights from the SPRAs being performed using the re-evaluated hazard, some plants may find that the inherent robustness of their plant design minimizes the potential for scenarios that mitigating strategies were designed to address (i.e., ELAP/LUHS). This effectively demonstrates the robustness of the mitigating strategies without the need for a licensee to take additional action to reasonably protect the mitigation strategies equipment. In other words, if the SPRA demonstrates a low level of risk, then protecting the mitigating strategies equipment consistent with the strategies developed per NEI 12-06 constitutes reasonable protection of that equipment. On the other hand, 15

Attachment 3: Responses to Questions in Sections VI and XI plants with more significant re-evaluated seismic hazards or those that find limited robustness in as-built SSCs may well find that enhancements to mitigating strategies play an important role in maintaining plant safety.

Based on past SPRA experience, the SPRA results may indicate that the ELAP/LUHS scenarios that mitigating strategies are designed to address are driven by specific low capacity components. They may also indicate that the SSCs in the plant systems, whose failure could cause the risk from ELAP/LUHS sequences to become high, are sufficiently rugged. In other cases, the risk from ELAP/LUHS scenarios may occur due to the low capacity of one or more components. The SPRA can be used to target the most effective means to enhance plant safety and provide reasonable protection of the integrated plant mitigation capability.

Industry is developing a systematic process that uses the insights from the plant-specific SPRAs to identify where enhancements to plant mitigation strategies provide the potential for significant improvement in plant safety. The industry guidance being developed in NEI 12-06 utilizes a risk-informed process that considers small changes in risk defined in integrated decision-making process outlined in RG 1.174 and credits the defense-in-depth attributes of the plant design, including redundancy, diversity, and radiological release barriers.

Defense in depth and diversity are addressed implicitly in the SPRA by conservatively considering the capacities of the relevant redundant systems and features that protect the reactor. Barrier redundancy is addressed by consideration of both the core damage and the large early release insights.

Therefore, for plants that have performed an SPRA, the results provide detailed plant-specific insights into the seismically-induced scenarios that can impact plant safety. These insights can, in turn, assist the plant in understanding the specific susceptibilities to ELAP/LUHS scenarios that the mitigating strategies implemented under EA 12-049 are targeted to address. Plants can utilize the results and insights from an SPRA to identify the degree to which protection for the reevaluated seismic hazard is achieved. Because the SPRA considers the reevaluated seismic hazard, it also provides insights into whether these mitigation strategies should be enhanced. If the SPRA demonstrates that the risk from ELAP/LUHS scenarios that the mitigation strategies implemented under EA 12-049 are intended to address is low, the mitigating strategies developed per NEI 12-06 would be determined to be adequate for the reevaluated hazard. The proposed rule language appears broad enough to allow a licensee to satisfy proposed section 50.155(c)(2)(i) by demonstrating that the risk from ELAP/LUHS scenarios is sufficiently low. However, to make this point more explicit the industry is suggesting proposed rule language in 50.155(b)(1)(i)(d).

Implementation guidance to support this risk-informed demonstration of reasonable protection of mitigating strategies equipment for the reevaluated hazard will be provided in a subsequent revision to NEI 12-06. Goes with NEI SR-13 and 14]

16

Attachment 3: Responses to Questions in Sections VI and XI 10.) Command and Control

[The industry prefers that the expansion of scope of regulatory oversight of the organizational structures be accomplished through the imposition of a new requirement, as currently proposed, and not by communicating the understanding that the scope of the existing requirements covers the full spectrum of events that would be included in this rulemaking. In general, we believe that there should be a clear demarcation between response planning and capabilities described in a site emergency plan, associated with the requirements of 10 CFR 50 Appendix E, and those for beyond design basis events to be governed by proposed 10 CFR 50.155. This separation facilitates better understanding of the underlying requirements and planning bases for various program elements, and the application of change control processes. NEI SR-17]

17

Attachment 3: Responses to Questions in Sections VI and XI Cumulative Effects of Regulation Questions (FRN Section XI) 1.) Rule Compliance Dates

[The rule language in 50.155(g)(1) would require that each holder of an operating license comply with all provisions of this section no later than 2 years following the effective date of the rule. As noted in our response to (refer to response to prior question), this timeframe is not adequate.

The degree to which the reevaluated seismic or flooding hazard(s) may impact the implementation of mitigating strategies varies widely across the operating reactor fleet, and the various evaluations necessary to prepare for any necessary modifications are in different stages of completion, for example:

• Some sites have not yet finished their flooding hazard reevaluations: These situations are due to work that must be completed by the US Army Corps of Engineers.

• Some sites have simple evaluations: A number of sites have reevaluated hazards that are bounded by the design basis of the facility and the level of effort to demonstrate compliance with the proposed rule may be complete in advance of the effective date of the rule.

• Some sites will need to complete additional evaluations: These sites have reevaluated hazards that exceed the design basis of the facility. They must perform detailed Mitigating Strategies Assessments or MSAs in order to evaluate the effect of the external hazard on their mitigating strategies.

• Some sites still must develop the methodology needed to perform their MSAs: For example, the input for Seismic MSAs that use Path 5 (SSE greater than 2xSSE) may be risk-informed based upon a seismic PRA, which is currently in progress. A two year implementation timeline would not provide adequate time for review of the SPRA results by the NRC Staff prior to completion of modifications under the Rule.

Completion of the engineering, design, planning and installation of any identified modifications or other plant changes is a complex process; sufficient time should be provided to completed the work efficiently, for example:

• Utilities will not start the modification process until their MSAs have been approved by the NRC (note that utilities will not start this process when their hazard report results have been approved as stated on page 70634 of the FRN because it is the MSA that will determine the results of the hazard on mitigating strategies, not the hazard report.) At this point they will need to prepare, plan, and implement the necessary modifications or procedure changes and train their staff. Some of the plant modifications will require access to plant equipment or spaces that are not available except during outages.

• If greater than minor modifications are indicated, a two year implementation window would tend to require that the modifications be performed at risk or fast-tracked, where engineering/design would be performed in parallel with installation of the change. This is inefficient and increases the risk for errors and rework.

18

Attachment 3: Responses to Questions in Sections VI and XI Therefore, the industry suggests that each holder of an operating license submit a schedule for achieving full compliance with the requirements of 50.155 within 90 days from the effective date of the rule.

50.155(g)(1) - Each holder of an operating license under this part on [EFFECTIVE DATE OF FINAL RULE] shall submit to the U.S. Nuclear Regulatory Commission a schedule for achieving full compliance with the requirements of 50.155 no later than 90 days following [EFFECTIVE DATE IF THE FINAL RULE]. NEI CER-1]

In addition, [to address the potential for rule compliance date issues for new plants, we suggest revising proposed Part 50, Appendix E, VII.1.b as follows:

b. A holder of a combined license issued under 10 CFR part 52 before the Commission has made the finding under § 52.103(g) of this chapter shall perform this analysis and submit it to the NRC under

§ 52.3 of this chapter at least 2 years before the date specified for completion of the last inspections, tests, and analyses in the inspections, tests, analyses, and acceptance criteria (ITAAC) completion schedule required by § 52.99(a) of this chapter for the plant OR [DATE 365 DAYS AFTER EFFECTIVE DATE OF THE FINAL RULE], whichever is later. NEI CER-2]

19

Attachment 3: Responses to Questions in Sections VI and XI 2.) CER Challenges

[The circumstances of each plant in implementing the proposed rule requirements will be unique and there will be instances where additional time for full implementation of rule requirements will be necessary. In these instances it is incumbent upon the licensee to request modification of implementation dates through existing processes (e.g., 10 CFR 50.12 and 10 CFR 50.90) with sufficient supporting basis for the change. It is equally important, as directed by the Commission in its response to SECY 15-0050, that NRC apply risk-informed decision-making in its review of such relief requests. NEI CER-3]

20

Attachment 3: Responses to Questions in Sections VI and XI 3.) Implementation

[There likely will be instances where conflicts will arise in the implementation of the proposed rules requirements. In these cases it will be important for NRC to allow licensees the latitude to resolve the conflicts in a manner that best meets the objectives of safety and security. Plants should be allowed to prioritize regulatory activities where conflicts in schedule are identified or provide alternative means for compliance in instances where conflicts require an alternative to be established. NRC should review and approve such requests through existing processes. NEI CER-4]

21

Attachment 3: Responses to Questions in Sections VI and XI 4.) Unintended Consequences

[There may be unintended consequences that result from the proposed new requirements if the NRC does not set forth a transparent transition from Orders EA-12-049 and EA-12-051 to 10 CFR 50.155. Some licensees have already achieved compliance with Orders EA-12-049 and EA-12-051 in accordance with JLD-ISG-2012-01 Rev. 0, and JLD-ISG-2012-03 Rev. 0, and their associated NEI guidance documents. 10 CFR 50.155 and the RGs associated with DG-1301, and DG-1317 may specify actions that are additional to, and/or different from, the actions required by the JLDs to achieve to compliance with the NRC Orders. 10 CFR 50.155 and the associated RGs also may specify actions that are less restrictive than the corresponding actions needed for compliance with the orders. It is not clear if and when compliance with Orders EA-12-049 and EA-12-051 will no longer be required following issuance of 10 CFR 50.155 and the associated RGs. To avoid unintended consequences associated with two similarbut potentially not identicalsets of requirements, the NRC should rescind Orders EA-12-049 and EA-12-051 once § 50.155 becomes effective. See, e.g., 78 Fed. Reg. 16,922 (Mar. 19, 2013) (discussing the rescission of orders following issuance of 10 C.F.R. Part 37). For the same reasons, the NRC should formally close out its § 50.54(f) information requests and eliminate license conditions that duplicate requirements currently in § 50.54(hh)(2). NEI CER-5]

22

Attachment 3: Responses to Questions in Sections VI and XI 5.) Regulatory Analysis

[The Commission properly concluded that the imposition of SAMG requirements is unwarranted and that SAMGs should continue to be implemented through a voluntary industry initiative.

The industry agrees with the Commissions decision against including requirements that would, in essence, codify the industry initiative on severe accident management guidelines (SAMGs). NEI SR-18] [Although the draft regulatory analysis properly rejects the option of including a SAMG requirement in the regulations, it contains statements that could mislead the public on the status and strength of industrys SAMG initiative. Specifically, the draft regulatory analysis claims that new information reveals that the industrys SAMG initiative was not entirely successful.2 According to the draft regulatory analysis, this means that the NRC cannot have a sufficient level of regulatory assurance that SAMGs will be updated and maintained over time and that licensees will maintain their capability to effectively implement SAMGs absent a regulatory requirement for SAMGs.3 This conclusion is incorrect and fails to mention post-Fukushima improvements to the industrys approach to SAMGs. By letter dated October 26, 2015, the industry informed the NRC that NEIs Nuclear Strategic Issues Advisory Committee (NSIAC) recently approved an industry initiative on SAMGs.4 Under this new initiative, each licensee will perform timely updates of their site-specific SAMGs based on revisions to Owners Group generic severe accident technical guidelines. Licensees will also ensure that SAMGs are considered within plant configuration management processes, integrated with other emergency response guideline sets and symptom-based EOPs and validated. To begin implementation of this industry initiative, each licensee has sent a letter to the NRC docketing their site-specific commitments. To ensure the final regulatory analysis is accurate, the NRC should accurately reflect the current status of the industry initiative on SAMGs.

In our May 11, 2015 letter, NEI also expressed industrys generic concern with the misuse of qualitative information to support regulatory decisions and provided a detailed discussion of how the proposal to incorporate SAMGs into the proposed rule exemplified such misuse.5 The Commissions decision not to include the SAMG requirement in the proposed rule strikes the appropriate balance in considering the available quantitative information, as well as qualitative considerations.

The Commissions decision is consistent with the agencys internal guidance on management of industry commitments, which is provided in NRR Office Instruction Managing Regulatory Commitments Made by Licensees to the NRC, LIC-105, Rev. 5 (Sept. 5, 2013). As explained in the Federal Register notice soliciting public comment on the proposed rule, although not required by NRC regulations SAMGs are well established guidance documents that have been developed by the 2

NRC, Regulatory Analysis, Proposed Rulemaking to Address Mitigation of Beyond-Design-Basis Events, at p 60 (Oct. 2015).

3 Id.

4 Letter from A. Pietrangelo (NEI) to M. Johnson, Industry Initiative to Maintain Severe Accident Management Guidelines, Oct. 26, 2015.

5 Letter from A. Pietrangelo (NEI) to M. Satorius, Use of Qualitative Factors in Regulatory Decision Making, May 11, 2015.

23

Attachment 3: Responses to Questions in Sections VI and XI nuclear power industry with substantial NRC involvement, have been implemented by every operating nuclear power reactor licensee for decades, and are the subject of a license condition for combined licenses.6 Further, the industry has committed to strengthening its SAMG program since the Fukushima accident.7 LIC-105 reinforces the continued importance of regulatory commitments in the NRCs regulatory scheme, stating:

Issues concerning the use of regulatory commitments usually center on the legal standing of the commitment and the NRC staffs ability to enforce the action committed to by a licensee.

The staff determined that keeping regulatory commitments as an element of licensing basis information should continue because, when handled properly, the commitments support the overall licensing process by adding flexibility, improving efficiency, and maintaining the flow of information between the staff and licensees. These advantages usually outweigh concerns that a licensee is not legally bound to fulfill and subsequently control an action appropriately classified as a regulatory commitment. Various assessments performed by the NRC staff supported this view. See, for example, the Assessment of Regulatory Processes That Utilize Regulatory Commitments, dated November 26, 2008 (Ref. 5).8 Further, the 2008 Assessment of Regulatory Processes That Utilize Regulatory Commitments cited above provides the following guidance on deciding whether it is appropriate to convert regulatory commitments to obligations (i.e., legally binding requirements):

Consistent with the guidance in SECY-98-224, and the definition of obligation in NRR Office Instruction LIC-100, escalating a licensee commitment into a legally binding regulatory requirement should be reserved for matters that warrant:

(1) inclusion in the technical specifications based on the criteria in 10 CFR 50.36; or (2) inclusion in the license based on determination by the NRC staff that the issue is of high safety or regulatory significance.9 We note that the Commissions decision not to include a SAMG requirement in the proposed rule is also consistent with the criteria provided above. That is, a SAMG requirement would not warrant inclusion in the technical specifications under the criteria provided in § 50.36 and - given the results of the regulatory and backfitting analyses provided with the proposed rule - would not rise to the level of high safety or regulatory significance.

We encourage the NRC to keep the guidance provided in LIC-105, as well as the historical references supporting that document, in mind when evaluating issues associated with the management of industry commitments. NEI SR-19]

[The NRC has failed to justify invoking the adequate protection backfit exception to impose the new multiple source term dose assessment requirement.

The proposed rule and regulatory analysis properly recognizes that the new requirement to monitor and assess multiple source terms constitutes a backfit.10 But rather than perform a systematic and 6

80 Fed. Reg. 70,610, 70,616.

7 See id. at 70,617.

8 LIC-105, at pg. 1.

9 Assessment of Regulatory Processes That Utilize Regulatory Commitments, (Nov. 26, 2008), at pg. 11.

10 See 80 Fed. Reg. at 70,638; Regulatory Analysis at p. 2.

24

Attachment 3: Responses to Questions in Sections VI and XI documented analysis demonstrating that this new requirement will result in a cost-justified substantial increase in safety, the NRC has invoked backfit exception in 10 C.F.R. § 50.109(a)(4)(ii) for regulatory actions that are necessary to ensure that the facility provides adequate protection to the health and safety of the public. As discussed below, the draft regulatory analysis fails to demonstrate that this proposed new requirement warrants invoking the adequate protection exception.

An NRC decision to invoke the adequate protection exception is an extremely significant decision.

Because NRCs regulations are presumed to ensure adequate protection, that presumption can be overcome only by significant new information or some showing that the regulations do not address some significant safety issue.11 Such occurrences should be rare and only after careful deliberation by the Commission. As Commissioner Ostendorff observed: This agency must vigilantly ensure that the memory of Fukushima Daiichi does not result in loose interpretations of our adequate protection mandate. Fukushima Daiichi was a terrible accident, and that should never be forgotten. But what also should not be forgotten is that it was an accident that occurred in another countrya country with a different regulatory structure and a different regulatory culture. I have not seen any evidence that suggests our current regulatory structure in the United States is broken or that there is any need to divert from the stable, predictable way that the NRC evaluates issues. The NRC must adhere to its well-proven approach to regulation. If we do not, the regulations will be only as predictable as the five individuals carrying the title Commissioner.12 While the operating experience at Fukushima Daiichi demonstrated that the ability to assess multiple source terms could help plant personnel prioritize emergency actions after a beyond-design-basis external event, the draft regulatory analysis does not show that the absence of such capabilities during the Fukushima accident contributed in any way to radiological consequences. Given the extensive, required actions that licensees are already taking in the name of adequate protection to mitigate beyond-design-basis external events, the NRC should not use this exception to tack on an additional, less significant requirement. To be sure, the industry decided after Fukushima to voluntarily implement multiple source term dose assessment capabilities. But this voluntary action does not give the NRC a free pass to lower the threshold for an adequate protection decision. Yet the draft regulatory analysis fails to explain why this new requirement, on top of the extensive required and voluntary actions already being undertaken to address beyond-design-basis external events, is necessary to ensure adequate protection.

Instead of providing a reasonable justification for invoking the adequate protection exception, the draft regulatory analysis discusses existing emergency preparedness requirements. It then claims that this new requirement is considered to be part of the essential emergency preparedness regulatory infrastructure that is required to meet current emergency preparedness regulatory objectives, and as such, is considered part of the set of emergency preparedness requirements to provide reasonable assurance of adequate protection of public health and safety, consistent with the 11 See Final Rule, Revision of Backfitting Process for Power Reactors, 53 Fed. Reg. 20,603, 20,608 (June 6, 1988).

12 Commissioner W.C. Ostendorff & K.A. Sexton, Adequate Protection After the Fukushima Daiichi Accident: A Constant in a World of Change, OECD Nuclear Law Bulletin, No. 91, Vol. 1, p.21 (Sept.

2013).

25

Attachment 3: Responses to Questions in Sections VI and XI regulatory basis for emergency preparedness that has existed for more than three decades.13 These unsupported, conclusory statements about meeting current emergency preparedness regulatory objectives are insufficient to support an adequate protection finding.

In summary, the draft regulatory analysis fails to overcome the presumption that current regulations and orders currently ensure adequate protection because it identifies no significant safety issue that is going unaddressed. On top of the extensive, required actions that licensees are already taking, the industry is voluntarily implementing multiple source term dose assessment capabilities to assist in the mitigation of remote, yet potentially serious beyond-design-basis external events. Rather than place these actions in their proper context, the draft regulatory analysis offers generic platitudes about meeting existing emergency preparedness regulatory objectives. Accordingly, the NRC has not justified using the adequate protection exception and should not impose this new requirement absent an analysis demonstrating that it will result in a cost-justified substantial increase in safety.

NEI SR-20]

13 Regulatory Analysis at p. 54-55.

26

NEI 13-06 [Revision 1]

Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents

February 2016

[BLANK PAGE]

NEI 13-06

[Revision 1]

Nuclear Energy Institute Enhancements to Emergency

Response

Capabilities for Beyond Design Basis Events and Severe Accidents

February 2016 ACKNOWLEDGMENTS This document was developed by the Nuclear Energy Institute (NEI) Emergency Preparedness (EP) Working Group with assistance from the Beyond Design Basis (BDB) Event Response Drill Task Force.

NEI BDB Event Response Drill Task Force NEI Chairperson: David Young Industry Members:

Walt Lee - TVA Nuclear/Corporate Nick Pappas - APS/Palo Verde Nuclear Generating Station Mike Slobodien - PSEG Nuclear/Salem and Hope Creek Brian Trimble - Exelon Nuclear/Corporate Mary Ann Wilson - Entergy Nuclear/Corporate NOTI CE Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.

NEI 13-06 (Revision 1)

February 2016 EXECUTIVE

SUMMARY

This technical report provides guidance for the completion of actions necessary to address the Tier 2 Emergency Preparedness (EP) enhancements identified in US Nuclear Regulatory Commission (NRC) Report, Recommendations for Enhancing Reactor Safety in the 21st Century

[The Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident].1&2 These actions reflect the approach discussed in COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, and related NRC staff and Nuclear Energy Institute (NEI) documents. Specifically, the NRC staff determined that certain Tier 2 EP items are being addressed adequately through implementation of NRC Order EA 049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events.

Order EA-12-049 addresses NRC NTTF Report Recommendation 4 and stemmed directly from Recommendation 4.2. The activities undertaken by the industry to comply with the Order will resolve two of the three Tier 2 items contained in NRC NTTF Report Recommendation 9.3; these items are periodic training and drills, and EP equipment and facilities, both associated with responses to a multi-unit and/or extended loss of AC power event.3 The remaining Tier 2 item from Recommendation 9.3 deals with multi-unit dose assessment capability and is not within scope of Order EA-12-049 activities.

NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, provides guidance on the format and content of licensee responses to Order EA-12-049. The guidance also covers information related to FLEX deployment, including training and drills, and equipment and facility topics captured in Recommendation 9.3. For example, NEI 12-06, states, Where appropriate, the integrated FLEX drills should be organized on a team or crew basis and conducted periodically; with all time-sensitive actions to be evaluated over a period of not more than eight years. It further states, Periodic training should be provided to site emergency response leaders on beyond design-basis emergency response strategies and implementing guidelines, and procedures/guidance should identify the protective clothing or other equipment or actions necessary.

In addition, NEI 12-06 recommends utilization of the staffing and communication resources identified in NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities. The latter document was developed to address the two Tier 1 topics from Recommendation 9.3 - staffing and communications. NEI 12-01 states,

[a] licensee should identify additional work areas necessary for the performance of expanded response functions. The use of alternate emergency response facilities should be considered.

This statement addresses the facilities needed to house the response staff.

1 This report is commonly referred to as the NRC NTTF Report.

2 The tier assignments made to the EP enhancements are discussed in SECY-11-0137, Prioritization of i

Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011 3

Staff documents may refer to an extended loss of AC power as a prolonged Station Blackout (SBO).

i

NEI 13-06 (Revision 1)

February 2016 With the preceding in mind, NEI and the industry have created this technical report to promote consistent implementation of the actions that address the Tier 2 EP enhancements discussed above.

Three of the topics addressed by COMSECY-13-0010 are also relevant to NRC NTTF Recommendation 8. These topics are training, drills and exercises, and they are discussed in an NRC document entitled, Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013.4 The Recommendation 8 regulatory basis was subsequently incorporated into Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015, with changes directed by the NRC Commissioners in Staff Requirements - SECY-15-0065 -

Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015. In recognition of the interrelationship between of the discussions presented in the COMSECY, the regulatory basis and the proposed rule, and the desirability of having well-integrated guidance, this document addresses training, and drills and exercises for beyond design basis events and severe accidents.

Finally, fleet and site leadership teams should carefully consider which department(s) will be assigned a responsibility for addressing one or more of the EP and emergency response-related enhancements discussed in this document. It is important that leadership teams have a full understanding of the requirements related to EP and Beyond Design Basis (BDB) emergency response capabilities in order to identify potential gaps in organizational knowledge, skill sets, and alignment/coordination that could impact sustainability. In particular, opportunities to leverage organizational resources and synergies in order to improve performance should be pursued.

4 Available on regulations.gov; see Docket ID: NRC-2012-0031.

ii

NEI 13-06 (Revision 1)

February 2016 TABLE OF CONTENTS EXECUTIVE

SUMMARY

............................................................................... i 1 INTRODUCTION ................................................................................... 1 1.1 SCOPE AND PURPOSE OF NEI 13-06 ................................................................................ 1 2 MULTI-UNIT DOSE ASSESSMENT ....................................................... 3 2.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS ......................... 3 2.2 RELATED REFERENCE DOCUMENTS ............................................................................... 3 2.3 RECOMMENDED ACTIONS ................................................................................................ 3 3 TRAINING ............................................................................................ 6 3.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS ......................... 6 3.2 RELATED REFERENCE DOCUMENTS ............................................................................... 7 3.3 RECOMMENDED ACTIONS ................................................................................................ 8 4 EP FACILITIES AND EQUIPMENT ..................................................... 11 4.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS ....................... 11 4.2 RELATED REFERENCE DOCUMENTS ............................................................................. 12 4.3 RECOMMENDED ACTIONS .............................................................................................. 12 5 DRILLS AND EXERCISES................................................................... 14 5.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS ....................... 14 5.2 RELATED REFERENCE DOCUMENTS ............................................................................. 15 5.3 RECOMMENDED ACTIONS .............................................................................................. 15 6 REFERENCES..................................................................................... 27 APPENDIX A - BDB EVENT RESPONSE DRILL OBJECTIVES

.........................................A-1 APPENDIX B - EXAMPLE MITIGATION STRATEGY LIST

.................................................B-1 3

NEI 13-06 (Revision 1)

February 2016

[BLANK PAGE]

4

NEI 13-06 (Revision 1)

February 2016 ENHANCEMENTS TO EMERGENCY RESPONSE CAPABILITIES FOR BEYOND DESIGN BASIS EVENTS AND SEVERE ACCIDENTS 1 INTRODUCTION 1.1 SCOPE AND PURPOSE OF NEI 13-06 This technical report provides guidance for the performance of licensee actions that will address certain aspects of recommendations contained in US Nuclear Regulatory Commission (NRC) Report, Recommendations for Enhancing Reactor Safety in the 21st Century [The Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident]. The specific recommendations are:

• Recommendation 4.2 - Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design basis external events and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.

• Recommendation 8.1 - Order licensees to modify the EOP technical guidelines (required by Supplement 1, Requirements for Emergency Response Capability, to NUREG-0737, issued January 1983 (GL 82-33), to (1) include EOPs, SAMGs, and EDMGs in an integrated manner, (2) specify clear command and control strategies for their implementation, and (3) stipulate appropriate qualification and training for those who make decisions during emergencies.

• Recommendation 8.4 - Initiate rulemaking to require more realistic, hands-on training and exercises on SAMGs and EDMGs for all staff expected to implement the strategies and those licensee staff expected to make decisions during emergencies, including emergency coordinators and emergency directors.

• Recommendation 9.3 [relevant wording excerpted] - Order licensees to do the following until rulemaking is complete:

o Add guidance to the emergency plan that documents how to perform a multiunit dose assessment (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.

o Conduct periodic training and exercises for multiunit and prolonged SBO [Station Blackout] scenarios. Practice (simulate) the identification and acquisition of offsite resources, to the extent possible.

o Ensure that EP equipment and facilities are sufficient for dealing with multiunit and prolonged SBO scenarios.

These recommendations were subsequently evaluated by the NRC staff and refined into various regulatory positions and actions. NEI 13-06 addresses the positions and actions 1

discussed in COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned. The topics in the COMSECY include multi-unit dose assessment, training, EP facilities and equipment, and drills and exercises.

2

NEI 13-06 (Revision 1)

February 2016 Additionally, the COMSECY makes reference to certain topics that are also within the scope of Recommendation 8; these topics are training, drills and exercises related to implementation of FLEX Support Guidelines (FSGs), Severe Accident Management Guidelines (SAMGs) and Extensive Damage Mitigation Guidelines (EDMGs). In recognition of the need for well-integrated guidance, NEI 13-06 addresses the training, and drill and exercise aspects of the COMSECY and Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015. The latter reflects changes directed by the NRC Commissioners in Staff Requirements - SECY 0065 - Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015.

Finally, this document uses the term FLEX Support Guidelines or FSGs to connote the document(s) developed or enhanced in response to NRC Order EA-12-049, Order Modifying Licenses with regard to Requirements for Mitigating Strategies for Beyond Design Basis External Events, and which describe/direct the operator and field actions necessary to implement mitigating strategies in response to a beyond design basis external event. Depending upon Owners Group guidance, and fleet and site standards, these actions may be contained in a document(s) with a different name. Each licensee should ensure that their appropriate site-specific documents are utilized when addressing the FLEX-related guidance contained in this document.

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February 2016 2 MULTI-UNIT DOSE ASSESSMENT 2.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS 2.1.1 Recommendation 9 The Task Force recommends that the Commission direct the staff to do the following:

9.3 Order licensees to do the following until rulemaking is complete:

Add guidance to the emergency plan that documents how to perform a multiunit dose assessment (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.

2.2 RELATED REFERENCE DOCUMENTS SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011 NEI Letter, Industry Implementation of Multi-unit Dose Assessment Capability, Pollock to Wiggins, dated January 28, 2013 NRC Letter, Wiggins to Pollock, dated February 27, 2013 NEI Letter, Commitment for Implementation of Multi-Unit Dose Assessment Capability, Pollock to Wiggins, dated March 14, 2013 NEI Letter, Commitment for Implementation of Multi-Unit Dose Assessment Capability, Pietrangelo to Nuclear Strategic Issues Advisory Committee Steering Group, dated March 22, 2013 COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 Site-specific letter to NRC staff concerning the intent to implement multi-unit (source) dose assessment capability, dated on or around June 30, 2013 Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015 2.3 RECOMMENDED ACTIONS 2.3.1 Industry Performance Standard for Multi-Unit Dose Assessment 4

All single and multi-unit sites should establish the capability to perform offsite dose assessments during an event involving concurrent radiological releases from all on-site 5

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February 2016 units and/or multiple release points (i.e., whether from one or multiple units5), consistent with the description contained in the site-specific licensee letter to the NRC staff dated on or around June 30, 2013.

The multi-unit dose assessment capability should be computerized (i.e., offsite dose projections are generated using a computer-based model), and reflect the normally expected use of radiological and meteorological indications, e.g., incorporated into the sites emergency dose projection software as an assessment option. It should be available to support responses during events both within and beyond the plant design basis. In particular, the capability should exist to project offsite doses during an event involving an extended loss of AC power affecting all onsite units.

In addition to the normally used calculation methods and input indications, the capability should also accommodate the use of alternate methods and indications to address instances when normal data sources may be unavailable. For example, in cases where a plant vent radiation monitor is non-functional, a dose projection model might have the capability to project offsite doses based on a source term derived from a dose rate measurement in the plant or field. Or if onsite meteorological data is not available, then dose assessments are performed using parameter values obtained from a pre-identified near-site source or the National Weather Service.

A licensee may elect to also include a backup method (e.g., a manual method) to supplement the computerized method discussed above; if this option is pursued, the backup method should be capable of producing results within a reasonable time period (e.g., within about 30 minutes). In addition, consideration should be given to establishing a procedurally-driven peer/second person check of manually derived output, where warranted.

Implementation of this enhancement may necessitate the addition of a backup power source (e.g., an uninterruptable power supply) to onsite dose assessment computing platforms or ensuring the availability of computing platforms at locations away from the site (e.g., at an ERO alternate facility or an Emergency Operations Facility). It does not require the installation of new, or modification of existing, plant equipment such as radiation monitors, flow detectors and meteorological instrumentation (including associated data processors and power sources).

Each licensee should discuss their capability to perform multi-unit dose assessment with the appropriate Offsite Reponses Organization (ORO) agency officials, and determine if any changes are necessary to ORO plans and procedures.

2.3.2 Emergency Classification and Protective Action Recommendations Multi-unit dose assessment results should be assessed in accordance with the licensees existing emergency classification scheme and Protective Action Recommendation (PAR) decision-making process.

5 This topic is referred to as multi-unit dose assessment for ease of reading; however, it should be understood to mean the capability to assess concurrent releases from multiple release sources/points such as reactor cores and spent fuel pools. It is therefore applicable to single-unit sites as well.

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NEI 13-06 (Revision 1)

February 2016 Each licensee should verify that the capability exists to issue a PAR for appropriate areas beyond the Emergency Planning Zone (EPZ) boundary, in accordance with existing regulatory requirements and guidance.

Consideration should be given to addressing the following points in the site-specific procedure or guideline that implements the multi-unit dose assessment capability.

• Projected offsite doses should be compared against the Emergency Action Levels (EALs) to determine if a change in the emergency classification is warranted.

• Projected offsite doses should be compared against appropriate decision-making criteria to determine if a change in PARs is warranted.

2.3.3 Training Each licensee should provide training to the personnel responsible for performing a multi-unit dose assessment. Training materials, delivery methods and frequencies, and evaluation techniques should be developed using established Systematic Approach to Training (SAT) processes.

2.3.4 Performance Enhancing Experience Periodic opportunities for a performance enhancing experience should be provided to personnel responsible for performing multi-unit dose assessment and assessing the results. Such opportunities may include performance during a drill or exercise (as an in sequence or out-of-sequence activity) or a separate/stand-alone mini-drill. These opportunities should be provided consistent with the extent-of-play and methods normally used to implement mini-drills, drills or exercises involving a demonstration of dose assessment capabilities.

2.3.5 Quality and Maintenance-Related Requirements Equipment and software used to implement a multi-unit dose assessment capability should be procured and installed under the commercial and site requirements normally applicable to the EP Program.

Programmatic controls should be applied to appropriate equipment and software to ensure availability and reliability, including the performance of periodic inventory checks and functionality testing.

2.3.6 Considerations for Program Documents A capability for performing multi-unit dose assessment need not be described in the site emergency plan; however, this capability should be described in a document maintained through a fleet or site document control process. The document should be retained for the life of the plant.

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NEI 13-06 (Revision 1)

February 2016 3 TRAINING 3.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS 3.1.1 Recommendation 4 The Task Force recommends that the Commission direct the staff to begin the actions given below to further enhance the ability of nuclear power plants to deal with the effects of prolonged SBO conditions at single and multiunit sites without damage to the nuclear fuel in the reactor or spent fuel pool and without the loss of reactor coolant system or primary containment integrity.

4.2 Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design-basis external events and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.

• This existing equipment currently provides some of the coping capability that is recommended for the long term, but current storage requirements do not ensure that it will be available after a design-basis external event. This requirement would increase the likelihood that the equipment will be available if called upon.

• The staff should also consider conforming changes to the requirements in 10 CFR 50.54(hh)(2) to address multiunit response capacity.

3.1.2 Recommendation 8 The Task Force recommends that the Commission direct the staff to further enhance the current capabilities for onsite emergency actions in the following ways:

8.1 Order licensees to modify the EOP technical guidelines (required by Supplement 1, Requirements for Emergency Response Capability, to NUREG-0737, issued January 1983 (GL 82-33), to (1) include EOPs, SAMGs, and EDMGs in an integrated manner, (2) specify clear command and control strategies for their implementation, and (3) stipulate appropriate qualification and training for those who make decisions during emergencies.

8.4 Initiate rulemaking to require more realistic, hands-on training and exercises on SAMGs and EDMGs for all staff expected to implement the strategies and those licensee staff expected to make decisions during emergencies, including emergency coordinators and emergency directors.

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NEI 13-06 (Revision 1)

February 2016 3.1.3 Recommendation 9 The Task Force recommends that the Commission direct the staff to do the following:

9.3 Order licensees to do the following until rulemaking is complete:

Conduct periodic training and exercises for multiunit and prolonged SBO scenarios.

Practice (simulate) the identification and acquisition of offsite resources, to the extent possible.

3.2 RELATED REFERENCE DOCUMENTS SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011 NRC letter, Request for Information 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, dated March 12, 2012 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 NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012 NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012 NRC 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, dated August 29, 2012 Site-specific letter to NRC staff transmitting results of a communications assessment performed in response to NRC 50.54(f) letter; initial letter dated on or around October 31, 2012 and a possible follow-up letter dated on or around February 28, 2013 COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 Site-specific letter to NRC staff transmitting results of a first-phase staffing assessment performed in response to NRC 50.54(f) letter, dated on or around April 30, 2013; a second-phase staffing assessment is due to the NRC staff no later than 4 months prior to the beginning of the second refueling outage (as described in the site response to NRC Order EA-12-049 9

NEI 13-06 (Revision 1)

February 2016 Site-specific Integrated Plan for implementing NRC Order EA-12-049 Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013 Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015 3.3 RECOMMENDED ACTIONS 3.3.1 BDB Event Response Training Each licensee should provide training to the key personnel relied upon to implement the procedures and guidelines for responding to a beyond design basis event or severe accident, including the site-specific integrated use of FLEX Support Guidelines (FSGs),

Extensive Damage Mitigation Guidelines (EDMGs) and Severe Accident Management Guidelines (SAMGs).6 Training materials, delivery methods and frequencies, and evaluation techniques should be developed using established processes that address the Systems approach to training (SAT) elements listed in 10 CFR 55.4, except for elements already covered under other NRC regulations. Training on these common elements can be addressed in a non-SAT training program that is acceptable for meeting regulatory required training (e.g., 10 CFR part 50, appendix E, section IV.F). Position-specific qualification requirements should also be identified, as appropriate.

The primary focus of licensed operator initial and requalification training programs should continue to be on developing and maintaining the knowledge, skills and abilities of operators to implement the Emergency Operating Procedures (EOPs). This goal should be balanced with the need to provide the additional SAT-based training necessary to ensure that operators have the capability to respond to a beyond design basis event or severe accident in accordance with site-specific strategies. Site administrative controls should be established to ensure that an individual has successfully completed all required training prior to assuming a licensed operator position on-shift (e.g., training could be performed after receipt of an initial operator license but before being assigned on-shift duties in the Control Room).

The SAT process may identify operator knowledge, skills and abilities necessary for the execution of site-specific FSG, EDMG and SAMG strategies beyond those associated with the Knowledge and Abilities (K/As) described in NRC guidance documents (e.g.

from NUREG-1122 or NUREG-1123). These items should be included in and evaluated as part of stations SAT-based training program.

Dynamic exams may be used consistent with simulator capabilities.

In addition to licensed operators, training should be provided to other licensee personnel with supporting responsibilities, including:

6 This training may be accomplished in different settings since implementation of some emergency response procedures and guidelines are dependent upon the nature of the postulated initiating event, the plant response/accident sequence, and the ability of responders to select and implement mitigation/management strategies.

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• Non-licensed operators, health physics staff, maintenance personnel, and other positions that would be called upon to perform implementing tasks.

• Support staff that would be evaluating plant conditions and recommending appropriate accident mitigating and management strategies for implementation.

• Personnel who would be requesting and coordinating the delivery of Final Phase (Phase 3) mitigating strategy equipment from an offsite location (e.g., from the National SAFER Response Center).

Training and qualification elements may be incorporated into a new training program, into an existing training program(s), or a combination of both. Non-SAT training programs that meet the needs for common elements do not need to be revised to use the SAT process.

The development of training and qualification requirements and materials should consider the degree to which the knowledge and abilities normally expected of a given position can be readily applied to an assigned task. Development should also recognize the availability of job/user aids and built-in equipment/hardware features that can improve human performance during stressful or adverse conditions (e.g., color coding, standardized connections, etc.).

Training program developers should assess and implement reasonable methods that may be used to facilitate practice at performing tasks under expected adverse conditions. The use of these methods should maintain an appropriate focus on the safety of plant personnel and equipment.

3.3.2 Plant-Referenced Simulator The fidelity of the plant-referenced simulator should be maintained in accordance with 10 CFR 55.46 as additional equipment is installed in the facility and utilized to support operation. Certification of simulator fidelity in accordance with ANSI/ANS-3.5, Nuclear Power Plant Simulators for Use in Operator Training and Examination, if used, is considered to be sufficient for the initial stages of a beyond-design-basis external event scenario until the existing capability of the simulator model is exceeded. Increasing the capability of the plant-referenced simulator to specifically model conditions associated with a beyond design basis event or severe accident is not required (e.g., models need not be upgraded to accommodate FLEX training or drills). Voluntary upgrades to one or more model aspects (e.g., instrumentation responses) may be performed using a best estimate basis for the modelling.

3.3.3 Ultimate Decision-Maker Qualifications As part of the required planning for responses to emergency conditions, each licensee has established a command and control structure for their Emergency Response Organization (ERO). Within this structure, there should be a position(s) with the assigned authority and responsibility for providing overall direction on the implementation of EOPs, FSGs, EDMGs and SAMGs for a unit or set of units; this authority and responsibility is referred 11

NEI 13-06 (Revision 1)

February 2016 to as the Ultimate Decision-Maker (UDM) function.7 Qualification requirements should be developed for the position(s) performing this function. These requirements should ensure that each UDM-qualified individual has sufficient technical understanding and leadership ability to make timely and informed decisions during a beyond design basis event or severe accident.

The need for periodic requalification should also be assessed in order to ensure that individuals have maintained the necessary knowledge and skills. Applicable program controls should be updated as necessary to reflect requalification requirements.

3.3.4 Training Development Guidance from Regulatory Responses In addition to the topics discussed above, training programs should also address the training-related actions described in:

• FLEX program implementing documents developed in accordance with NRC Order EA-12-049.

• The communications and staffing assessment responses provided to the NRC staff in accordance with the 50.54(f) letter dated March 12, 2012.

3.3.5 Considerations for Program Documents The training and qualifications for responding to a beyond design basis event or severe accident need not be described in the site emergency plan; however, this material should be described in a document maintained through a fleet or site document control process.

The document should be retained for the life of the plant.

7 The UDM function is described in NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents.

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NEI 13-06 (Revision 1)

February 2016 4 EP FACILITIES AND EQUIPMENT8 4.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS 4.1.1 Recommendation 4 The Task Force recommends that the Commission direct the staff to begin the actions given below to further enhance the ability of nuclear power plants to deal with the effects of prolonged SBO conditions at single and multiunit sites without damage to the nuclear fuel in the reactor or spent fuel pool and without the loss of reactor coolant system or primary containment integrity.

4.2 Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design-basis external events and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.

• This existing equipment currently provides some of the coping capability that is recommended for the long term, but current storage requirements do not ensure that it will be available after a design-basis external event. This requirement would increase the likelihood that the equipment will be available if called upon.

• The staff should also consider conforming changes to the requirements in 10 CFR 50.54(hh)(2) to address multiunit response capacity.

4.1.2 Recommendation 9 The Task Force recommends that the Commission direct the staff to do the following:

9.3 Order licensees to do the following until rulemaking is complete:

Ensure that EP equipment and facilities are sufficient for dealing with multiunit and prolonged SBO scenarios.

8 As used here, EP facilities and equipment refers to those facilities in which ERO members would perform their assigned functions during a Beyond Design Basis event response, and the necessary equipment located therein. It does not include the systems, structures, components or portable equipment used to implement accident mitigating or management strategies described in Abnormal/Emergency Operating Procedures, or FLEX Support, Severe 13

Accident Management or Extensive Damage Mitigation Guidelines.

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NEI 13-06 (Revision 1)

February 2016 4.2 RELATED REFERENCE DOCUMENTS SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011 NRC letter, Request for Information 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, dated March 12, 2012 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 NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012 NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012 NRC 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, dated August 29, 2012 Site-specific letter to NRC staff transmitting results of a communications assessment performed in response to NRC 50.54(f) letter; initial letter dated on or around October 31, 2012 and a possible follow-up letter dated on or around February 28, 2013 COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 Site-specific letter to NRC staff transmitting results of a first-phase staffing assessment performed in response to NRC 50.54(f) letter, dated on or around April 30, 2013; a second-phase staffing assessment is due to the NRC staff no later than 4 months prior to the beginning of the second refueling outage (as described in the site response to NRC Order EA-12-049 Site-specific Integrated Plan for implementing NRC Order EA-12-049 Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015 4.3 RECOMMENDED ACTIONS 4.3.1 Industry Performance Standard for EP Facilities and Equipment Each licensee should implement the Emergency Preparedness (EP) facility and equipment enhancements identified in their communications and staffing assessments provided to the NRC staff in accordance with the 50.54(f) letter.

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NEI 13-06 (Revision 1)

February 2016 For EP facility and equipment enhancements not addressed by the requirements or guidance discussed above, the following approaches are recommended.

• Determine applicable design and configuration control measures.

• Items may be procured and installed under the commercial and site requirements normally applied to EP facilities and equipment.

• For multi-unit sites, ensure that sufficient quantities of radiation protection equipment and supplies are, or can be made, available to support protracted operation of an expanded Emergency Response Organization (ERO).

• Programmatic controls should be developed to ensure the availability and reliability of EP facilities and equipment, including the performance of periodic inventory checks, functionality testing and maintenance.

• Supporting contracts with vendors should be periodically verified.

4.3.2 Considerations for Program Documents The facilities and equipment used exclusively for responding to a beyond design basis event or severe accident need not be described in the site emergency plan; however, these items should be described in a document maintained through a fleet or site document control process. The document should be retained for the life of the plant.

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NEI 13-06 (Revision 1)

February 2016 5 DRILLS AND EXERCISES 5.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS 5.1.1 Recommendation 4 The Task Force recommends that the Commission direct the staff to begin the actions given below to further enhance the ability of nuclear power plants to deal with the effects of prolonged SBO conditions at single and multiunit sites without damage to the nuclear fuel in the reactor or spent fuel pool and without the loss of reactor coolant system or primary containment integrity.

4.2 Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design-basis external events and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.

• This existing equipment currently provides some of the coping capability that is recommended for the long term, but current storage requirements do not ensure that it will be available after a design-basis external event. This requirement would increase the likelihood that the equipment will be available if called upon.

• The staff should also consider conforming changes to the requirements in 10 CFR 50.54(hh)(2) to address multiunit response capacity.

5.1.2 Recommendation 8 The Task Force recommends that the Commission direct the staff to further enhance the current capabilities for onsite emergency actions in the following ways:

8.4 Initiate rulemaking to require more realistic, hands-on training and exercises on SAMGs and EDMGs for all staff expected to implement the strategies and those licensee staff expected to make decisions during emergencies, including emergency coordinators and emergency directors.

5.1.3 Recommendation 9 The Task Force recommends that the Commission direct the staff to do the following:

9.3 Order licensees to do the following until rulemaking is complete:

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NEI 13-06 (Revision 1)

February 2016 Conduct periodic training and exercises for multiunit and prolonged SBO scenarios.

Practice (simulate) the identification and acquisition of offsite resources, to the extent possible.

5.2 RELATED REFERENCE DOCUMENTS SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011 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 NRC letter, Request for Information 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, dated March 12, 2012 NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012 NRC 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, dated August 29, 2012 COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 Site-specific letter to NRC staff transmitting results of a first-phase staffing assessment performed in response to NRC 50.54(f) letter, dated on or around April 30, 2013; a second-phase staffing assessment is due to the NRC staff no later than 4 months prior to the beginning of the second refueling outage (as described in the site response to NRC Order EA-12-049 Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013 Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015 5.3 RECOMMENDED ACTIONS 5.3.1 Industry Performance Standards for BDB Event Response Drills Each licensee should demonstrate the capability for effective integrated use of their accident mitigation and management procedure and guideline sets. In particular, the ability to transition between procedure and guideline sets, and select the best strategy for preventing or mitigating fuel damage and limiting radiological releases, is demonstrated.

Complementary methods will be necessary to accomplish this demonstration since the procedures and guidelines implemented for a given scenario are dependent upon the 18

NEI 13-06 (Revision 1)

February 2016 nature of the postulated initiating event, the plant response/accident sequence, and the ability of responders to select and implement mitigation/management strategies. The use of complementary methods will also promote more effective use of resources (e.g.,

facilitates targeted drill objectives, avoids excessive drill down time and durations, etc.), and minimize potential safety challenges to personnel and equipment. These methods are discussed below and involve conducting:

• A drill that demonstrates the integrated use of FLEX strategies under the control of an Abnormal Operating Procedure (AOP) or Emergency Operating Procedure (EOP), as appropriate to the postulated scenario. Specific considerations for this drill are discussed in section 5.3.4.

• A drill that demonstrates the transition from a controlling AOP, EOP or Extensive Damage Mitigation Guidelines (EDMG) into Severe Accident Management Guidelines (SAMGs), and the selection of appropriate severe accident management strategies. The integrated use of FLEX strategies may occur if directed by the controlling SAMG and as appropriate to the postulated scenario. Specific considerations for this drill are discussed in section 5.3.5.9

• A drill that demonstrates the use of EDMG strategies.10 The integrated use of AOPs and EOPs, and FLEX strategies, may occur if directed by the controlling EDMG as appropriate to the postulated scenario. Specific considerations for this drill are discussed in section 5.3.6.

• A drill or drills to demonstrate the capability to utilize equipment necessary to implement each strategy for responding to a beyond design basis event or severe accident. Specific considerations for this drill are discussed in section 5.3.7.

The initial occurrence of each drill type listed above should be aligned with the implementation milestones for the Mitigation of Beyond-Design-Basis Events Rule.

Also for each drill type listed above, a subsequent drill should be conducted within 8 calendar years of the preceding occurrence. For example, an initial FLEX strategy drill is conducted in June, 2017; the next FLEX strategy drill should be conducted by December 31, 2025.

5.3.2 Common BDB Event Response Drill Attributes 5.3.2.1 The following attributes apply to any BDB event response drill requiring implementation of FSGs, SAMGs or EDMGs, and the Drill Manager should consider them when developing the drill scenario and implementation methods.

• If not leading the effort, it is recommended that a fleet or site Emergency Preparedness (EP) Department be involved with the development and 9

The SAMG drill is not a regulatory requirement and is performed on a voluntary basis.

10 As used here, EDMG should be understood to mean the site document(s) developed to address 10 CFR 50.54(hh)(2), and the related guidance in NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline.

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February 2016 implementation of the drill11.

• Two or more of the drills described above may be combined and conducted as one activity. A drill(s) may also be included within the scope of another drill (e.g., a scheduled ERO drill) or an evaluated exercise conducted to meet the requirements of 10 CFR 50, Appendix E.

• Conducting a BDB event response drill may require a set of site resources different from those normally used to conduct EP drills. The Drill Manager should identify the site resources (e.g., staffing and equipment) necessary to conduct the drill and ensure that they are scheduled/reserved.

In particular, consider items that should be available to support the selected demonstrations of in-field/plant actions (e.g., movement of a portable pump).

• All normal site security, radiation protection and personnel safety requirements should be followed during the drill. These requirements should be carefully considered when developing the drill scope, extent-of-play and scenario.

• Scenario time jumps/compression may be used during the drill; however, the Drill Manager should be aware that operating experience has indicated such techniques may cause confusion among drill participants unless carefully scripted and controlled.

• Emergency response functions described in the site emergency plan should be implemented as appropriate to the drill scope, extent-of-play and scenario, and consistent with normal EP drill program practices.

• The licensee should determine whether drill performance will count towards the DEP and ERO performance indicators, consistent with the guidance in NEI 99-02.

• Drill controller and evaluator duty assignments and responsibilities should be consistent with normal fleet or site drill program practices. In particular, assignments should be made to observe and assess player performance in a manner similar to that done for other drills.

• Use of radiation protection equipment by personnel responsible for deploying portable equipment in the field/plant should be performed.

• Following a drill, the licensee should conduct a drill critique and develop a drill report. The report should include a timeline of the decisions and actions taken to implement the selected BDB event response strategies.

11 This recommendation is limited to drill development and implementation. No position is taken with respect to elements.

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which fleet or site department(s) should be assigned ownership of BDB event response programs or program elements.

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• Identified drill weaknesses and deficiencies should be placed into the appropriate fleet or site corrective action program.

5.3.3 Use of a Plant-Referenced Simulator during BDB Event Response Drills Drills should utilize the capabilities of the plant-referenced simulator(s) to the degree practicable by current simulator modeling.

In cases where the postulated drill scenario events exceed the limits of the simulator model, or such limits would be exceeded soon after the drill is commenced, the simulator should not be used. Key parameter values supporting the drill should be generated and supplied to participants through other means (e.g., best estimate values are developed and provided using paper data sheets).

For a multiple-unit site with one plant-referenced simulator, the simulator may be used during a drill and the resulting data taken as representative of all onsite units if consistent with the postulated scenario conditions (i.e., the postulated events affect all onsite units in a similar manner).

5.3.4 Drill Demonstrating Integrated Use of FLEX Strategies Under the Control of an AOP or EOP 5.3.4.1 The following organizations and facilities should participate in the drill.

• A simulated Control Room for all on-site units. The Control Room(s) may be simulated in any location, consistent with the guidance in step 5.3.3 (e.g., simulator, conference room or classroom, TSC, etc.). Control Room players may be limited to those necessary for the planned demonstration.

• The primary Emergency Operations Facility (EOF) or alternate EOF, if the use of the facility is anticipated during the response to the postulated event.

• An offsite facility to which the onsite Emergency Response Organization (ERO) would report during the period when the site is inaccessible (e.g.,

an ERO alternative facility12), if the use of the facility is anticipated during the response to the postulated event.

• Offsite Response Organizations (OROs)13 should be invited to participate; however, their participation is not required.

• The National SAFER Response Center should be invited to participate; however, actual delivery of equipment is not required.

12 An ERO alternative facility is the staging area for augmented ERO personnel used during a response to a hostile action, as described in the site emergency plan.

13 OROs are those state, local and tribal agencies with primary responsibility for coordinating and implementing offsite emergency measures.

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February 2016 5.3.4.2 The Drill Manager14 should consider the following items when developing the drill scope and extent-of-play.

• As used in this section, drill means a performance enhancing experience during which participant performance is assessed against a certain standard (e.g., a drill objective). Such experiences typically exclude classroom training and facilitated meetings where on-the-spot instruction and coaching is expected.

• Control Room players should process through the operating procedures and guidelines that would be used to respond to the postulated event.

• The drill duration need not exceed the assumed elapsed time necessary for augmented ERO personnel to access the site following the initiating event, as specified in the licensees staffing assessments performed pursuant to the NRCs 50.54(f) letter dated March 12, 2012. This elapsed time is typically 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.15 Since the arrival times of ERO personnel reporting to the site from offsite locations during the drill should be consistent with the times specified in the staffing assessments, it is unlikely that the onsite TSC and OSC will be activated during the drill (unless the drill duration exceeds the assumed time necessary for ERO personnel to access the site).

• The arrival times of response personnel reporting to the EOF and/or an ERO alternate facility should reasonably reflect the postulated scenario conditions and the facilitys distance from the plant site.

• Sufficient drill time should be allowed for the appropriate augmented ERO position to demonstrate the ability to assume command and control of the event response from the Shift Manager.

• Drill players should use the communications systems and equipment that would be employed during an actual response to the postulated event.

This equipment may be simulated if changes or modifications would be required to support drill use (e.g., the simulated Control Room could not use a system without the installation of a new antenna and cabling). The decision to use or simulate this equipment should also include resource and equipment safety considerations.

• A control cell should be established to simulate non-participating organizations.

• Appropriate personnel at ERO facilities should demonstrate the ability to request the acquisition, and coordinate the delivery, of equipment from the National SAFER Response Center (NSRC) consistent with site procedures and guidelines; however, activation of the NSRC is not required. If the 14 As used in this document, Drill Manager refers to the individual with the overall responsibility for coordinating preparation and implementation of a BDB event response drill.

15 Refer to NEI 12-01, assumption 2.2.4, and site-specific staffing assessments.

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February 2016 NSRC is not participating, then a control cell should be established to simulate the appropriate contact point. Actual delivery of equipment from an NSRC will be simulated or occur as an out-of-sequence activity as coordinated with, and agreed to in advance, by the NSRC.

5.3.4.3 The Drill Manager should consider the following items when developing the drill scenario and implementation methods.

• Determine the strategies, procedures and guidelines to be demonstrated during the drill, and specify the necessary operating mode(s) for each onsite unit in the scenario initial conditions.

• The assumed drill start time for the initiating event should occur during a period of minimum on-shift staffing, i.e., during a backshift, weekend or holiday.16

• The drill should be initiated by a beyond design basis event that results in an extended loss of AC power (ELAP) simultaneously affecting all onsite units.

• The postulated drill scenario conditions should be generally consistent with the event assumptions listed in NEI 12-01 and NEI 12-06.

• Controllers should track the assignment/deployment of on-shift personnel, and promptly identify any instances where such assignments/deployments exceed to the number of available individuals17. Such instances should be reported to the players, documented in a controller log and discussed in the drill critique. The players are responsible for determining what changes to assignments/deployments are necessary during the drill to account for staffing constraints identified by a controller.

• The scenario need not include the postulated failure of portable equipment.

• The drill scenario need not include a postulated radiological release.

• The scenario may assume that requested response assistance provided by OROs and other offsite resource providers (e.g., corporate support) is available within reasonably expected timeframes.

5.3.5 Drill Demonstrating the Transition from a Controlling AOP, EOP or EDMG into SAMGs 5.3.5.1 The following organizations and facilities should participate in the drill.

16 To allow for drill conduct during a normal work day, the scenario may use an assumed day and/or start time (e.g.,

a drill conducted during normal work hours on a Tuesday may assume that the scenario takes place on a Saturday).

17 The number of available individuals should be determined from, and consistent with, the staffing assessments performed in response to the NRC 50.54(f) letter of March 12, 2012.

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• A simulated Control Room for all on-site units. The Control Room(s) may be simulated in any location, consistent with the guidance in step 5.3.3 (e.g., simulator, conference room or classroom, TSC, etc.). Control Room players may be limited to those necessary for the planned demonstration.

• The primary or alternate emergency response facilities which house personnel with responsibility for evaluation of SAMG strategies and related decision-making for implementation. Players may be limited to these individuals.

• Offsite Response Organizations (OROs) should be invited to participate; however, their participation is not required.

• Participation by the NSRC is not required.

5.3.5.2 The Drill Manager should consider the following items when developing the drill scope and extent-of-play.

• As used in this section, drill means a performance enhancing experience during which participant performance is assessed against a certain standard (e.g., a drill objective). Such experiences typically exclude classroom training and facilitated meetings where on-the-spot instruction and coaching is expected.

• Control Room players should process through the operating procedures and guidelines that would be used to respond to the postulated event.

• The drill should facilitate demonstration of the ability of the appropriate ERO decision-maker to assume command and control of the event response from the Shift Manager.

• Drill players should use the communications systems and equipment that would be employed during an actual response to the postulated event.

This equipment may be simulated if changes or modifications would be required to support drill use (e.g., the simulated Control Room could not use a system without the installation of a new antenna and cabling). The decision to use or simulate this equipment should also include resource and equipment safety considerations.

• A control cell should be established to simulate non-participating organizations. For example, if portions of the Technical Support Center staff are participating, the Drill Manager should consider establishing a control cell to simulate needed contacts with the Operational Support Center and EOF staffs.

• The drill should facilitate demonstration of the evaluation and decision-making for at least two SAMG strategies.

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February 2016 5.3.5.3 The Drill Manager should consider the following items when developing the drill scenario and implementation methods.

• The drill initial conditions should reflect the occurrence of an accident or event that resulted in the onset of conditions leading to fuel damage, and driving entry into SAMGs for at least one unit.18 The initial conditions should also specify the operating mode(s) of each onsite unit that existed prior to the accident or event, based on the strategies, procedures and guidelines to be demonstrated during the drill. The transition from the procedure(s) in effect, and into SAMGs, should be demonstrated.

• All ERO facilities may be assumed to be activated.

• The scenario may assume that requested response assistance provided by OROs and other offsite resource providers (e.g., corporate support) is available within reasonably expected timeframes.

5.3.6 Drill Demonstrating the Use of EDMG Strategies 5.3.6.1 The following organizations and facilities should participate in the drill.

• Appropriate on-shift personnel should be selected based on whether or not the drill scenario assumes that the control room command and control structure remains available.

o If available, establish a simulated Control Room for all on-site units.

The Control Room(s) may be simulated in any location, consistent with the guidance in step 5.3.3 (e.g., simulator, conference room or classroom, TSC, etc.). Control Room players may be limited to those necessary for the planned demonstration.

o If not available, personnel should be those that can be expected to respond to an event involving a loss of large areas of the plant due to explosions or fire, and causing a loss of the normal on-shift command and control structure.

• On-site emergency response facilities or other locations that would be expected to be available following an event involving a loss of large areas of the plant due to explosions or fire, as described in the drill scenario.

• Offsite Response Organizations (OROs) should be invited to participate; however, their participation is not required.

• Participation by the NSRC is not required.

18 For example, a BDB seismic event occurred several hours ago that resulted in implementation of FLEX strategies.

A second BDB seismic event occurred that impacted the ability to sustain one or more FLEX strategies, and more hours have elapsed. The drill would begin with conditions that are then degrading into those requiring a transition into SAMGs.

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February 2016 5.3.6.2 The Drill Manager should consider the following items when developing the drill scope and extent-of-play.

• As used in this section, drill means a performance enhancing experience during which participant performance is assessed against a certain standard (e.g., a drill objective). Such experiences typically exclude classroom training and facilitated meetings where on-the-spot instruction and coaching is expected.

• Operators and other appropriate players should process through the operating procedures and guidelines that would be used to respond to the postulated event.

• The arrival times of response personnel reporting to the site from offsite locations should be consistent with those described in the site emergency plan.

• Sufficient drill time should be allowed for the appropriate augmented ERO position to demonstrate the ability to assume command and control of the event response.

• Drill players should use the communications systems and equipment that would be employed during an actual response to the postulated event.

This equipment may be simulated if changes or modifications would be required to support drill use. The decision to use or simulate this equipment should also include resource and equipment safety considerations.

• A control cell should be established to simulate non-participating organizations.

• The drill should facilitate demonstration of the evaluation and decision-making for at least two extensive damage mitigating strategies.

5.3.6.3 The Drill Manager should consider the following items when developing the drill scenario and implementation methods.

• The assumed drill start time for the initiating event should occur during a period of minimum on-shift staffing, i.e., during a backshift, weekend or holiday.19

• The drill should be initiated by an event involving a loss of large areas of the plant due to explosions or fire. The scenario should specify whether or not the concurrent loss of the normal on-shift command and control structure is assumed to have occurred. These conditions should result in operators or other available on-shift personnel implementing EDMGs.

19 To allow for drill conduct during a normal work day, the scenario may use an assumed day and/or start time (e.g.,

a drill conducted during normal work hours on a Tuesday may assume that the scenario takes place on a Saturday).

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February 2016

• Controllers should track the assignment/deployment of on-shift personnel, and promptly identify any instances where such assignments/deployments exceed to the number of available individuals20. Such instances should be reported to the players, documented in a controller log and discussed in the drill critique. The players are responsible for determining what changes to assignments/deployments are necessary during the drill to account for staffing constraints identified by a controller.

• The scenario need not include the postulated failure of portable equipment.

• The drill scenario need not include a postulated radiological release.

• The scenario may assume that requested response assistance provided by OROs and other offsite resource providers (e.g., corporate support) is available within reasonably expected timeframes.

5.3.7 Drills Demonstrating the Use of Strategy-Related Equipment 5.3.7.1 Each licensee should create a list of the mitigating strategies described in site-specific FSGs, SAMGs and EDMGs.21 An example list of strategies is presented in Attachment B.22 The capability to mobilize equipment used for debris removal should also be included in the list. For each listed strategy, the capability to utilize the key equipment necessary for performing an implementing method should be periodically demonstrated as discussed in step 5.3.1.

5.3.7.2 The capability to implement a strategy using installed plant equipment may be demonstrated during a drill or as an out-of-sequence activity. The licensee may include an out-of-sequence demonstration within the scope of another scheduled activity. Such opportunities may include, but are not limited to, a mini-drill or Dynamic Learning Activity, a Job Performance Measure/Task Performance Evaluation or a demonstration associated with another program activity (e.g., a fire protection program inspection). Demonstration credit may also be given for performance during an actual event. All such demonstrations must be consistent with plant configuration control requirements and sound operational decision-making. Actual manipulation or operation of equipment is not required.

5.3.7.3 The capability to implement a strategy using portable equipment may be demonstrated during a drill or as an out-of-sequence activity. The licensee may include an out-of-sequence demonstration within the scope of another 20 The number of available individuals should be consistent with the site emergency plan plus any additional personnel filling positions for which administrative controls exist to ensure 24/7 staffing.

21 SAMG strategy equipment drills are not a regulatory requirement and are performed on a voluntary basis.

22 The example list reflects currently operating plant designs that employ active safety features, and is for illustrative purposes only. As noted, each facility will need to create a site-specific listing based on site-specific mitigating strategies. This includes plant designs based on passive safety features such as the Westinghouse AP1000 or GE-Hitachi ESBWR.

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February 2016 scheduled activity. Such opportunities may include, but are not limited to, a mini-drill or Dynamic Learning Activity, a Job Performance Measure/Task Performance Evaluation or a demonstration associated with another program activity (e.g., a fire protection program inspection). Demonstration credit may also be given for performance during an actual event.

The demonstration of portable equipment should entail the movement of the equipment from its storage location to the location where it would be placed and operated, consistent with plant configuration control requirements and sound operational decision-making. Should placement in the expected operating location not be practicable, movement to an alternate (drill) location is acceptable. Actual connection/hookup or operation of equipment is not required.

5.3.7.4 If the same (or essentially the same) strategy is described in two or more emergency response guideline sets, then the capability to implement that strategy need be demonstrated only once over a given 8-year period (i.e.,

consistent with the drill periodicity guidance in step 5.3.1). For example, a PWR site has a strategy for feeding a steam generator described in its FSGs, SAMGs and EDMGs. The demonstration of an implementing method for this strategy, such as using a portable pump in accordance with an FSG, would satisfy the strategy demonstration requirement for all three guideline sets.

5.3.7.5 The capability to mobilize equipment used for debris removal may be demonstrated during a drill or as an out-of-sequence activity. The licensee may include an out-of-sequence demonstration within the scope of another scheduled activity. Such opportunities may include, but are not limited to, a mini-drill or Dynamic Learning Activity, a Job Performance Measure/Task Performance Evaluation or a surveillance. Demonstration credit may also be given for performance during an actual event (e.g., the same equipment is used to clear site roads following a heavy snowfall).

5.3.7.6 For a mitigating strategy expected to be implemented within the assumed elapsed time necessary for ERO personnel to access the site (as specified in the licensees staffing assessments performed pursuant to the NRCs 50.54[f]

letter dated March 12, 2012), the following drill guideline should be considered.

• The number of individuals performing the demonstration should be consistent with the number expected to be available during a real event; this number may be determined from a staffing assessment. Deviations from a staffing assessment should be documented in a controller log and discussed in the drill critique.

5.3.8 BDB Event Response Drill Objectives Appendix A, BDB Event Response Drill Objectives, presents generic drill objectives that a licensee should use to develop a site-specific set of objectives for each BDB event response drill. Each objective has an associated listing of Performance Attributes; these 25

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February 2016 attributes define successful objective performance and should be used to develop the site-specific evaluation criteria for each objective. The development of objectives and evaluation criteria should be informed by the content of site-specific procedures and guidelines, and the established drill scope and extent-of-play. While a licensee is not expected to use the generic objectives verbatim, the function(s) described by each objective, and the associated performance attributes, should be considered during the development of the drill objectives and evaluation material.

Objectives described in the fleet/site EP drill and exercise program may also be considered for demonstration during a BDB event response drill. These objectives, and their associated evaluation criteria, should be reviewed and revised as necessary to reflect differences between expected performance during a design basis event and a beyond design basis event. For example, additional time may be necessary to complete certain activities such as ORO notifications, the personnel accountability process and activation of ERO emergency response facilities during a beyond design basis event response. The licensee should determine reasonable performance standards based on site-specific capabilities, and reflect these in the objectives and evaluation criteria.

As noted above, each BDB event response drill should be critiqued to identify weaknesses and deficiencies. Licensees should modify their critique processes as necessary to ensure a thorough review and evaluation of BDB-related drill objectives.

5.3.9 Considerations for Program Documents The drills conducted to demonstrate responses to a beyond design basis event or severe accident need not be described in the site emergency plan; however, these activities should be described in a document maintained through a fleet or site document control process. The document should be retained for the life of the plant.

Each licensee should review the condition screening and evaluation requirements described in their corrective action program(s), and determine if changes are necessary.

The purpose of this review is to ensure that program criteria will properly prioritize conditions associated with beyond design basis event response capabilities and appropriately allocate resources for their correction. In particular, the prioritization and allocation of resources should be balanced with other needs, and commensurate with the anticipated benefits to overall accident or event response capabilities (e.g., changes offering lower relative or absolute benefits should be assigned lower priorities).

26

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February 2016 6 REFERENCES

• NRC Report, 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

• SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011

• 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

• NRC letter, Request for Information 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, dated March 12, 2012

• NRC 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, dated August 29, 2012

• NRC Letter, Wiggins to Pollock, dated February 27, 2013

• COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013

• Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013

• Staff Requirements - SECY-15-0065 - Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015

• Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015

• NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, dated December 2006

• NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012

• NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012

• NEI Letter, Industry Implementation of Multi-unit Dose Assessment Capability, Pollock to Wiggins, dated January 28, 2013 27

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• NEI Letter, Commitment for Implementation of Multi-Unit Dose Assessment Capability, Pollock to Wiggins, dated March 14, 2013

• NEI Letter, Commitment for Implementation of Multi-Unit Dose Assessment Capability, Pietrangelo to Nuclear Strategic Issues Advisory Committee Steering Group, dated March 22, 2013

• NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, dated February 2016 28

NEI 13-06 (Revision 1)

February 2016 APPENDIX A - BDB EVENT RESPONSE DRILL OBJECTIVES Recommended Objective Performance Attributes

1. Demonstrate the ability of on-shift

• The Shift Manager provides effective operations personnel to perform integrated command and control of the accident or implementation of operating procedures event response until relieved and guidelines for responding to a beyond

• Perform processing of, and transitions design basis event or severe accident. between, applicable procedures and guidelines.

• Perform evaluation and decision-making related to the selection of mitigation or management strategies and actions.

• Communicate selected mitigation or management strategies and actions to the appropriate personnel.

2. Demonstrate the ability of the [ERO

• Perform turnover of command and control position assuming UDM function from Shift consistent with the applicable procedures Manager] to assume command and control or guidelines.

for the selection and implementation of

• Perform decision-making related to the mitigation and management strategies. selection of mitigation and management strategies and actions, including those associated with a multi-unit response if applicable.

• Direct the communication of selected mitigation and management strategies and actions to the Control Room and other appropriate personnel.

3. Demonstrate the ability of the augmented

• Perform evaluation and recommendations ERO staff to evaluate and recommend related to the selection of mitigation and mitigation and management strategies. management strategies and actions, including those associated with a multi-unit response if applicable.

• Communicate selected mitigation and management strategies and actions to the Control Room and other appropriate personnel.

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February 2016 Recommended Objective Performance Attributes

4. Demonstrate the ability of the on-shift and Establish and maintain required augmented ERO staff to communicate communications in accordance with applicable during a beyond design basis event or procedures and guidelines. [Wording should severe accident. reflect which organizations will be represented by a controller/control cell.]

• Offsite Response Organizations

• NRC ENS

• Between ERO facilities

• On-site and in-plant response teams

• Offsite monitoring teams

5. Demonstrate the ability to operate the * [Specify the mitigating or management installed plant equipment necessary for strategy(ies) to be demonstrated during the implementing a mitigating or management drill; select these from the list of strategies strategy. developed per the guidance in section 5.3.7.]

• [Specify which key implementing actions will be performed, simulated or discussed during the drill.]

• Verify that the necessary actions for implementing a mitigating or management strategy can be performed by the available staff.

• Verify that personnel assigned actions do not have concurrent collateral duties which would preclude timely performance.

6. Demonstrate the ability to deploy the * [Specify the mitigating or management portable equipment necessary for strategy(ies) to be demonstrated during the implementing a mitigating or management drill; select these from the list of strategies strategy. developed per the guidance in section 5.3.7.]

• [Specify which key implementing actions will be performed, simulated or discussed during the drill.]

• Verify that the necessary actions for implementing a mitigating or management strategy can be performed by the available staff.

• Verify that personnel assigned actions do not have concurrent collateral duties which would preclude timely performance.

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February 2016 Recommended Objective Performance Attributes

7. Demonstrate the ability to deploy * [Specify which key implementing actions equipment necessary for debris removal in will be performed, simulated or discussed order to allow/improve access to the during the drill.]

unit(s). * [Specify the location(s) where demonstration will occur.]

• Verify that the necessary actions for performing debris removal can be implemented by the available staff.

• Verify that personnel assigned actions do not have concurrent collateral duties which would preclude timely performance.

8. Demonstrate the adequacy of EP facilities

• EP facilities can adequately accommodate and equipment to support the augmented expected personnel during the response to a ERO during a beyond design basis event. beyond design basis event affecting all onsite units.

• Augmented ERO personnel have the equipment necessary to perform assigned duties during a beyond design basis event affecting all onsite units.

9. Demonstrate the ability to perform multi- Perform an offsite dose assessment following a unit/source dose assessment. beyond design basis event or severe accident resulting in concurrent radiological releases from all on-site units (multi-unit site) or multiple release points (single-unit site).

Note This drill objective may demonstrated during a drill or exercise (as an in sequence or out-of-sequence activity) or a separate/stand-alone mini-drill. Refer to section 2.3.4 for additional information.

10. Demonstrate the ability to notify the The NSRC is notified of the event and National SAFER Response Center (NSRC) equipment needs in accordance with and coordinate the delivery of requested appropriate procedures or guidelines. [Site equipment. protocol may have this notification being made to INPO instead of directly to the NSRC; revise wording as needed. Wording should also reflect which organizations will be represented by a controller/control cell.]

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[BLANK PAGE]

A-4

NEI 13-06 (Revision 1)

February 2016 APPENDIX B - EXAMPLE MITIGATION STRATEGY LIST Example Boiling Water Reactor (BWR) Mitigating Strategies Flex Support Guidelines 1. DC load shedding/stripping

2. Use of RCIC/HPCI/IC during an ELAP

3. Repower instrumentation needed to maintain safety functions with portable power supplies

4. Use of alternate water supply to support core and spent fuel pool heat removal

5. Depressurize RPV for injection with portable injection source

6. Containment venting

7. Repower hydrogen igniters with a portable power supply (BWR Mark III containments only)

8. Spent fuel pool cooling via makeup with a portable injection source Severe Accident 1. Inject into (makeup to) reactor pressure vessel/reactor coolant Management Guidelines system (RPV/RCS)

2. Depressurize the RPV/RCS

3. Spray within the RPV

4. Operate isolation condenser

5. Spray into containment

6. Inject into containment

7. Operate recombiners

8. Operate igniters

9. Inert the containment with noncondensable gases

10. Vent the primary containment

11. Inject into the spent fuel pool

12. Spray the spent fuel pool

13. Vent/ventilate the reactor building or auxiliary building

14. Scrub releases by external spraying of buildings Extensive Damage 1. Manual operation of RCIC/IC Mitigation Guidelines (or 2. DC power supplies to allow depressurization of RPV and other related guidelines injection with portable pump describing mitigating 3. Utilize feedwater and condensate actions for an event

4. Makeup to hotwell.

involving a loss of large areas of the plant due to 5. Makeup to CST explosions or fire) 6. Maximize CRD flow

7. Procedure to isolate RWCU

8. Manually open containment vent lines

9. Inject water into the drywell

10. Portable sprays B-1

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February 2016 Example Pressurized Water Reactor (PWR) Mitigating Strategies Flex Support Guidelines 1. DC load shedding/stripping

2. Use of AFW/EFW during an ELAP

3. Repower instrumentation needed to maintain safety functions with portable power supplies

4. Use of alternate water supply to support core and spent fuel pool heat removal (including all portable/staged pumps)

5. Depressurize steam generator for makeup with portable injection source

6. Means to provide borated RCS makeup

7. Containment spray (if applicable)

8. Operate hydrogen igniters (ice condenser containments)

9. Spent fuel pool cooling via makeup with a portable injection source

10. Mode 5 & 6 RCS makeup using portable injection source Severe Accident 1. Inject into (makeup to) reactor vessel/reactor coolant system Management Guidelines 2. Depressurize the RCS

3. Restart reactor coolant pump (RCP)

4. Depressurize steam generators

5. Inject into (feed) the steam generators

6. Spray into containment

7. Inject into containment

8. Operate fan coolers

9. Operate hydrogen igniters (ice condenser containments)

10. Vent the containment

11. Inject into the spent fuel pool

12. Spray the spent fuel pool

13. Vent/ventilate the auxiliary building

14. Scrub releases by external spraying of buildings Extensive Damage 1. Makeup to RWST Mitigation Guidelines (or 2. Manually depressurize steam generators to reduce RCS other related guidelines inventory loss describing mitigating 3. Manual operation of turbine (or diesel)-driven AFW/EFW actions for an event pump involving a loss of large

4. Manually depressurize steam generators and use portable areas of the plant due to pump explosions or fire)

5. Makeup to CST

6. Containment flooding with portable pump

7. Portable sprays (if available)

8. Internal Spent Fuel Pool Makeup

9. External Spent Fuel Pool Makeup B-2

NEI 13-06 [Revision 01]

Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents

September 2014 February 2016

[THIS PAGE IS LEFT BLANK INTENTIONALLY]

NEI 13-06 [Revision 01]

Nuclear Energy Institute Enhancements to Emergency

Response

Capabilities for Beyond Design Basis Events and Severe Accidents

September 2014 February 2016

ACKNOWLEDGMENTS This document was developed by the Nuclear Energy Institute (NEI) Emergency Preparedness (EP) Working Group with assistance from the Beyond Design Basis (BDB) Event Response Drill Task Force.

NEI BDB Event Response Drill Task Force NEI Chairperson: David Young Industry Members:

Walt Lee - TVA Nuclear/Corporate Nick Pappas - APS/Palo Verde Nuclear Generating Station Mike Slobodien - PSEG Nuclear/Salem and Hope Creek Brian Trimble - Exelon Nuclear/Corporate Mary Ann Wilson - Entergy Nuclear/Corporate NOTI CE Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.

NEI 13-06 (Revision 01)

September 2014 February 2016 EXECUTIVE

SUMMARY

This technical report provides guidance for the completion of actions necessary to address the Tier 2 Emergency Preparedness (EP) enhancements identified in US Nuclear Regulatory Commission (NRC) Report, Recommendations for Enhancing Reactor Safety in the 21st Century

[The Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident].1&2 These actions reflect the approach discussed in COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, and related NRC staff and Nuclear Energy Institute (NEI) documents. Specifically, the NRC staff determined that certain Tier 2 EP items are being addressed adequately through implementation of NRC Order EA 049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events.

Order EA-12-049 addresses NRC NTTF Report Recommendation 4 and stemmed directly from Recommendation 4.2. The activities undertaken by the industry to comply with the Order will resolve two of the three Tier 2 items contained in NRC NTTF Report Recommendation 9.3; these items are periodic training and drills, and EP equipment and facilities, both associated with responses to a multi-unit and/or extended loss of AC power event.3 The remaining Tier 2 item from Recommendation 9.3 deals with multi-unit dose assessment capability and is not within scope of Order EA-12-049 activities.

NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, provides guidance on the format and content of licensee responses to Order EA-12-049. The guidance also covers information related to FLEX deployment, including training and drills, and equipment and facility topics captured in Recommendation 9.3. For example, NEI 12-06, states,

[w]hereWhere appropriate, the integrated FLEX drills should be organized on a team or crew basis and conducted periodically; with all time-sensitive actions to be evaluated over a period of not more than eight years. It further states, Periodic training should be provided to site emergency response leaders on beyond design-basis emergency response strategies and implementing guidelines, and procedures/guidance should identify the protective clothing or other equipment or actions necessary.

In addition, NEI 12-06 recommends utilization of the staffing and communication resources identified in NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities. The latter document was developed to address the two Tier 1 topics from Recommendation 9.3 - staffing and communications. NEI 12-01 states,

[a] licensee should identify additional work areas necessary for the performance of expanded response functions. The use of alternate emergency response facilities should be considered.

This statement addresses the facilities needed to house the response staff.

1 This report is commonly referred to as the NRC NTTF Report.

2 The tier assignments made to the EP enhancements are discussed in SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011 i

3 Staff documents may refer to an extended loss of AC power as a prolonged Station Blackout (SBO).

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September 2014 February 2016 With the preceding in mind, NEI and the industry have created this technical report to promote consistent implementation of the actions whichthat address the Tier 2 EP enhancements discussed above.

Three of the topics addressed by COMSECY-13-0010 are also relevant to NRC NTTF Recommendation 8. These topics are training, drills and exercises, and they are discussed in an NRC document entitled, Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013.4 The Recommendation 8 regulatory basis was subsequently incorporated into Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015, with changes directed by the NRC Commissioners in Staff Requirements - SECY-15-0065 -

Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015. In recognition of the interrelationship between of the discussions presented in the COMSECY, the regulatory basis and the regulatory basisproposed rule, and the desirability of having well-integrated guidance, this document also addresses training, qualifications,and drills and exercises for beyond design basis events and severe accidents.

Finally, fleet and site leadership teams should carefully consider which department(s) will be assigned a responsibility for addressing one or more of the EP and emergency response-related enhancements discussed in this document. It is important that leadership teams have a full understanding of the requirements related to EP and Beyond Design Basis (BDB) emergency response capabilities in order to identify potential gaps in organizational knowledge, skill sets, and alignment/coordination that could impact sustainability. In particular, opportunities to leverage organizational resources and synergies in order to improve performance should be pursued.

4 Available on regulations.gov; see Docket ID: NRC-2012-0031.

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September 2014 February 2016 TABLE OF CONTENTS EXECUTIVE

SUMMARY

............................................................................... i 1 INTRODUCTION ................................................................................... 1 1.1 SCOPE AND PURPOSE OF NEI 13-06 ................................................................................ 1 2 MULTI-UNIT DOSE ASSESSMENT ....................................................... 3 2.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS ......................... 3 2.2 RELATED REFERENCE DOCUMENTS ............................................................................... 3 2.3 RECOMMENDED ACTIONS ................................................................................................ 3 3 TRAINING ............................................................................................ 7 3.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS ......................... 7 3.2 RELATED REFERENCE DOCUMENTS ............................................................................... 8 3.3 RECOMMENDED ACTIONS ................................................................................................ 9 4 EP FACILITIES AND EQUIPMENT ..................................................... 12 4.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS ....................... 12 4.2 RELATED REFERENCE DOCUMENTS ............................................................................. 13 4.3 RECOMMENDED ACTIONS .............................................................................................. 13 5 DRILLS AND EXERCISES................................................................... 15 5.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS ....................... 15 5.2 RELATED REFERENCE DOCUMENTS ............................................................................. 16 5.3 RECOMMENDED ACTIONS .............................................................................................. 16 6 REFERENCES..................................................................................... 29 APPENDIX A - BDB EVENT RESPONSE DRILL OBJECTIVES

.........................................A-1 APPENDIX B - EXAMPLE MITIGATION STRATEGY LIST

.................................................B-1 3

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[THIS PAGE IS LEFT BLANK INTENTIONALLY]

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September 2014 February 2016 ENHANCEMENTS TO EMERGENCY RESPONSE CAPABILITIES FOR BEYOND DESIGN BASIS EVENTS AND SEVERE ACCIDENTS 1 INTRODUCTION 1.1 SCOPE AND PURPOSE OF NEI 13-06 This technical report provides guidance for the performance of licensee actions that will address certain aspects of recommendations contained in US Nuclear Regulatory Commission (NRC) Report, Recommendations for Enhancing Reactor Safety in the 21st Century [The Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident]. The specific recommendations are:

• Recommendation 4.2 - Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design basis external events and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.

• Recommendation 8.1 - Order licensees to modify the EOP technical guidelines (required by Supplement 1, Requirements for Emergency Response Capability, to NUREG-0737, issued January 1983 (GL 82-33), to (1) include EOPs, SAMGs, and EDMGs in an integrated manner, (2) specify clear command and control strategies for their implementation, and (3) stipulate appropriate qualification and training for those who make decisions during emergencies.

• Recommendation 8.4 - Initiate rulemaking to require more realistic, hands-on training and exercises on SAMGs and EDMGs for all staff expected to implement the strategies and those licensee staff expected to make decisions during emergencies, including emergency coordinators and emergency directors.

• Recommendation 9.3 [relevant wording excerpted] - Order licensees to do the following until rulemaking is complete:

o Add guidance to the emergency plan that documents how to perform a multiunit dose assessment (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.

o Conduct periodic training and exercises for multiunit and prolonged SBO [Station Blackout] scenarios. Practice (simulate) the identification and acquisition of offsite resources, to the extent possible.

o Ensure that EP equipment and facilities are sufficient for dealing with multiunit and prolonged SBO scenarios.

These recommendations were subsequently evaluated by the NRC staff and refined into 1

various regulatory positions and actions. NEI 13-06 addresses the positions and actions discussed in COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency 2

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September 2014 February 2016 Preparedness for Japan Lessons Learned. The topics in the COMSECY include multi-unit dose assessment, training, EP facilities and equipment, and drills and exercises.

Additionally, the COMSECY makes reference to certain topics that are also within the scope of Recommendation 8; these topics are training, drills and exercises. With respect to Recommendation 8, these topics apply to the related to implementation of FLEX Support Guidelines (FSGs), Severe Accident Management Guidelines (SAMGs) and Extensive Damage Mitigation Guidelines (EDMGs). In recognition of the need for well-integrated guidance, NEI 13-06 addresses the training, qualification,and drill and exercise aspects of the COMSECY and Onsite Emergency Response Capabilities, RegulatoryProposed Rule - Mitigation of Beyond Design Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8,Events (RIN 3150-AJ49), dated October 1, 2013November 2, 2015. The latter reflects changes directed by the NRC Commissioners in Staff Requirements - SECY-15-0065 - Proposed Rulemaking:

Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015.

Finally, this document uses the term FLEX Support Guidelines or FSGs to connote the document(s) developed or enhanced in response to NRC Order EA-12-049, Order Modifying Licenses with regard to Requirements for Mitigating Strategies for Beyond Design Basis External Events, and which describe/direct the operator and field actions necessary to implement mitigating strategies in response to a beyond design basis external event. Depending upon Owners Group guidance, and fleet and site standards, these actions may be contained in a document(s) with a different name. Each licensee should ensure that their appropriate site-specific documents are utilized when addressing the FLEX-related guidance contained in this document.

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September 2014 February 2016 2 MULTI-UNIT DOSE ASSESSMENT 2.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS 2.1.1 Recommendation 9 The Task Force recommends that the Commission direct the staff to do the following:

9.3 Order licensees to do the following until rulemaking is complete:

Add guidance to the emergency plan that documents how to perform a multiunit dose assessment (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.

2.2 RELATED REFERENCE DOCUMENTS SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011 NEI Letter, Industry Implementation of Multi-unit Dose Assessment Capability, Pollock to Wiggins, dated January 28, 2013 NRC Letter, Wiggins to Pollock, dated February 27, 2013 NEI Letter, Commitment for Implementation of Multi-Unit Dose Assessment Capability, Pollock to Wiggins, dated March 14, 2013 NEI Letter, Commitment for Implementation of Multi-Unit Dose Assessment Capability, Pietrangelo to Nuclear Strategic Issues Advisory Committee Steering Group, dated March 22, 2013 COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 Site-specific letter to NRC staff concerning the intent to implement multi-unit (source) dose assessment capability, dated on or around June 30, 2013 Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015 2.3 RECOMMENDED ACTIONS 2.3.1 Industry Performance Standard for Multi-Unit Dose Assessment 4

All single and multi-unit sites should establish the capability to perform offsite dose assessments during an event involving concurrent radiological releases from all on-site 5

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September 2014 February 2016 units and/or multiple release points (i.e., whether from one or multiple units5), consistent with the description contained in the site-specific licensee letter to the NRC staff dated on or around June 30, 2013.

The multi-unit dose assessment capability should be computerized (i.e., offsite dose projections are generated using a computer-based model), and reflect the normally expected use of radiological and meteorological indications, e.g., incorporated into the sites emergency dose projection software as an assessment option. It should be available to support responses during events both within and beyond the plant design basis. In particular, the capability should exist to project offsite doses during an event involving an extended loss of AC power affecting all onsite units.

In addition to the normally used calculation methods and input indications, the capability should also accommodate the use of alternate methods and indications to address instances when normal data sources may be unavailable. For example, in cases where a plant vent radiation monitor is non-functional, a dose projection model might have the capability to project offsite doses based on a source term derived from a dose rate measurement in the plant or field. Or if onsite meteorological data is not available, then dose assessments are performed using parameter values obtained from a pre-identified near-site source or the National Weather Service.

A licensee may elect to also include a backup method (e.g., a manual method) to supplement the computerized method discussed above; if this option is pursued, the backup method should be capable of producing results within a reasonable time period (e.g., within about 30 minutes). In addition, consideration should be given to establishing a procedurally-driven peer/second person check of manually derived output, where warranted.

Implementation of this enhancement may necessitate the addition of a backup power source (e.g., an uninterruptable power supply) to onsite dose assessment computing platforms or ensuring the availability of computing platforms at locations away from the site (e.g., at an ERO alternate facility or an Emergency Operations Facility). It does not require the installation of new, or modification of existing, plant equipment such as radiation monitors, flow detectors and meteorological instrumentation (including associated data processors and power sources).

Each licensee should discuss their capability to perform multi-unit dose assessment with the appropriate Offsite Reponses Organization (ORO) agency officials, and determine if any changes are necessary to ORO plans and procedures.

5 This topic is referred to as multi-unit dose assessment for ease of reading; however, it should be understood to mean the capability to assess concurrent releases from multiple release sources/points such as reactor cores and spent fuel pools. It is therefore applicable to single-unit sites as well.

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September 2014 February 2016 2.3.2 Emergency Classification and Protective Action Recommendations Multi-unit dose assessment results should be assessed in accordance with the licensees existing emergency classification scheme and Protective Action Recommendation (PAR) decision-making process.

Each licensee should verify that the capability exists to issue a PAR for appropriate areas beyond the Emergency Planning Zone (EPZ) boundary, in accordance with existing regulatory requirements and guidance.

Consideration should be given to addressing the following points in the site-specific procedure or guideline that implements the multi-unit dose assessment capability.

• Projected offsite doses should be compared against the Emergency Action Levels (EALs) to determine if a change in the emergency classification is warranted.

• Projected offsite doses should be compared against appropriate decision-making criteria to determine if a change in PARs is warranted.

2.3.3 Training Each licensee should provide training to the personnel responsible for performing a multi-unit dose assessment. Training materials, delivery methods and frequencies, and evaluation techniques should be developed using established Systematic Approach to Training (SAT) processes.

2.3.4 Performance Enhancing Experience Periodic opportunities for a performance enhancing experience should be provided to personnel responsible for performing multi-unit dose assessment and assessing the results. Such opportunities may include performance during a drill or exercise (as an in sequence or out-of-sequence activity) or a separate/stand-alone mini-drill. These opportunities should be provided consistent with the extent-of-play and methods normally used to implement mini-drills, drills or exercises involving a demonstration of dose assessment capabilities.

2.3.5 Quality and Maintenance-Related Requirements Equipment and software used to implement a multi-unit dose assessment capability should be procured and installed under the commercial and site requirements normally applicable to the EP Program.

Programmatic controls should be applied to appropriate equipment and software to ensure availability and reliability, including the performance of periodic inventory checks and functionality testing.

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September 2014 February 2016 2.3.6 Considerations for Program Documents A capability for performing multi-unit dose assessment need not be described in the site emergency plan; however, this capability should be described in a document maintained through a fleet or site document control process. The document should be retained for the life of the plant.

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September 2014 February 2016 3 TRAINING 3.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS 3.1.1 Recommendation 4 The Task Force recommends that the Commission direct the staff to begin the actions given below to further enhance the ability of nuclear power plants to deal with the effects of prolonged SBO conditions at single and multiunit sites without damage to the nuclear fuel in the reactor or spent fuel pool and without the loss of reactor coolant system or primary containment integrity.

4.2 Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design-basis external events and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.

• This existing equipment currently provides some of the coping capability that is recommended for the long term, but current storage requirements do not ensure that it will be available after a design-basis external event. This requirement would increase the likelihood that the equipment will be available if called upon.

• The staff should also consider conforming changes to the requirements in 10 CFR 50.54(hh)(2) to address multiunit response capacity.

3.1.2 Recommendation 8 The Task Force recommends that the Commission direct the staff to further enhance the current capabilities for onsite emergency actions in the following ways:

8.1 Order licensees to modify the EOP technical guidelines (required by Supplement 1, Requirements for Emergency Response Capability, to NUREG-0737, issued January 1983 (GL 82-33), to (1) include EOPs, SAMGs, and EDMGs in an integrated manner, (2) specify clear command and control strategies for their implementation, and (3) stipulate appropriate qualification and training for those who make decisions during emergencies.

8.4 Initiate rulemaking to require more realistic, hands-on training and exercises on SAMGs and EDMGs for all staff expected to implement the strategies and those licensee staff expected to make decisions during emergencies, including emergency coordinators and emergency directors.

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September 2014 February 2016 3.1.3 Recommendation 9 The Task Force recommends that the Commission direct the staff to do the following:

9.3 Order licensees to do the following until rulemaking is complete:

Conduct periodic training and exercises for multiunit and prolonged SBO scenarios.

Practice (simulate) the identification and acquisition of offsite resources, to the extent possible.

3.2 RELATED REFERENCE DOCUMENTS SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011 NRC letter, Request for Information 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, dated March 12, 2012 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 NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012 NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012 NRC 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, dated August 29, 2012 Site-specific letter to NRC staff transmitting results of a communications assessment performed in response to NRC 50.54(f) letter; initial letter dated on or around October 31, 2012 and a possible follow-up letter dated on or around February 28, 2013 COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 Site-specific letter to NRC staff transmitting results of a first-phase staffing assessment performed in response to NRC 50.54(f) letter, dated on or around April 30, 2013; a second-phase staffing assessment is due to the NRC staff no later than 4 months prior to the beginning of the second refueling outage (as described in the site response to NRC Order EA-12-049 8

NEI 13-06 (Revision 01)

September 2014 February 2016 Site-specific Integrated Plan for implementing NRC Order EA-12-049 Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013 Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015 3.3 RECOMMENDED ACTIONS 3.3.1 BDB Event Response Training Each licensee should provide training to the key personnel relied upon to implement the procedures and guidelines for responding to a beyond design basis event or severe accident, including the site-specific integrated use of FLEX Support Guidelines (FSGs),

Extensive Damage Mitigation Guidelines (EDMGs) and Severe Accident Management Guidelines (SAMGs).6 Training materials, delivery methods and frequencies, and evaluation techniques should be developed using established processes that address the Systems approach to training (SAT) elements listed in 10 CFR 55.4., except for elements already covered under other NRC regulations. Training on these common elements can be addressed in a non-SAT training program that is acceptable for meeting regulatory required training (e.g., 10 CFR part 50, appendix E, section IV.F). Position-specific qualification requirements should also be identified, as appropriate.

The primary focus of licensed operator initial and requalification training programs should continue to be on developing and maintaining the knowledge, skills and abilities of operators to implement the Emergency Operating Procedures (EOPs). This goal should be balanced with the need to provide the additional SAT-based training necessary to ensure that operators have the capability to respond to a beyond design basis event or severe accident in accordance with site-specific strategies. Site administrative controls should be established to ensure that an individual has successfully completed all required training prior to assuming a licensed operator position on-shift (e.g., training could be performed after receipt of an initial operator license but before being assigned on-shift duties in the Control Room).

The SAT process may identify operator knowledge, skills and abilities necessary for the execution of site-specific FSG, EDMG and SAMG strategies beyond those associated with the Knowledge and Abilities (K/As) described in NRC guidance documents (e.g.

from NUREG-1122 or NUREG-1123). These items should be included in and evaluated as part of stations SAT-based training program.

Dynamic exams may be used consistent with simulator capabilities.

6 This training may be accomplished in different settings since implementation of some emergency response procedures and guidelines are dependent upon the nature of the postulated initiating event, the plant response/accident sequence, and the ability of responders to select and implement mitigation/management strategies.

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September 2014 February 2016 In addition to licensed operators, SAT-based training should be provided to other licensee personnel with supporting responsibilities, including:

• Non-licensed operators, health physics staff, maintenance personnel, and other positions that would be called upon to perform implementing tasks.

• Support staff that would be evaluating plant conditions and recommending appropriate accident mitigating and management strategies for implementation.

• Personnel who would be requesting and coordinating the delivery of Final Phase (Phase 3) mitigating strategy equipment from an offsite location (e.g., from a Regionalthe National SAFER Response Center).

Training and qualification elements may be incorporated into a new training program, into an existing training program(s), or a combination of both. Non-SAT training programs that meet the needs for common elements do not need to be revised to use the SAT process.

The development of training and qualification requirements and materials should consider the degree to which the knowledge and abilities normally expected of a given position can be readily applied to an assigned task. Development should also recognize the availability of job/user aids and built-in equipment/hardware features that can improve human performance during stressful or adverse conditions (e.g., color coding, standardized connections, etc.).

Training program developers should assess and implement reasonable methods that may be used to facilitate practice at performing tasks under expected adverse conditions. The use of these methods should maintain an appropriate focus on the safety of plant personnel and equipment.

3.3.2 Plant-Referenced Simulator The fidelity of the plant-referenced simulator should be maintained in accordance with 10 CFR 55.46 as additional equipment is installed in the facility and utilized to support operation. The Certification of simulator should also be updated as additional accident monitoring instrumentation is installedfidelity in accordance with ANSI/ANS-3.5, Nuclear Power Plant Simulators for Use in Operator Training and Examination, if used, is considered to be sufficient for the Control Room. Modelling of instrumentation responses should use current initial stages of a beyond-design-basis external event scenario until the existing capability of the simulator model capabilities, and consideris exceeded. Increasing the anticipated effectscapability of the environmentalplant-referenced simulator to specifically model conditions associated with a beyond design basis event or severe accident on the reliability of the instrumentation readings. Such considerationis not required (e.g., models need not be upgraded to accommodate FLEX training or drills). Voluntary upgrades to one or more model aspects (e.g.,

instrumentation responses) may be onperformed using a best estimate basis. Increasing the capability of the plant-referenced simulator to specifically model the conditions of the 10

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September 2014 February 2016 reactor core or stored spent fuel during a beyond design basis event or severe accident is not required.for the modelling.

3.3.3 Ultimate Decision-Maker Qualifications As part of the required planning for responses to emergency conditions, each licensee has established a command and control structure for their Emergency Response Organization (ERO). Within this structure, there should be a position(s) with the assigned authority and responsibility for providing overall direction on the implementation of EOPs, FSGs, EDMGs and SAMGs for a unit or set of units; this authority and responsibility is referred to as the Ultimate Decision-Maker (UDM) function.7 Qualification requirements should be developed for the position(s) performing this function. These requirements should ensure that each UDM-qualified individual has sufficient technical understanding and leadership ability to make timely and informed decisions during a beyond design basis event or severe accident.

The need for periodic requalification should also be assessed in order to ensure that individuals have maintained the necessary knowledge and skills. Applicable program controls should be updated as necessary to reflect requalification requirements.

3.3.4 Training Development Guidance from Regulatory Responses In addition to the topics discussed above, training programs should also address the training-related actions described in:

• FLEX program implementing documents developed in accordance with NRC Order EA-12-049.

• The communications and staffing assessment responses provided to the NRC staff in accordance with the 50.54(f) letter dated March 12, 2012.

3.3.5 Considerations for Program Documents The training and qualifications for responding to a beyond design basis event or severe accident need not be described in the site emergency plan; however, this material should be described in a document maintained through a fleet or site document control process.

The document should be retained for the life of the plant.

7 The UDM function is described in NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents.

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September 2014 February 2016 4 EP FACILITIES AND EQUIPMENT8 4.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS 4.1.1 Recommendation 4 The Task Force recommends that the Commission direct the staff to begin the actions given below to further enhance the ability of nuclear power plants to deal with the effects of prolonged SBO conditions at single and multiunit sites without damage to the nuclear fuel in the reactor or spent fuel pool and without the loss of reactor coolant system or primary containment integrity.

4.2 Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design-basis external events and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.

• This existing equipment currently provides some of the coping capability that is recommended for the long term, but current storage requirements do not ensure that it will be available after a design-basis external event. This requirement would increase the likelihood that the equipment will be available if called upon.

• The staff should also consider conforming changes to the requirements in 10 CFR 50.54(hh)(2) to address multiunit response capacity.

4.1.2 Recommendation 9 The Task Force recommends that the Commission direct the staff to do the following:

9.3 Order licensees to do the following until rulemaking is complete:

Ensure that EP equipment and facilities are sufficient for dealing with multiunit and prolonged SBO scenarios.

8 As used here, EP facilities and equipment refers to those facilities in which ERO members would perform their assigned functions during a Beyond Design Basis event response, and the necessary equipment located therein. It does not include the systems, structures, components or portable equipment used to implement accident mitigating or management strategies described in Abnormal/Emergency Operating Procedures, or FLEX Support, Severe Accident Management or Extensive Damage Mitigation Guidelines.

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September 2014 February 2016 4.2 RELATED REFERENCE DOCUMENTS SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011 NRC letter, Request for Information 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, dated March 12, 2012 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 NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012 NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012 NRC 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, dated August 29, 2012 Site-specific letter to NRC staff transmitting results of a communications assessment performed in response to NRC 50.54(f) letter; initial letter dated on or around October 31, 2012 and a possible follow-up letter dated on or around February 28, 2013 COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 Site-specific letter to NRC staff transmitting results of a first-phase staffing assessment performed in response to NRC 50.54(f) letter, dated on or around April 30, 2013; a second-phase staffing assessment is due to the NRC staff no later than 4 months prior to the beginning of the second refueling outage (as described in the site response to NRC Order EA-12-049 Site-specific Integrated Plan for implementing NRC Order EA-12-049 Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015 4.3 RECOMMENDED ACTIONS 4.3.1 Industry Performance Standard for EP Facilities and Equipment Each licensee should implement the Emergency Preparedness (EP) facility and equipment enhancements identified in their communications and staffing assessments 13

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September 2014 February 2016 provided to the NRC staff in accordance with the 50.54(f) letter.

For EP facility and equipment enhancements not addressed by the requirements or guidance discussed above, the following approaches are recommended.

• Determine applicable design and configuration control measures.

• Items may be procured and installed under the commercial and site requirements normally applied to EP facilities and equipment.

• For multi-unit sites, ensure that sufficient quantities of radiation protection equipment and supplies are, or can be made, available to support protracted operation of an expanded Emergency Response Organization (ERO).

• Programmatic controls should be developed to ensure the availability and reliability of EP facilities and equipment, including the performance of periodic inventory checks, functionality testing and maintenance.

• Supporting contracts with vendors should be periodically verified.

4.3.2 Considerations for Program Documents The facilities and equipment used exclusively for responding to a beyond design basis event or severe accident need not be described in the site emergency plan; however, these items should be described in a document maintained through a fleet or site document control process. The document should be retained for the life of the plant.

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September 2014 February 2016 5 DRILLS AND EXERCISES 5.1 APPLICABLE ASPECTS OF NRC NTTF REPORT RECOMMENDATIONS 5.1.1 Recommendation 4 The Task Force recommends that the Commission direct the staff to begin the actions given below to further enhance the ability of nuclear power plants to deal with the effects of prolonged SBO conditions at single and multiunit sites without damage to the nuclear fuel in the reactor or spent fuel pool and without the loss of reactor coolant system or primary containment integrity.

4.2 Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design-basis external events and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.

• This existing equipment currently provides some of the coping capability that is recommended for the long term, but current storage requirements do not ensure that it will be available after a design-basis external event. This requirement would increase the likelihood that the equipment will be available if called upon.

• The staff should also consider conforming changes to the requirements in 10 CFR 50.54(hh)(2) to address multiunit response capacity.

5.1.2 Recommendation 8 The Task Force recommends that the Commission direct the staff to further enhance the current capabilities for onsite emergency actions in the following ways:

8.4 Initiate rulemaking to require more realistic, hands-on training and exercises on SAMGs and EDMGs for all staff expected to implement the strategies and those licensee staff expected to make decisions during emergencies, including emergency coordinators and emergency directors.

5.1.3 Recommendation 9 The Task Force recommends that the Commission direct the staff to do the following:

9.3 Order licensees to do the following until rulemaking is complete:

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September 2014 February 2016 Conduct periodic training and exercises for multiunit and prolonged SBO scenarios.

Practice (simulate) the identification and acquisition of offsite resources, to the extent possible.

5.2 RELATED REFERENCE DOCUMENTS SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011 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 NRC letter, Request for Information 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, dated March 12, 2012 NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012 NRC 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, dated August 29, 2012 COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 Site-specific letter to NRC staff transmitting results of a first-phase staffing assessment performed in response to NRC 50.54(f) letter, dated on or around April 30, 2013; a second-phase staffing assessment is due to the NRC staff no later than 4 months prior to the beginning of the second refueling outage (as described in the site response to NRC Order EA-12-049 Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013 Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015 5.3 RECOMMENDED ACTIONS 5.3.1 Industry Performance Standards for BDB Event Response Drills Each licensee should demonstrate the capability for effective integrated use of their accident mitigation and management procedure and guideline sets. In particular, the ability to transition between procedure and guideline sets, and select the best strategy for preventing or mitigating fuel damage and limiting radiological releases, is demonstrated.

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September 2014 February 2016 procedures and guidelines implemented for a given scenario are dependent upon the nature of the postulated initiating event, the plant response/accident sequence, and the ability of responders to select and implement mitigation/management strategies. The use of complementary methods will also promote more effective use of resources (e.g.,

facilitates targeted drill objectives, avoids excessive drill down time and durations, etc.), and minimize potential safety challenges to personnel and equipment. These methods are discussed below and involve conducting:

• A drill that demonstrates the integrated use of FLEX strategies under the control of an Abnormal Operating Procedure (AOP) or Emergency Operating Procedure (EOP), as appropriate to the postulated scenario. Specific considerations for this drill are discussed in section 5.3.4.

• A drill that demonstrates the transition from a controlling AOP, EOP or Extensive Damage Mitigation Guidelines (EDMG) into Severe Accident Management Guidelines (SAMGs), and the selection of appropriate severe accident management strategies. The integrated use of FLEX strategies may occur if directed by the controlling SAMG and as appropriate to the postulated scenario. Specific considerations for this drill are discussed in section 5.3.5.9

• A drill that demonstrates the use of EDMG strategies.10 The integrated use of AOPs and EOPs, and FLEX strategies, may occur if directed by the controlling EDMG as appropriate to the postulated scenario. Specific considerations for this drill are discussed in section 5.3.6.

• A drill or drills to demonstrate the capability to utilize equipment necessary to implement each strategy for responding to a beyond design basis event or severe accident. Specific considerations for this drill are discussed in section 5.3.7.

The initial occurrence of each drill type listed above should be aligned with the implementation milestones for the Mitigation of Beyond-Design-Basis Events Rule.

Also for each drill type listed above, a subsequent drill should be conducted within 8 calendar years of the preceding occurrence. For example, an initial FLEX strategy drill is conducted in June, 2017; the next FLEX strategy drill should be conducted by December 31, 2025.

5.3.2 Common BDB Event Response Drill Attributes 5.3.2.1 The following attributes apply to any BDB event response drill requiring implementation of FSGs, SAMGs or EDMGs, and the Drill Manager should consider them when developing the drill scenario and implementation methods.

• If not leading the effort, it is recommended that a fleet or site Emergency 9

The SAMG drill is not a regulatory requirement and is performed on a voluntary basis.

10 As used here, EDMG should be understood to mean the site document(s) developed to address 10 CFR 50.54(hh)(2), and the related guidance in NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline.

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September 2014 February 2016 Preparedness (EP) Department be involved with the development and implementation of the drill11.

• Two or more of the drills described above may be combined and conducted as one activity. A drill(s) may also be included within the scope of another drill (e.g., a scheduled ERO drill) or an evaluated exercise conducted to meet the requirements of 10 CFR 50, Appendix E.

• Conducting a BDB event response drill may require a set of site resources different from those normally used to conduct EP drills. The Drill Manager should identify the site resources (e.g., staffing and equipment) necessary to conduct the drill and ensure that they are scheduled/reserved.

In particular, consider items that should be available to support the selected demonstrations of in-field/plant actions (e.g., movement of a portable pump).

• All normal site security, radiation protection and personnel safety requirements should be followed during the drill. These requirements should be carefully considered when developing the drill scope, extent-of-play and scenario.

• Scenario time jumps/compression may be used during the drill; however, the Drill Manager should be aware that operating experience has indicated such techniques may cause confusion among drill participants unless carefully scripted and controlled.

• Emergency response functions described in the site emergency plan should be implemented as appropriate to the drill scope, extent-of-play and scenario, and consistent with normal EP drill program practices.

• The licensee should determine whether drill performance will count towards the DEP and ERO performance indicators, consistent with the guidance in NEI 99-02.

• Drill controller and evaluator duty assignments and responsibilities should be consistent with normal fleet or site drill program practices. In particular, assignments should be made to observe and assess player performance in a manner similar to that done for other drills.

• Use of radiation protection equipment by personnel responsible for deploying portable equipment in the field/plant should be performed.

• Following a drill, the licensee should conduct a drill critique and develop a 11 This recommendation is limited to drill development and implementation. No position is taken with respect to which fleet or site department(s) should be assigned ownership of BDB event response programs or program elements.

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September 2014 February 2016 drill report. The report should include a timeline of the decisions and actions taken to implement the selected BDB event response strategies.

• Identified drill weaknesses and deficiencies should be placed into the appropriate fleet or site corrective action program.

5.3.3 Use of a Plant-Referenced Simulator during BDB Event Response Drills Drills should utilize the capabilities of the plant-referenced simulator(s) to the degree practicable by current simulator modeling.

In cases where the postulated drill scenario events exceed the limits of the simulator model, or such limits would be exceeded soon after the drill is commenced, the simulator should not be used. Key parameter values supporting the drill should be generated and supplied to participants through other means (e.g., best estimate values are developed and provided using paper data sheets).

For a multiple-unit site with one plant-referenced simulator, the simulator may be used during a drill and the resulting data taken as representative of all onsite units if consistent with the postulated scenario conditions (i.e., the postulated events affect all onsite units in a similar manner).

5.3.4 Drill Demonstrating Integrated Use of FLEX Strategies Under the Control of an AOP or EOP 5.3.4.1 The following organizations and facilities should participate in the drill.

• A simulated Control Room for all on-site units. The Control Room(s) may be simulated in any location, consistent with the guidance in step 5.3.3 (e.g., simulator, conference room or classroom, TSC, etc.). Control Room players may be limited to those necessary for the planned demonstration.

• The primary Emergency Operations Facility (EOF) or alternate EOF, if the use of the facility is anticipated during the response to the postulated event.

• An offsite facility to which the onsite Emergency Response Organization (ERO) would report during the period when the site is inaccessible (e.g.,

an ERO alternative facility12), if the use of the facility is anticipated during the response to the postulated event.

• Offsite Response Organizations (OROs)13 should be invited to participate; 12 An ERO alternative facility is the staging area for augmented ERO personnel used during a response to a hostile action, as described in the site emergency plan.

13 OROs are those state, local and tribal agencies with primary responsibility for coordinating and implementing offsite emergency measures.

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September 2014 February 2016 however, their participation is not required.

• The appropriate RegionalNational SAFER Response Center (RRC) should be invited to participate; however, actual delivery of equipment is not required.

5.3.4.2 The Drill Manager14 should consider the following items when developing the drill scope and extent-of-play.

• As used in this section, drill means a performance enhancing experience during which participant performance is assessed against a certain standard (e.g., a drill objective). Such experiences typically exclude classroom training and facilitated meetings where on-the-spot instruction and coaching is expected.

• Control Room players should process through the operating procedures and guidelines that would be used to respond to the postulated event.

• The drill duration need not exceed the assumed elapsed time necessary for augmented ERO personnel to access the site following the initiating event, as specified in the licensees staffing assessments performed pursuant to the NRCs 50.54(f) letter dated March 12, 2012. This elapsed time is typically 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.15 Since the arrival times of ERO personnel reporting to the site from offsite locations during the drill should be consistent with the times specified in the staffing assessments, it is unlikely that the onsite TSC and OSC will be activated during the drill (unless the drill duration exceeds the assumed time necessary for ERO personnel to access the site).

• The arrival times of response personnel reporting to the EOF and/or an ERO alternate facility should reasonably reflect the postulated scenario conditions and the facilitys distance from the plant site.

• Sufficient drill time should be allowed for the appropriate augmented ERO position to demonstrate the ability to assume command and control of the event response from the Shift Manager.

• Drill players should use the communications systems and equipment that would be employed during an actual response to the postulated event.

This equipment may be simulated if changes or modifications would be required to support drill use (e.g., the simulated Control Room could not use a system without the installation of a new antenna and cabling). The decision to use or simulate this equipment should also include resource and equipment safety considerations.

14 As used in this document, Drill Manager refers to the individual with the overall responsibility for coordinating preparation and implementation of a BDB event response drill.

15 Refer to NEI 12-01, assumption 2.2.4, and site-specific staffing assessments.

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• A control cell should be established to simulate non-participating organizations.

• Appropriate personnel at ERO facilities should demonstrate the ability to request the acquisition, and coordinate the delivery, of equipment from the supporting RRCNational SAFER Response Center (NSRC) consistent with site procedures and guidelines; however, activation of the RRCNSRC is not required. If the RRCNSRC is not participating, then a control cell should be established to simulate the appropriate contact point. Actual delivery of equipment from an RRCNSRC will be simulated or occur as an out-of-sequence activity as coordinated with, and agreed to in advance, by the RRCNSRC.

5.3.4.3 The Drill Manager should consider the following items when developing the drill scenario and implementation methods.

• Determine the strategies, procedures and guidelines to be demonstrated during the drill, and specify the necessary operating mode(s) for each onsite unit in the scenario initial conditions.

• The assumed drill start time for the initiating event should occur during a period of minimum on-shift staffing, i.e., during a backshift, weekend or holiday.16

• The drill should be initiated by a beyond design basis event that results in an extended loss of AC power (ELAP) simultaneously affecting all onsite units.

• The postulated drill scenario conditions should be generally consistent with the event assumptions listed in NEI 12-01 and NEI 12-06.

• Controllers should track the assignment/deployment of on-shift personnel, and promptly identify any instances where such assignments/deployments exceed to the number of available individuals17. Such instances should be reported to the players, documented in a controller log and discussed in the drill critique. The players are responsible for determining what changes to assignments/deployments are necessary during the drill to account for staffing constraints identified by a controller.

• The scenario need not include the postulated failure of portable equipment.

• The drill scenario need not include a postulated radiological release.

16 To allow for drill conduct during a normal work day, the scenario may use an assumed day and/or start time (e.g.,

a drill conducted during normal work hours on a Tuesday may assume that the scenario takes place on a Saturday).

17 The number of available individuals should be determined from, and consistent with, the staffing assessments performed in response to the NRC 50.54(f) letter of March 12, 2012.

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• The scenario may assume that requested response assistance provided by OROs and other offsite resource providers (e.g., corporate support) is available within reasonably expected timeframes.

5.3.5 Drill Demonstrating the Transition from a Controlling AOP, EOP or EDMG into SAMGs 5.3.5.1 The following organizations and facilities should participate in the drill.

• A simulated Control Room for all on-site units. The Control Room(s) may be simulated in any location, consistent with the guidance in step 5.3.3 (e.g., simulator, conference room or classroom, TSC, etc.). Control Room players may be limited to those necessary for the planned demonstration.

• The primary or alternate emergency response facilities which house personnel with responsibility for evaluation of SAMG strategies and related decision-making for implementation. Players may be limited to these individuals.

• Offsite Response Organizations (OROs) should be invited to participate; however, their participation is not required.

• Participation by an RRCthe NSRC is not required.

5.3.5.2 The Drill Manager should consider the following items when developing the drill scope and extent-of-play.

• As used in this section, drill means a performance enhancing experience during which participant performance is assessed against a certain standard (e.g., a drill objective). Such experiences typically exclude classroom training and facilitated meetings where on-the-spot instruction and coaching is expected.

• Control Room players should process through the operating procedures and guidelines that would be used to respond to the postulated event.

• The drill should facilitate demonstration of the ability of the appropriate ERO decision-maker to assume command and control of the event response from the Shift Manager.

• Drill players should use the communications systems and equipment that would be employed during an actual response to the postulated event.

This equipment may be simulated if changes or modifications would be required to support drill use (e.g., the simulated Control Room could not use a system without the installation of a new antenna and cabling). The decision to use or simulate this equipment should also include resource and equipment safety considerations.

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• A control cell should be established to simulate non-participating organizations. For example, if portions of the Technical Support Center staff are participating, the Drill Manager should consider establishing a control cell to simulate needed contacts with the Operational Support Center and EOF staffs.

• The drill should facilitate demonstration of the evaluation and decision-making for at least two SAMG strategies.

5.3.5.3 The Drill Manager should consider the following items when developing the drill scenario and implementation methods.

• The drill initial conditions should reflect the occurrence of an accident or event that resulted in the onset of conditions leading to fuel damage, and driving entry into SAMGs for at least one unit.18 The initial conditions should also specify the operating mode(s) of each onsite unit that existed prior to the accident or event, based on the strategies, procedures and guidelines to be demonstrated during the drill. The transition from the procedure(s) in effect, and into SAMGs, should be demonstrated.

• All ERO facilities may be assumed to be activated.

• The scenario may assume that requested response assistance provided by OROs and other offsite resource providers (e.g., corporate support) is available within reasonably expected timeframes.

5.3.6 Drill Demonstrating the Use of EDMG Strategies 5.3.6.1 The following organizations and facilities should participate in the drill.

• Appropriate on-shift personnel should be selected based on whether or not the drill scenario assumes that the control room command and control structure remains available.

o If available, establish a simulated Control Room for all on-site units.

The Control Room(s) may be simulated in any location, consistent with the guidance in step 5.3.3 (e.g., simulator, conference room or classroom, TSC, etc.). Control Room players may be limited to those necessary for the planned demonstration.

o If not available, personnel should be those that can be expected to respond to an event involving a loss of large areas of the plant due to 18 For example, a BDB seismic event occurred several hours ago that resulted in implementation of FLEX strategies.

A second BDB seismic event occurred that impacted the ability to sustain one or more FLEX strategies, and more hours have elapsed. The drill would begin with conditions that are then degrading into those requiring a transition into SAMGs.

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September 2014 February 2016 explosions or fire, and causing a loss of the normal on-shift command and control structure.

• On-site emergency response facilities or other locations that would be expected to be available following an event involving a loss of large areas of the plant due to explosions or fire, as described in the drill scenario.

• Offsite Response Organizations (OROs) should be invited to participate; however, their participation is not required.

• Participation by an RRCthe NSRC is not required.

5.3.6.2 The Drill Manager should consider the following items when developing the drill scope and extent-of-play.

• As used in this section, drill means a performance enhancing experience during which participant performance is assessed against a certain standard (e.g., a drill objective). Such experiences typically exclude classroom training and facilitated meetings where on-the-spot instruction and coaching is expected.

• Operators and other appropriate players should process through the operating procedures and guidelines that would be used to respond to the postulated event.

• The arrival times of response personnel reporting to the site from offsite locations should be consistent with those described in the site emergency plan.

• Sufficient drill time should be allowed for the appropriate augmented ERO position to demonstrate the ability to assume command and control of the event response.

• Drill players should use the communications systems and equipment that would be employed during an actual response to the postulated event.

This equipment may be simulated if changes or modifications would be required to support drill use. The decision to use or simulate this equipment should also include resource and equipment safety considerations.

• A control cell should be established to simulate non-participating organizations.

• The drill should facilitate demonstration of the evaluation and decision-making for at least two extensive damage mitigating strategies.

5.3.6.3 The Drill Manager should consider the following items when developing the drill scenario and implementation methods.

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• The assumed drill start time for the initiating event should occur during a period of minimum on-shift staffing, i.e., during a backshift, weekend or holiday.19

• The drill should be initiated by an event involving a loss of large areas of the plant due to explosions or fire. The scenario should specify whether or not the concurrent loss of the normal on-shift command and control structure is assumed to have occurred. These conditions should result in operators or other available on-shift personnel implementing EDMGs.

• Controllers should track the assignment/deployment of on-shift personnel, and promptly identify any instances where such assignments/deployments exceed to the number of available individuals20. Such instances should be reported to the players, documented in a controller log and discussed in the drill critique. The players are responsible for determining what changes to assignments/deployments are necessary during the drill to account for staffing constraints identified by a controller.

• The scenario need not include the postulated failure of portable equipment.

• The drill scenario need not include a postulated radiological release.

• The scenario may assume that requested response assistance provided by OROs and other offsite resource providers (e.g., corporate support) is available within reasonably expected timeframes.

5.3.7 Drills Demonstrating the Use of Strategy-Related Equipment 5.3.7.1 Each licensee should create a list of the mitigating strategies described in site-specific FSGs, SAMGs and EDMGs.21 An example list of strategies is presented in Attachment B.22 The capability to mobilize equipment used for debris removal should also be included in the list. For each listed strategy, the capability to utilize the key equipment necessary for performing an implementing method should be periodically demonstrated as discussed in step 5.3.1.

5.3.7.2 The capability to implement a strategy using installed plant equipment may be demonstrated during a drill or as an out-of-sequence activity. The licensee 19 To allow for drill conduct during a normal work day, the scenario may use an assumed day and/or start time (e.g.,

a drill conducted during normal work hours on a Tuesday may assume that the scenario takes place on a Saturday).

20 The number of available individuals should be consistent with the site emergency plan plus any additional personnel filling positions for which administrative controls exist to ensure 24/7 staffing.

21 SAMG strategy equipment drills are not a regulatory requirement and are performed on a voluntary basis.

22 The example list reflects currently operating plant designs that employ active safety features, and is for illustrative purposes only. As noted, each facility will need to create a site-specific listing based on site-specific mitigating strategies. This includes plant designs based on passive safety features such as the Westinghouse AP1000 or GE-Hitachi ESBWR.

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September 2014 February 2016 may include an out-of-sequence demonstration within the scope of another scheduled activity. Such opportunities may include, but are not limited to, a mini-drill or Dynamic Learning Activity, a Job Performance Measure/Task Performance Evaluation or a demonstration associated with another program activity (e.g., a fire protection program inspection). Demonstration credit may also be given for performance during an actual event. All such demonstrations must be consistent with plant configuration control requirements and sound operational decision-making. Actual manipulation or operation of equipment is not required.

5.3.7.3 The capability to implement a strategy using portable equipment may be demonstrated during a drill or as an out-of-sequence activity. The licensee may include an out-of-sequence demonstration within the scope of another scheduled activity. Such opportunities may include, but are not limited to, a mini-drill or Dynamic Learning Activity, a Job Performance Measure/Task Performance Evaluation or a demonstration associated with another program activity (e.g., a fire protection program inspection). Demonstration credit may also be given for performance during an actual event.

The demonstration of portable equipment should entail the movement of the equipment from its storage location to the location where it would be placed and operated, consistent with plant configuration control requirements and sound operational decision-making. Should placement in the expected operating location not be practicable, movement to an alternate (drill) location is acceptable. Actual connection/hookup or operation of equipment is not required.

5.3.7.4 If the same (or essentially the same) strategy is described in two or more emergency response guideline sets, then the capability to implement that strategy need be demonstrated only once over a given 8-year period (i.e.,

consistent with the drill periodicity guidance in step 5.3.1). For example, a PWR site has a strategy for feeding a steam generator described in its FSGs, SAMGs and EDMGs. The demonstration of an implementing method for this strategy, such as using a portable pump in accordance with an FSG, would satisfy the strategy demonstration requirement for all three guideline sets.

5.3.7.5 The capability to mobilize equipment used for debris removal may be demonstrated during a drill or as an out-of-sequence activity. The licensee may include an out-of-sequence demonstration within the scope of another scheduled activity. Such opportunities may include, but are not limited to, a mini-drill or Dynamic Learning Activity, a Job Performance Measure/Task Performance Evaluation or a surveillance. Demonstration credit may also be given for performance during an actual event (e.g., the same equipment is used to clear site roads following a heavy snowfall).

5.3.7.6 For a mitigating strategy expected to be implemented within the assumed elapsed time necessary for ERO personnel to access the site (as specified in the licensees staffing assessments performed pursuant to the NRCs 50.54[f]

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September 2014 February 2016 letter dated March 12, 2012), the following drill guideline should be considered.

• The number of individuals performing the demonstration should be consistent with the number expected to be available during a real event; this number may be determined from a staffing assessment. Deviations from a staffing assessment should be documented in a controller log and discussed in the drill critique.

5.3.8 BDB Event Response Drill Objectives Appendix A, BDB Event Response Drill Objectives, presents generic drill objectives that a licensee should use to develop a site-specific set of objectives for each BDB event response drill. Each objective has an associated listing of Performance Attributes; these attributes define successful objective performance and should be used to develop the site-specific evaluation criteria for each objective. The development of objectives and evaluation criteria should be informed by the content of site-specific procedures and guidelines, and the established drill scope and extent-of-play. While a licensee is not expected to use the generic objectives verbatim, the function(s) described by each objective, and the associated performance attributes, should be considered during the development of the drill objectives and evaluation material.

Objectives described in the fleet/site EP drill and exercise program may also be considered for demonstration during a BDB event response drill. These objectives, and their associated evaluation criteria, should be reviewed and revised as necessary to reflect differences between expected performance during a design basis event and a beyond design basis event. For example, additional time may be necessary to complete certain activities such as ORO notifications, the personnel accountability process and activation of ERO emergency response facilities during a beyond design basis event response. The licensee should determine reasonable performance standards based on site-specific capabilities, and reflect these in the objectives and evaluation criteria.

As noted above, each BDB event response drill should be critiqued to identify weaknesses and deficiencies. Licensees should modify their critique processes as necessary to ensure a thorough review and evaluation of BDB-related drill objectives.

5.3.9 Considerations for Program Documents The drills conducted to demonstrate responses to a beyond design basis event or severe accident need not be described in the site emergency plan; however, these activities should be described in a document maintained through a fleet or site document control process. The document should be retained for the life of the plant.

Each licensee should review the condition screening and evaluation requirements described in their corrective action program(s), and determine if changes are necessary.

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September 2014 February 2016 allocation of resources should be balanced with other needs, and commensurate with the anticipated benefits to overall accident or event response capabilities (e.g., changes offering lower relative or absolute benefits should be assigned lower priorities).

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September 2014 February 2016 6 REFERENCES

• NRC Report, 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

• SECY-11-0137, Prioritization of Recommended Actions to be taken in Response to Fukushima Lessons Learned, dated October 3, 2011

• 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

• NRC letter, Request for Information 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, dated March 12, 2012

• NRC 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, dated August 29, 2012

• NRC Letter, Wiggins to Pollock, dated February 27, 2013

• COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013

• Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013

• Staff Requirements - SECY-15-0065 - Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015

• Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015

• NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, dated July 2009December 2006

• NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012

• NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012

• NEI Letter, Industry Implementation of Multi-unit Dose Assessment Capability, Pollock to Wiggins, dated January 28, 2013 29

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• NEI Letter, Commitment for Implementation of Multi-Unit Dose Assessment Capability, Pollock to Wiggins, dated March 14, 2013

• NEI Letter, Commitment for Implementation of Multi-Unit Dose Assessment Capability, Pietrangelo to Nuclear Strategic Issues Advisory Committee Steering Group, dated March 22, 2013

• NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, dated September 2014February 2016 30

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September 2014 February 2016 APPENDIX A - BDB EVENT RESPONSE DRILL OBJECTIVES Recommended Objective Performance Attributes

1. Demonstrate the ability of on-shift

• The Shift Manager provides effective operations personnel to perform integrated command and control of the accident or implementation of operating procedures event response until relieved and guidelines for responding to a beyond

• Perform processing of, and transitions design basis event or severe accident. between, applicable procedures and guidelines.

• Perform evaluation and decision-making related to the selection of mitigation or management strategies and actions.

• Communicate selected mitigation or management strategies and actions to the appropriate personnel.

2. Demonstrate the ability of the [ERO

• Perform turnover of command and control position assuming UDM function from Shift consistent with the applicable procedures Manager] to assume command and control or guidelines.

for the selection and implementation of

• Perform decision-making related to the mitigation and management strategies. selection of mitigation and management strategies and actions, including those associated with a multi-unit response if applicable.

• Direct the communication of selected mitigation and management strategies and actions to the Control Room and other appropriate personnel.

3. Demonstrate the ability of the augmented

• Perform evaluation and recommendations ERO staff to evaluate and recommend related to the selection of mitigation and mitigation and management strategies. management strategies and actions, including those associated with a multi-unit response if applicable.

• Communicate selected mitigation and management strategies and actions to the Control Room and other appropriate personnel.

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4. Demonstrate the ability of the on-shift and Establish and maintain required augmented ERO staff to communicate communications in accordance with applicable during a beyond design basis event or procedures and guidelines. [Wording should severe accident. reflect which organizations will be represented by a controller/control cell.]

• Offsite Response Organizations

• NRC ENS

• Between ERO facilities

• On-site and in-plant response teams

• Offsite monitoring teams

5. Demonstrate the ability to operate the * [Specify the mitigating or management installed plant equipment necessary for strategy(ies) to be demonstrated during the implementing a mitigating or management drill; select these from the list of strategies strategy. developed per the guidance in section 5.3.7.]

• [Specify which key implementing actions will be performed, simulated or discussed during the drill.]

• Verify that the necessary actions for implementing a mitigating or management strategy can be performed by the available staff.

• Verify that personnel assigned actions do not have concurrent collateral duties which would preclude timely performance.

6. Demonstrate the ability to deploy the * [Specify the mitigating or management portable equipment necessary for strategy(ies) to be demonstrated during the implementing a mitigating or management drill; select these from the list of strategies strategy. developed per the guidance in section 5.3.7.]

• [Specify which key implementing actions will be performed, simulated or discussed during the drill.]

• Verify that the necessary actions for implementing a mitigating or management strategy can be performed by the available staff.

• Verify that personnel assigned actions do not have concurrent collateral duties which would preclude timely performance.

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7. Demonstrate the ability to deploy * [Specify which key implementing actions equipment necessary for debris removal in will be performed, simulated or discussed order to allow/improve access to the during the drill.]

unit(s). * [Specify the location(s) where demonstration will occur.]

• Verify that the necessary actions for performing debris removal can be implemented by the available staff.

• Verify that personnel assigned actions do not have concurrent collateral duties which would preclude timely performance.

8. Demonstrate the adequacy of EP facilities

• EP facilities can adequately accommodate and equipment to support the augmented expected personnel during the response to a ERO during a beyond design basis event. beyond design basis event affecting all onsite units.

• Augmented ERO personnel have the equipment necessary to perform assigned duties during a beyond design basis event affecting all onsite units.

9. Demonstrate the ability to perform multi- Perform an offsite dose assessment following a unit/source dose assessment. beyond design basis event or severe accident resulting in concurrent radiological releases from all on-site units (multi-unit site) or multiple release points (single-unit site).

Note This drill objective may demonstrated during a drill or exercise (as an in sequence or out-of-sequence activity) or a separate/stand-alone mini-drill. Refer to section 2.3.4 for additional information.

10. Demonstrate the ability to notify the The RRCNSRC is notified of the event and RegionalNational SAFER Response Center equipment needs in accordance with (RRCNSRC) and coordinate the delivery of appropriate procedures or guidelines. [Site requested equipment. protocol may have this notification being made to INPO instead of directly to the RRCNSRC; revise wording as needed. Wording should also reflect which organizations will be represented by a controller/control cell.]

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September 2014 February 2016 APPENDIX B - EXAMPLE MITIGATION STRATEGY LIST Example Boiling Water Reactor (BWR) Mitigating Strategies Flex Support Guidelines 1. DC load shedding/stripping

2. Use of RCIC/HPCI/IC during an ELAP

3. Repower instrumentation needed to maintain safety functions with portable power supplies

4. Use of alternate water supply to support core and spent fuel pool heat removal

5. Depressurize RPV for injection with portable injection source

6. Containment venting

7. Repower hydrogen igniters with a portable power supply (BWR Mark III containments only)

8. Spent fuel pool cooling via makeup with a portable injection source Severe Accident 1. Inject into (makeup to) reactor pressure vessel/reactor coolant Management Guidelines system (RPV/RCS)

2. Depressurize the RPV/RCS

3. Spray within the RPV

4. Operate isolation condenser

5. Spray into containment

6. Inject into containment

7. Operate recombiners

8. Operate igniters

9. Inert the containment with noncondensable gases

10. Vent the primary containment

11. Inject into the spent fuel pool

12. Spray the spent fuel pool

13. Vent/ventilate the reactor building or auxiliary building

14. Scrub releases by external spraying of buildings Extensive Damage 1. Manual operation of RCIC/IC Mitigation Guidelines (or 2. DC power supplies to allow depressurization of RPV and other related guidelines injection with portable pump describing mitigating 3. Utilize feedwater and condensate actions for an event

4. Makeup to hotwell.

involving a loss of large areas of the plant due to 5. Makeup to CST explosions or fire) 6. Maximize CRD flow

7. Procedure to isolate RWCU

8. Manually open containment vent lines

9. Inject water into the drywell

10. Portable sprays B-1

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September 2014 February 2016 Example Pressurized Water Reactor (PWR) Mitigating Strategies Flex Support Guidelines 1. DC load shedding/stripping

2. Use of AFW/EFW during an ELAP

3. Repower instrumentation needed to maintain safety functions with portable power supplies

4. Use of alternate water supply to support core and spent fuel pool heat removal (including all portable/staged pumps)

5. Depressurize steam generator for makeup with portable injection source

6. Means to provide borated RCS makeup

7. Containment spray (if applicable)

8. Operate hydrogen igniters (ice condenser containments)

9. Spent fuel pool cooling via makeup with a portable injection source

10. Mode 5 & 6 RCS makeup using portable injection source Severe Accident 1. Inject into (makeup to) reactor vessel/reactor coolant system Management Guidelines 2. Depressurize the RCS

3. Restart reactor coolant pump (RCP)

4. Depressurize steam generators

5. Inject into (feed) the steam generators

6. Spray into containment

7. Inject into containment

8. Operate fan coolers

9. Operate hydrogen igniters (ice condenser containments)

10. Vent the containment

11. Inject into the spent fuel pool

12. Spray the spent fuel pool

13. Vent/ventilate the auxiliary building

14. Scrub releases by external spraying of buildings Extensive Damage 1. Makeup to RWST Mitigation Guidelines (or 2. Manually depressurize steam generators to reduce RCS other related guidelines inventory loss describing mitigating 3. Manual operation of turbine (or diesel)-driven AFW/EFW actions for an event pump involving a loss of large

4. Manually depressurize steam generators and use portable areas of the plant due to pump explosions or fire)

5. Makeup to CST

6. Containment flooding with portable pump

7. Portable sprays (if available)

8. Internal Spent Fuel Pool Makeup

9. External Spent Fuel Pool Makeup B-2

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Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents

February 2016

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NEI 14-01

[Revision 1]

Nuclear Energy Institute Emergency

Response

Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents

February 2016 ACKNOWLEDGMENTS This document was developed by the Boiling Water Reactor Owners Group (BWROG), the Pressurized Water Reactor Owners Group (PWROG) and the Nuclear Energy Institute (NEI).

The lead/coordinating document contributors are presented below.

BWROG:

Lesa Hill - Southern Nuclear and BWROG Chairperson Jay Lyter - Exelon Nuclear and Vice Chairperson, BWROG Emergency Procedures Committee PWROG:

Jack Stringfellow - Southern Nuclear and PWROG Chairperson Steve Pierson - Exelon Nuclear and PWROG Procedures Subcommittee Representative NEI:

David Young - Senior Project Manager, Emergency Preparedness In addition, the document contents were reviewed by the NEI Emergency Response Steering Committee and the Emergency Preparedness Working Group.

NOTICE Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.

NEI 14-01 (Revision 1)

February 2016 EXECUTIVE

SUMMARY

U.S. nuclear power plant licensees currently maintain the capability to implement beyond design basis accident mitigation and management strategies developed through several separate initiatives. Each strategy has been converted into implementing actions and recommendations within three separate sets of procedures and guidelines: Emergency Operating Procedures (EOPs), Severe Accident Management Guidelines (SAMGs), and Extensive Damage Mitigation Guidelines (EDMGs). In addition to these existing procedure and guideline sets, the industry is currently developing a new set of guidelines, referred to as FLEX Support Guidelines (FSGs), in response to Order EA-12-049 issued by the U.S. Nuclear Regulatory Commission (NRC)1.

Having been developed separately, each of these procedure and guideline sets are subject to varying levels of regulatory requirements and industry commitments, as are the training, drills, and exercises intended to maintain the capability for effective implementation.

The EOPs were designed to restore and maintain safety functions, and place the plant in a safe shutdown condition. EOPs are required by Title 10 of the Code of Federal Regulations (10 CFR)

Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and are included in the administrative control sections of a licensees technical specifications. The training requirements for EOPs are primarily contained within 10 CFR Part 55, Operators Licenses.

Licensed operators are required to show sufficient knowledge of the EOPs on an initial written examination, in accordance with 10 CFR 55.41 (Reactor Operators) or 10 CFR 55.43 (Senior Reactor Operators), and the ability to implement the EOPs through an initial operating test that meets the requirements of 10 CFR 55.45. Licensed operators are required to continuously demonstrate that they have maintained their knowledge of the EOPs through the requalification program required by 10 CFR 55.59.

SAMGs provide guidance to operators and designated support staff for use in the event that accident conditions progress beyond the mitigation capabilities described in the EOPs (e.g., fuel damage is imminent or has occurred). The SAMGs were developed as a voluntary industry initiative in response to NRC Generic Letter 88-20, Supplement 2, Accident Management Strategies for Consideration in the Individual Plant Examination Process, dated April 4, 19902.

There is currently no regulatory requirement for licensees to develop, maintain, train, drill or exercise SAMGs.

Following the terrorist attacks of September 11, 2001, the NRC ordered licensees to develop strategies and specific implementing guidance for maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire. These extensive damage mitigation requirements were subsequently imposed as license conditions for individual licensees and then made generically applicable under 10 CFR 50.54(hh)(2) through the Power Reactor Security Requirements final rule (74 FR 13926; March 27, 2009). As a result, EDMGs were created to provide guidance to operating crews and other plant staff on the implementation of strategies for responding to an event involving a loss of large areas of the plant due to explosions or fire.

1 Refer to NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies i

for Beyond Design Basis External Events, dated March 12, 2012; NRC ADAMS ML #12054A735.

2 Refer to NRC ADAMS ML #031200551 i

NEI 14-01 (Revision 1)

February 2016 On March 11, 2011, a magnitude 9.0 earthquake struck off the coast of the Japanese island of Honshu. Approximately 40 minutes after the earthquake, the first of several large tsunami waves inundated the Fukushima Dai-ichi Nuclear Power Plant site. The tsunami waves resulted in extensive damage to site facilities, and a complete and extended loss of AC electrical power at Fukushima Dai-ichi Units 1 through 5; one diesel generator remained functional on Unit 6.

Despite the actions of the operators following the earthquake and tsunami, cooling was lost to the fuel in the Unit 1 reactor after several hours, the Unit 3 reactor after about 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and the Unit 2 reactor after about 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br />; fuel damage resulted in each unit shortly after the loss of cooling.

In the days following the Fukushima Dai-ichi accident, the NRC Chairman directed the staff to establish a senior-level agency task force to conduct a full review of the agencys processes and regulations in light of the events in Japan. This task force, referred to as the Near-Term Task Force (NTTF), was also directed to identify recommended improvements to agency policies and regulatory practices. The NTTF provided its recommendations to the Commission in a report dated July 12, 2011.3 In Recommendation 8 of the NTTF report, the Task Force recommended strengthening and integrating the onsite emergency response capabilities described in EOPs, SAMGs, and EDMGs.

As discussed in SECY-11-0124, Recommended Actions to be Taken Without Delay from the Near-Term Task Force Report, dated September 9, 2011, the NRC staff proposed to proceed with a rulemaking associated with the methodology for integration of onsite emergency response processes, procedures, training and exercises. This decision led to the development of a document entitled, Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013. The Recommendation 8 regulatory basis was subsequently incorporated into Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015, with changes directed by the NRC Commissioners in Staff Requirements - SECY-15-0065 -

Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015.

In the Staff Requirements Memorandum referenced above, the NRC Commissioners directed the removal of requirements for SAMGs from the proposed Mitigation of Beyond Design Basis Events rule. The industry continues to believe that SAMGs provide a useful tool to plant operators in the unlikely event of a severe accident and should be maintained. To this end, the NEI Nuclear Strategic Issues Advisory Committee (NSIAC) approved an Industry Initiative on SAMGs that requires each licensee to docket site-specific commitments concerning the updating these guidelines, and their consideration within plant configuration management processes, integration with other emergency response guideline sets and symptom-based EOPs, and validation.

This document provides guidance for ensuring that EOPs, EDMGs, FSGs and SAMGs are integrated in a cohesive, effective and usable manner. It also addresses recommendations for the development of mitigation and management guidelines, and command and control structures, for responding to beyond design basis events and severe accidents. Guidance concerning the related aspects of training, drills and exercises is contained in NEI 13-06, Enhancements to Emergency 3

Refer to NRC ADAMS ML #111861807 ii

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February 2016 TABLE OF CONTENTS EXECUTIVE

SUMMARY

............................................................................... i 1 INTRODUCTION ................................................................................... 1 2 PROCEDURE INTEGRATION ............................................................... 3 2.1 OVERVIEW ..................................................................................................................... 3 2.2 PROCEDURES AND GUIDELINES ....................................................................................... 3 2.3 EMERGENCY RESPONSE PROCEDURE AND GUIDELINES SETS ..................................... 4 2.4 INTEGRATION OF PROCEDURE AND GUIDELINE SETS .................................................. 5 2.5 COORDINATION WITH FIRE RESPONSE STRATEGIES ..................................................... 6 3 REQUIREMENTS FOR SAMGS AND SUPPORTING GUIDELINES ........ 8 3.1 OVERVIEW ..................................................................................................................... 8 3.2 SEVERE ACCIDENT MANAGEMENT GUIDELINES............................................................ 8 3.3 FLEX SUPPORT GUIDELINES ........................................................................................ 13 3.4 EXTENSIVE DAMAGE MITIGATION GUIDELINES .......................................................... 13 4 COMMAND AND CONTROL................................................................. 14 4.1 OVERVIEW ................................................................................................................... 14 4.2 COMMAND AND CONTROL KEY FUNCTIONS ................................................................ 14 4.3 COMMAND AND CONTROL STRUCTURE CONSIDERATIONS ......................................... 14 5 REFERENCES..................................................................................... 17 5

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February 2016 EMERGENCY RESPONSE PROCEDURES AND GUIDELINES FOR BEYOND DESIGN BASIS EVENTS AND SEVERE ACCIDENTS 1 INTRODUCTION Each nuclear power plant licensee maintains sets of operating procedures that provide direction for responding to a wide spectrum of off-normal and emergency events and conditions. Direction is provided for addressing events and conditions both within the plant design basis as well as certain events and conditions that are beyond the design basis. These procedure sets are typically known as Alarm Response Procedures (ARPs), Abnormal Operating Procedures (AOPs) and Emergency Operating Procedures (EOPs), and they instruct licensed operators on the steps necessary to maintain safe operation and protect fission product barriers during all modes of plant operation.

In response to the lessons learned from the accident at Three Mile Island, the nuclear industry developed Severe Accident Management Guidelines (SAMGs) as a voluntary initiative.4 The SAMGs describe additional strategies meant to provide operators and the plant staff with the capability to manage accident sequences that progress beyond the capacity of the mitigating strategies contained in the EOPs (e.g., adequate core cooling cannot be maintained). In doing so, the strategy focus changes from preventing fuel damage to mitigating the consequences of fuel damage, including minimizing radiological releases and protecting personnel.

Existing site-specific EOPs and SAMGs are based on generic technical guidelines developed in response to NUREG-0737, Item I.C.1, Guidance for the Evaluation and Development of Procedures for Transients and Accidents, and NEI 91-04, Severe Accident Issue Closure Guidelines, Revision 1, respectively. The generic technical guidelines were created by the Boiling Water Reactor (BWR) and Pressurized Water Reactor (PWR)

Owners Groups, and, in the case of the SAMGs, utilize applicable technical research and bases materials provided by the Electric Power Research Institute (EPRI). Using these generic guidelines, each licensee has developed EOPs and SAMGs that are appropriate for their specific plant technology, and function as an integrated set of strategies and implementing instructions.

Following the terrorist attacks of September 11, 2001, the NRC ordered licensees to develop strategies and specific guidance for maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with a loss of large areas of the plant due to explosions or fire; the NRC order was eventually codified in 10 CFR 50.54 (hh). U.S. nuclear power plant operators developed their response strategies and guidelines in accordance with NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline. The guideline sets that resulted from these efforts are typically referred to Extensive Damage Mitigation Guidelines (EDMGs).

1

4 Refer to NRC Generic Letter 88-20, Supplement 2, Accident Management Strategies for Consideration in the Individual Plant Examination Process, dated April 4, 1990.

2

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February 2016 As a result of the review of the March 11, 2011, accident at the Fukushima Dai-ichi Nuclear Power Plant, the NRC Near-Term Task Force (NTTF) made several recommendations intended to strengthen and integrate the onsite emergency response capabilities described in EOPs, SAMGs, and EDMGs; these recommendations are referred to collectively as Recommendation 8. All aspects of Recommendation 8 were subsequently evaluated by the NRC staff and refined into a regulatory basis to support future rulemaking; see Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013.5 . The Recommendation 8 regulatory basis was subsequently incorporated into Proposed Rule -

Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015, with changes directed by the NRC Commissioners in Staff Requirements - SECY-15-0065 -

Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015.

In the Staff Requirements Memorandum referenced above, the NRC Commissioners directed the removal of requirements for SAMGs from the proposed Mitigation of Beyond Design Basis Events rule. The industry continues to believe that SAMGs provide a useful tool to plant operators in the unlikely event of a severe accident and should be maintained.

To this end, the NEI Nuclear Strategic Issues Advisory Committee (NSIAC) approved an Industry Initiative on SAMGs that requires each licensee to docket site-specific commitments concerning the updating these guidelines, and their consideration within plant configuration management processes, integration with other emergency response guideline sets and symptom-based EOPs, and validation.

This document provides guidance for addressing the SAMG Industry Initiative and certain aspects of the Recommendation 8 regulatory basis; these topics are procedure integration, requirements for SAMGs and supporting guidelines, and a command and control structure for responding to a beyond design basis event or severe accident. The guidance was developed for commercial nuclear power reactors operating in the United States as of 2016.

Adoption or modification of this guidance by future operating plants should be based on discussions with the appropriate technology Owners Group and the NRC staff.

5 Refer to NRC ADAMS ML #13101A344 3

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February 2016 2 PROCEDURE INTEGRATION 2.1 OVERVIEW Each licensee should establish an overall framework for strategies that would be used to mitigate and manage the consequences of a beyond design basis event and severe accident. This framework should address the integrated use of emergency response procedures and guidelines such that they have been designed to work together to implement the best available strategy for preventing or mitigating fuel damage, and limiting radiological releases. The effective integration of procedures and guidelines is characterized by the attributes listed in Section 2.4, Integration of Procedure and Guideline Sets.

For purposes of this document, a strategy refers to a plan of action for maintaining or restoring a safety function6 in order to mitigate the effects of a beyond design basis event or manage the consequences of a severe accident. A strategy can be implemented by one or more methods. As used here, a method is a series of actions designed to implement a specific strategy. As an illustrative example of all three terms, consider that a portable pump (a method) may be used to inject water into the reactor pressure vessel (a strategy) for the purpose of maintaining core cooling (a safety function).

It is recognized that the usage of the above terms in NRC and industry documents, although generally similar, has varied somewhat over the years depending upon the preferences of authors and the purpose of a particular document. It will therefore be necessary to carefully apply these terms within the context of site-specific documents (i.e., in cases where different terms are used for the concepts identified above).

2.2 PROCEDURES AND GUIDELINES It is important to distinguish the difference between emergency response procedures and guidelines. Procedures are documents written as sequential instructions for performing a function or addressing plant conditions, and operators and plant staff are expected to follow the prescribed instructions in a step-by-step and verbatim manner. Exceptions to this expectation should be rare and necessary only in extraordinary circumstances.

As opposed to procedures, guidelines do not necessarily provide a prescribed set of instructions and may not be followed in a step-by-step manner. Rather, they provide suggested strategies and implementing methods that may be used to address an adverse event or condition, typically those beyond a plants design basis. Within guidelines, operators and plant staff have the latitude to respond as necessary to unpredictable and dynamic situations. During a beyond design basis event or severe accident, guidance documents would be used to focus the attention and actions of the operators and plant staff on the most important threats to safety and provide suggested optimal strategies for addressing plant conditions.

6 The safety functions of interest during a beyond design basis event or severe accident response are typically core 4

cooling, containment and spent fuel pool cooling.

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February 2016 2.3 EMERGENCY RESPONSE PROCEDURE AND GUIDELINES SETS This document employs the following terms when referring to procedure and guideline sets used by operators to respond to off-normal and emergency conditions. Depending upon Owners Group guidance, and fleet and site standards, a procedure and guideline set may be called by another name. Further, the decision to provide a given set of response instructions within a procedure or a guideline may vary from site-to-site. Each licensee should ensure that the appropriate site-specific document sets, and individual documents, are utilized when implementing the guidance contained in this document.

2.3.1 Abnormal Operating Procedures (AOPs)

AOPs are procedures that direct operator actions for restoring a function, system, or component to normal operating conditions following a transient or event. AOPs may also be used to mitigate an event or condition that is not severe enough to require use of an Emergency Operating Procedure (EOP), such as primary system leakage.

Further, AOPs may provide direction for responding to a wide range of off-normal and emergency conditions including, but not limited to, design basis-related events such as a Control Room evacuation, a fire, or a security threat; events initiated during shutdown or refueling operating modes; and natural and man-made hazardous conditions such as severe weather or toxic gas releases.

2.3.2 Emergency Operating Procedures (EOPs)

EOPs are procedures that direct operator actions for mitigating the consequences of transients and accidents that cause plant parameters to exceed reactor protection system or engineered safety features actuation setpoints. These procedures are developed using guidelines promulgated by the applicable Owners Group in response to NUREG-0737, Clarification of TMI Action Plan Requirements; Clarification Item I.C.1, Guidance for the Evaluation and Development of Procedures for Transients and Accidents.

2.3.3 FLEX Support Guidelines (FSGs)

FSGs are guidelines that provide strategies relying upon the use of installed and portable equipment and resources to maintain or restore core cooling, containment, and SFP cooling capabilities during beyond design basis events. The strategies and capabilities reflected in these guidelines address the requirements of NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events. Guidance concerning the development of FSGs is contained in Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.

2.3.4 Extensive Damage Mitigation Guidelines (EDMGs)

EDMGs are guidelines that provide strategies to maintain or restore core cooling, containment, and SFP cooling capabilities under the circumstances associated with the loss of large areas of the plant due to explosions or fire. These strategies and capabilities 6

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February 2016 address the requirements of 10 CFR 50.54(hh)(2). Guidance concerning the development of EDMGs is contained in NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline.

2.3.5 Severe Accident Management Guidelines (SAMGs)

SAMGs are guidelines that provide strategies to manage the consequences of an accident or event which would be implemented upon receipt of specific plant parameter values indicative of imminent or actual damage to irradiated fuel (e.g., high core exit thermocouple temperatures or low RPV water level). These guidelines employ strategies intended to arrest the progression of fuel damage, maintain the capability of the containment as long as possible, and minimize radiological releases. Guidance concerning the development of SAMGs is contained in this document.

SAMGs may be referred to as Severe Accident Guidelines (SAGs) at some sites.

2.4 INTEGRATION OF PROCEDURE AND GUIDELINE SETS Each licensees emergency response procedure and guideline sets should address the following considerations.

• A programmatic control document describing the framework for integration of mitigation and management strategies in response to a beyond design basis event or severe accident should be developed and maintained. The site-specific framework should consider the generic technical guidance provided by the appropriate Owners Group. Deviations from the generic technical guidance should be documented along with the supporting rationale.

For illustrative purposes, a simplified example framework is depicted in Figure 2.1.

• Strategies should be available to address potential or actual fuel damaging conditions present in the reactor core or the spent fuel pool.

• Strategies should be reviewed to identify potential gaps or inconsistencies.

• Each strategy should be included within a controlling procedure or guideline. Where appropriate, expectations concerning parallel processing of procedures and/or guidelines should be described.

• Criteria such as plant conditions and parameters that require a transition from one controlling procedure or guideline to another should be clearly identified.

• Criteria for implementing the actions described in a supporting procedure or guideline should be clearly identified in the controlling procedure or guideline.

• Strategies should be available to address a beyond design basis event or severe accident occurring during any mode of operation, consistent with the associated NRC staff-endorsed guidance. The degree to which a controlling procedure may or may not be fully applicable during some plant operating modes should be considered.

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• Strategies should be available to address an event involving a loss of large areas of the plant due to explosions or fire, including the possible loss of the Control Room command and control structure, consistent with the associated NRC staff-endorsed guidance in NEI 06-12. The degree to which a controlling procedure may or may not be fully applicable during some plant operating modes should be considered.

• Integration of EDMGs should reflect site-specific commitments made in response to NRC security orders.

• Integration of FSGs should reflect site-specific commitments related to NRC Order EA-12-049.

2.5 COORDINATION WITH FIRE RESPONSE STRATEGIES SAMGs and FSGs provide a core set of strategies that can be used to respond to a variety of failures and concurrent events. SAMGs were developed to address plant conditions associated with a fuel damaging event and utilize a symptom-based approach to strategy selection. They provide a wide range of strategies and implementing methods, which, by design, can be adjusted during an emergency in response to plant conditions and concurrent events, such as a fire. FSGs provide strategies for mitigating the effects of an Extended Loss of AC Power (ELAP). Consistent with NRC staff-endorsed guidance, the development of FSG strategies assumed that there were no independent concurrent events, including a postulated fire.

Unlike analyses associated with design basis accidents, determining accident progression and consequences for beyond design basis events and severe accidents is problematic given the effectively unbounded nature of the accident sequences. This is particularly true when the coincident occurrence of two or more events or accidents is postulated (e.g., an ELAP and a fire). While recognizing that concurrent events such as a fire could occur during a beyond design basis event and severe accident, it is not possible to predict resulting strategy impacts in any reliable/certain manner beforehand. For this reason, programmatic documents, and/or procedures and guidelines, should provide direction for selecting the appropriate strategy at the time of the emergency. For example, the Emergency Response Organization position(s) holding Ultimate Decision-Maker (UDM) authority7 could have guidance for selecting the appropriate strategy, and then determining the priorities and actions necessary for implementation.

7 Discussed in Section 4 of this document.

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February 2016 Figure 2.1 Simplified Example Framework FLEX Support Guidelines Severe Accident Extensive Damage Management Guidelines Emergency Operating Support Procedures Mitigation Guidelines Procedures Abnormal Operating Procedures Alarm Response Procedures General Operating Procedures Severity Note - EDMG capabilities/methods may be referenced in Emergency Operating Procedures (EOPs) and/or Severe Accident Management Guidelines (SAMGs).

In addition, BWR Support Procedures include the Technical Support Guidelines which support implementation of EOPs and SAMGs.

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February 2016 3 REQUIREMENTS FOR SAMGS AND SUPPORTING GUIDELINES 3.1 OVERVIEW Each licensee should maintain Severe Accident Management Guidelines (SAMGs) and supporting guidelines which consider the generic technical guidance provided by the applicable technology Owners Group. This includes the development of any additional guidance necessary for responding to a beyond design basis event or severe accident affecting the cooling of irradiated fuel stored in a spent fuel pool. With respect to guidance issued by the Nuclear Energy Institute (NEI), the material in this document supersedes that provided in Section 5 of NEI 91-04, Severe Accident Issue Closure Guidelines, for the development, implementation and maintenance of severe accident management programs.

3.2 SEVERE ACCIDENT MANAGEMENT GUIDELINES 3.2.1 Development of Generic Severe Accident Management Guidance Following the March, 1979, accident at Three Mile Island, the Electric Power Research Institute (EPRI) engaged in an extensive research program to better understand the nature of nuclear power plant accidents that could result in significant damage of the fuel -

referred to as severe accidents. Before the Three Mile Island accident, operator procedures and training had focused almost exclusively on preventing an upset condition from progressing to the point at which the fuel was damaged. To broaden the spectrum of emergency response guidance, EPRI developed generic accident management strategies and implementing methods that could be taken to limit the consequences of a severe accident. This guidance was issued in EPRI Technical Report TR-101869, Severe Accident Management Guidance Technical Basis Report (SAMG-TBR), dated April 1993.

The SAMG-TBR is organized into two volumes. Volume 1 defines severe accident damage conditions for the reactor core, spent fuel pool, and containment; identifies the Candidate High-Level Actions (CHLAs) that may be taken to best manage these conditions; and summarizes the effects that could result from implementation of each CHLA. Volume 2 is composed of appendices, each of which describes the physical behavior for one type of phenomenon relevant to severe accidents. These appendices also include the technical bases for calculation aids that can be used to estimate the plant response if an action is taken. Although these calculations are generally not intended to provide detailed results, they are sufficient to allow consideration of the relative benefits and possible undesired effects associated with each action.

In October, 2012, EPRI published an updated SAMG-TBR, Technical Report TR-1025295, to address lessons learned from the March, 2011, accident at Fukushima Dai-ichi, and incorporate other insights from research and analysis conducted over the intervening 20 years. While the actions described in the original report continue to 1

represent appropriate responses to severe accident conditions, several new technical considerations arising from the Fukushima accident were incorporated (e.g., makeup 1

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February 2016 water quality, spent fuel pool actions, hydrogen buildup mitigation, etc.). EPRI also issued a separate report dealing with strategies to limit radiological releases following a severe accident; refer to Technical Report TR-1026539, Investigation of Strategies for Mitigating Radiological Releases in Severe Accidents, dated October 2012. The latter report is applicable to a Boiling Water Reactor with a Mk 1 or Mk 2 containment.

The Boiling Water Reactor Owners Group (BWROG) and Pressurized Water Reactor Owners Group (PWROG) have created generic technical materials to guide the development of site-specific SAMGs for each technology. These technical guidelines translate the insights from the above discussed EPRI reports into a template containing recommended technology-appropriate strategies, and implementing methods, for mitigating the consequences of a severe accident. The development of technical guidelines is based on reference plants, and utilizes engineering data derived from severe accident analyses, operating experience and phenomenological research.

3.2.2 Principles for SAMGs The following principles should be applied to the development and implementation of SAMGs:

• Site-specific strategies and implementing methods should be based upon existing plant systems, structures and components, and available portable equipment.

Modifications to the plant design are permitted but not required.

• Any plant system, structure or component, and available portable equipment, may be used to implement an accident management strategy, irrespective of safety classification or other design-related criteria. In addition, the normally-applied controls on the use or configuration of a plant system, structure or component may be altered if necessary to implement a strategy (e.g., establishing a system lineup not described in the facility licensing basis).

• The inclusion of a plant system, structure or component within a severe accident management strategy implementing method does not impose any additional design or maintenance-related requirements on that item (i.e., beyond those associated with the existing specifications and programs). For example, the design-basis safety classification of a plant system, structure or component - safety-related, important to safety, etc. - is not changed because of its employment within a strategy implementing method.

• Strategies should reflect a best-estimate understanding of accident progression and consequences.

• SAMG entry conditions and operator actions should be symptom-based and clearly linked to specific plant parameters. Identification of the initiating event should not be required in order to determine which strategy should be implemented.

• The best possible operational guidance should be specified to restore and maintain key plant parameters within limits which define controlled and stable plant conditions, irrespective of licensing or design basis assumptions or commitments.

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• Operator actions and decision-making criteria (e.g., a parameter value or trend that prompts a given action) should be determined using best-estimate assumptions and calculations, irrespective of licensing or design basis analytical assumptions and calculations.

• The capability to assess decision-making criteria (e.g., a parameter value or trend that prompts a given action) should accommodate the use of any available indications.

Potential uncertainties in instrumentation readings caused by anticipated severe accident environmental conditions should be considered during the development of decision-making criteria.

• SAMG strategies may employ implementing methods or capabilities described in FLEX Support Guidelines (FSGs) or Extensive Damage Mitigation Guidelines (EDMGs).

• Computational aides should be provided when direct diagnosis of key plant conditions cannot be determined solely from instrumentation.

3.2.3 Considerations for Site-Specific SAMGs 3.2.3.1 Document Development Site-specific severe accident management strategies, and associated implementing guidance, should be based on the generic technical guideline documents developed by the applicable Owners Group. Strategies and implementing guidance should reflect the plant-specific technology, design and operating characteristics, and control parameters and values. The SAMG principles discussed above should also be considered during the development or revision of implementing guidance.

Document developers should assess the applicability and utility of each strategy, and related material, presented in the generic technical guidelines. If deviations from the guidelines are necessary, they should be identified, documented and supported with a technical basis. For example, a deviation may be necessary if a particular generic strategy cannot be reconciled with the plant design. The technical basis for a deviation should address the potential effects on other strategies and/or recommended implementing methods.

A licensee may also include an additional strategy(ies) and/or implementing method(s) within their accident mitigation and management guidance documents. As with other deviations, these additions should be identified, documented and supported with a technical basis.

Licensees electing not to use the generic Owners Group technical guidelines should prepare a technical basis for all strategies and implementing methods described in their site-specific guidelines. The technical basis for the SAMGs should cite relevant research and analysis, and address the lessons learned from industry events such as the Fukushima Dai-Ichi accident. It should also discuss investigated strategies and methods that might be taken to limit the 10

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February 2016 release of radioactive materials over an extended period following an accident.

Guidelines for responding to a severe accident should be developed in accordance with the appropriate fleet or site-specific programmatic requirements, including the applicable writers guide. In cases where one does not exist, a writers guide should be developed. A writers guide should contain all the information necessary to develop the plant-specific guidelines, and provisions for documentation of deviations from the generic Owners Group guidance.

3.2.3.2 Document Verification and Validation Guidelines for responding to a severe accident should be verified and validated in accordance with an applicable fleet or site procedure development process. This includes guidelines developed for use by operators as well as those intended for implementation by the accident management support staff (e.g., engineers in the TSC). Absent an appropriate verification and validation process, one should be developed.

Verification and validation processes should assess the technical accuracy and adequacy of the instructions, and the ability of personnel to follow and implement them. The verification process should confirm the compatibility of document instructions with referenced equipment, user-aides and supplies (e.g., portable equipment, posted job aids, strategy evaluation materials, etc.).

The validation process should demonstrate that the document provides the instructions necessary to implement the guidance.

Guidelines should be verified and validated using existing plant capabilities.

Increasing the capability of the plant-referenced simulator to specifically model the conditions of the reactor core or stored spent fuel during a beyond design basis event or severe accident is not required. As a consequence, the technical rigor applied to verification and validation activities may be different than that normally used for Abnormal Operating Procedures and Emergency Operating Procedures.

The verification and validation process should accommodate the differences between non-severe and severe accident conditions. In particular, the process should recognize that severe accidents are characterized by uncertainties in both their progression and consequences. Some other key differences include:

• There may be no clear outcome for an accident management strategy. For example, adding water to a damaged core undergoing melting may, or may not, result in arresting core damage and, in some cases, may introduce new accident management challenges.

• There may not be a right or wrong decision at any given point in time during a severe accident response. Every severe accident management strategy has the potential for both positive and negative consequences 11

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February 2016 related to its implementation and these consequences can be very situation dependent. In addition, there may be cases where a negative consequence can be mitigated through implementation of another strategy within some event-specific timeframe.

Due to the unbounded nature of severe accident sequences and potential resulting conditions, a limited number of scenarios should be developed for the SAMG validation process (i.e., a sample group). These scenarios should allow for reasonable assurance that key decision points and transition guidance will support implementation accident management strategies. The assumed conditions and data used in the validation process should be determined on a "best estimate" basis.

3.2.3.3 Document Updating and Maintenance Review, revision, approval, distribution and placement of SAMGs should be performed in accordance with the appropriate fleet or site document control process. The need to make changes should be assessed whenever:

• Changes to the facility that may impact the capability to implement strategies are identified.8

• The applicable generic severe accident technical guidelines are updated (e.g., a change to a guideline) or revised.

Potential changes should be tracked by an appropriate fleet or site process (e.g., a corrective action program).

A revision to the applicable generic severe accident technical guidelines should be assessed and implemented within 2 refueling outages or 3 years of the publication date, whichever is greater.

3.2.3.4 User Aids The development, verification and validation of user aids should be consistent with applicable fleet and/or site policies.

3.2.3.5 Priority Setting for Document Changes Each licensee should update the condition screening and evaluation requirements described in their corrective action program(s) as needed to promote the appropriate prioritization of corrective actions associated with severe accident management response capabilities. In particular, work prioritization and the assignment of resources for these types of conditions should be properly balanced with other site needs, and commensurate with the anticipated benefits to overall accident or event response capabilities (e.g.,

8 Programmatic controls should be implemented to identify these types of facility changes (e.g., proposed design changes, configuration controls, etc.).

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February 2016 changes offering lower relative or absolute benefits should be assigned lower priorities).

3.3 FLEX SUPPORT GUIDELINES Following an assessment of the accident at Fukushima Dai-Ichi, the NRC issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events, on March 12, 2012. On August 29, 2012, the NRC staff issued Interim Staff Guidance (ISG) 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, Revision 0.9 This document assists nuclear power reactor applicants and licensees with the identification of measures needed to comply with requirements of the mitigating strategies order. The ISG endorses, with clarifications, the methodologies described in the industry guidance document, Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.

The development, verification, validation and maintenance of FSGs should be performed in accordance with each licensees procedure/guideline development processes, and the guidance provided in NEI 12-06.

3.4 EXTENSIVE DAMAGE MITIGATION GUIDELINES As a result of the terrorist attacks of September 11, 2001, the NRC issued an Interim Compensatory Measures (ICM) Order to all power reactor licensees on February 25, 2002. This Order required compliance with specified interim safeguards and security compensatory measures. Section B.5.b of the ICM Order required the development of specific guidance and strategies to maintain core cooling, containment, and SFP cooling capabilities using existing or readily available resources (equipment and personnel) that could be effectively implemented under the circumstances associated with loss of large areas of the plant due to explosions or fire. Eventually, the requirements of Section B.5.b of the ICM Order were codified in 10 CFR 50.54(hh)(2); refer to SECY-08-099 and SRM-M081217B. The NRC staff-endorsed guidance for complying with 10 CFR 50.54(hh)(2) is contained in NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline.

The development, verification, validation and maintenance of EDMGs should be performed in accordance with each licensees procedure/guideline development processes, and the guidance provided in NEI 06-12.

9 Refer to NRC ADAMS ML #12229A174 13

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February 2016 4 COMMAND AND CONTROL 4.1 OVERVIEW Each licensee should ensure that their emergency command and control structures are capable of directing responses to a beyond design basis event or severe accident, including those affecting multiple units on a site, in accordance with established procedure and guideline sets.

4.2 COMMAND AND CONTROL KEY FUNCTIONS Command and control structures should clearly identify the Emergency Response Organization (ERO) position(s) with the ultimate authority for making decisions necessary for the implementation of emergency response procedures and guidelines during a beyond design basis event or severe accident. For purposes of the guidance in this document, the position with this authority is referred to as the Ultimate Decision-Maker (UDM). The position(s) assigned the UDM function should have the authority and capability of performing the following key command and control functions:

• Selection of the procedure or guideline set(s) most appropriate to address the event and/or plant conditions.

• Determination of the strategy(ies) to be implemented, and the necessary conditions and timing for implementation.

• Direction of the onsite and offsite resources needed to implement the selected strategy(ies).

• Direction of an action not contained in, or contrary to, procedures or guidelines, if it is determined that the action will provide greater protection of public health and safety.

• Interface with the ERO position holding overall command and control authority within the site ERO (and fleet-level ERO, if applicable), if the two authorities are held by different positions.

The qualifications for an UDM are discussed in NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents.

4.3 COMMAND AND CONTROL STRUCTURE CONSIDERATIONS Procedures or guidelines used by the ERO should provide for implementation of command and control structures consistent with the following considerations.

• The UDM authority and responsibilities should be integrated into ERO command and control structures and protocols. It is not necessary to create a new ERO position or title.

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• The Shift Manager should serve as the UDM during the implementation of Abnormal Operating Procedures (AOPs) and Emergency Operating Procedures (EOPs).

• Following a transition into Severe Accident Management Guidelines (SAMGs), the UDM authority and responsibilities may be retained by the Shift Manager, or transferred to an UDM-qualified individual located in another facility. The instructions/guidance for transferring the UDM role to a location outside the Control Room should include an assessment of the availability of the supporting personnel and resources necessary to implement all the command and control key functions.

• Following the transfer of the UDM function to an ERO position-holder located outside the Control Room (e.g., in the TSC), the support staff assisting with strategy evaluation and selection should include at least one member who holds an active SRO license, or has successfully completed an SRO licensing or certification program in the past, applicable to the affected onsite unit(s).10 If a site hosts different technologies, then at least one individual with the SRO background described above should be available for each different unit technology (e.g., a PWR and a BWR, or an active safety feature plant and a passive safety feature plant).

• Following an event associated with loss of large areas of the plant due to explosions or fire, and causing a loss of the Control Room command and control structure, a procedure or guideline should describe the position(s) that could assume command and control of the event response. Due to the contingent and short-term nature of this assignment, and the initial focus on implementation of pre-planned EDMG strategies, it is not necessary for this position(s) to hold a UDM qualification. A procedure or guideline should specify how command and control are subsequently transferred to a position which does possess a UDM qualification.

• The UDM is able to direct changes to a pre-planned fire response strategy if necessary to support implementation of an accident or event mitigation or management strategy.

• The UDM assignment(s) should be consistent with the licensees staffing assessments performed in accordance with NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, and the associated regulatory responses to NRC letter, Request for Information 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, dated March 12, 2012.

• The authorities and responsibilities necessary to coordinate the acquisition and delivery of offsite resources are defined.

• At sites operating within a fleet structure, fleet-level command and control capabilities should be integrated into the licensees command and control structures if 10 The SRO certification should meet the requirements of ANSI/ANS 3.1, Selection, Qualification and Training of Personnel for Nuclear Power Plants.

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February 2016 such support will be relied upon during a beyond design basis event or severe accident.

• Specific UDM authorities and/or responsibilities that may be delegated, if any, are defined.

• Where appropriate, procedures and guidelines should contain guidance concerning the implementation of emergency response actions in accordance with 10 CFR 50.54(x) and the associated approval of such actions in accordance with 10 CFR 50.54(y).

16

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• NUREG-0737, Clarification of TMI Action Plan Requirements, dated November 1980

• NRC Generic Letter 88- 20, Supplement 2, Accident Management Strategies for Consideration in the Individual Plant Examination Process, dated April 4, 1990

• NRC Report, 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

• SECY-11-0124, Recommended Actions to be Taken Without Delay from the Near-Term Task Force Report, dated September 9, 2011

• 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

• NRC letter, Request for Information 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, dated March 12, 2012

• NRC 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, dated August 29, 2012

• Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013

• Staff Requirements - SECY-15-0065 - Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015

• Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015

• Electric Power Research Institute (EPRI) Technical Report, Severe Accident Management Guidance - Technical Basis Report, TR-101869, dated April 1993

• Electric Power Research Institute (EPRI) Technical Report, Severe Accident Management Guidance - Technical Basis Report, TR-1025295, dated October 2012

• Electric Power Research Institute (EPRI) Technical Report, Investigation of Strategies for Mitigating Radiological Releases in Severe Accidents, TR-1026539, dated October 2012

• NEI 91-04, Severe Accident Issue Closure Guidelines, Revision 1, dated December 1994 17

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• NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, dated December 2006

• NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012

• NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide

• NEI Letter, Industry Initiative to Maintain Severe Accident Management Guidelines, Pietrangelo to Johnson, dated October 26, 2015

• NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents, dated February 2016 18

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Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents September 2014 February 2016

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Nuclear Energy Institute Emergency

Response

Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents

September 2014 February 2016

ACKNOWLEDGMENTS This document was developed by the Boiling Water Reactor Owners Group (BWROG), the Pressurized Water Reactor Owners Group (PWROG) and the Nuclear Energy Institute (NEI).

The lead/coordinating document contributors are presented below.

BWROG:

Lesa Hill - Southern Nuclear and BWROG Chairperson Jay Lyter - Exelon Nuclear and Vice Chairperson, BWROG Emergency Procedures Committee PWROG:

Jack Stringfellow - Southern Nuclear and PWROG Chairperson Steve Pierson - Exelon Nuclear and PWROG Procedures Subcommittee Representative NEI:

David Young - Senior Project Manager, Emergency Preparedness In addition, the document contents were reviewed by the NEI Emergency Response Steering Committee and the Emergency Preparedness Working Group.

NOTICE Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.

NEI 14-01 (Revision 01)

September 2014 February 2016 EXECUTIVE

SUMMARY

U.S. nuclear power plant licensees currently maintain the capability to implement beyond design basis accident mitigation and management strategies developed through several separate initiatives. Each strategy has been converted into implementing actions and recommendations within three separate sets of procedures and guidelines: Emergency Operating Procedures (EOPs), Severe Accident Management Guidelines (SAMGs), and Extensive Damage Mitigation Guidelines (EDMGs). In addition to these existing procedure and guideline sets, the industry is currently developing a new set of guidelines, referred to as FLEX Support Guidelines (FSGs), in response to Order EA-12-049 issued by the U.S. Nuclear Regulatory Commission (NRC)1.

Having been developed separately, each of these procedure and guideline sets are subject to varying levels of regulatory requirements and industry commitments, as are the training, drills, and exercises intended to maintain the capability for effective implementation.

The EOPs were designed to restore and maintain safety functions, and place the plant in a safe shutdown condition. EOPs are required by Title 10 of the Code of Federal Regulations (10 CFR)

Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and are included in the administrative control sections of a licensees technical specifications. The training requirements for EOPs are primarily contained within 10 CFR Part 55, Operators Licenses.

Licensed operators are required to show sufficient knowledge of the EOPs on an initial written examination, in accordance with 10 CFR 55.41 (Reactor Operators) or 10 CFR 55.43 (Senior Reactor Operators), and the ability to implement the EOPs through an initial operating test that meets the requirements of 10 CFR 55.45. Licensed operators are required to continuously demonstrate that they have maintained their knowledge of the EOPs through the requalification program required by 10 CFR 55.59.

SAMGs provide guidance to operators and designated support staff for use in the event that accident conditions progress beyond the mitigation capabilities described in the EOPs (e.g., fuel damage is imminent or has occurred). The SAMGs were developed as a voluntary industry initiative in response to NRC Generic Letter 88-20, Supplement 2, Accident Management Strategies for Consideration in the Individual Plant Examination Process, dated April 4, 19902.

There is currently no regulatory requirement for licensees to develop, maintain, train, drill or exercise SAMGs.

Following the terrorist attacks of September 11, 2001, the NRC ordered licensees to develop strategies and specific implementing guidance for maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire. These extensive damage mitigation requirements were subsequently imposed as license conditions for individual licensees and then made generically applicable under 10 CFR 50.54(hh)(2) through the Power Reactor Security Requirements final rule (74 FR 13926; March 27, 2009). As a result, EDMGs were created to 1

Refer to 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; NRC ADAMS ML #12054A735.

2 Refer to NRC ADAMS ML #031200551 i

NEI 14-01 (Revision 01)

September 2014 February 2016 provide guidance to operating crews and other plant staff on the implementation of strategies for responding to an event involving a loss of large areas of the plant due to explosions or fire.

On March 11, 2011, a magnitude 9.0 earthquake struck off the coast of the Japanese island of Honshu. Approximately 40 minutes after the earthquake, the first of several large tsunami waves inundated the Fukushima Dai-ichi Nuclear Power Plant site. The tsunami waves resulted in extensive damage to site facilities, and a complete and extended loss of AC electrical power at Fukushima Dai-ichi Units 1 through 5; one diesel generator remained functional on Unit 6.

Despite the actions of the operators following the earthquake and tsunami, cooling was lost to the fuel in the Unit 1 reactor after several hours, the Unit 3 reactor after about 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and the Unit 2 reactor after about 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br />; fuel damage resulted in each unit shortly after the loss of cooling.

In the days following the Fukushima Dai-ichi accident, the NRC Chairman directed the staff to establish a senior-level agency task force to conduct a full review of the agencys processes and regulations in light of the events in Japan. This task force, referred to as the Near-Term Task Force (NTTF), was also directed to identify recommended improvements to agency policies and regulatory practices. The NTTF provided its recommendations to the Commission in a report dated July 12, 2011.3 In Recommendation 8 of the NTTF report, the Task Force recommended strengthening and integrating the onsite emergency response capabilities described in EOPs, SAMGs, and EDMGs.

As discussed in SECY-11-0124, Recommended Actions to be Taken Without Delay from the Near-Term Task Force Report, dated September 9, 2011, the NRC staff proposed to proceed with a rulemaking associated with the methodology for integration of onsite emergency response processes, procedures, training and exercises. This decision led to the development of a document entitled, Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013. The Recommendation 8 regulatory basis was subsequently incorporated into Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015, with changes directed by the NRC Commissioners in Staff Requirements - SECY-15-0065 -

Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015.

In the Staff Requirements Memorandum referenced above, the NRC Commissioners directed the removal of requirements for SAMGs from the proposed Mitigation of Beyond Design Basis Events rule. The industry continues to believe that SAMGs provide a useful tool to plant operators in the unlikely event of a severe accident and should be maintained. To this end, the NEI Nuclear Strategic Issues Advisory Committee (NSIAC) approved an Industry Initiative on SAMGs that requires each licensee to docket site-specific commitments concerning the updating these guidelines, and their consideration within plant configuration management processes, integration with other emergency response guideline sets and symptom-based EOPs, and validation.

This document provides guidance for ensuring that EOPs, EDMGs, FSGs and SAMGs are 3

Refer to NRC ADAMS ML #111861807 ii

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September 2014 February 2016 integrated in a cohesive, effective and usable manner. It also addresses recommendations for the development of mitigation and management guidelines, and command and control structures, for responding to beyond design basis events and severe accidents. Guidance concerning the related aspects of training, drills and exercises is contained in NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents.

iii

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September 2014 February 2016 TABLE OF CONTENTS EXECUTIVE

SUMMARY

.................................................................................. i 1 INTRODUCTION ...................................................................................... 1 2 PROCEDURE INTEGRATION ................................................................... 3 2.1 OVERVIEW........................................................................................................................... 3 2.2 PROCEDURES AND GUIDELINES .......................................................................................... 3 2.3 EMERGENCY RESPONSE PROCEDURE AND GUIDELINES SETS ......................................... 4 2.4 INTEGRATION OF PROCEDURE AND GUIDELINE SETS ....................................................... 5 2.5 COORDINATION WITH FIRE RESPONSE STRATEGIES ........................................................ 6 3 REQUIREMENTS FOR SAMGS AND SUPPORTING GUIDELINES .......... 8 3.1 OVERVIEW........................................................................................................................... 8 3.2 SEVERE ACCIDENT MANAGEMENT GUIDELINES .............................................................. 8 3.3 FLEX SUPPORT GUIDELINES ........................................................................................... 13 3.4 EXTENSIVE DAMAGE MITIGATION GUIDELINES ............................................................. 13 4 COMMAND AND CONTROL ................................................................... 15 4.1 OVERVIEW......................................................................................................................... 15 4.2 COMMAND AND CONTROL KEY FUNCTIONS ................................................................... 15 4.3 COMMAND AND CONTROL STRUCTURE CONSIDERATIONS ............................................ 15 5 REFERENCES ........................................................................................ 18 v

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September 2014 February 2016 EMERGENCY RESPONSE PROCEDURES AND GUIDELINES FOR BEYOND DESIGN BASIS EVENTS AND SEVERE ACCIDENTS 1 INTRODUCTION Each nuclear power plant licensee maintains sets of operating procedures that provide direction for responding to a wide spectrum of off-normal and emergency events and conditions. Direction is provided for addressing events and conditions both within the plant design basis as well as certain events and conditions that are beyond the design basis. These procedure sets are typically known as Alarm Response Procedures (ARPs), Abnormal Operating Procedures (AOPs) and Emergency Operating Procedures (EOPs), and they instruct licensed operators on the steps necessary to maintain safe operation and protect fission product barriers during all modes of plant operation.

In response to the lessons learned from the accident at Three Mile Island, the nuclear industry developed Severe Accident Management Guidelines (SAMGs) as a voluntary initiative.4 The SAMGs describe additional strategies meant to provide operators and the plant staff with the capability to manage accident sequences that progress beyond the capacity of the mitigating strategies contained in the EOPs (e.g., adequate core cooling cannot be maintained). In doing so, the strategy focus changes from preventing fuel damage to mitigating the consequences of fuel damage, including minimizing radiological releases and protecting personnel.

Existing site-specific EOPs and SAMGs are based on generic technical guidelines developed in response to NUREG-0737, Item I.C.1, Guidance for the Evaluation and Development of Procedures for Transients and Accidents, and NEI 91-04, Severe Accident Issue Closure Guidelines, Revision 1, respectively. The generic technical guidelines were created by the Boiling Water Reactor (BWR) and Pressurized Water Reactor (PWR)

Owners Groups, and, in the case of the SAMGs, utilize applicable technical research and bases materials provided by the Electric Power Research Institute (EPRI). Using these generic guidelines, each licensee has developed EOPs and SAMGs that are appropriate for their specific plant technology, and function as an integrated set of strategies and implementing instructions.

Following the terrorist attacks of September 11, 2001, the NRC ordered licensees to develop strategies and specific guidance for maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with a loss of large areas of the plant due to explosions or fire; the NRC order was eventually codified in 10 CFR 50.54 (hh). U.S. nuclear power plant operators developed their response strategies and guidelines in accordance with NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline. The guideline sets that resulted from these efforts are typically referred to Extensive Damage Mitigation Guidelines (EDMGs).

4 Refer to NRC Generic Letter 88-20, Supplement 2, Accident Management Strategies for Consideration in the Individual Plant Examination Process, dated April 4, 1990.

1

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September 2014 February 2016 As a result of the review of the March 11, 2011, accident at the Fukushima Dai-ichi Nuclear Power Plant, the NRC Near-Term Task Force (NTTF) made several recommendations intended to strengthen and integrate the onsite emergency response capabilities described in EOPs, SAMGs, and EDMGs; these recommendations are referred to collectively as Recommendation 8. All aspects of Recommendation 8 were subsequently evaluated by the NRC staff and refined into a regulatory basis to support future rulemaking; see Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 20135. .6 . The Recommendation 8 regulatory basis was subsequently incorporated into Proposed Rule -

Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015, with changes directed by the NRC Commissioners in Staff Requirements - SECY-15-0065 -

Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015.

In the Staff Requirements Memorandum referenced above, the NRC Commissioners directed the removal of requirements for SAMGs from the proposed Mitigation of Beyond Design Basis Events rule. The industry continues to believe that SAMGs provide a useful tool to plant operators in the unlikely event of a severe accident and should be maintained.

To this end, the NEI Nuclear Strategic Issues Advisory Committee (NSIAC) approved an Industry Initiative on SAMGs that requires each licensee to docket site-specific commitments concerning the updating these guidelines, and their consideration within plant configuration management processes, integration with other emergency response guideline sets and symptom-based EOPs, and validation.

This document provides guidance for addressing threethe SAMG Industry Initiative and certain aspects of the regulatory basis associated with Recommendation 8 -regulatory basis; these topics are procedure integration, requirements for SAMGs and supporting guidelines, and a command and control structure for responding to a beyond design basis event or severe accident. The guidance was developed for commercial nuclear power reactors operating in the United States as of 20142016. Adoption or modification of this guidance by future operating plants should be based on discussions with the appropriate technology Owners Group and the NRC staff.

5 Refer to NRC ADAMS ML #13101A344 6

Refer to NRC ADAMS ML #13101A344 2

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September 2014 February 2016 2 PROCEDURE INTEGRATION 2.1 OVERVIEW Each licensee should establish an overall framework for strategies that would be used to mitigate and manage the consequences of a beyond design basis event and severe accident. This framework should address the integrated use of emergency response procedures and guidelines such that they have been designed to work together to implement the best available strategy for preventing or mitigating fuel damage, and limiting radiological releases. The effective integration of procedures and guidelines is characterized by the attributes listed in Section 2.4, Integration of Procedure and Guideline Sets.

For purposes of this document, a strategy refers to a plan of action for maintaining or restoring a safety function7 in order to mitigate the effects of a beyond design basis event or manage the consequences of a severe accident. A strategy can be implemented by one or more methods. As used here, a method is a series of actions designed to implement a specific strategy. As an illustrative example of all three terms, consider that a portable pump (a method) may be used to inject water into the reactor pressure vessel (a strategy) for the purpose of maintaining core cooling (a safety function (core cooling).

It is recognized that the usage of the above terms in NRC and industry documents, although generally similar, has varied somewhat over the years depending upon the preferences of authors and the purpose of a particular document. It will therefore be necessary to carefully apply these terms within the context of site-specific documents (i.e., in cases where different terms are used for the concepts identified above).

2.2 PROCEDURES AND GUIDELINES It is important to distinguish the difference between emergency response procedures and guidelines. Procedures are documents written as sequential instructions for performing a function or addressing plant conditions, and operators and plant staff are expected to follow the prescribed instructions in a step-by-step and verbatim manner. Exceptions to this expectation should be rare and necessary only in extraordinary circumstances.

As opposed to procedures, guidelines do not necessarily provide a prescribed set of instructions and may not be followed in a step-by-step manner. Rather, they provide suggested strategies and implementing methods that may be used to address an adverse event or condition, typically those beyond a plants design basis. Within guidelines, operators and plant staff have the latitude to respond as necessary to unpredictable and dynamic situations. During a beyond design basis event or severe accident, guidance documents would be used to focus the attention and actions of the operators and plant staff on the most important threats to safety and provide suggested optimal strategies for 7

The safety functions of interest during a beyond design basis event or severe accident response are typically core cooling, containment and spent fuel pool cooling.

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2.3 EMERGENCY RESPONSE PROCEDURE AND GUIDELINES SETS This document employs the following terms when referring to procedure and guideline sets used by operators to respond to off-normal and emergency conditions. Depending upon Owners Group guidance, and fleet and site standards, a procedure and guideline set may be called by another name. Further, the decision to provide a given set of response instructions within a procedure or a guideline may vary from site-to-site. Each licensee should ensure that the appropriate site-specific document sets, and individual documents, are utilized when implementing the guidance contained in this document.

2.3.1 Abnormal Operating Procedures (AOPs)

AOPs are procedures that direct operator actions for restoring a function, system, or component to normal operating conditions following a transient or event. AOPs may also be used to mitigate an event or condition that is not severe enough to require use of an Emergency Operating Procedure (EOP), such as primary system leakage.

Further, AOPs may provide direction for responding to a wide range of off-normal and emergency conditions including, but not limited to, design basis-related events such as a Control Room evacuation, a fire, or a security threat; events initiated during shutdown or refueling operating modes; and natural and man-made hazardous conditions such as severe weather or toxic gas releases.

2.3.2 Emergency Operating Procedures (EOPs)

EOPs are procedures that direct operator actions for mitigating the consequences of transients and accidents that cause plant parameters to exceed reactor protection system or engineered safety features actuation setpoints. These procedures are developed using guidelines promulgated by the applicable Owners Group in response to NUREG-0737, Clarification of TMI Action Plan Requirements; Clarification Item I.C.1, Guidance for the Evaluation and Development of Procedures for Transients and Accidents.

2.3.3 FLEX Support Guidelines (FSGs)

FSGs are guidelines that provide strategies relying upon the use of installed and portable equipment and resources to maintain or restore core cooling, containment, and SFP cooling capabilities during beyond design basis events. The strategies and capabilities reflected in these guidelines address the requirements of NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events. Guidance concerning the development of FSGs is contained in Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.

2.3.4 Extensive Damage Mitigation Guidelines (EDMGs)

EDMGs are guidelines that provide strategies to maintain or restore core cooling, containment, and SFP cooling capabilities under the circumstances associated with the 4

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September 2014 February 2016 loss of large areas of the plant due to explosions or fire. These strategies and capabilities address the requirements of 10 CFR 50.54(hh)(2). Guidance concerning the development of EDMGs is contained in NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline.

2.3.5 Severe Accident Management Guidelines (SAMGs)

SAMGs are guidelines that provide strategies to manage the consequences of an accident or event which would be implemented upon receipt of specific plant parameter values indicative of imminent or actual damage to irradiated fuel (e.g., high core exit thermocouple temperatures or low RPV water level). These guidelines employ strategies intended to arrest the progression of fuel damage, maintain the capability of the containment as long as possible, and minimize radiological releases. Guidance concerning the development of SAMGs is contained in this document.

SAMGs may be referred to as Severe Accident Guidelines (SAGs) at some sites.

2.4 INTEGRATION OF PROCEDURE AND GUIDELINE SETS Each licensees emergency response procedure and guideline sets should address the following considerations.

• A programmatic control document describing the framework for integration of mitigation and management strategies in response to a beyond design basis event or severe accident should be developed and maintained. The site-specific framework should consider the generic technical guidance provided by the appropriate Owners Group. Deviations from the generic technical guidance should be documented along with the supporting rationale.

For illustrative purposes, a simplified example framework is depicted in Figure 2.1.

• Strategies should be available to address potential or actual fuel damaging conditions present in the reactor core or the spent fuel pool.

• Strategies should be reviewed to identify potential gaps or inconsistencies.

• Each strategy should be included within a controlling procedure or guideline. Where appropriate, expectations concerning parallel processing of procedures and/or guidelines should be described.

• Criteria such as plant conditions and parameters that require a transition from one controlling procedure or guideline to another should be clearly identified.

• Criteria for implementing the actions described in a supporting procedure or guideline should be clearly identified in the controlling procedure or guideline.

• Strategies should be available to address a beyond design basis event or severe accident occurring during any mode of operation, consistent with the associated NRC staff-endorsed guidance. The degree to which a controlling procedure may or may not be fully applicable during some plant operating modes should be considered.

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• Strategies should be available to address an event involving a loss of large areas of the plant due to explosions or fire, including the possible loss of the Control Room command and control structure, consistent with the associated NRC staff-endorsed guidance in NEI 06-12. The degree to which a controlling procedure may or may not be fully applicable during some plant operating modes should be considered.

• Integration of EDMGs should reflect site-specific commitments made in response to NRC security orders.

• Integration of FSGs should reflect site-specific commitments related to NRC Order EA-12-049.

2.5 COORDINATION WITH FIRE RESPONSE STRATEGIES SAMGs and FSGs provide a core set of strategies that can be used to respond to a variety of failures and concurrent events. SAMGs were developed to address plant conditions associated with a fuel damaging event and utilize a symptom-based approach to strategy selection. They provide a wide range of strategies and implementing methods, which, by design, can be adjusted during an emergency in response to plant conditions and concurrent events, such as a fire. FSGs provide strategies for mitigating the effects of an Extended Loss of AC Power (ELAP). Consistent with NRC staff-endorsed guidance, the development of FSG strategies assumed that there were no independent concurrent events, including a postulated fire.

Unlike analyses associated with design basis accidents, determining accident progression and consequences for beyond design basis events and severe accidents is problematic given the effectively unbounded nature of the accident sequences. This is particularly true when the coincident occurrence of two or more events or accidents is postulated (e.g., an ELAP and a fire). While recognizing that concurrent events such as a fire could occur during a beyond design basis event and severe accident, it is not possible to predict resulting strategy impacts in any reliable/certain manner beforehand. For this reason, programmatic documents, and/or procedures and guidelines, should provide direction for selecting the appropriate strategy at the time of the emergency. For example, the Emergency Response Organization position(s) holding Ultimate Decision-Maker (UDM) authority8 could have guidance for selecting the appropriate strategy, and then determining the priorities and actions necessary for implementation.

8 Discussed in Section 4 of this document.

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September 2014 February 2016 Figure 2.1 Simplified Example Framework FLEX Support Guidelines Severe Accident Extensive Damage Management Guidelines Emergency Operating Support Procedures Procedures Abnormal Operating Mitigation Guidelines Procedures Alarm Response Procedures General Operating Procedures Severity Note - EDMG capabilities/methods may be referenced in Emergency Operating Procedures (EOPs) and/or Severe Accident Management Guidelines (SAMGs).

In addition, BWR Support Procedures include the Technical Support Guidelines which support implementation of EOPs and SAMGs.

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September 2014 February 2016 3 REQUIREMENTS FOR SAMGS AND SUPPORTING GUIDELINES 3.1 OVERVIEW Each licensee should maintain Severe Accident Management Guidelines (SAMGs) and supporting guidelines which consider the generic technical guidance provided by the applicable technology Owners Group. This includes the development of any additional guidance necessary for responding to a beyond design basis event or severe accident affecting the cooling of irradiated fuel stored in a spent fuel pool. With respect to guidance issued by the Nuclear Energy Institute (NEI), the material in this document supersedes that provided in Section 5 of NEI 91-04, Severe Accident Issue Closure Guidelines, for the development, implementation and maintenance of severe accident management programs.

3.2 SEVERE ACCIDENT MANAGEMENT GUIDELINES 3.2.1 Development of Generic Severe Accident Management Guidance Following the March, 1979, accident at Three Mile Island, the Electric Power Research Institute (EPRI) engaged in an extensive research program to better understand the nature of nuclear power plant accidents that could result in significant damage of the fuel -

referred to as severe accidents. Before the Three Mile Island accident, operator procedures and training had focused almost exclusively on preventing an upset condition from progressing to the point at which the fuel was damaged. To broaden the spectrum of emergency response guidance, EPRI developed generic accident management strategies and implementing methods that could be taken to limit the consequences of a severe accident. This guidance was issued in EPRI Technical Report TR-101869, Severe Accident Management Guidance Technical Basis Report (SAMG-TBR), dated April 1993.

The SAMG-TBR is organized into two volumes. Volume 1 defines severe accident damage conditions for the reactor core, spent fuel pool, and containment; identifies the Candidate High-Level Actions (CHLAs) that may be taken to best manage these conditions; and summarizes the effects that could result from implementation of each CHLA. Volume 2 is composed of appendices, each of which describes the physical behavior for one type of phenomenon relevant to severe accidents. These appendices also include the technical bases for calculation aids that can be used to estimate the plant response if an action is taken. Although these calculations are generally not intended to provide detailed results, they are sufficient to allow consideration of the relative benefits and possible undesired effects associated with each action.

In October, 2012, EPRI published an updated SAMG-TBR, Technical Report TR-1025295, to address lessons learned from the March, 2011, accident at Fukushima Dai-ichi, and incorporate other insights from research and analysis conducted over the intervening 20 years. While the actions described in the original report continue to represent appropriate responses to severe accident conditions, several new technical 8

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September 2014 February 2016 considerations arising from the Fukushima accident were incorporated (e.g., makeup water quality, spent fuel pool actions, hydrogen buildup mitigation, etc.). EPRI also issued a separate report dealing with strategies to limit radiological releases following a severe accident; refer to Technical Report TR-1026539, Investigation of Strategies for Mitigating Radiological Releases in Severe Accidents, dated October 2012. The latter report is applicable to a Boiling Water Reactor with a Mk 1 or Mk 2 containment.

The Boiling Water Reactor Owners Group (BWROG) and Pressurized Water Reactor Owners Group (PWROG) have created generic technical materials to guide the development of site-specific SAMGs for each technology. These technical guidelines translate the insights from the above discussed EPRI reports into a template containing recommended technology-appropriate strategies, and implementing methods, for mitigating the consequences of a severe accident. The development of technical guidelines is based on reference plants, and utilizes engineering data derived from severe accident analyses, operating experience and phenomenological research.

3.2.2 Principles for SAMGs The following principles should be applied to the development and implementation of SAMGs:

• Site-specific strategies and implementing methods should be based upon existing plant systems, structures and components, and available portable equipment.

Modifications to the plant design are permitted but not required.

• Any plant system, structure or component, and available portable equipment, may be used to implement an accident management strategy, irrespective of safety classification or other design-related criteria. In addition, the normally-applied controls on the use or configuration of a plant system, structure or component may be altered if necessary to implement a strategy (e.g., establishing a system lineup not described in the facility licensing basis).

• The inclusion of a plant system, structure or component within a severe accident management strategy implementing method does not impose any additional design or maintenance-related requirements on that item (i.e., beyond those associated with the existing specifications and programs). For example, the design-basis safety classification of a plant system, structure or component - safety-related, important to safety, etc. - is not changed because of its employment within a strategy implementing method.

• Strategies should reflect a best-estimate understanding of accident progression and consequences.

• SAMG entry conditions and operator actions should be symptom-based and clearly linked to specific plant parameters. Identification of the initiating event should not be required in order to determine which strategy should be implemented.

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September 2014 February 2016 key plant parameters within limits which define controlled and stable plant conditions, irrespective of licensing or design basis assumptions or commitments.

• Operator actions and decision-making criteria (e.g., a parameter value or trend that prompts a given action) should be determined using best-estimate assumptions and calculations, irrespective of licensing or design basis analytical assumptions and calculations.

• The capability to assess decision-making criteria (e.g., a parameter value or trend that prompts a given action) should accommodate the use of any available indications.

Potential uncertainties in instrumentation readings caused by anticipated severe accident environmental conditions should be considered during the development of decision-making criteria.

• SAMG strategies may employ implementing methods or capabilities described in FLEX Support Guidelines (FSGs) or Extensive Damage Mitigation Guidelines (EDMGs).

• Computational aides should be provided when direct diagnosis of key plant conditions cannot be determined solely from instrumentation.

3.2.3 Considerations for Site-Specific SAMGs 3.2.3.1 Document Development Site-specific severe accident management strategies, and associated implementing guidance, should be based on the generic technical guideline documents developed by the applicable Owners Group. Strategies and implementing guidance should reflect the plant-specific technology, design and operating characteristics, and control parameters and values. The SAMG principles discussed above should also be considered during the development or revision of implementing guidance.

Document developers should assess the applicability and utility of each strategy, and related material, presented in the generic technical guidelines. If deviations from the guidelines are necessary, they should be identified, documented and supported with a technical basis. For example, a deviation may be necessary if a particular generic strategy cannot be reconciled with the plant design. The technical basis for a deviation should address the potential effects on other strategies and/or recommended implementing methods.

A licensee may also include an additional strategy(ies) and/or implementing method(s) within their accident mitigation and management guidance documents. As with other deviations, these additions should be identified, documented and supported with a technical basis.

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September 2014 February 2016 described in their site-specific guidelines. The technical basis for the SAMGs should cite relevant research and analysis, and address the lessons learned from industry events such as the Fukushima Dai-Ichi accident. It should also discuss investigated strategies and methods that might be taken to limit the release of radioactive materials over an extended period following an accident.

Guidelines for responding to a severe accident should be developed in accordance with the appropriate fleet or site-specific programmatic requirements, including the applicable writers guide. In cases where one does not exist, a writers guide should be developed. A writers guide should contain all the information necessary to develop the plant-specific guidelines, and provisions for documentation of deviations from the generic Owners Group guidance.

3.2.3.2 Document Verification and Validation Guidelines for responding to a severe accident should be verified and validated in accordance with an applicable fleet or site procedure development process. This includes guidelines developed for use by operators as well as those intended for implementation by the accident management support staff (e.g., engineers in the TSC). Absent an appropriate verification and validation process, one should be developed.

Verification and validation processes should assess the technical accuracy and adequacy of the instructions, and the ability of personnel to follow and implement them. The verification process should confirm the compatibility of document instructions with referenced equipment, user-aides and supplies (e.g., portable equipment, posted job aids, strategy evaluation materials, etc.).

The validation process should demonstrate that the document provides the instructions necessary to implement the guidance.

Guidelines should be verified and validated using existing plant capabilities.

Increasing the capability of the plant-referenced simulator to specifically model the conditions of the reactor core or stored spent fuel during a beyond design basis event or severe accident is not required. As a consequence, the technical rigor applied to verification and validation activities may be different than that normally used for Abnormal Operating Procedures and Emergency Operating Procedures.

The verification and validation process should accommodate the differences between non-severe and severe accident conditions. In particular, the process should recognize that severe accidents are characterized by uncertainties in both their progression and consequences. Some other key differences include:

• There may be no clear outcome for an accident management strategy. For example, adding water to a damaged core undergoing melting may, or may not, result in arresting core damage and, in some cases, may 11

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• There may not be a right or wrong decision at any given point in time during a severe accident response. Every severe accident management strategy has the potential for both positive and negative consequences related to its implementation and these consequences can be very situation dependent. In addition, there may be cases where a negative consequence can be mitigated through implementation of another strategy within some event-specific timeframe.

Due to the unbounded nature of severe accident sequences and potential resulting conditions, a limited number of scenarios should be developed for the SAMG validation process (i.e., a sample group). These scenarios should allow for reasonable assurance that key decision points and transition guidance will support implementation accident management strategies. The assumed conditions and data used in the validation process should be determined on a "best estimate" basis.

3.2.3.3 Document Updating and Maintenance Review, revision, approval, distribution and placement of SAMGs should be performed in accordance with the appropriate fleet or site document control process. The need to make changes should be assessed whenever:

• Changes to the facility that may impact the capability to implement strategies are identified.9

• The applicable generic severe accident technical guidelines are updated (e.g., a change to a guideline) or revised.

Potential changes should be tracked by an appropriate fleet or site process (e.g., a corrective action program).

A revision to the applicable generic severe accident technical guidelines should be assessed and implemented within 2 refueling outages or 3 years of the publication date, whichever is greater.

3.2.3.4 User Aids The development, verification and validation of user aids should be consistent with applicable fleet and/or site policies.

9 Programmatic controls should be implemented to identify these types of facility changes (e.g., proposed design changes, configuration controls, etc.).

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September 2014 February 2016 3.2.3.5 Priority Setting for Document Changes Each licensee should update the condition screening and evaluation requirements described in their corrective action program(s) as needed to promote the appropriate prioritization of corrective actions associated with severe accident management response capabilities. In particular, work prioritization and the assignment of resources for these types of conditions should be properly balanced with other site needs, and commensurate with the anticipated benefits to overall accident or event response capabilities (e.g.,

changes offering lower relative or absolute benefits should be assigned lower priorities).

3.3 FLEX SUPPORT GUIDELINES Following an assessment of the accident at Fukushima Dai-Ichi, the NRC issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events, on March 12, 2012. On August 29, 2012, the NRC staff issued Interim Staff Guidance (ISG) 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, Revision 0.10 This document assists nuclear power reactor applicants and licensees with the identification of measures needed to comply with requirements of the mitigating strategies order. The ISG endorses, with clarifications, the methodologies described in the industry guidance document, Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0.

The development, verification, validation and maintenance of FSGs should be performed in accordance with each licensees procedure/guideline development processes, and the guidance provided in NEI 12-06.

3.4 EXTENSIVE DAMAGE MITIGATION GUIDELINES As a result of the terrorist attacks of September 11, 2001, the NRC issued an Interim Compensatory Measures (ICM) Order to all power reactor licensees on February 25, 2002. This Order required compliance with specified interim safeguards and security compensatory measures. Section B.5.b of the ICM Order required the development of specific guidance and strategies to maintain core cooling, containment, and SFP cooling capabilities using existing or readily available resources (equipment and personnel) that could be effectively implemented under the circumstances associated with loss of large areas of the plant due to explosions or fire. Eventually, the requirements of Section B.5.b of the ICM Order were codified in 10 CFR 50.54(hh)(2); refer to SECY-08-099 and SRM-M081217B. The NRC staff-endorsed guidance for complying with 10 CFR 50.54(hh)(2) is contained in NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline.

10 Refer to NRC ADAMS ML #12229A174 13

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September 2014 February 2016 4 COMMAND AND CONTROL 4.1 OVERVIEW Each licensee should ensure that their emergency command and control structures are capable of directing responses to a beyond design basis event or severe accident, including those affecting multiple units on a site, in accordance with established procedure and guideline sets.

4.2 COMMAND AND CONTROL KEY FUNCTIONS Command and control structures should clearly identify the Emergency Response Organization (ERO) position(s) with the ultimate authority for making decisions necessary for the implementation of emergency response procedures and guidelines during a beyond design basis event or severe accident. For purposes of the guidance in this document, the position with this authority is referred to as the Ultimate Decision-Maker (UDM). The position(s) assigned the UDM function should have the authority and capability of performing the following key command and control functions:

• Selection of the procedure or guideline set(s) most appropriate to address the event and/or plant conditions.

• Determination of the strategy(ies) to be implemented, and the necessary conditions and timing for implementation.

• Direction of the onsite and offsite resources needed to implement the selected strategy(ies).

• Direction of an action not contained in, or contrary to, procedures or guidelines, if it is determined that the action will provide greater protection of public health and safety.

• Interface with the ERO position holding overall command and control authority within the site ERO (and fleet-level ERO, if applicable), if the two authorities are held by different positions.

The qualifications for an UDM are discussed in NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents.

4.3 COMMAND AND CONTROL STRUCTURE CONSIDERATIONS Procedures or guidelines used by the ERO should provide for implementation of command and control structures consistent with the following considerations.

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• The UDM authority and responsibilities should be integrated into ERO command and control structures and protocols. It is not necessary to create a new ERO position or title.

• The Shift Manager should serve as the UDM during the implementation of Abnormal Operating Procedures (AOPs) and Emergency Operating Procedures (EOPs).

• Following a transition into Severe Accident Management Guidelines (SAMGs), the UDM authority and responsibilities may be retained by the Shift Manager, or transferred to an UDM-qualified individual located in another facility. The instructions/guidance for transferring the UDM role to a location outside the Control Room should include an assessment of the availability of the supporting personnel and resources necessary to implement all the command and control key functions.

• Following the transfer of the UDM function to an ERO position-holder located outside the Control Room (e.g., in the TSC), the support staff assisting with strategy evaluation and selection should include at least one member who holds an active SRO license, or has successfully completed an SRO licensing or certification program in the past, applicable to the affected onsite unit(s).11 If a site hosts different technologies, then at least one individual with the SRO background described above should be available for each different unit technology (e.g., a PWR and a BWR, or an active safety feature plant and a passive safety feature plant).

• Following an event associated with loss of large areas of the plant due to explosions or fire, and causing a loss of the Control Room command and control structure, a procedure or guideline should describe the position(s) that could assume command and control of the event response. Due to the contingent and short-term nature of this assignment, and the initial focus on implementation of pre-planned EDMG strategies, it is not necessary for this position(s) to hold a UDM qualification. A procedure or guideline should specify how command and control are subsequently transferred to a position which does possess a UDM qualification.

• The UDM is able to direct changes to a pre-planned fire response strategy if necessary to support implementation of an accident or event mitigation or management strategy.

• The UDM assignment(s) should be consistent with the licensees staffing assessments performed in accordance with NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, and the associated regulatory responses to NRC letter, Request for Information 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, dated March 12, 2012.

11 The SRO certification should meet the requirements of ANSI/ANS 3.1, Selection, Qualification and Training of Personnel for Nuclear Power Plants.

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• The authorities and responsibilities necessary to coordinate the acquisition and delivery of offsite resources are defined.

• At sites operating within a fleet structure, fleet-level command and control capabilities should be integrated into the licensees command and control structures if such support will be relied upon during a beyond design basis event or severe accident.

• Specific UDM authorities and/or responsibilities that may be delegated, if any, are defined.

• Where appropriate, procedures and guidelines should contain guidance concerning the implementation of emergency response actions in accordance with 10 CFR 50.54(x) and the associated approval of such actions in accordance with 10 CFR 50.54(y).

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September 2014 February 2016 5 REFERENCES

• NUREG-0737, Clarification of TMI Action Plan Requirements, dated November 1980

• NRC Generic Letter 88- 20, Supplement 2, Accident Management Strategies for Consideration in the Individual Plant Examination Process, dated April 4, 1990

• NRC Report, 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

• SECY-11-0124, Recommended Actions to be Taken Without Delay from the Near-Term Task Force Report, dated September 9, 2011

• 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

• NRC letter, Request for Information 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, dated March 12, 2012

• NRC 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, dated August 29, 2012

• NRC staff report, Onsite Emergency Response Capabilities, Regulatory Basis to Address Nuclear Regulatory Commission Near-Term Task Force Recommendation 8, dated October 1, 2013

• Staff Requirements - SECY-15-0065 - Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49), dated August 27, 2015

• Proposed Rule - Mitigation of Beyond Design Basis Events (RIN 3150-AJ49), dated November 2, 2015

• Electric Power Research Institute (EPRI) Technical Report, Severe Accident Management Guidance - Technical Basis Report, TR-101869, dated April 1993

• Electric Power Research Institute (EPRI) Technical Report, Severe Accident Management Guidance - Technical Basis Report, TR-1025295, dated October 2012

• Electric Power Research Institute (EPRI) Technical Report, Investigation of Strategies for Mitigating Radiological Releases in Severe Accidents, TR-1026539, dated October 2012 18

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• NEI 91-04, Severe Accident Issue Closure Guidelines, Revision 1, dated December 1994

• NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, dated July 2009December 2006

• NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, dated May 2012

• NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 2012

• NEI Letter, Industry Initiative to Maintain Severe Accident Management Guidelines, Pietrangelo to Johnson, dated October 26, 2015

• NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents, dated September 2014February 2016

• Formatted: Indent: Left: 0.63", No bullets or numbering 19