ML17251A039

NEI 17-13 Draft MBDBE Rule Implementation Guidance Document

ML17251A039
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Site:	Nuclear Energy Institute
Issue date:	06/30/2017
From:	Nuclear Energy Institute
To:	Michael Brown Japan Lessons-Learned Division
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MITIGATION OF BEYOND DESIGN BASIS EVENTS RULE IMPLEMENTATION GUIDANCE Prepared by the Nuclear Energy Institute June 2017 Acknowledgments This document was developed and reviewed by the Nuclear Energy Institute (NEI) Mitigating Beyond Design Basis Events Rule Implementation Sub Group (MBDBE RISG) which functioned as part of the Beyond Design Basis Task Force (BDB TF).

NEI would like to thank the members of the MBDBE RISG for the time and effort expended in the preparation of this guideline. Special thanks are offered to leaders of the five teams that prepared the matrices in this document: Phil Amway (Exelon), Randy Bunt (SNC), Dennis Jones (TVA), Jon Kapitz (Xcel Energy), and Brenda Kovarik (AEP).

The Nuclear Energy Institute is the nuclear energy industrys policy organization.

This document and additional about nuclear energy are available at nei.org 1201 F Street, NW Washington, DC 20004

June 8, 17 NEI 17-03, [Rev A]

NEI Chairperson: Jim Riley / John Egdorf Industry Members:

Diane Aitken, Dominion Jon Kapitz, Xcel Energy Phil Amway, Exelon Brenda Kovarik, AEP Chris Bagley, MPR Brandon Lacy, TVA Mike Cymbor, Enercon Scott Martin, Entergy Randy Bunt, SNC Mike Powell, APS Dave Distel, Exelon Alvin Robertson, Westinghouse Allan Elms, Dominion Sue Sallade, Exelon Paul Guill, Duke Tracy St. Clair, First Energy Dennis Jones, TVA Rick Wachowiak, EPRI Mike Kammer, SCE&G 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.

The opinions, conclusions, and recommendations set forth in this report are those of the authors and do not necessarily represent the views of NEI, its employees, members or consultants.

Because NEI is supported in part by Federal funds, NEIs activities are subject to Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color, or national origin, and other federal laws and regulations, rules, and orders issued thereunder prohibiting discrimination. Written complaints of exclusion, denial of benefits or other discrimination of those bases under this program may be filed with the United States Nuclear Regulatory Commission, Washington, DC 20555 or any other appropriate federal regulatory agency or, among others, the Tennessee Valley Authority (TVA),

Office of Equal Employment Opportunity, 400 West Summit Hill Drive, Knoxville, TN 37902 ii

June 8, 17 NEI 17-03, [Rev A]

TABLE OF CONTENTS Acknowledgments 1 INTRODUCTION ...........................................................................................................................1 2 UFSAR CONSIDERATIONS .............................................................................................................1 3 SCOPE .........................................................................................................................................2 4 GENERAL MATRIX USAGE.............................................................................................................2 5 PREVIEW OF SIGNIFICANT GAPS AND ACTIONS .............................................................................3 6 MBDBE RULE CROSS REFERENCE ..................................................................................................3 7 NEI 12-06 REVISION COMPARISON ................................................................................................... 3 8 NEI 12-01 COMPARISON ..............................................................................................................3 9 NEI 13-06 COMPARISON ..............................................................................................................3 10 NEI 14-01 COMPARISON ..............................................................................................................3 11 RG 1.226 TO JLD-ISG 1201-01 COMPARISON .................................................................................3 12 RG 1.227 TO JLD-ISG-2012-03 COMPARISON .................................................................................3 13 REFERENCES ................................................................................................................................3 iii

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1 INTRODUCTION The NRC pursued numerous regulatory actions following the 2011 Fukushima Dai-ichi event in Japan. These actions began with the work of the Near-Term Task Force (NTTF) and the development of the associated NTTF recommendations. The NRCs response to the NTTF Report was provided in SECY- 11-0124, (Recommended Actions to Be Taken without Delay from the Near-Term Task Force Report), and SECY-11-0137 (Prioritization of Recommended Actions To Be Taken in Response to Fukushima Lessons Learned). These two papers identified actions to be taken in the near term and prioritized the NTTF recommendations. The near-term actions ultimately culminated in the issuance of three orders, a request for information under 10 CFR Section 50.54(f) that addressed several regulatory issues, and two Advance Notices of Proposed Rulemaking (ANPR). The regulatory efforts to address lessons learned from Fukushima have evolved over time, and the two rulemaking activities discussed in the ANPRs were consolidated into the Mitigation of Beyond-Design-Basis Events (MBDBE) rule: 10 CFR 50.155.

10 CFR 50.155 applies to power reactor applicants and licensees and includes the following:

• Provisions that make generically applicable requirements previously imposed by Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ADAMS ML12054A735), for the mitigation of beyond-design-basis external events. These requirements constitute the majority of the requirements in this rule, and are located mainly in 10 CFR 50.155(b)(1), with portions in paragraphs (c), (d), (e),

and (g) as described further below.

• Requirements for licensees to consider the effects of the reevaluated seismic and flooding hazards information within the mitigation strategies and guidelines, in accordance with the Commission direction provided in SRM-COMSECY-14-0037 (ADAMS ML15089A236), Staff Requirements -

COMSECY-14-0037 -Integration of Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluation of Flooding Hazards, dated March 30, 2015. These requirements appear in 10 CFR 50.155(b)(2).

• Requirements previously in 10 CFR 50.54(hh)(2) for mitigation of the effects of a loss of a large area of the plant due to explosions or fire. These requirements appear in 10 CFR 50.155(b)(3).

• Requirements to integrate the above capabilities with the emergency operating procedures. These requirements appear in 10 CFR 50.155(b)(4).

• Reasonable protection requirements that enable the proper degree of regulatory assurance to be applied to the equipment and structures, systems, and components (SSCs) that perform a beyond-design-basis function for the purposes of 10 CFR 50.155. These requirements appear in 10 CFR 50.155(c)(2) and (c)(3).

• Supporting requirements for the integrated response capability that include staffing, communications, training, drills or exercises, and documentation of changes. These requirements are found in 10 CFR 50.155(b), (c), (d), (e) and (g).

• Provisions that make generically applicable requirements previously imposed by Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS ML12056A044), for remotely monitoring the spent fuel pool wide-range level. These requirements appear in 10 CFR 50.155(f).

• Requirements that facilitate the decommissioning of reactors that are subject to this rule. These requirements appear in 10 CFR 50.155(a)(2).

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• Provisions that rescind orders, including Orders EA-12-049 and EA-12-051, for which 10 CFR 50.155 will now provide the governing substantive requirements. These requirements appear in 10 CFR 50.155(i).

• Provisions that facilitate the removal of a variety of license conditions for which 10 CFR 50.155 will now provide the governing substantive requirements. These requirements appear in 10 CFR 50.155(i).

This document provides guidance to assist licensee implementation of 10 CFR 50.155 provisions.

Note that NEI has prepared another document that can assist rule implementation. The BDB Event Response Program Manual provides an outline (or roadmap) for developing an emergency response program manual that can be used at the fleet or site level. Rather than building a new program manual, this document recommends that the various elements it describes be blended into the existing FLEX/SFPI program document.

The BDP Event Response Program Manual can be found at https://www.nei.org/Member-Center/Member-Resources/Department-Hubs/Fukushima-Regulatory-Response-for-Members.

2 UFSAR CONSIDERATIONS There is no specific requirement to address beyond-design-basis aspects of 50.155 compliance topics in the UFSAR. Note that some aspects of the changes made to address beyond-design-basis accidents should be included in the UFSAR if they affect design basis systems, structures, or components already included in the document (e.g.,

installation of new connection points on safety related equipment or systems for FLEX pumps and generators, changes to the seismic capacity of tanks, etc.).

3 SCOPE NEI 17-03 provides guidance for the implementation of 10 CFR 50.155 through matrices that cross reference the rule and its statements of consideration (FRN MLXXXXXX proposed rule ML16292A026) with existing NEI guidelines and other applicable references. Some of the matrices provide assessments of potential gaps that a licensee may encounter during implementation of 10 CFR 50.155.

The top-level matrix in NEI 17-03 is the Rule Requirements Cross Reference. This matrix does not address a specific document; rather it relates all of the rule paragraphs to the various documents and guidelines that provide more information on the applicable requirement. The other matrices in NEI 17-03 address specific documents as follows:

• NEI 12-06, Revisions 0, 2, and 4: Diverse and Flexible Coping Strategies (FLEX) Implementation Guide

• NEI 12-01, Revision 0: Guidance for Assessing Beyond Design Basis Accident Response Staffing and Communication Capabilities

• NEI 13-06, Revision 1: Elements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents

• NEI 14-01, Revision 1: Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents

• RG 1.226 to JLD-ISG-2012-01: Flexible Mitigation Strategies for Beyond Design Basis Events

• RG 1.227 to JLD-ISG-2012-03: Wide Range Spent Fuel Pool Level Instrumentation A matrix was not developed for RG 1.228, Integrated Response Capabilities for Beyond-Design-Basis Events, because this regulatory guide did not evolve from a single ISG, rather it was created to document the NRCs endorsements of the emergency response guidelines that were developed subsequent to the Fukushima event (NEI 12-01, 13-06, and 14-01).

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NEI 17-03 matrices fall into two types: cross reference, and comparison. A brief description of each matrix is provided below:

• Cross Reference Matrix o MBDBE Rule Requirements Cross Reference Matrix - This matrix relates every paragraph in the final rule to associated industry guidance and relevant information in the rules Statements of Consideration. Differences and applicable generic actions are identified.

• Revision Comparison Matrices o NEI 12-06 Revision Comparison Matrix - NEI 12-06 (Diverse and Flexible Coping Strategies (FLEX) Implementation Guide) was the industrys principal guidance for the design and implementation of FLEX. Licensees may presently be implementing different revisions of this document. This matrix identifies the differences between the three revisions of NEI 12-06 that have been endorsed by the NRC (revisions 0, 2, and 4) and assists with the decision of whether to adopt a different revision and what should be addressed if an older revision is used.

o RG 1.226 to JLD-ISG-1201-01 Comparison Matrix - 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) endorsed revisions 0 and 2 of NEI 12-06. RG 1.226, (Flexible Mitigation Strategies for Beyond-Design-Basis Events) endorses revision 4 of NEI 12-06. This matrix examines the differences between the ISG and the RG.

o RG 1.227 to JLD-ISG-2012-03 to RG 1.227 Comparison Matrix - JLD-ISG-2012-03 (Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation) endorsed revision 1 of NEI 12-02 (Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation. RG 1.227, Wide-Range Spent Fuel Pool Level Instrumentation) also endorses revision 1. This matrix examines the differences between the ISG and the RG.

o NEI 12-01 Comparison Matrix - NEI 12-01 (Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities) was developed and endorsed by the NRC years before 10 CFR 50.155 became effective. This guideline is referenced by the Regulatory Guide that covers Integrated Response Capabilities (RG 1.228), but like NEI 13-06 and 14-01, not all of the guideline is applicable to implementation of 10 CFR 50.155.

This matrix identifies the sections of NEI 12-01 that are applicable and provide interpretations and other information relevant to each applicable section.

o NEI 13-06 Comparison Matrix - NEI 13-06 (Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents) was endorsed by the NRC and referenced by RG 1.228, but like NEI 12-01 and 14-01, not all of the guideline is applicable to implementation of 10 CFR 50.155. This matrix identifies the sections of NEI 13-06 that are applicable and provides interpretations and other information relevant to each applicable section. Note a portion of NEI 13-06 was committed to by licensees because of a voluntary commitment to the NRC in fall 2015.

o NEI 14-01 Comparison Matrix - NEI 14-01 (Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents) was endorsed by the NRC and referenced by RG 1.228, but like NEI 12-01 and 13-06, not all of the guideline is applicable to implementation of 10 CFR 50.155. This matrix identifies the sections of NEI 14-01 that are applicable and provides interpretations and other information relevant to each applicable section. This matrix also identifies that generic activities are planned to support licensee implementation of 10 CFR 50.155. Note a significant portion of NEI 14-01 was committed to by licensees because of a voluntary commitment to the NRC in fall 2015.

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Each matrix includes a summary that highlights the key conclusions of its gap assessment. Many of these matrices identify various generic industry activities that are in place or planned to assist with implementation of 10 CFR 50.155.

4 GENERAL MATRIX USAGE Users performing gap assessments for implementation of 10 CFR 50.155 should consider the following guidance:

• Information in the document Section column of some matrices may only be a summary of the guidance from the indicated section. Users are encouraged to refer to the specific section of the document for which the gap assessment has been performed to obtain a full understanding of the guidance.

• The Statement of Considerations provides important information concerning the Nuclear Regulatory Commissions intent with respect to the rule requirements. Applicable sections of the Statement of Considerations are referenced in the matrices. Users are encouraged to read the referenced sections of the Statement of Considerations to gain insights into the requirements and how the interpretations in the matrices were derived.

• Users do not have to revalidate generic information in the table. The information has been developed and reviewed by members of the NEI MBDBE Rule Implementation Sub Group for use as a starting point to assist users in successful rule implementation.

• Users should validate information in the Gap Assessment / Recommended Action column for site specific applicability, even where none appears in that column (i.e., verify that there are no site specific gaps for that portion of the guidance).

NOTE THAT IN ALL CASES, IT IS THE RESPONSIBILITY OF EVERY LICENSEE TO EXAMINE ITS LICENSING BASES AND DETERMINE WHAT ADDITIONAL ACTIONS MAY BE NECESSARY TO ACHIEVE FULL COMPLIANCE WITH 10 CFR 50.155 5 PREVIEW OF SIGNIFICANT GAPS AND ACTIONS Each matrix includes an introduction that summarizes its major impacts and necessary actions. This section presents a preview of the more significant of these items.

5.1 10 CFR 50.155 Rule Cross Reference Matrix

• Licensees who have not implemented NEI 12-06, revision 4 will need to update their programs to address this revision, or be able to explain why implementation of an earlier revision is acceptable. See the NEI 12-06 Revision Comparison Matrix for an identification of the differences.

• 10 CFR 50.155(g) applies change control requirements to the entire rule, including EDMGs (see 155(b)(3)). Ensure that a specific change control process is in place for EDMGs to document that changes to them continue to meet the requirements. Furthermore, ensure configuration control procedures properly handle the hand-off between different change control requirements.

• 10 CFR 50.155 must be implemented within 2 years of its effective date for most plants, or 3 years for BWRs that received the EA-13-109 Order on severe accident capable hardened containment vents, unless delays associated with reevaluated hazards apply. In that case related to hazards, a request ( n o t a n e x c e p t i o n ) for an alternative compliance date must be submitted within 90 days of the rule effective date.

• Ensure that the site-specific v o l u n t a r y commitment to perform multiple source term dose assessments is maintained.

• Ensure that the NSIAC Initiative (voluntary commitment) on SAMGs is maintained.

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5.2 NEI 12-06 Revision Comparison Matrix

• Validation Requirements including providing a basis for time sensitive actions performed more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the initiation of the event. (Section 3.2.1.7 and Appendix E)

• Incorporation by reference of several supplemental guidance documents. (Section 3.2.1.13)

• Clarification on minimum quantities of hoses and cables to be maintained allowing for potential reduction in equipment. (Section 3.2.2)

• Clarifications on minimum Spent Fuel Pool Cooling Strategy spray requirements allowing for potential reduction in equipment. (Table 3-1, 3-2 and Appendix C, D)

• Clarifications on alternate locations for instrument readings. (Section 5.3.3)

• Clarifications to support using existing station processes to manage maintenance and testing. (Section 11.5.2)

• Clarifications to support managing out of service time include separating functional from protected and using station corrective actions and work control processes. (Section 11.5.3)

• Clarification on Configuration Control to support long term sustainability of FLEX Program including FLEX Strategy change management. (Section 11.8)

• Removal of recommendation to maintain Final Integrated Plan (FIP) as a living document. (Section 13.2) 5.3 NEI 12-01 Comparison Matrix

• NOTES:

o 10 CFR 50.155(b)(5) requirements for staffing capabilities are applicable to the requirements of 10 CFR 50.155 (b)(1) through (b)(3).

o 10 CFR 50.155(c)(4) requirements for communications capabilities are applicable to the requirements of 10 CFR 50.155 (b)(1) and (b)(2)..

o Although the requirements for communications capabilities contained in 10 CFR 50.155(c)(4) are not applicable to paragraph 10 CFR 50.155(b)(3) (EDMGs), all licensees have existing communications capabilities supporting EDMGs at the guidance level. See the B.5.b Phase 1 guidance letter dated February 25, 2005, Items B.1.i and B.2.b. Further details are available in NUREG 0800, Standard Review Plan, Section 19.4, Acceptance Criteria Item 12.

• Verify drill or exercise critiques and training feedback mechanisms include consideration of staffing and communications capabilities and assessments in the performance of 10 CFR 50.155 related drills, exercises and training.

• Verify the applicable change control process (e.g., 10 CFR 50.155(g) as implemented in the FLEX program document) contains adequate administrative controls for the identification of impacts to staffing and communications assessments that may impact the implementation of 10 CFR 50.155(b) strategies.

• Include a demonstration of the associated communications capability when conducting the initial drill or exercise that demonstrates the capability to transition to and use one or more of the strategies and guidelines in either paragraphs (b)(1), (b)(2) or (b)(3) of 10 CFR 50.155. This drill or exercise must be completed within four years of the effective date of the rule.

• Confirm communications capabilities committed to in response to the 10 CFR 50.54(f) letter comply with the requirements of 10 CFR 50.155(c)(4).Verify that communications equipment necessary to implement 10 CFR 50.155(c)(4) or to implement 10 CFR 50.155(b)(3) strategies is included in inventory checklists and is periodically verified functional with periodic maintenance tasks and frequencies defined.

• Verify that communications equipment contracts with vendors supporting communications equipment necessary to implement 10 CFR 50.155(c)(4) are maintained current and periodically verified.

• Verify that communications equipment procurement specifications or purchasing documents are consistent with requirements normally applied to other EP equipment and should be commonly available, commercial grade with readily available parts and replacement.

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• Verify that agreements with communications service providers that enable access to Government Emergency Telecommunications Service (GETS), the Telecommunications Service Priority (TSP) programs and the Wireless Priority Service (WPS)are maintained current and periodically verified. Information related to these services may be obtained from https://www.dhs.gov/office-emergency-communications, under the Response Support section of the web page. Note that the National Communications Service (NCS) referenced in NEI 12-01 was disbanded by Executive Order 13618 on July 6, 2012 and the cited website is no longer functional.

• Verify agreements with communications providers of Emergency Services (e.g., satellite phone service) are maintained current and periodically verified.

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5.4 NEI 13-06 Comparison Matrix

• A site must have the capability to predict offsite doses during an event involving an extended loss of all AC power affecting all onsite units. Previously, the requirement to perform this did not require the assumption of an extended loss of AC power. Even though not required by the rule, licensee regulatory commitments include the capability to predict dose from multiple source terms.

• An ERO role identified as Ultimate Decision Maker is defined. This individual is assigned authority and responsibility for providing overall direction on the implementation of EOPs, FSGs, EDMGs and SAMGs for a unit or set of units.

• On an eight (8) year frequency, sites must conduct drills demonstrating BDB strategies (including communications capabilities), including:

o 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.

o 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. Even though not required by the rule, licensee regulatory commitments include SAMGs to be integrated with the EOP network.

o A drill that demonstrates the use of EDMG strategies.

o 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.

It is important to note that while it is acceptable to use an EP exercise to accomplish the new drill requirements, it is recommended that exercises not be used to meet these requirements. Graded exercises serve a specific purpose to meet the regulatory required emergency planning requirements.

Combining BDB drills with a graded exercise could lead to confusion and conflicts that interfere with objectives of either or both of the activities.

5.5 NEI 14-01 Comparison Matrix

• Verify Severe Accident Management Guidelines (SAMGs) are revised and maintained in accordance with the new NSSS Owners Group guidance by the utility commitment date in the letter sent to the NRC.

• Integrate the appropriate guidelines (FSGs, EDMGs) with the EOPs in accordance with the revised NSSS Owners Group guidance. Provide the necessary training of new tasks on the procedure integration using the SAT process.

• Designate a member of the Emergency Response Organization (ERO) as the Ultimate Decision Maker (UDM). Provide the necessary training required for the position to ERO personnel designated.

5.6 RG 1.226 to JLD-ISG-1201-01 Comparison Matrix

• RG 1.226 endorses NEI 12-06, Revision 4, but its implementation section allows use of other NRC acceptable methods.

• The ISG recognizes that FLEX equipment may be pre-staged for up to 45 days to reduce the risk of maintenance or outage activities. All other instances of unavailability due to the lack of reasonable protection are limited to 14 days. The RG 1.226 discussion on this topic only includes the 14 day allowed outage time with no mention of the exception for 45 days if deployed to reduce the risk of maintenance or outage activities. However, in the NRC Staffs concluding position, the NRC Staff states that Section 11.5.4 provides an acceptable method for controlling unavailability of the equipment to satisfy that element of reasonable protection. Note there is a distinction for deployed equipment for maintenance or outage activities with regard to reasonable protection.

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5.7 RG 1.227 to JLD-ISG-2012-03 Comparison Matrix The Applicable Regulations section of RG 1.227 explains a 10 CFR 50.155(f) requirement that each licensee provide reliable means to remotely monitor wide-range water level for each spent fuel pool at its site until five years have elapsed since all of the fuel within that spent fuel pool was last used in a reactor vessel for power generation. Paragraph 50.155(f) removes the requirement for operating nuclear power plants to provide wide-range spent fuel pool level monitoring capabilities for spent fuel pools that contain only fuel greater than five years old. This condition typically exists at plants with multiple spent fuel pools that use only one of the pools for freshly discharged fuel. Paragraph 50.155(a)(2)(i) removes the requirement for wide-range spent fuel pool level monitoring capabilities for all spent fuel pools at a nuclear power plant that has permanently ceased operation and removed all fuel from the reactor vessel once the NRC has docketed the appropriate certifications without regard to the age of the fuel in the pools.

6 MBDBE RULE CROSS REFERENCE Introduction The Mitigation of Beyond Design Basis Events (MBDBE) Rule Cross Reference matrix identifies sources of additional guidance and background for every paragraph in 10 CFR 50.155. It also includes information on the following related regulations and two subjects that were not included in the rule.

• 10 CFR 50 Appendix E - Emergency Planning and Preparedness for Production and Utilization Facilities

• 10 CFR 52.80 - Contents of applications: additional technical information

• Multiple Source Term Dose Assessments (MSTDAs)

• Severe Accident Mitigation Guidelines (SAMGs) 10 CFR 50.155 does not include requirements for MSTDAs and SAMGs, except for a requirement to integrate the SAMGs with the existing EOPs, because the NRC took credit for pre-existing licensee commitments (NSIAC Initiative) in these areas. It is important that licensees maintain these commitments in order to remain consistent with the basis for the rule. The Commission directed the staff in SRM-SECY-15-0065 to incorporate oversight of SAMGs into the ROP.

Major Gap Assessments and Recommended Actions The information provided below is a summary of the most significant observations in the 10 CFR 50.155 Rule Requirements Cross Reference Matrix.

• Licensees who have not implemented NEI 12-06, rev 4 should either update their programs to address this revision, or be able to explain why implementation of an earlier revision is acceptable. See the NEI 12-06 Revision Comparison Matrix for an identification of the differences.

• The impact of many of the rule requirements depends on associated guidance. When this is the case, the 10 CFR 50.155 Rule Requirements Cross Reference Matrix refers the user to the appropriate guideline matrix in this document for information on impact and actions.

• 10 CFR 50.155(g) applies change control requirements to the entire rule, including EDMGs (that are required under paragraph 155(b)(3)). Ensure that a specific change control process is in place for EDMGs to document that changes to them continue to meet the requirements. Furthermore, ensure configuration control procedures properly handle the hand-off between the different change control requirements that govern other plant equipment and programs.

• 10 CFR 50.155 must be implemented within 2 years of its effective date for most plants, or 3 years for BWRs that received the EA-13-109 Order on severe accident capable hardened containment vents unless delays associated with reevaluated hazards apply. In that case related to hazards, a request ( n o t a n e x c e p t i o n ) for an alternative compliance date must be submitted within 90 days of the rule effective date.

• Ensure that the site-specific commitment f o r a c a p a b i l i t y to perform MSTDAs is maintained.

• Ensure that the NSIAC Initiative on SAMGs is maintained.

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Users Notes Due to the large size of this matrix, it has been formatted to extend across two adjacent facing pages.

An explanation of the information in each column of the matrix follows:

• Previous NRC Requirement - Quotes the applicable sections of each of the requirements that preceded 10 CFR 50.155. These include:

o EA-12-049 - Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events o EA-12-051 - Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation o 10 CFR 50.54(hh)(2) - Extreme Damage Mitigation Guidelines (EDMGs)

• 10 CFR 50.155 Requirements - Quotes every section of the rule

• Associated Current Industry Guidance - Provides references to existing industry guidance for the associated 10 CFR 50.155 paragraphs.. The following guidance documents are referenced:

o NEI 06 B.5.b Phase 2 & 3 Submittal Guideline o NEI 12 Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities o NEI 12 Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation o NEI 12 Diverse and Flexible Coping Strategies (FLEX) Implementation Guide o NEI 13 Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents o NEI 14 Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents

• Delta between 50.155 and previous requirements / current guidance - Identifies significant difference between the requirements in the rule and any applicable previous requirements or industry guidance

• SOC (FRN XXXXX) Reference - The Statements of Consideration (SOC) are published with the rule and provide valuable insights into the NRC Staff and Commission thinking behind the associated regulatory requirement. The SOC section number and title is provided for each rule paragraph. In addition, a page reference is provided to indicate where the discussion on the specific subject can be found.

• Impact / Interpretation - When applicable, provides additional thoughts on interpretation of the regulation (beyond that information provided by the associated industry guidance and the SOC).

• Action - captures any generic actions being undertaken by the industry to address the regulatory requirement. In many cases, these actions are captured in other matrices within this document and a reference to the applicable matrix is provided. This column should be used by licensees to capture utility-specific actions.

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Previous NRC Requirement 10 CFR 50.155 Requirements Associated Current Industry Guidance EA-12-049, pg. 7: All holders of operating (a) Applicability. NEI 12-06, R4, Sec 1.5, Applicability licenses issued under Part 50 shall, (1) Each holder of an operating license for a notwithstanding the provisions of any nuclear power reactor under this part and NEI 12-01, R0, Sec 1.1, Response Commission regulation or license to the each holder of a combined license under part Staffing Assessment contrary, comply with the requirements 52 of this chapter for which the Commission described in Attachment 2 to this Order except to the extent that a more stringent requirement has made the finding under § 52.103(g) shall NEI 12-02, R1, Exec Summary is set forth in the license. comply with the requirements of this section until the NRCs docketing of the license NEI 13-06, R1, Sec 1.1, Scope And EA-12-049, pg. 8: All holders of COLs issued holders certifications described in §§ Purpose of NEI 13-06 under Part 52 shall, notwithstanding the 50.82(a)(1) or 52.110(a) of this chapter.

provisions of any Commission regulation or NEI 14-01, R1, Sec 1, Introduction license to the contrary, comply with the requirements described in Attachment 3 to this Order except to the extent that a more stringent requirement is set forth in the license.

EA-12-051, pg. 8: All holders of operating licenses issued under Part 50 shall, notwithstanding the provisions of any Commission regulation or license to the contrary, comply with the requirements described in Attachment 2 to this Order except to the extent that a more stringent requirement is set forth in the license.

EA-12-051, pg. 9: All holders of COLs issued under Part 52 shall, notwithstanding the provisions of any Commission regulation or license to the contrary, comply with the requirements described in Attachment 3 to this Order except to the extent that a more stringent requirement is set forth in the license.

10CFR50.54(hh)(3)

This section does not apply to a nuclear power plant for which the certifications required under

§ 50.82(a) or § 52.110(a)(1) of this chapter have been submitted.

License conditions associated with Mitigation Strategies, SFPI for Summer 2 & 3, radiological protection mitigation strategies - B5b, and the COLs for the new reactor licensees contain clauses related to applicability termination.

10

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Rule adds a termination clause. V.C.: Applicability - pg. 60 10 CFR 50.54(hh)(3), which None has been renumbered as 50.54(hh)(3) is being modified to V.C.: EDMGs - pg. 80 (hh)(2) by the MBDBE reflect the proper section numbers Rulemaking, formerly for the certifications (50.82(a)(1) and VI.: Paragraph 50.155(a), provided the termination 52.110(a)). This affects the Applicability- pg. 111 clause for the EDMGs, termination of the 50.54(hh)(1) which is now provided by requirements for COL holders and is 50.155(a)(2). See the a backfit. (See the supplement to discussion on that section SECY-16-0142 dated 2/22/2017.) The with regard to the changes original version of (hh)(3) terminated in the termination criteria the B.5.a and B.5.b requirements on for EDMGs.

submittal of the certification of permanent cessation of operations rather than the certification of permanent removal of fuel from the reactor vessel; this was in error and the NRC corrected it using the original adequate protection justification.

11

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance 10CFR50.54(hh)(3) - termination provision for (2)(i) Once the NRC has docketed the None 50.54(hh)(2) for EDMGs certifications described in § 50.82(a)(1) or § This section does not apply to a nuclear power 52.110(a) of this chapter, submitted by a plant for which the certifications required under licensee subject to the requirements of this

§ 50.82(a) or § 52.110(a)(1) of this chapter have section, that licensee need only comply with been submitted.

the requirements of § 50.155(b) through (e),

and (g) of this section associated with spent fuel pool cooling capabilities.

(ii) Holders of operating licenses or combined licenses for which the NRC has docketed the certifications described in § 50.82(a)(1) or § 52.110(a) of this chapter need not meet the requirements of this section except for the requirements of paragraph (b)(3) of this section associated with spent fuel pool cooling capabilities once the decay heat of the fuel in the spent fuel pool can be removed solely by heating and boiling of water within the spent fuel pool and the boil-off period provides sufficient time for the licensee to obtain off-site resources to sustain the spent fuel pool cooling function indefinitely, as demonstrated by an analysis performed and retained by the licensee.

Licensee specific (iii) is a licensee specific requirement. None 10CFR50.54(hh)(3) - termination provision for (iv) Holders of operating licenses or None 50.54(hh)(2) for EDMGs combined licenses for which the NRC has This section does not apply to a nuclear power docketed the certifications described in § plant for which the certifications required under 50.82(a)(1) or § 52.110(a) of this chapter

§ 50.82(a) or § 52.110(a)(1) of this chapter have need not meet the requirements of this been submitted.

section once all irradiated fuel has been permanently removed from the spent fuel pool(s).

12

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance IV.L: Clarifications to Decommissioning activities Include in decommissioning The life of an Order is related to the Decommissioning Provisions - plan existence of the operating license. pg. 47 This section avoids the Orders typically include clauses need for a licensee to regarding provisions for rescission or IV.N.3:,Comment Regarding request exemptions from relaxation of them upon a showing of Decommissioning - pg. 51 these requirements upon cessation of operation and good cause, paralleling the permanent removal of fuel Enforcement Manual, section 2.7.8. V.C., Decommissioning reactors from the reactor vessel, as

. - pg. 61 well as further exemptions once the fuel is old enough V.C., Assumed Damage State for and decay heat has Development of the Strategies reduced sufficiently.

and Guidelines - pg. 76 VI., Paragraph 50.155(a),

Applicability - pg. 112 None V.C., Decommissioning Reactors Exempts Millstone Power None

- pg. 65 Station Unit 1 from the requirements of 10 CFR VI., Paragraph 50.155(a)(2)(iii) - 50.155 pg. 113 This provision extends the See references above for Decommissioning activities. Include in decommissioning effectiveness of the regulation for 50.155(a)(2)(i) plan B.5.b SFP strategies until the Extends the applicability of irradiated fuel is removed from the the regulation for B.5.b SFP SFP, taking the place of the current strategies until the Mitigation Strategies license irradiated fuel is removed from the SFP and avoids the condition requirement for all need for an exemption operating power reactors request once the criteria are met.

13

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance EA-12-049, Att 2, pg. 1, (5): (b) Integrated response capability. NEI 12-06, R4 Full compliance shall include procedures, Each applicant or licensee shall develop, guidance, training, and acquisition, staging, implement, and maintain an integrated or installing of equipment needed for the response capability that includes:

strategies.

EA-12-049, Att 2, (2): (1) Mitigation Strategies for Beyond-Design- NEI 12-06, R4, Sec 1.3, FLEX Objectives These strategies must be capable of Basis External Events. Strategies and & Guiding Principles and Sec 5.3.1, mitigating a simultaneous loss of all guidelines to mitigate beyond-design-basis Protection of FLEX Equipment alternating current (ac) power and loss of external events from natural phenomena normal access to the ultimate heat sink and that are developed assuming a loss of all ac NEI 14-01, R1, Sec 3.3, Flex Support have adequate capacity to address power concurrent with either a loss of Guidelines (FSGs) challenges to core cooling, containment, normal access to the ultimate heat sink or, and SFP cooling capabilities at all units on a for passive reactor designs, a loss of normal site subject to this Order." access to the normal heat sink. These strategies and guidelines must be capable of being implemented site-wide and must EA-12-049, Att 2 & 3, (2): include:

Applicable to Vogtle Units 3 and 4 -

identical language except for referring to the normal (vs. ultimate) heat sink.

EA-12-049, Att 2, (1): (i) Maintaining or restoring core cooling, NEI 12-06, R4, Sec 1.3, FLEX Objectives Licensees or construction permit (CP) holders containment, and spent fuel pool cooling &Guiding Principles shall develop, implement, and maintain capabilities; and guidance and strategies to maintain or restore core cooling, containment and SFP cooling capabilities following a beyond-design-basis external event.

EA-12-049, Att 3, (1):

Licensees shall develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment and SFP cooling capabilities following a beyond-design-basis external event.

14

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance None V.A.2, Rule-making Objectives - Impact depends on the Use NEI 12-06 Revision Gap pg. 54 revision of NEI 12-06 a Review Matrix Licensee used to V.C.,: Integrated Response implement FLEX for Capability - pg.66 compliance to Order EA 049 VI., Paragraph 50.155(b),

Integrated response capability -

pg. 113 None IV.D., Loss of all AC - pg. 26 Impact depends on the Use NEI 12-06 Revision Gap revision of NEI 12-06 a Review Matrix Note that the rule and SOC clarify the IV.N.1., Different Approach to Licensee used to interpretation of loss of all ac power. MBDBE - pg. 49 implement FLEX for Use NEI 14-01 Compliance The rule intent is consistent with NEI compliance to Order EA Matrix 12-06 as explained in the Statements V.A. 1, Rule-making Objectives - 049 of Consideration, Public Comments pg. 53 and Changes to the Rule, section D, page 27. Also see JLD-ISG-2012-01, V.B. 1,: Rule-making Scope - pg.

R2. Sec 1.2. 55 V.C., Assumed Damage State for Development of the Strategies and Guidelines - pg. 69 VI., Paragraph 50.155(b),

Integrated response capability -

p 115 None VI., Paragraph 50.155(b), Impact depends on the Use NEI 12-06 Revision Gap Integrated response capability - revision of NEI 12-06 a Review Matrix pg. 115 Licensee used to implement FLEX for compliance to Order EA 049 15

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance EA-12-049, Att 2: (ii) The acquisition and use of offsite NEI 12-06, R4, Sec 2.5,

...The transition phase requires providing assistance and resources to support the Synchronization with Off-Site sufficient, portable, onsite equipment and functions required by paragraph (b)(1)(i) of Resources consumables to maintain or restore these this section indefinitely, or until sufficient site functions until they can be accomplished functional capabilities can be maintained NEI 12-06, R4, Sec 12, Off Site with resources brought from off site. The without the need for the mitigation Resources final phase requires obtaining sufficient strategies.

offsite resources to sustain those functions indefinitely."

SRM to COMSECY-14-0037: (2) Reevaluated Seismic and Flooding Hazards NEI 12-06, R4: Appendices G / H, The Commission has approved the staffs Mitigation. Each licensee that received Mitigating Strategies Assessment for recommendation 1 that licensees for the March 12, 2012, NRC letter New Flood / Seismic Hazard operating nuclear power plants need to issued under § 50.54(f) of this part shall Information address the reevaluated flooding hazards consider the effects of the reevaluated within their mitigating strategies for hazards information developed in response to beyond-design-basis external events; and that request if the magnitude of those recommendation 2 that licensees for hazards exceeds the external design basis of operating nuclear power plants may need the facility. Licensees shall address the to address some specific flooding scenarios effects of the reevaluated hazard information that could significantly damage the power using one or both of the following plant site by developing targeted or approaches:

scenario-specific mitigating strategies, possibly including unconventional (i) The mitigation strategies and guidelines measures, to prevent fuel damage in required by paragraph (b)(1) of this section, reactor cores or spent fuel pools. as implemented or as modified; (ii) Event-specific approaches.

16

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Eliminates the phased approach and IV.K., Consideration of Explicit No impact expected. The Use NEI 12-06 Revision Gap replaces with a performance based Requirements for a Three-Phase guidance for coordination Review Matrix approach as stated in the SOC Page Response - pg. 46 of and transition to off-site

46. This recognizes that future resources has not changed nuclear plant designers may be able V.C., Assumed Damage State for significantly between NEI to develop and implement strategies Development of the Strategies 12-06 Revisions and guidelines that do not rely on a and Guidelines - pg. 77 three phase approach.

VI., Paragraph 50.155(b),

Adds the consideration that site Integrated response capability -

functional capabilities can be restored pg. 116 without the need for the on-going use of mitigation strategies.

However, the rule intent is consistent with NEI 12-06.

Industry agreed to do flooding and IV.B., Seismic and Flooding Impact depends on the Integrate MSAs with FLEX seismic mitigating strategy Reevaluated Hazards - pg. 22 revision of NEI 12-06 strategies assessments (MSAs) based on an Appendix G/H a Licensee understanding of the intent of the V.C., Equipment - pg. 91 used to complete the MSAs Use NEI 12-06 Revision Gap SRM and the expected requirements Review Matrix in 10 CFR 50.155. MSAs were VI., Paragraph 50.155(b),

complete as part of this commitment Integrated response capability -

but actions out of those MSAs may pg. 116 not have been completed at the time of the rule effective date. These actions will have to be completed as part of the rule implementation.

17

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance 10CFR50.54(hh)(2): (3) Extensive Damage Mitigation Guidelines NEI 06-12, R2/R3, B.5.b Phase 2 & 3 Each licensee shall develop and (EDMGs). Strategies and guidelines to Submittal Guideline implement guidance and strategies maintain or restore core cooling, intended to maintain or restore core containment, and spent fuel pool cooling NEI 14-01, R1, Sec 2.4, Integration Of cooling, containment, and spent fuel pool capabilities under the circumstances Procedure And Guideline Sets, and Sec cooling capabilities under the associated with loss of large areas of the 3.4, Extensive Damage Mitigation circumstances associated with loss of large plant impacted by the event, due to Guidelines areas of the plant due to explosions or fire, explosions or fire, to include strategies and to include strategies in the following areas: guidelines in the following areas: NUREG 0800, Sec 19.4, Strategies and (i) Firefighting; (i) Firefighting; Guidance to Address Loss-of-Large (ii) Operations to mitigate fuel damage; (ii) Operations to mitigate fuel damage; and Areas of the Plant Due to Explosions and (iii) Actions to minimize radiological release. and Fires (iii) Actions to minimize radiological release. U.S. Nuclear Regulatory Commission, "NRC Staff Guidance for Use in EA-06-137 Achieving Satisfactory Compliance with February 25, 2002, Order Section Mitigation Strategies License Condition B.5.b," Letter from James E. Dyer (NRC) to Holders of Licenses for Operating Power Reactors, February 25, 2005.

None (4) Integration of capabilities required by NEI 12-06, R4, Sec 2.4, Programmatic paragraphs (b)(1) through (b)(3) of this Controls section with the Emergency Operating Procedures (EOPs). NEI 12-06, R4, Sec 11.4, Procedural Guidance NEI 13-06, R1, Sec 5.3.1, Industry Performance Standards for BDB Event Response Drills NEI 14-01, R1 - Procedure Integration -

Sec 2.1, 2.4: (not including SAMG recommendations) 18

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance There is a minor difference in the V.C., Decommissioning A staffing analysis for 10 Licensees are committed to preamble wording of 50.155(b) which reactors - pg. 61 CFR 50.155(b)(3) is satisfied either rev 2 or 3 of NEI 06-requires licensees to develop, by the analysis performed 12. Check your implement, and maintain, as V.C., Integrated Response to meet the requirement in commitment.

compared to the words in Capability - pg. 66 10 CFR 50, Appendix E, 50.54(hh)(2) which require that Section IV.A.9, and the Use the NEI 14-01 licensees develop and implement V.C., EDMGs - pg. 79 guidance in NSIR/DPR-ISG- Compliance Matrix the strategies.

01, Interim Staff Guidance V.C., Equipment - p 92 Emergency Planning For Nuclear Power Plants.

V.C.,: Implementation - p 101 VI., Paragraph 50.155(b),

Integrated response capability -

pg. 118 New requirement in addition to the V.A.2., Rulemaking Objectives, This is addressed through Use NEI 12-06 Revision Gap guidance in NEI 12-06. The Establishes new requirements the implementation of NEI Review Matrix Statements of Consideration state for an integrated response 14-01 and the industry that these strategies, guidelines, and capability - pg. 55 voluntary commitment to Use the NEI 13-06 and 14-01 procedures were developed at maintain SAMGs. Review Compliance Matrices separate times over a period of V.B ., Rulemaking Scope, Scope of plant SAMGs will be several decades, and that the of Procedure and Guideline included as part of the associated efforts have been focused Integration - pg. 57, Reactor Oversight Process on responding to different types of (ROP).

initiating events and plant damage Guideline Sets Excluded from the states. They may not properly reflect Final Rule pg. 59 The BWROG and PWROG consideration of the interfaces, are developing generic dependencies, and interactions. V.C ., Integrated Response approaches for some of the EDMGs are a good example, as they Capability - pg. 66 NEI 14-01 requirements were not part of the post-Fukushima that will require site actions. V.C., Integration with EOPs - specific implementation.

pg. 81 VI., Paragraph 50.155(b),

Integrated response capability -

pg. 119 19

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance None (5) Sufficient staffing to support NEI 12-06, Sec 11.7, Staffing, and implementation of the capabilities required Appendix E Attachment 4, Guidance in paragraphs (b)(1) through (b)(3) of this On The Consideration Of Performance section in conjunction with the EOPs to Attributes.

respond to events.

NEI 12-01, R0, Sec 1.1, Response Staffing Assessment NEI 12-01, R0, Secs 3.4 thru 3.10, elements of a response staffing study NEI 14-01, R1, Sec 4.2, Command and Control Key Functions and Sec 4.3, Command and Control Structure Considerations None (6) A supporting organizational structure NEI 14-01, R1, sec 4.1, 4.2, and 4.3, with defined roles, responsibilities, and Command and Control authorities for directing and performing the capabilities required in paragraphs (b)(1) NEI 12-01, R0, Executive Summary through (b)(3) of this section.

NEI 12-01, R0, Introduction NEI 12-01, Table 1-1, Summary of Licensee Actions for Responding to NRC Information Requests Related to EP NEI 14-01, R1, Sec 4.2, Command and Control Key Functions and Sec 4.3, Command and Control Structure Considerations 20

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance The staffing and communications IV.F., Relocation and Revision to This potentially will require Use NEI 12-01 and 14-01 requirements in 10 CFR 50.155 were the Staffing and Communications a staffing analysis if Compliance Matrices not explicit requirements in the Requirements - pg. 32 flooding or seismic MSA Mitigation Strategies Order (EA results changed your 049), even though both were V.B.2 & V.B.3, Rulemaking strategy. A staffing considered and addressed as part of Scope - pg.55 analysis for 10 CFR implementation of the Order. The 50.155(b)(3) is satisfied by NRC addressed these requirements V.C., Staffing - pg. 84 the analysis performed to in the rules supporting backfitting meet the requirement in and issue finality assessment. VI., Paragraph 50.155(b), 10 CFR 50, Appendix E, Integrated response capability - Section IV.A.9, and the Paragraph (b)(5) applies staffing pg. 119 guidance in NSIR/DPR-ISG-necessary for an integrated response 01, Interim Staff Guidance capability to support use of the Emergency Planning For capabilities in §50.155(b), which Nuclear Power Plants.

includes strategies required by (b)(3).

As described on Page 120 of the SOC, the staffing requirement of (b)(5) is verified through the use of drills, existing training analyses and other methods as opposed to the methodology contained in NEI 12-01.

Guidance on requirements is V.B.2 & V.B.3, Rulemaking See NEI 12-01, 13-06 and Use NEI 12-01, 13-06 and 14-provided in NEI 12-01, 13-06 and Scope - pg. 55 14-01 Compliance Matrices 01 Compliance Matrices 14-01.

V.C., Command and Control -

pg. 85 VI., Paragraph 50.155(b),

Integrated response capability -

pg.120 21

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance EA-12-049, Att 2, (3): (c) Equipment. NEI 12-06, R4, Sec 3.3, Considerations Licensees or CP holders must provide (1) The equipment relied on for the In Utilizing Off-Site Resources reasonable protection for the associated mitigation strategies, guidelines, and event-equipment from external events. Such specific approaches required by paragraphs NEI 12-06, R4, Sec 2.3, Define Site-protection must demonstrate that there is (b)(1) and (b)(2) of this section must have Specific Flex Strategies adequate capacity to address challenges to sufficient capacity and capability to perform core cooling, containment, and SFP cooling the functions required by paragraphs (b)(1) NEI 12-06, R4, Sec 11.2, Equipment capabilities at all units on a site subject to and (b)(2). Design this Order.

(2) The equipment relied on for the NEI 12-06, R4, Sec 11.3, Equipment EA-12-049, Att 3 (for Vogtle 3 & 4), (3): mitigation strategies and guidelines required Storage Licensees must provide reasonable by paragraph (b)(1) of this section must be protection for the associated equipment reasonably protected from the effects of NEI 12-06, R4, App G / H - Mitigating from external events. Such protection must natural phenomena that are equivalent in Strategies Assessments For New demonstrate that there is adequate magnitude to the phenomena assumed for Flooding / Seismic Hazard capacity to address challenges to core developing the design basis of the facility. Information.

cooling, containment, and SFP cooling capabilities at all units on a site subject to (3) The equipment relied on for paragraph this Order. (b)(2) of this section must be reasonably protected from the effects of the reevaluated hazards determined in response to the March 12, 2012, NRC letter issued under § 50.54(f) of this part.

22

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Rule requires addressing the effect of IV.C., Reasonable Protection - MSAs were completed or Use NEI 12-06 Revision Gap the reevaluated seismic and flooding pg. 23 are on-going after the Review Matrix hazards on the FLEX equipment, the development and Order did not require this, but IV.M., Clarifications to implementation of the FLEX Complete MSAs per industry agreed to perform Equipment Requirements and strategies. As a minimum, established regulatory Mitigating Strategies Assessments. Removal of Proposed actions from the MSAs will schedule and Integrate The need to evaluate the FLEX Maintenance Requirement - pg. have to be addressed and MSAs with FLEX strategies.

equipment against the reevaluated 47 configuration control of the hazard was implied by the SRM to MSA inputs, assumptions C O M SECY-14-0037. Industry V.C., Equipment - pg. 87 and capabilities will need to executives agreed to perform be maintained as part of Mitigating Strategies Assessments V!., Paragraph 50.155(c), the FLEX program to satisfy without specific direction from the Equipment - pg. 120 the (b)(2) section of the NRC based on the intent of the SRM rule.

and the understanding that this V!., Paragraph 50.155(c),

would ultimately be required by 10 Equipment, Reasonable CFR 50.155. Protection - pg. 122 23

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance None (4) Each licensee shall provide sufficient NEI 12-01, R0, Executive Summary communications capability, both onsite and offsite, to support implementation of the NEI 12-01, R0, Introduction mitigation strategies and guidelines of paragraphs (b)(1) and (b)(2) of this section. NEI 12-01, R0, Table 1-1, Summary of Licensee Actions for Responding to NRC Information Requests Related to EP NEI 12-01, R0, Secs: 4.1.thru 4.11, communications during an extended loss of AC power NEI 13-06, R1, recommended actions for EP facilities and equipment, Secs 4.3.1 and 4.3.2 24

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance None - As identified in the SOC, page IV.F., Relocation and Revision to Communications Use NEI 12-01 and 13-06 102, the communication the Staffing and Communications assessments were Compliance Matrices requirements were included as part Requirements - pg. 32 completed as part of the of the implementation of the response to the Fukushima Mitigating Strategy Order. V.B.2 & V.B.3, Rulemaking 50.54(f) letter and licensees Scope - pg. 55 may have made commitments to maintain V.C., Onsite and offsite or enhance communications capability - pg. communications under 101 ELAP conditions. Many Licensees used the V!., Paragraph 50.155(c), communications Equipment - pg. 125 capabilities described in these assessments as part of the FLEX strategies. As a minimum, configuration control and maintenance of the communications equipment need to be maintained as part of the FLEX program to satisfy the (C)(4) section of the rule.

Part of the reason the NRC moved the communications requirements from App E to 50.155 was to avoid requiring licensees to include the beyond-design-basis communications in their EP plans. This avoids issues with change control under 50.54(q) rather than 50.155(g).

There can be impacts on the ability to change items later if they have been included in the EP plan.

25

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance None (d) Training requirements. Each licensee shall NEI 06-12, R 2, numerous locations provide for the training and qualification of personnel that perform activities in NEI 13-06, R1, Recommended actions accordance with the capabilities required by for BDB event response training, Sec paragraphs (b)(1) through (b)(3) of this 3.3.1, 3.3.2, 3.3.3, 3.3.4, and 3.3.5 section. The training and qualification on these activities must be developed using the NEI 12-06, R4, Sec 11.6, Training systems approach to training as defined in § 55.4 of this chapter except for elements already covered under other NRC regulations.

26

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Licensees are required to use the SAT V.C., Training - pg. 93 Current training programs Action is only required for process for newly identified training as defined in 10 CFR can new training requirements requirements to support the VI., Paragraph 50.155(d), provide for the knowledge identified as part of rule effective use of the strategies and Training requirements - pg. and abilities required for implementation guidelines required by the Rule 126 performing activities in accordance with the Use NEI 13-06 Compliance strategies and guidelines Matrix required by the final Rule.

NRC is not requiring licensees to revise these training programs to use the SAT process to meet the MBDBE requirements:

(a) 10 CFR 55, Operators Licenses (b) 10 CFR 50.120, Training and Qualification of Nuclear Plant Personnel (c) 10 CFR 50, Appendix E, Section IV.F, training for Emergency Response personnel 27

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance Part 50 App E, F.2.j., Training: The (e) Drills or exercises. NEI 12-01, R0, Secs: 4.1.thru 4.11, exercises conducted under paragraph 2 of (1) An applicant for an operating license communications during an extended this section by nuclear power reactor issued under this part shall conduct an initial loss of AC power licensees must provide the opportunity for drill or exercise that demonstrates the the ERO to demonstrate proficiency in the capability to transition to and use one or NEI 13-06, R1, Executive Summary key skills necessary to implement the more of the strategies and guidelines in principal functional areas of emergency e i t h e r paragraphs (b)(1) or (b)(3) of this NEI 13-06, R1, Sec 5.3, recommended response identified in paragraph 2.b of this section including demonstration of the actions for drills and exercises, section. Each exercise must provide the opportunity for the ERO to demonstrate associated communications capability, no (excluding SAMG recommendations):

key skills specific to emergency response more than 12 months before issuance of an duties in the control room, TSC, OSC, EOF, operating license for the unit described in the and joint information center. Additionally, license application.

in each eight calendar year exercise cycle, nuclear power reactor licensees shall vary the content of scenarios during exercises conducted under paragraph 2 of this section to provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to respond to the following scenario elements: hostile action directed at the plant site, no radiological release or an unplanned minimal radiological release that does not require public protective actions, an initial classification of or rapid escalation to a Site Area Emergency or General Emergency, implementation of strategies, procedures, and guidance developed under § 50.54(hh)(2), and integration of offsite resources with onsite response. The licensee shall maintain a record of exercises conducted during each eight year exercise cycle that documents the content of scenarios used to comply with the requirements of this paragraph.

Each licensee shall conduct a hostile action exercise for each of its sites no later than December 31, 2015. The first eight-year exercise cycle for a site will begin in the calendar year in which the first hostile action exercise is conducted. For a site licensed under Part 52, the first eight-year exercise cycle begins in the calendar year of the initial exercise required by Section IV.F.2.a.

28

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Establishes requirements for initial IV.J., Drill Frequency - pg. 44 Other than timing, the Use NEI 12-01and 13-06 drills or exercises for applicants for requirements are the same Compliance Matrices Part 50 licenses. Other than timing, V.B.2 & V.B.3, Rulemaking as those established under the requirements are the same as Scope - pg. 55 (e)(4) for those that already those established under (e)(4) for hold licenses. at the time those that already hold licenses at V.C., Drills or Exercises - pg. 95 the rule becomes effective.

the time the rule becomes effective.

VI., Paragraph 50.155(e), Drills Although NEI 13-06 does not or exercises - pg. 127 specifically address its applicability for new plants, its intent in this VI., 10 CFR Part 50, Appendix E, regard is implied in the executive Section IV, Training - pg. 137 summary which states that the purpose of the document is to promote consistent implementation of the actions that address the Tier 2 EP enhancements discussed above.

The discussion being referred to addresses Order EA-12-049 and NEI 12-06, both of which are applicable to new plants.

Note that the rule does not extend to SAMGs.

10 CFR 50.54(hh)(2) strategies, procedures, and guidance is replaced with 10 CFR 50.155 drill and exercise requirements 29

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance Part 50 App E, F.2.j., Training: The (2) A holder of a combined license issued NEI 12-01, R0, Secs: 4.1.thru 4.11, exercises conducted under paragraph 2 of under part 52 of this chapter before the communications during an extended this section by nuclear power reactor Commission has made the finding under § loss of AC power licensees must provide the opportunity for 52.103(g), shall conduct an initial drill or the ERO to demonstrate proficiency in the exercise that demonstrates the capability to NEI 13-06, R1, Executive Summary key skills necessary to implement the transition to and use one or more of the principal functional areas of emergency strategies and guidelines in either paragraphs NEI 13-06, R1, Sec 5.3, recommended response identified in paragraph 2.b of this (b)(1) or (b)(3) of this section including actions for drills and exercises, section. Each exercise must provide the opportunity for the ERO to demonstrate demonstration of the associated (excluding SAMG recommendations):

key skills specific to emergency response communications capability, no more than 12 duties in the control room, TSC, OSC, EOF, months before the date specified for and joint information center. Additionally, completion of the last inspections, tests, and in each eight calendar year exercise cycle, analyses in the inspections, tests, analyses, nuclear power reactor licensees shall vary and acceptance criteria completion schedule the content of scenarios during exercises required by § 52.99(a) of this chapter for the conducted under paragraph 2 of this unit described in the combined license.

section to provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to respond to the following scenario elements: hostile action directed at the plant site, no radiological release or an unplanned minimal radiological release that does not require public protective actions, an initial classification of or rapid escalation to a Site Area Emergency or General Emergency, implementation of strategies, procedures, and guidance developed under § 50.54(hh)(2), and integration of offsite resources with onsite response. The licensee shall maintain a record of exercises conducted during each eight year exercise cycle that documents the content of scenarios used to comply with the requirements of this paragraph.

Each licensee shall conduct a hostile action exercise for each of its sites no later than December 31, 2015. The first eight-year exercise cycle for a site will begin in the calendar year in which the first hostile action exercise is conducted. For a site licensed under Part 52, the first eight-year exercise cycle begins in the calendar year of the initial exercise required by Section IV.F.2.a.

30

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Establishes requirements for initial IV.J., Drill Frequency - pg. 44 This is a COL-specific Use NEI 12-01 and 13-06 drills or exercises for applicants for requirement that omits Compliance Matrices Part 52 licenses. Other than timing, VI.,. Paragraph 50.155(e), Drills (b)(2) because no COL the requirements are the same as or exercises - pg. 129 holders have reevaluated those established under (e)(4) for hazards.

those that already hold licenses at the time the rule becomes effective Other than timing, the and have received their 52.103(g) requirements are the same finding (Commission permission to as those established under operate). (e)(4) for those that already hold licenses at the time Although NEI 13-06 does not the rule becomes effective.

specifically address its applicability for new plants, its intent in this regard is implied in the executive summary which states that the purpose of the document is to promote consistent implementation of the actions that address the Tier 2 EP enhancements discussed above.

The discussion being referred to addresses Order EA-12-049 and NEI 12-06, both of which are applicable to new plants.

Note that the rule does not extend to SAMGs 10 CFR 50.54(hh)(2) strategies, procedures, and guidance is replaced with 10 CFR 50.155 drill and exercise requirements 31

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance Part 50 App E, F.2.j., Training: The (3) Once the Commission issues an operating NEI 12-01, R0, Secs: 4.1.thru 4.11, exercises conducted under paragraph 2 of license to an entity described in paragraph communications during an extended this section by nuclear power reactor (e)(1) of this section or makes the finding loss of AC power licensees must provide the opportunity for under § 52.103(g) of this chapter for an the ERO to demonstrate proficiency in the entity described in paragraph (e)(2) of this NEI 13-06, R1, Executive Summary key skills necessary to implement the section, the licensee shall conduct principal functional areas of emergency subsequent drills or exercises that NEI 13-06, R1, Sec 5.3, recommended response identified in paragraph 2.b of this collectively demonstrate a capability to use actions for drills and exercises, section. Each exercise must provide the opportunity for the ERO to demonstrate at least one of the strategies and guidelines (excluding SAMG recommendations) key skills specific to emergency response in each of paragraphs (b)(1) and (b)(3) of this duties in the control room, TSC, OSC, EOF, section in succeeding 8-year intervals. The and joint information center. Additionally, drills or exercises performed to demonstrate in each eight calendar year exercise cycle, this capability must include transitions from nuclear power reactor licensees shall vary other procedures and guidelines as the content of scenarios during exercises applicable, including demonstration of the conducted under paragraph 2 of this associated communications capability. Each section to provide the opportunity for the licensee shall not exceed 8 years between ERO to demonstrate proficiency in the key any consecutive drills or exercises.

skills necessary to respond to the following scenario elements: hostile action directed at the plant site, no radiological release or an unplanned minimal radiological release that does not require public protective actions, an initial classification of or rapid escalation to a Site Area Emergency or General Emergency, implementation of strategies, procedures, and guidance developed under § 50.54(hh)(2), and integration of offsite resources with onsite response. The licensee shall maintain a record of exercises conducted during each eight year exercise cycle that documents the content of scenarios used to comply with the requirements of this paragraph.

Each licensee shall conduct a hostile action exercise for each of its sites no later than December 31, 2015. The first eight-year exercise cycle for a site will begin in the calendar year in which the first hostile action exercise is conducted. For a site licensed under Part 52, the first eight-year exercise cycle begins in the calendar year of the initial exercise required by Section IV.F.2.a 32

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Establishes requirements for initial VI., Paragraph 50.155(e), Drills Other than timing, the Use NEI 12-01 and 13-06 drills or exercises for applicants for or exercises - p 129 requirements are the same Compliance Matrices Part 52 licenses. Other than timing, as those established under the requirements are the same as (e)(4) for those that already those established under (e)(4) for hold licenses at the time those that already hold licenses at the rule becomes effective.

the time the rule becomes effective and have received their 52.103(g) finding (Commission permission to operate).

Although NEI 13-06 does not specifically address its applicability for new plants, its intent in this regard is implied in the executive summary which states that the purpose of the document is to promote consistent implementation of the actions that address the Tier 2 EP enhancements discussed above.

The discussion being referred to addresses Order EA-12-049 and NEI 12-06, both of which are applicable to new plants.

Note that the rule does not extend to SAMGs 33

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance Part 50 App E, F.2.j., Training: The (4) A holder of an operating license issued NEI 12-01, R0, Secs: 4.1.thru 4.11, exercises conducted under paragraph 2 of under this part [[or a combined license under communications during an extended this section by nuclear power reactor part 52 of this chapter for which the loss of AC power licensees must provide the opportunity for Commission has made the finding specified in the ERO to demonstrate proficiency in the § 52.103(g)]] as of [EFFECTIVE DATE OF THE NEI 13-06, R1, Sec 5.3, recommended key skills necessary to implement the FINAL RULE], shall conduct an initial drill or actions for drills and exercises principal functional areas of emergency exercise that demonstrates the capability to (excluding SAMG recommendations) response identified in paragraph 2.b of this transition to and use one or more of the section. Each exercise must provide the strategies and guidelines in either paragraph opportunity for the ERO to demonstrate (b)(1), (b)(2), or (b)(3) of this section, or for a key skills specific to emergency response combined license holder paragraphs (b)(1) duties in the control room, TSC, OSC, EOF, and (b)(3), including demonstration of the and joint information center. Additionally, associated communications capability

, by [DATE 4 YEARS AFTER EFFECTIVE DATE OF in each eight calendar year exercise cycle, THE FINAL RULE]. Following this initial drill or nuclear power reactor licensees shall vary exercise, the licensee shall conduct the content of scenarios during exercises subsequent drills, exercises, or both that conducted under paragraph 2 of this collectively demonstrate a capability to use at section to provide the opportunity for the least one of the strategies and guidelines ERO to demonstrate proficiency in the key under paragraph (b)(1) or (b)(2), and at least skills necessary to respond to the following one of the strategies and guidelines under scenario elements: hostile action directed paragraph (b)(3), or for combined license at the plant site, no radiological release or holders, in each paragraphs (b)(1) and (b)(3) an unplanned minimal radiological release of this section, in succeeding 8-year that does not require public protective intervals. The drills or exercises performed to actions, an initial classification of or rapid demonstrate this capability must include escalation to a Site Area Emergency or transitions from other procedures and General Emergency, implementation of guidelines as applicable, including strategies, procedures, and guidance demonstration of the associated developed under § 50.54(hh)(2), and communications capability. Each licensee shall integration of offsite resources with onsite not exceed 8 years between any consecutive response. The licensee shall maintain a drills or exercises.

record of exercises conducted during each eight year exercise cycle that documents the content of scenarios used to comply with the requirements of this paragraph.

Each licensee shall conduct a hostile action exercise for each of its sites no later than December 31, 2015. The first eight-year exercise cycle for a site will begin in the calendar year in which the first hostile action exercise is conducted. For a site licensed under Part 52, the first eight-year exercise cycle begins in the calendar year of the initial exercise required by Section IV.F.2.a 34

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Note that the rule does not extend V.B., Rulemaking Scope, Severe None for those that already Use NEI 12-01 and 13-06 to SAMGs as noted in the SOC on Accident Management Guideline hold Part 50 licenses at the Compliance Matrices page 56. and Multiple Source Term Dose time the rule becomes Assessment - pg. 56 effective.

VI., Paragraph 50.155(e), Drills or exercises - pg. 130 35

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance EA-12-051, Att. 2: (f) Spent fuel pool monitoring. In order to All licensees identified in Attachment 1 to support effective prioritization of event NEI 12-02, R1, Exec Summary.

this Order shall have a reliable indication of mitigation and recovery actions, each the water level in associated spent fuel licensee shall provide reliable means to NEI 12-02, R1,Section 2.3, Wide Range storage pools capable of supporting remotely monitor wide-range water level for Pool Level Instrumentation identification of the following pool water each spent fuel pool at its site until 5 years level conditions by trained personnel: (1) have elapsed since all of the fuel within that level that is adequate to support operation spent fuel pool was last used in a reactor of the normal fuel pool cooling system, (2) vessel for power generation. This provision level that is adequate to provide does not apply to General Electric Mark III substantial radiation shielding for a person upper containment pools.

standing on the spent fuel pool operating deck, and (3) level where fuel remains covered and actions to implement make-up water addition should no longer be deferred.

EA-12-063, Reliable Spent Fuel Pool Instrumentation SFPI Specific License Condition None (g) Documentation of changes. NEI 12-06, R4, Sec 11.8, Configuration (1) A licensee may make changes in the Control implementation of the requirements in this section without NRC approval, provided that before implementing each such change, the licensee demonstrates that the provisions of this section continue to be met and maintains documentation of changes until the requirements of this section no longer apply.

36

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance The Rule added a termination clause. IV.I., Spent Fuel Pool Decommissioning activities Include in decommissioning Instrumentation Requirements - plan Rule specifically excludes GE Mark III pg. 43 The 5-year limitation and upper containment pools. the exclusion of upper Previously this distinction was made IV.N.2., Comments that Suggest containment pools in the in the guidance (NEI 12-02) the NRC Revisit Issues Associated rule is essentially an exemption to cover these with SFP Safety - pg. 51 elements of the guidance Decommissioning requirements are that would otherwise result new. V.C., Decommissioning reactors in backfitting. See NEI 12-

- pg. 61 02, section 2.3.

V.C., Spent Fuel Pool Monitoring - pg. 96 VI., Paragraph 50.155(f), Spent fuel pool monitoring - pg. 131 None. IV.H., Change Control This is intended to be Refer to the NEI 12-06 Enhancements - pg. 39 consistent with the change revision comparison matrix control guidance in NEI 12-V.C., Documentation of 06. Section 155(g) applies Changes - pg. 97 change control NEI 06-12 (EDMG) does not requirements to the entire V!., Paragraph 50.155(g), contain change control rule, including EDMGs Documentation of changes - guidance, but licensees (155(b)(3)). Ensure that a pg. 131 may have specific specific change control requirements. The B.5.b process is in place for strategies relied on the EDMGs.

licensees regulatory commitment management program for control of the specifics. The rule requirement should be interpreted to mean that changes to EDMGs that are consistent with existing endorsed guidance may be made without prior NRC approval. For example, a licensee may change EDMG strategies to make them the same as FLEX strategies without prior NRC approval as long as all applicable requirements are met.

37

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance None (2) Changes in the implementation of None requirements in this section subject to other change control processes than paragraph (g) of this section must be processed via their respective change control processes, unless the changes being evaluated impact only the implementation of the requirements of this section.

None (h) Implementation. Unless otherwise None specified in this section:

(1) Each holder of an operating license for a nuclear power reactor under this part on

[INSERT EFFECTIVE DATE OF THE FINAL RULE]

and each holder of a combined license under part 52 of this chapter for which the Commission made the finding specified in § 52.103(g) as of [INSERT EFFECTIVE DATE OF THE FINAL RULE], shall continue to comply with the provisions of paragraph (b)(3) of this section, and shall comply with all other provisions of this section no later than

[INSERT DATE 3 YEARS AFTER EFFECTIVE DATE OF THE FINAL RULE] for licensees that received NRC Order EA-13-109 or [INSERT DATE 2 YEARS AFTER EFFECTIVE DATE OF THE FINAL RULE] for all other applicable licensees.

38

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance None. This is consistent with other V.C., Documentation of None Ensure configuration control change control processes. Changes - pg. 99 procedures properly handle the hand-off between VI., Paragraph 50.155(g), different change control Documentation of changes - p requirements dictated by 133 other regulations (e.g.,

50.59, 73.58, etc.).

Establishes rule compliance date for IV.G., Flexible Scheduling 10CFR50.155 must be Complete rule OLs issued for Licensees under Part Provisions and Cumulative Effects implemented within 2 years implementation within 3 50 and for COLs issued for Licensees of Regulation Feedback - pg. 34 (3 years for BWRs that years or request an under Part 52. received Order EA-12-109 - alternative compliance date.

V.C., Implementation - pg. 100 severe accident capable hardened vent order -

VI., Paragraph 50.155(h), applicable to BWRs with Implementation - pg. 134 Mark 1 or 2 containments) of its effective date unless delays caused by reevaluated hazards apply.

Note that the requirements for EDMGs in 50.155(b)(3) have merely been relocated from 50.54(hh)(2) and compliance must be maintained.

39

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance None (2) For licensees that cannot achieve None compliance with paragraph (b)(2) of this section to address a reevaluated hazard within the schedule of paragraph (h)(1) of this section, the NRC will consider an alternative compliance date if the licensee submits to the Director, Office of Nuclear Reactor Regulation, under § 50.4 of this part, no later than [INSERT DATE 90 DAYS AFTER THE EFFECTIVE DATE OF THE FINAL RULE], a request to revise the compliance date with good cause for not achieving compliance within the schedule of paragraph (h)(1) of this section. Unless the licensee is notified to the contrary, the submitted request to revise the compliance date will be regarded as approved by the Commission 120 days after submission to the Commission.

40

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Establishes flexible schedule of IV.G., Flexible Scheduling Determine if If implementation will be compliance for Licensees developing Provisions and Cumulative Effects implementation will be delayed because of external mitigation strategies to comply with of Regulation Feedback - pg. 34 delayed beyond 2 years (3 hazard evaluations, request paragraph (b)(2). years for BWRS with Mark an alternative compliance V.C., Implementation - pg. 100 1 or 2 containments) due date within 90 days of the to external hazard rule effective date.

VI., Paragraph 50.155(h), evaluations.

Implementation, p 135 41

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance None (i) Rescission of orders and removal of license None conditions.

(1) On [INSERT DATE 3 YEARS AFTER EFFECTIVE DATE OF THE FINAL RULE], Order EA-12-049, Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Order EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation, and Order EA-12-063, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, are rescinded for each licensee or construction permit holder that was issued those Orders.

(2) On [INSERT THE EFFECTIVE DATE OF THE FINAL RULE], Order EA-06-137, Order Modifying Licenses, is rescinded for each licensee that was issued Order EA-06-137.

(3) On [INSERT THE EFFECTIVE DATE OF THE FINAL RULE], the Mitigation Strategies License Condition is deemed removed from the power reactor license of each licensee subject to this section.

(4) On [INSERT THE EFFECTIVE DATE OF THE FINAL RULE], the license condition associated with Order EA-06-137 is deemed removed from the power reactor license of each applicable licensee subject to this section.

Licensee specific (5), (6), (7), (8) and (9) are licensee specific None rescission requirements applicable to:

Enrico Fermi Nuclear Plant Unit 3, Virgil C.

Summer Nuclear Station Units 2 and 3, and William States Lee South Texas Project Units 3 and 4, Levy Nuclear Plant Units 1 and 2 42

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance The rescission of the Orders 3 years V.C., Order Rescission and There are no known None after the effective date of the rule Removal of License Conditions - problems with this will make both the rule and the pg. 103 condition. The rule is Orders effective at the same time for intended to add the some licensees. VI., Paragraph 50.155(i), requirements in the Orders Rescission of orders and removal to the regulation without of license conditions - pg. 135 changing the requirements.

Rescission of the Order EA-06-137 is set at the effective date of the rule along with the removal of the Mitigation Strategies License Condition and the license condition associated with EA-06-137.

This matches up with the paragraph (h)(1) requirement for continued compliance with paragraph (b)(3) to avoid a regulatory gap.

Rescission of the Orders EA-12-049 and -051 is set at 3 years after the effective date of the rule to bound the implementation timing for BWRs that received EA-13-109 and have 3 years to achieve compliance with the rule.

The importance of this is that a licensee requesting a flexible schedule under paragraph (h)(2) would need to address the issue of avoiding regulatory gaps as part of the good cause justifying the flexible schedule.

None None None Nothing generic.

43

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance App E, IV.F.2.j Appendix E to Part 50Emergency Planning and None The exercises conducted under paragraph 2 of Preparedness for Production and Utilization this section by nuclear power reactor licensees Facilities:

must provide the opportunity for the ERO to IV.F.2.j. The exercises conducted under paragraph demonstrate proficiency in the key skills 2 of this section by nuclear power reactor necessary to implement the principal functional licensees must provide the opportunity for the areas of emergency response identified in ERO to demonstrate proficiency in the key skills paragraph 2.b of this section. Each exercise necessary to implement the principal functional m u s t provide the opportunity for the ERO to areas of emergency response identified in demonstrate key skills specific to emergency paragraph 2.b of this section. Each exercise must response duties in the control room, TSC, OSC, provide the opportunity for the ERO to EOF, and joint information center. Additionally, demonstrate key skills specific to emergency in each eight calendar year exercise cycle, response duties in the control room, TSC, OSC, nuclear power reactor licensees shall vary the EOF, and joint information center. Additionally, in content of scenarios during exercises conducted each 8-calendar-year exercise cycle, nuclear under paragraph 2 of this section to provide the power reactor licensees shall vary the content of opportunity for the ERO to demonstrate scenarios during exercises conducted under proficiency in the key skills necessary to respond paragraph 2 of this section to provide the to the following scenario elements: hostile opportunity for the ERO to demonstrate action directed at the plant site, no radiological proficiency in the key skills necessary to respond release or an unplanned minimal radiological to the following scenario elements: hostile action release that does not require public protective directed at the plant site, no radiological release actions, an initial classification of or rapid or an unplanned minimal radiological release that escalation to a Site Area Emergency or General does not require public protective actions, an Emergency, implementation of strategies, initial classification of or rapid escalation to a Site procedures, and guidance developed under § Area Emergency or General Emergency, and 50.54(hh)(2), and integration of offsite integration of offsite resources with onsite resources with onsite response. The licensee response. The licensee shall maintain a record of shall maintain a record of exercises conducted exercises conducted during each 8-year exercise during each eight year exercise cycle that cycle that documents the content of scenarios documents the content of scenarios used to used to comply with the requirements of this comply with the requirements of this paragraph. paragraph. Each licensee shall conduct a hostile Each licensee shall conduct a hostile action action exercise for each of its sites no later than exercise for each of its sites no later than December 31, 2015. The first 8-year exercise cycle December 31, 2015. The first eight-year exercise for a site will begin in the calendar year in which cycle for a site will begin in the calendar year in the first hostile action exercise is conducted. For a which the first hostile action exercise is site licensed under 10 CFR part 52, the first 8-year conducted. For a site licensed under Part 52, the exercise cycle begins in the calendar year of the first eight-year exercise cycle begins in the initial exercise required by section IV.F.2.a of this calendar year of the initial exercise required by appendix.

Section IV.F.2.a.

App E, VI.3.c VI.3.c. In the event of a failure of NRC- None In the event of a failure of the NRC supplied equipment; a replacement will be s u p p l i e d onsite modem, a replacement furnished by the NRC for licensee installation.

unit will be furnished by the NRC for licensee installation.

44

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Removed reference to 50.54(hh)(2). V.B.2 & V.B.3, Rulemaking Required minimum Use the NEI 13-06 This regulation was moved to Scope - pg. 55 performance for this was Compliance Matrix 155(b)(3), and the associated drill reduced from an element requirement was moved to 10 CFR of the evaluated exercise 50.155(e) VI., 10 CFR Part 50, Appendix E, program to a drill.

Section IV, Training - pg. 137 Generalized modem to V.C., Technology-Neutral None None equipment. This change has no Emergency Response Data effect on licensees. System - pg. 107 VI., 10 CFR Part 50, Appendix E, Section VI, Emergency Response Data Systems - pg. 137 45

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance 10 CFR 50.34(i) 10 CFR 50.34(i) None (i) A description and plans for (i) Mitigation of beyond-design-basis implementation of the guidance and events. Each applicant for a power reactor strategies intended to maintain or restore operating license under this part must core cooling, containment, and spent fuel include the applicants plans for pool cooling capabilities under the implementing the requirements of § circumstances associated with the loss of 50.155, including a schedule for achieving large areas of the plant due to explosions or full compliance with these requirements.

fire as required by § 50.54(hh)(2) of this chapter. The application must also include a description of:

(1) The integrated response capability required by § 50.155(b); and (2) The equipment upon which the strategies and guidelines required by § 50.155(b)(1) rely, including the planned locations of the equipment and how the equipment meets the requirements of § 50.155(c).

§ 52.80 Contents of applications; additional 10 CFR 52.80(d) technical information.

A description and plans for implementation of the guidance and (d) The applicants plans for implementing strategies intended to maintain or restore the requirements of § 50.155 of this chapter core cooling, containment, and spent fuel including a schedule for achieving full pool cooling capabilities under the compliance with these requirements, and a circumstances associated with the loss of description of: (1) The integrated response large areas of the plant due to explosions capability required by § 50.155(b) of this or fire as required by § 50.54(hh)(2) of this chapter; and (2) The equipment upon which chapter.

the strategies and guidelines required by § 50.155(b)(1) of this chapter rely, including the planned locations of the equipment and how the equipment meets the requirements of § 50.155(c) of this chapter.

Other rulemaking documents: Statements of Consideration / Reg Analysis None None NEI 13-06, R1, Sec 2.3.1, Industry Performance Standard for Multi-Unit Dose Assessment 46

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance Replaced reference to EDMGs with VI., § 50.34 Contents of None None one to the new rule on mitigating Applications; Additional Technical strategies, which includes the EDMG Information - pg. 109 requirement in 50.155.(b)(3)

VI., § 52.80 Contents of Applications; Additional Technical Information - pg. 137 Other rulemaking documents: Statements of Consideration / Reg Analysis The rule does not include a IV.E. Multiple Source Term Dose The decision to not Ensure that the site-specific requirement for multi-release point Assessment, p 28 include Multiple Release commitment to perform dose assessment capability, Point Dose Assessments multiple -release point dose although inclusion of requirements V.B., Rule-making Scope," was made in some part assessments is maintained.

in this area was considered during -pg. 56 based upon completion the rule making process. of the regulatory Develop standardized commitments for all language for a commitment operating power reactor to multiple release point licensees.

dose assessment Use NEI 13-06 Compliance Matrix 47

June 8, 17 NEI 17-03, [Rev A]

Previous NRC Requirement 10CFR50.155 Requirements Associated Current Industry Guidance None None NEI 14-01, R1, secs 1, Introduction, and 3, Requirements For SAMGs And Supporting Guidelines 48

June 8, 17 NEI 17-03, [Rev A]

Delta between 50.155 and previous SOC (ML16292A026) Reference Impact/ Interpretation Action requirements / current guidance The rule does not include SAMG V.B ., Rule-making Scope, p - 56 Reg Analysis, section 2.3 Ensure that the NSIAC requirements. states: The Commission Initiative on SAMGs is V.C ., Command and Control - p concluded that the maintained.

However, in November 2015 the NEI 87 imposition of SAMG Nuclear Strategic Issues Advisory requirements was not Use NEI 14-01 Gap Analysis Committee (NSIAC) approved an warranted because it did Matrix not meet the substantial Industry Initiative on SAMGs that additional protection requires each licensee to docket site-criteria under 10 CFR specific commitments concerning the 50.109(a)(3). Consequently, updating these guidelines, and their this regulatory analysis does consideration within plant not further evaluate configuration management SAMGs as proposed processes, integration with other requirements in the final emergency response guideline sets MBDBE Rule. Instead, and symptom-based EOPs, and SAMGs will continue to be validation. implemented and maintained through a Every utility with a part 50 license voluntary industry initiative sent a letter to the NRC in late 2015 as discussed in SRM-SECY-documenting their commitment to 0065 and in Option 1.

the Initiative.

Note that SRM-SECY 065 included direction that Note that the Commissions Order SAMG oversight be related to North Anna 3s COL (CLI- included in the ROP: The 17-08) contains relevant staff should update the information pertaining to their Reactor Oversight Process views on SAMG implementation for to explicitly provide Part 52 licensees. periodic oversight of industry's implementation of the SAMGs. NRC guidance should clarify how deviations or performance deficiencies would be addressed.

49

June 8, 17 NEI 17-03, [Rev A]

7 NEI 12-06 REVISION COMPARISON Introduction NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, has evolved over time from its initial issuance as the industry guidance document to implement the requirements of Order EA-12-049 to the current revision as the industry guidance document for implementation of 10 CFR 50.155. Individual licensee stations implemented and achieved compliance with Order EA-12-049 at different points in time and were not always consistent in site specific adoption of endorsed white papers or FAQs. The NEI 12-06 Revision C o m p a r i s o n provides section-by-section identification of changes in NEI 12-06 to support the users effective and efficient identification of gaps for their resolution during implementation of 10 CFR 50.155. The information captured in the Impact/Interpretation and Action columns is based upon an assumption that NEI 12-06 Revision 4 will be used for implementation of 10 CFR 50.155.

The NEI 12-06 Revision Comparison Matrix identifies changes in each section of the following endorsed revisions;

• NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012

• NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 2, December 2015

• NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 4, December 2016 Changes in other versions of NEI 12-06 including the not-endorsed Revision 1 and Revision 3 are not specifically captured in the matrices. As such, the changes from Revision 1 are contained in the R-2 Change column unless the Revision 1 change was further altered or removed by the Revision 2 change. Similarly, the Revision 3 changes are contained in the R-4 change column. NEI 12-06 Sections with no changes from Revision 0 through Revision 4 are not listed in the Matrix. NEI 12-06 changes to format or spelling such as changing n to N or renumbering of footnotes are not shown.

The FLEX Strategy Validation Revision Comparison is provided in a separate matrix to accommodate the initial guidance being a white paper in lieu of being included in NEI 12-06, Revision 0. This supplemental Matrix provides a table showing the significant changes made in the published versions of;

• NEI FLEX Validation Process White Paper, Attachment to APC 14-17, July 18, 2014

• NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 2, December 2015, Appendix E

• NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 4, December 2016, Appendix E An explanation of the information provided in each column of the matrix follows:

• Section - Provides the NEI 12-06 Section number and title.

• R-2 Change - Provides changes in text of NEI 12-06 between revision 0 and revision 2. Intermediary changes from NEI 12-06 revision 1 are not included.

• R-4 Change - Provides changes in text of NEI 12-06 between revision 2 and revision 4. Intermediary changes from NEI 12-06 revision 3 are not included.

50

June 8, 17 NEI 17-03, [Rev A]

June 8, 17 NEI 17-03, [Rev A]

• Impact/Interpretation - Provides additional thoughts on the impact or interpretation of the change in the guidance. Also provides potential areas where a reduction in the as-implemented FLEX Program could be available depending on individual station implementation.

• Action - Captures likely actions for resolution in the transition from initial Order implementation to achieve MBDBE Rule compliance (at NEI 12-06 Revision 4).

Notations are included in individual change cells to provide cross-reference to FLEX FAQs that have been incorporated or are related to the topic of the guidance section.

Notations are also included in individual change cells to provide a cross-reference to clarifications provided within the endorsement documents;

• JLD-ISG-2012-01, Revision 0, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, August 29, 2012, ML12229A174 {Endorsement of NEI 12-06 Revision 0)

• JLD-ISG-2012-01, Revision 1, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, January 22, 2016, ML15357A163 {Endorsement of NEI 12-06, Revision 2 with clarifications}

• JLD-ISG-2012-01, Revision 2, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, February 2017, ML17005A188 {Endorsement of NEI 12-06, Revision 4 with clarifications}

NEI FLEX FAQ Disposition Table provides a cross-reference to NEI 12-06 Section where the information was incorporated. This table is provided as an aide to the user of the NEI 12-06 Revision Comparison Matrix.

FAQ references that were incorporated into NEI 12-06 sections are included in individual Matrix cells and related FAQ references are also provided. These Incorporated FAQs and/or Related FAQs can be referenced to provide additional insights on the topic and its resolution.

Note that in all cases, it is the responsibility of every licensee to examine its licensing bases and determine what additional actions may be necessary to achieve full compliance with 10 CFR 50.155 including determination of the revision level of the implementing guidance.

Summary of Major Gap Assessments/Recommended Actions The major gaps/recommended actions in the NEI 12-06 Revision Comparison Matrix include;

• Validation Requirements including providing a basis for time sensitive actions performed more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the initiation of the event. (Section 3.2.1.7 and Appendix E)

• Incorporation by reference of several supplemental guidance documents. (Section 3.2.1.13)

• Clarification on minimum quantities of hoses and cables to be maintained allowing for potential reduction in equipment. (Section 3.2.2)

• Clarification on minimum Spent Fuel Pool Cooling Strategy spray requirements allowing for potential reduction in equipment. (Table 3-1, 3-2 and Appendix C, D)

• Clarifications on alternate locations for instrument readings. (Section 5.3.3)

• Clarifications to support using existing station processes to manage maintenance and testing. (Section 11.5.2)

• Clarifications to support managing out of service time including separating functional from protected 51

June 8, 17 NEI 17-03, [Rev A]

and using station corrective actions and work control processes. (Section 11.5.3)

• Clarification on Configuration Control to support long term sustainability of FLEX Program including FLEX Strategy change management. (Section 11.8)

• Removal of recommendation to maintain Final Integrated Plan (FIP) as a living document. (Section 13.2)

• Addition of the reevaluated flooding hazard and seismic hazard for determining the adequacy of the FLEX Strategies. (Appendix G and Appendix H)

USER NOTES Due to the large size of this matrix, it has been formatted to extend across two adjacent facing pages.

Matrix provides description of changes in the progression of the revisions of NEI 12-06.

The User enters in the left side column for each row that corresponds to their currently implemented FLEX Mitigating Strategies NEI revision level as well as adoption of endorsed white papers and FAQs. Then, using the information on the changes in each revision of NEI 12-06 and moving to the right, the user identifies the impact to their FLEX Mitigating Strategies and actions needed to close the gap in support of 10 CFR 50.155 implementation aligned with NEI 12-06 Revision 4. The gaps, impact and actions can be used to assist with the decision of whether to adopt a newer revision, or to develop a justification for use of an older revision.

For example if a stations FLEX Mitigating Strategies were implemented using NEI 12-06 Revision 0, the aggregate of the changes in columns R-2 Change and R-4 Changes have the potential to impact the FLEX Mitigating Strategies in achieving compliance with NEI 12-06, Revision 4 and the MBDBE. Potential impacts could be only administrative for the change in revision of the NEI 12-06 with no change in requirements, or no change in the net requirements between Revision 0 and Revision 4. Additionally, the potential impact could be none if the clarifications incorporated into NEI 12-06 are consistent or not more restrictive as adopted in site-specific FLEX implementation.

Also see Section 3.0, General Matrix Usage, for general usage information.

52

June 8, 17 NEI 17-03, [Rev A]

53

June 8, 17 NEI 17-03, [Rev A]

NEI 12-06 Section R-2 Change R-4 Change Revision 0, Date August 2012 to Revision 2 Cover Page Revision 4, December 2016 December 2015 Added Revision Table Lists Description of Major Changes from Rev 2 to Rev 4 and footnote that Rev 4 superseded Rev 3.

Section 11.5 Revision Table No Change Section 11.6 Section 13.2 Tables C-3 & D-3 Appendix H - Section H.4.3 Appendix H - Section H.4.5 Updated to align with titles and numbering Updated to align with titles and numbering within body of document. within body of document.

Updated to align with titles and numbering Added Executive Summary, changed within body of document.

Section 13 from submittal guidance to Table of Contents documentation and deleted status reports Added Revision Summary and deleted from this section. Utilized Appendix E Executive Summary.

placeholder for validation guidance, Added Appendices G and H for flooding and Added numbering to already existing seismic MSAs. Minor format changes.

paragraphs in numerous locations.

Clarified that while guidance addresses event caused by BDBEE, the strategies may 1: Introduction be applied as directed regardless of cause. No Change Incorporated the answer to FAQ 2014-01 into Section 1 and Section 11.4.1.

Changed containment integrity to just containment. Replaced portable equipment with plant and FLEX 1.1: Background equipment, and clarified that FLEX No Change equipment may be stored near the plant site. Removed the phrase that FLEX equipment would be staged 54

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Update FLEX governing documents if FLEX Program and supporting document impact changing NEI 12-06 Revision level for FLEX mitigating strategies compliance.

Editorial None Editorial None Clarification None (Additional detail provided in Section 11.4)

Clarification None 55

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Added that R2 also addresses approaches for addressing reevaluated flood and 1.2: Purpose seismic hazard information and aligns with No Change Mitigating Beyond-Design-Basis Events rulemaking.

Clarifying wording changes in first paragraph to address an ELAP concurrent Replaced installed plant equipment with with a LUHS.

just plant equipment. Combined on-site portable equipment and pre-staged off-site resources as FLEX equipment.

Replaced Transition from installed plant 1.3: FLEX Objectives equipment to on-site FLEX equipment.

and Guiding With Augment or transition from plant Principles equipment to on-site FLEX equipment and consumables to maintain or restore key functions. for phase 2 approach Identified that FLEX coordination with SAMGs is addressed in NEI 14-01.

BWR MK I and II may utilize vent capability order EA-13-109 for anticipatory venting to meet the requirements of mitigating strategies rather than requiring reliable 1.4: Relationship to Last sentence changed from will be hardened vents under EA-12-050.

Other Tier 1 included as Appendix H to is included Requirements in Appendix H Added a paragraph addressing reevaluated flood and seismic hazard information point to new Appendix G and H for mitigating strategies assessment Subsection number & title added.

Deleted reference to tables in EA-12-049 1.5: Applicability No Change along with Tables 1-1 and 1-2 which were copies of attachments 2 and 3 of order.

56

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action None Clarification MSA related changes are addressed in Appendices G and H.

None Clarification & Editorial See NEI 14-01 Compliance Matrix for details.

Clarification None Editorial None 57

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Remove containment as being more challenging from at power conditions Relocated discussion that FLEX strategies are not explicitly designed for outage conditions due to small fraction of cycle in outage is relocated to new section 3.2.3.

Deleted/relocated bullets referring to 2: Overview of primary and alternate connection point Implementation No Change providing higher reliability, and requiring Process makeup flow rates and sizing of connections to support outage conditions Deleted paragraph stated that 50.54(hh)(2) equipment may be used for FLEX but must still meet NEI 06-12.

Deleted statement that NEI 12-06 will be changed to address specific application of FLEX to other reactor designs.

Provided clarification by combining various equipment categories into plant equipment 2.1: Establishing and FLEX equipment.

Baseline Coping No Change Capability Deleted third bullet referring to enhancement of capabilities deployed under 50.54(hh)(2)

Added that aggregate of FLEX considerations is discussed in Section 10 2.2: Determine The guidance from the endorsed white Applicable Extreme No Change paper and the subsequent FAQ 2013-10 External Hazards was incorporated into a new Section 3.2.3 and the previous guidance in Section 2 was deleted.

Minor clarification of storage requirement 2.3, Define Site- applicability to on-site FLEX equipment.

Specific FLEX No Change Deleted The process for defining the full Strategies extent of the FLEX coping capability is described in Section 10.

58

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification & Editorial None Clarifications None Editorial None Clarification & Editorial None 59

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change 2.4: Programmatic Clarified that storage requirements apply to No Change Controls on-site Flex Equipment 2.5: Synchronization Change off-site equipment to offsite with Off-Site No Change FLEX equipment.

Resources Changes consistent with terminology plant 3, Step 1: Establish equipment and FLEX equipment.

Baseline Coping Deleted installed, portable, on-site and off- No Change Capability site as descriptions of equipment used in FLEX strategies.

Replaced reference to 50.54(hh)(2) with 3.1: Purpose more general term of loss of large areas No Change (LOLA) of the plant 3.2: Performance Changed installed equipment to plant No Change Attributes equipment.

3.2.1.1: General Deleted example of MAAP analysis for No Change Criteria BWR.

Added that the minimum conditions for plant equipment operability or functionality does not need to be assumed provided 3.2.1.2: Initial Plant adequate basis for assumed value. No Change Conditions Provided CST level example.

FAQ 2012-08 Footnote renumbered with no Clarified that installed AC sources means change in wording design basis installed sources. Also added that AC power from batteries via inverters NOTE:

remains available. Added footnote, JLD-ISG-2012-01 R 2 Section 1.2 provides reference to 10 CFR 50.2. clarification for ELAP vs. loss of all AC 3.2.1.3: Initial power.

Conditions Replaced seismic events, floods, high winds and missiles with applicable hazard. Footnote renumbered with no Added footnote, equipment only needs change in wording to be robust for the hazards for which it is relied on for mitigation in 3.2.1.3.3.

60

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification None Clarification None Clarification None Editorial None Clarification None Editorial None Clarification If minimum values were used within plants FLEX Confirm basis for assumed values is Strategy, it is likely to be conservative in lieu of captured in Program Documents.

administratively controlled values.

Basis of assumed values to be documented.

Clarification to differentiate that FLEX installed generators which are not assumed to be lost as part of ELAP.

ELAP is assumed as the initial condition for timing None and sequence of initial response actions.

Contingency procedures such as black start of RCIC and AFW and alternate instrument readings address the loss of all AC power.

Clarification that relaxed guidance in R 0 to make None more reasonable for site specific application.

61

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Clarified that loss motive force with no prospect for recovery applies to Service or circulating water pumps. Fire or other pumps may be [considered] available No Change provided they are robust for the applicable hazard(s) in 3.2.1.3.4.

FAQ 2012-07 and FAQ 2013-04 Fuel supplies, plant equipment and fire ring header as a water source remains available if stored in structures robust for applicable No Change hazards in 3.1.2.3.5.

3.2.1.3: Initial Replaced permanent plant equipment Conditions with plant equipment.

(Continued)

Replaced seismic events, floods, high No Change winds, and missiles with applicable hazard (s) in 3.2.1.3.6.

Related FAQ-2012-018 Replaced 50.54(hh)(2) equipment with loss of large area (LOLA) equipment and may be No Change used as on-site FLEX equipment in 3.2.1.3.7.

Clarified that the fire header may be considered available for any event for which it is robust. Previously this section was worded that the fire header could only No Change be assumed to be available if it was robust for all events in 3.2.1.3.10.

FAQ 2012-16 62

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification to address accepted alternative approaches to guidance in NEI 12-06 R0. While these Alternate Approaches were accepted by the NRC and docketed as Alternate Approaches to NEI 12-06 Rev 0 guidance. They are no longer classified as Potential update to FIP and/or program Alternate Approaches to the guidance in later document revisions of NEI 12-06 and are now recognized and endorsed as approved methods of the guidance.

There is no technical change, however, since the FIPs and/or program document may still refer to these as Alternate Approaches, these may require revision.

Clarification None Clarification None Editorial None Clarification None 63

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Changed installed plant equipment to plant equipment.

Added Augment" to to transition from No Change plant equipment."

3.2.1.7: Event Response Actions Note: JLD-ISG-2012-01 R2 provides Added consumables to maintain or restore clarification on Validation.

key functions.

Changed on-site FLEX equipment to FLEX equipment 3.2.1.12: Changed installed plant equipment to Qualification of Plant plant equipment and changed No Change Equipment equipment to plant equipment.

A new Section has been added providing a table of additional supplemental guidance documents (e.g., NRC endorsed position papers) containing methodologies that may 3.2.1.13: FLEX be used for various topics.

Analysis, No Change Methodologies and Note:

Generic Topics Previously NEI 12-06 called for site specific analyses but did not address methods. In the course of implementation of the Order certain analytical criteria or methods were developed and endorsed.

Changed installed plant equipment to No Change plant equipment.

3.2.2: Minimum Added Augment or to transition from No Change Baseline Capabilities plant equipment Added consumables to maintain or restore No Change key functions 64

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification adding details JLD-ISG-2012-01 R 2 points out that NEI 12-06 R 4 The Validation guidance used may not Section 3.2.1.7.6 requires Strategies that have a have required validation of actions time constraint to be successful should be identified performed >24 hours after the event.

and a basis provided that the time can reasonably Based on current guidance, review FIP be met. The ISG discusses the use of Level A or B timeline to verify time sensitive actions validation as a method to address the reasonably required >24 hours after the event were met criteria for those tasks expected to be validated or a basis provided that the performed >24 hours after the initiation of the event time can be reasonably met. Validation that have a time constraint. NEI 12-06 Appendix E or some other basis may need to be step E.5.1.2 states in part tasks performed greater provided for those that were not time than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the event will not be time validated using a Level A or B validation validated.

process.

(Additional information on Validation provided in Appendix E)

Clarification None Potential update to FIP and/or program This change formally incorporates all the industry document white papers and technical papers into the NEI 12-06 guidance. Many licensee strategies adopted the Implementation of change control will white papers and docketed this information, the vary dependent upon which revision of current FIPs and/or program document may refer to NEI 12-06 is being adopted. If NEI 12-these as white papers and not formal guidance of 06 R2 or R4 is adopted that NEI 12-06. There is no technical change in the incorporates the white paper the individual white paper content, however, since the content of the white paper is no longer FIPs and/or program document may still refer to an alternate approach that requires these positions as white papers, these may require additional evaluation of applicability to revision. facility.

Clarification None Clarification None Clarification None 65

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Changed equipment to plant No Change equipment in 3.2.2.13 &

3.2.2.15.

Changed equipment to plant or FLEX equipment, changed portable pump to pump, and changed portable lighting to lighting In 3.2.2.3, 3.2.2.5, 3.2.2.6, 3.2.2.8, 3.2.2.12 &3.2.2.13.

No Change Added provision that a heat transfer analysis is not required when crediting an alternate makeup water (raw water) source provided there is guidance to transition to a more preferable water source as soon as is 3.2.2: Minimum practical in 3.2.2.5. FAQ 2013-11 Baseline Capabilities (Continued)

Replaced portable pumps with FLEX equipment to provide makeup No Change in 3.2.2.13, 3.2.2.15, 3 . 2 . 2 . 1 6 & 3 . 2 . 2 . 1 7 FAQ 2013-06 Added paragraph saying the sizing of SFP makeup should be based on maximum design heat load. However, for the purposes of determining the response time No Change for the SFP strategies when makeup is required, may use worst case heat load assuming plant is at power, i.e., fuel is in the reactor vessel in 3.2.2.14. FAQ 2013-05 Changed containment integrity to No Change containment function, changed coping equipment to FLEX equipment in 3.2.2.15.

Moved the N+1 discussion that was after No Change 3.2.2.15 into its own Section 3.2.2.16 66

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification None Clarification This section incorporates the NRC endorsed industry Alternate Approaches to R 0 guidance. While these Alternate Approaches were accepted by the Potential update to FIP and/or program NRC and docketed as Alternate Approaches to NEI document 12-06 R0 guidance. They are no longer classified as Alternate Approaches to the guidance and are Implementation of change control will now recognized and endorsed as approved methods vary dependent upon which revision of of the NEI 12-06 later revision guidance.

NEI 12-06 is being adopted. If NEI 12-There is no technical change, however, since the FIPs 06 R2 or R4 is adopted that and/or program document may still refer to these as incorporates the white paper the Alternate Approaches, these may require revision.

content of the white paper is no longer an alternate approach that requires Clarification, FAQ 2013-11 was incorporated to additional evaluation of applicability to address use of raw water sources.

facility.

Clarification None Clarification None Clarification None Editorial None 67

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Deleted three sets of hose and cable from N+1 discussion and included the requirements and methods, with examples, No Change to meet +1 for hoses and cables.

Incorporated Generic Topic Hoses and Cables as listed in 3.2.1.16.

3.2.2: Minimum Moved the primary and alternate Baseline Capabilities discussion that was after 3.2.2.15 into its (Continued) own in 3.2.2.17. Added an example of a No Change primary and alternate connection point for electrical diversity from FAQ 2012-09 Added clarification that if separate strategies are used, the two strategies do not each need a primary and alternate No Change connection point provided the connection points for the two strategies are separate in 3.2.2.17 New section for Shutdown Modes. In addition to referring to shutdown Safety Assessment, this section includes specific Inserted and at end of third bullet in list.

considerations and provisions. This new 3.2.3: Shutdown section is consistent with the Generic Topic Modes Shutdown/Refueling Modes as listed in Section 3.2.1.13.

FAQ-2013-10 68

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification None Potential reduction in equipment requirements.

Editorial None Clarification Clarification None Clarification Potential update to FIP and/or program Incorporation of Industry white paper into NEI 12-06 document may impact FIP/program document references.

69

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Changed installed and portable equipment to plant and FLEX equipment consistent with other sections.

Removed reference to Order EA-12-050 for containment heat removal.

No Change Removed Spray via portable nozzles from Table 3-1: BWR FLEX SFP cooling. While this section of NEI 12-06 did not Baseline Capability change in R 4, Tables C-3 and C-4 were Summary NOTE: See JLD-ISG-2012-01 R1, revised to include the conditions for Section 1.1.d) provides conditions for eliminating the SFP spray cooling capability elimination of the SFP spray cooling contained in JLD-ISG-2012-01 R 1.

capability as described in Tables C-3 and D-3.

Replaced Per EA-12-051 with Wide-range spent fuel pool level instruments for SFP parameters Changed installed and portable equipment to plant and FLEX equipment consistent with other sections.

Removed reference to Order EA-12-050 for containment heat removal.

No Change Removed Spray via portable nozzles from Table 3-2, PWR FLEX SFP cooling. While this section of NEI 12-06 did not Baseline Capability change in R4, Tables C-3 and C-4 were Summary NOTE: See JLD-ISG-2012-01 R1, revised to include the conditions for Section 1.1.d) provides conditions for eliminating the SFP spray cooling capability elimination of the SFP spray cooling contained in JLD-ISG-2012-01 R1.

capability as described in Tables C-3 and D-3.

Replaced Per EA-12-051 with Wide-range spent fuel pool level instruments for SFP parameters 70

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarifications Potential reduction in equipment requirements in the None SFP cooling strategy if conditions from JLD-ISG-2012-01 R1 or NEI 12-06 R4 are met.

Clarifications Potential reduction in equipment requirements in the None SFP cooling strategy if conditions from JLD-ISG-2012-01 R1 or NEI 12-06 R4 are met.

71

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Changed equipment to FLEX equipment and off-site FLEX equipment Added that FLEX strategies and/or 3.3: Considerations resources do not need to be explicitly in Utilizing Off-site No Change planned for period beyond 72 hrs. FAQ Resources 2013-12 Deleted reference to Section 12 for a list of possible off-site [FLEX] equipment.

Clarified that protection is such that no one event causes failure of FLEX capability (N) 5.3.1: Protection of No Change FLEX Equipment Changed portable FLEX equipment to FLEX equipment.

5.3.1.2: Protection of Deleted portable for FLEX equipment No Change FLEX Equipment Rearranged some information and added guidance that location of reading should not rely on functioning of intervening electrical equipment e.g., converters, or relays. Added guidance that the reading should be obtained at the closest accessible 5.3.3: Procedural termination point to the containment No Change Interfaces penetration or parameter of measurement, as practical.

FFAQ 2014-01 (FAQ system was changed and FLEX FAQs became FFAQs so there is a FAQ 2014-01 and a FFAQ 2014-01) 6.1: Relationship to Revised to impact on safe shutdown Loss of AC Power No Change equipment.

and Loss of UHS 72

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarifications None Clarifications None Clarification None Review strategy to ensure that location of reading should not rely on functioning of intervening electrical equipment e.g.,

Clarification on alternate location for taking readings converters, or relays and that the reading for instruments should be obtained at the closest accessible termination point to the containment penetration or parameter o f measurement, as practical.

Clarification None 73

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Added expectation that if warning time is 6.2.2: credited, an evaluation of the adequacy Characterization of include warning time triggers and No Change the Applicable Flood implementation of actions/strategies.

Hazard Related FAQ-2012-13 Clarified that protection is such that no one event causes failure of FLEX capability (N)

Changed most recent site flood analysis 6.2.3.1: Protection of No Change to most recent design basis site flood FLEX Equipment analysis.

Changed portable pump, portable 6.2.3.2: Deployment equipment and portable pumps and power No Change of FLEX Equipment supplies to FLEX pump and FLEX equipment consistent with other sections.

7.1: Relationship to Revised to impact on safe shutdown Loss of AC Power & No Change equipment.

Loss of UHS 7.2.2:

Characterization of Changed pre-staging of equipment to No Change the Applicable High pre-staging of FLEX equipment.

Wind Hazard 74

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action New requirement.

If warning time is credited, the evaluation of the Review use of warning times in timelines adequacy of warning time includes review of the to ensure topic is incorporated in flooding event and warning time triggers needed to FIP/Program Documents.

implement any flood protection or mitigating strategies.

Clarification None Clarification None Clarification None Clarification None 75

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Recognizes that use of a combination of configurations may be used to protect FLEX equipment. Clarified that protection is No Change such that no one event causes failure of FLEX capability (N).

Changed structure to structure or structures to recognize that multiple No Change structures may be utilized to protect FLEX equipment.

Added when using load combination in ASCE 7-10, should use wind speeds from RG 1.76 R1 in combinations required 7.3.1: Protection of consistent with the Standard Review Plan FLEX Equipment and other safety-related applications (i.e., No Change wind speed by factor of 1.0).

FAQ 2012-12 Related FAQ 2012-14 Added clarification that the axis of separation applies to the structure No Change locations Added that tornado widths from NOAA 1950-2011 should be considered as the minimum separation distance for which No Change further analysis is not required to justify.

Related FAQ 2013-01 Added clarification that separation is not an acceptable reasonable protection method for hurricanes unless the separated structures are built to withstand hurricane No Change winds in which case the separation may be credited for tornado events.

FAQ 2013-02 76

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification to address accepted alternate Potential update to FIP and/or program approaches to guidance in NEI 12-06 R 0. While these document Alternate Approaches were accepted by the NRC and docketed as Alternate Approaches to NEI 12-06 Implementation of change control will R 0 guidance. They are no longer classified as vary dependent upon which revision of Alternate Approaches to the guidance in NEI 12-06 NEI 12-06 is being adopted. If NEI 12-R2 & R4 and are now recognized and endorsed as 06 R2 or R4 is adopted that approved methods of the NEI 12-06 later revision incorporates the white paper the guidance. There is no technical change, however, content of the white paper is no longer since the FIPs and/or program document may still an alternate approach that requires refer to these as Alternate Approaches, these may additional evaluation of applicability to require revision. facility.

Clarification None Clarification incorporating FAQ Potential update to FIP and/or program Incorporation of FAQ into NEI 12-06 may impact document FIP/program document references.

Clarification None Clarification None Clarification None 77

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Added note explaining that separation distance may be applied to non-robust plant equipment (e.g., to CSTs separated by No Change distance that are not robust for tornado missiles).

As it pertains to wind protection, added if (N) equipment is stored in a robust No Change 7.3.1: Protection of building, +1 equipment may be stored in a FLEX Equipment non-robust building.

(continued) Added multiple examples in a new section containing various possible configurations No Change for adequate wind protection. FAQ 2013-07 7.3.2: Deployment of Changed portable pumps to FLEX No Change FLEX Equipment pumps consistent with other sections.

Change portable equipment to FLEX No Change equipment consistent with other sections.

Changed stored in one of two 8.3.1: Protection of configurations to one or more of the FLEX Equipment following configurations No Change Clarified that N+1 applies to a set of equipment.

Clarified that high temperature evaluations are for FLEX equipment (storage, deployment, & operation) and not plant equipment.

9.2: Approach to Clarified that all sites will address impact of Extreme High high temperatures by changing sites No Change Temperature should consider to all sites will address Challenges Related FAQ 2012-15 78

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification None Clarification None Clarification None Clarification None Clarification None Clarification None Clarification that results in Section 9.3.2 providing None additional information related to evaluation of high ambient site temperatures. While Sections 3.2.2.10 and 9.3.1 provides additional information related to the evaluation of high temperatures at the location of equipment.

79

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Clarified that evaluations per Sections 5-9 used to store FLEX equipment such that FLEX (N) capability is maintained. Added footnote to acknowledge that FLEX Section 10.1: equipment storage locations may be Aggregation of FLEX outside the Owner Controlled Area No Change Strategies provided the equipment can be relocated in time to meet FLEX strategy requirements.

Consistent with Section 11.3.3 wording.

11.1: Quality Made clarification that quality attributes No Change Attributes are applicable to FLEX equipment.

Changed portable equipment to FLEX equipment consistent with other sections Deleted especially for spray strategies as 11.2: Equipment None it pertains to head loss due to elevation Design changes.

80

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification None Clarification None Clarification None 81

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Changed portable equipment to FLEX equipment and installed equipment to plant equipment consistent with other sections.

Added footnote that Manufacturers information may be used in establishing the basis for equipment use and does not require Appendix B qualification.

Added clarification that the requirements 11.3: Equipment No Change for primary connection point, alternate Storage connection point, N+1, and protection still apply if pre-staging or installing FLEX equipment.

Changed 50.54(hh)(2) equipment to LOLA equipment Related FAQ 2012-17 Added footnote referring to NEI 14-01 11.4.1: Procedure Deleted restriction of using of FSGs only for No Change Guidance Objectives BDBEE conditions. Guidance is to use FSGs only as directed.

FAQ 2014-01 Changed permanently installed 11.4.2: Operating equipment to plant equipment No Change Procedure Hierarchy consistent with other sections.

11.4.3: Development Added Validation standard for FSGs found No Change Guidance for FSGs in Appendix E 82

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification Pre-Staged equipment for risk reduction and equipment storage are not the same. Pre-staged None equipment that is not protected from applicable hazards is subject to time limitations while not in protected storage location.

Note: JLD-ISG-2012-01 R1, Section 3.4, Programmatic Controls for Unavailability or JLD-ISG-2012-01 R2, Section 3.4, Programmatic Controls for Functionality provides guidance on time limitations for nonfunctional or not reasonably protected.

None Clarification See NEI 14-01 Compliance Matrix for details.

Clarification None New element of guidance previously contained in White Paper. Perform Gap evaluation using guidance given below for Appendix E.

New Appendix is addressed in separate matrix.

83

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Changed to clarify that changes made for FLEX should also be screened for applicability to other license basis document change processes in addition to 11.4.4, Regulatory the UFSAR. No Change Screening/Evaluation Changed containment integrity to containment function consistent with other sections.

Deleted 10.54(hh)(2) from upper figure.

Centered EDMG in lower figure.

Figure 11-1 No Change Deleted B.5b Guidelines and reference to 50.54(hh)(2) guides in note below figure.

11.5: Maintenance No Change to Section Header No Change to Section Header and Testing Changed FLEX mitigation equipment and 11.5.1: Initial Portable equipment to FLEX equipment No Change Testing consistent with other sections.

Changed Portable equipment to FLEX equipment 11.5.2: Preventive Clarified that associated bases is site-Maintenance (PM) specific basis. No Change New section in Rev New section 11.5.3 2: Credit for existing controls for Maintenance and testing for plant No Change maintenance and equipment is conducted in accordance with testing for plant existing plant processes.

equipment 11.5.3: Managing Changes the term unavailability to FLEX equipment and Renumbered to Section 11.5.4, functionality (i.e., the ability to connection expanded and relocated out of service perform its intended function) and availability provisions resulting in additional adds the term protection. Relocated subsections as detailed below.

out of service provisions resulting in a reduction of subsections as detailed below.

84

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification None Clarification See NEI 14-01 Compliance Matrix for details Additional information contained in separate NEI 14-01 Compliance Matrix Editorial None Clarification None.

Validate FIP/Program documents align Clarification with EPRI templates or provide a site specific basis.

Clarification Confirm Program Documents /PM Plant equipment performing a FLEX function may be Process acknowledges testing of plant tested using the existing PMs established for that equipment also fulfills the FLEX equipment without imposing additional maintenance and testing requirements.

maintenance and testing requirements for the FLEX function. This is a reasonable approach because the existing plant PMs are based on failure modes that are based on the normal (design basis) usage of plant equipment and are expected to bound the failure modes that the FLEX PMs are intended to discover.

Clarification Differentiates FLEX equipment and connection None. Actions will be addressed in functionality and protection so that different allowed subsequent sections of Section 11.5.

outage times can be established for loss of function and protection 85

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change 11.5.3.a(R0),

11.5.4.a(R2, R4):

Control of FLEX Changed the term installed plant Changed the term unavailability equipment using equipment to plant equipment. to functionality other plant processes (e.g.,

Technical f )

Changed portable equipment to FLEX equipment.

11.5.3.b(R0), Added If the site FLEX (N) capability is met Moved and expanded the allowed outage 11.5.4.b(R2,R4): FLEX but not protected for all of the sites time for FLEX equipment that is not equipment allowed applicable hazards, then the allowed protected to Section 11.5.4.e and 11.5.4.f outage time with [outage time] is reduced to 45 days.

capability (N) .

maintained (90 days) Added new footnote providing basis for 45/90 day allowed outage time 11.5.3.c(R0),

11.5.4.c(R2,R4):

Added one connection point can be FLEX connection unavailable provided the remaining Changed the term available to functional point allowed connection point remains available consistent with other sections outage time with capability maintained Expanded and portion relocated to 11.5.4.g (R2) FAQ 2012-05 Changed portable equipment to FLEX 11.5.3.d(R0), equipment consistent with other sections.

11.5.4.d(R2, R4):

No compensatory action statements for non-Compensatory Includes connection points.

functional equipment exceeding 90 days or actions for exceeding prior to forecast of an external event 90 day allowed Applies to 90 day availability and 45 day provided (N) capability is maintained.

outage time or prior protection allowed outage times.

to forecast of an Outage times from 11.5.4.g (R2) adjusted and external event Establish compensatory actions prior to relocated to 11.5.4.d (R4) and 11.5.4.f(R4) exceeding the allowed outage time eliminating 11.5.4.g (R2).

86

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification Changes in terms are consistent with other sections and approaches. However, the concept of controlling None plant equipment supporting a FLEX function per the plant process such as Technical Specifications r e m a i n s unchanged.

The allowed outage time for FLEX equipment that is non-functional but in which FLEX (N) capability is None maintained has not been changed.

Changes to the 45 day allowed outage The allowed outage time for FLEX equipment that is time for FLEX equipment that is not not protected has changed from a blanket 45 days in protected will be discussed in Rev 4 Rev 2. See Rev 4 Section 11.5 (4.e) and (4.f) for a Section 11.5.4.e and 11.5.4.f discussion of those changes.

Clarification Rev 0 implies that both the primary and alternate connection points can be out of service for up to 90 Verify that the site FLEX program days provided some means of FLEX capability is document programmatic controls align maintained. Rev 2 and 4 clarify that at least one with the NEI 12-06 guidance.

connection point must remain functional to apply 90 day allowed outage time.

Clarification Separate allowed outage times for non-functional and unprotected FLEX equipment.

Rev 4 eliminates provision for use of compensatory actions for non-functional FLEX equipment that exceeds 90 days that was added in Rev 2. Added Verify that the site FLEX program initiation of actions (e.g., entering the condition into a document programmatic controls align corrective action or work management program). with the NEI 12-06 guidance.

Rev 4 eliminates need for compensatory actions in advance of forecast external events provided (N) capability is maintained.

87

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change 11.5.3.e(R0),

11.5.4.e(R2,R4):

Changed to Section 11.5.4.b.i Unavailability of FLEX Changes equipment to FLEX equipment equipment does not consistent with other sections. Changes the term available to functional result in loss of consistent with other sections.

protection for FLEX equipment protected by separation Relocated to Section 11.5.4.d 11.5.3.f(R0), Changes the term available to 11.5.4.f(R2,R4): Changed portable equipment to FLEX functional consistent with other sections.

FLEX equipment equipment consistent with other sections. Clarifies 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> action to enter condition in allowed outage Includes connection points. the corrective action program or work time and actions management program within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

with capability (N) Increases action time to implement not maintained compensatory actions from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 (24,72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) days (except for forecast external events).

R2 allows that if the site FLEX (N) capability is met but not protected for all of the sites applicable hazards, then the allowed unavailability is reduced to 45 days. R4 allows that If the FLEX capability (N) is met but the equipment being relied on to meet New guidance in Rev the FLEX capability (N) is not all in its 4, Allowed time for specified reasonable protection unprotected FLEX Guidance for unprotected FLEX equipment configuration for the N equipment, restore equipment and was not specifically addressed in R2. protection or implement compensatory compensatory actions to justify a temporary reasonable actions. (14/90 days) See 2 Section 11.5 4.g protection configuration within 14 days or in advance of a forecast external event. After that restore the specified reasonable protection configuration within 90 days.

Contained in 11.5.4.e in R4 88

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action None None Connection points specifically included in Rev 2 and 4.

Verify that the site FLEX program document programmatic controls align 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions clarified in Rev 4.

with the NEI 12-06 guidance.

Relaxation of allowed outage time in Rev 4.

Rev 4 removes the 45 day allowed time that equipment may be unprotected from applicable hazards and adds a 14 day timeframe for Verify that the site FLEX program compensatory actions for equipment not in its document programmatic controls align specified reasonable protection configuration and to with the NEI 12-06 guidance.

restore specified reasonable protection configuration within 90 days.

89

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Allowance for pre-deployment of equipment New guidance in Rev in unprotected configurations for up to 45 4, Allowed time for days if used to reduce risk of maintenance or unprotected FLEX Guidance for unprotected FLEX equipment outage activities. Contained in 11.5.4.f in R4.

equipment and was not specifically addressed in R2.

compensatory The provisions of Section 11.5.4.e do not actions. (45 days) apply to this condition.

Rewritten, but retains should use SAT Section 11.6.5, Removes details concerning process approach. Makes reference to the conduct of drills and refers to NEI 13-06.

NEI 13-06 and 10 CFR 55.4.

Deleted footnote about recommendation No Change to use SAT process, now contained within Section 11.6.

Modified footnote defining Emergency Response Leaders to include both site and No Change corporate emergency response personnel.

11.6: Training Replaced Section 11.6.5 with reference to Added footnote to reference NEI 13- 06.

NEI 13-06 that was previously in footnote and removed footnote.

90

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Rev 4 relaxes the need to establish compensatory actions for FLEX equipment in unprotected Verify that the site FLEX program configurations as long as the conditions for this document programmatic controls align section are met.

with the NEI 12-06 guidance.

Section 11.5.4.f does not make Section 11.3.6 inapplicable. JLD-ISG-2012-01 R2, Section 3.4, Programmatic Controls for Functionality provides guidance on time limitations for nonfunctional or not reasonably protected including making Section 11.3.6 inapplicable.

Clarification There were always requirements for periodic training the relationship to NEI 13-06 is new. Additional See separate NEI 13-06 compliance information contained in separate NEI 13-06 matrix Compliance Matrix.

Editorial None Clarification None See separate NEI 13-06 compliance See note above on NEI 13-06 matrix 91

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change No Change Section 11.8.3 Added clarification for making changes to FLEX strategies and Note:

when changes can be made without prior JLD-ISG-2012-01 takes no position and NRC approval.

defers to 10 CFR 50.155 wording Changed containment integrity to 11.8: Configuration containment function consistent with No Change Control other sections.

Section 11.8.4 & 11.8.5 Added guidance for when a change No Change requires NRC approval and documentation requirements for all changes.

12: Offsite Resources Numbered & added titles to sub-sections No Change Changed installed plant equipment to plant equipment consistent with other sections.

Changed transition from to augment 12.1:

with regarding use of plant equipment and Synchronization with No Change FLEX equipment used to maintain key Off-site Resources functions.

Deleted paragraphs referring to Tables 12-1 and 12-2 were sample lists of off-site FLEX equipment. Deleted Tables 12-1 and 12-2.

12.2: Minimum Capabilities of Off- New section number but no change to text. No Change Site Resources Changed title of section from Submittal Guidance to Documentation 13: Documentation No Change Deleted paragraphs under Section 13 that contained quotes from Order EA-12-049 submittal requirements.

92

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification Note: Section 11.8.3.a.iii refers to Order EA-12-049 None which will be withdrawn with the provision of 10 CFR 50.155 Editorial None Validate existing FLEX program document Provides additional guidance on when change programmatic controls align with requires NRC approval and how to document requirements.

Editorial None Editorial and Clarification None Editorial None Editorial None 93

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Added instructions that new applicants should submit how they will conform with 13.1: Overall guidance. The remainder of this section is No Change Integrated Plan materially the same with modifications made consistent with other sections.

Changed title of section from Status Reports to Final Report.

Relocated sentence about making changes Deleted the former Status Report section to the FLEX strategies in accordance with guidance.

guidance in Section 11.8.

New Section added reference to Section Deleted guidance that the FIP will be 11.8 and provides guidance for current 13.2: Final Report maintained as a living document with a expectations for the Final Integrated Plan formal record of changes maintained for the (FIP) and the maintenance as a living FIP.

document. Requires a formal record of changes to be maintained for the FIP.

.

Added footnote referencing NRC memorandum dated September 12, 2014 (ML14254A467)

Rev. 0 section removed with changes to 13.3: Final Report No Change Section 13.2 listed above.

Added internet address to individual 14: References No Change document references 94

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarifications None None Clarification Alignment with Section 11.8 Potential reduction in Programmatic Requirement for maintenance of FIP Removed requirement to maintain FIP.

document.

Editorial None Editorial None 95

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Added Alternate Mitigating Strategies No Change (AMS)

Added Associated Effects No Change Modified Baseline Coping Capability,"

changed installed and portable equipment No Change to plant and FLEX equipment.

Modified definition of beyond-design basis external events definition consistent with No Change the change from Section 1.3 to clarify that the ELAP occurs concurrently with a LUHS.

Added FIP No Change Modified FLEX Capability, changed installed, on site portable and pre-staged No Change off site resources to plant and FLEX equipment Added FLEX Equipment No Change Appendix A: Glossary FLEX equipment may be portable, pre-of Terms staged or installed.

Modified FLEX Strategies, changed No Change function to capabilities.

Added Flooding Event Duration No Change Added Flood Protection Feature No Change Modified Loss of normal access to the ultimate heat sink, deleted [Order No Change language].

Added Mitigating strategies assessment No Change Added Mitigating Strategies Flood Hazard No Change Information Deleted On-site FLEX Equipment No Change Added OIP No Change Added Program Document No Change Changed term in definition, unavailability Added Reasonable protection to non-functional Modified Robust to include or meets the current NRC design guidance for applicable No Change hazard (RG 1.76, R1) 96

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action New definition for Appendix G & Appendix H None New definition for Appendix G None Clarification None Clarification None Editorial None Clarification None Clarification None Clarification None New definition for Appendix G None New definition for Appendix G None Clarification None New definition for Appendix G & Appendix H None New definition for Appendix G None Editorial None Editorial None Editorial None Editorial None First sentence includes the term available, which should be considered equivalent to functional as used in the remainder of the definition.

Clarification, addressed in Section 7.3.1 None 97

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Modified Sustaining functions indefinitely, changed until recovery actions can be implemented to until No Change Appendix A: Glossary recovery actions are implemented.

of Terms (Continued) Deleted [Order language].

Added Targeted Hazard Mitigating No Change Strategies (THMS)

Added Warning time No Change Table B-1 Changed 10 CFR 50.54(hh)(2) to LOLA No Change Changed installed plant equipment to plant equipment consistent with other No Change sections Changed portable battery chargers to No Change FLEX battery chargers.

Changed portable pump to FLEX pump. No Change Deleted reliable, hardened from baseline capability under containment function for No Change other containment types (Mark III).

Deleted For Mark I and II containments, capability must credit required changes Appendix C:

associated with Order EA-12-0050 at a Approach to BWR No Change minimum from the performance Functions attributes of containment venting under containment function.

Added SFP spray capability back in with amplified guidance in the Performance Attributes section Deleted SFP spray capability under SFP for plants that credit below grade undrainable cooling. volume and for need to perform a seismic SFP integrity evaluation before removing the spray Eliminated need for FAQ-2013-09 flow capability from the FLEX strategy. This later change addresses the JLD-ISG-2012-01 R1 NOTE: See JLD-ISG-2012-01 R1 that retains this exception to this portion of the guidance.

capability with a condition for removal based on completion of a seismic evaluation of the SFP.

98

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification, addressed in Section 3.3 None New definition for Appendix G and Appendix H None New definition for Appendix G None Editorial None Clarification None Clarification None Clarification None Clarification, covered by previous items. This change is consistent with previous items of clarification see None Section Table 3-1 above Clarification, covered by previous items. This change is consistent with previous items of clarification see None Section Table 3-1 above Clarification, covered by previous items. This change is consistent with previous items of clarification see Section Table 3-1 above Potential reduction in equipment requirements in the None SFP cooling strategy if conditions from JLD-ISG-2012-01 R1 or NEI 12-06 R4 are met.

NOTE: The typical current BWR configuration does not meet the Performance Attribute exclusion criterion for a below-grade undrainable SFP.

99

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Deleted per Order EA-12-051 and in baseline capability and performance attributes under SFP Parameters.

Appendix C:

Approach to BWR Added reference to Wide-range spent fuel No Change Functions pool level instrument in Performance (Continued) Attributes.

Removed or direct use of spray from Purpose.

Changed installed plant equipment to plant equipment consistent with other No Change sections Changed portable battery chargers to No Change FLEX battery chargers.

Changed portable pump to FLEX pump. No Change Deleted including consideration of concurrent makeup or spray of SFP from the performance attributes of sustained No Change source of water under core cooling in Table D-1.

Appendix D:

Approach to PWR RCS inventory control/long-term sub-Functions criticality - Added performance attribute of diversity requirement if crediting re-No Change powering a charging pump.

FAQ-2013-06 Core Cooling in Modes 5 & 6 without SG -

deleted performance attribute of diversity requirement if crediting re-powering a charging pump. No Change FAQ-2013-06 Related FAQ-2012-19 and FAQ-2013-10 100

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification, covered by previous items. This change is consistent with previous items of clarification see None Section Table 3-1 above Clarification None Clarification None Clarification None Clarification, covered by previous items. This change is consistent with previous items of clarification see None Section Table 3-2 above Clarification None Clarification, covered by previous items. This change is consistent with previous items of clarification see None Section 3.2.3 above 101

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Restored SFP spray capability requirement Added SFP spray capability back in with amplified guidance in the Performance Attributes section for plants that credit below grade undrainable volume as determined under B.5.b/10 CFR50.54(hh)(2);

Deleted SFP spray capability under SFP and for need to perform a seismic SFP cooling. integrity evaluation per EPRI3002007148 or Eliminated need for FAQ-2013-09 other endorsed guidance before removing the spray flow capability from the FLEX Appendix D: NOTE: See JLD-ISG-2012-01 R1 that retains strategy.

Approach to PWR this capability with a condition for removal Functions based on completion of a seismic evaluation of the SFP.

SFP Parameters - deleted or direct use of spray from Purpose section. Deleted per EA-12-051 and added Wide-range spent No Change fuel pool level instruments in the Performance Attributes section No Change Appendix E: Changed from not used to Validation Note: JLD-ISG-2012-01 states Appendix E Validation Guidance Guidance can be used to determine actions are feasible but is not sufficient to s h o w reliability of actions.

F.1 - Deleted reference to the NRC Order No Change for AP1000 COL holders F.3 - Deleted reference to EA-012-049 and Appendix F: No Change Table 1.2 Guidance for AP1000 F.3.1 - Changed ELAP conditions caused Design by design basis hazard events to ELAP No Change conditions caused by beyond design basis hazards.

102

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Clarification, covered by previous items. This change is consistent with previous items of clarification see Section Table 3-2 above None Potential reduction in equipment requirements in the SFP cooling strategy if conditions from JLD-ISG-2012-01 R1 or NEI 12-06 R4 are met.

Clarification, covered by previous items. This change is consistent with previous items of clarification see None Section Table 3-2 above A separate comparison evaluation has been performed to identify differences between validations performed per NEI 12-06 Rev 0 using the Perform Gap evaluation using guidance NEI validation guidance white paper and validations given below for Appendix E.

performed per NEI 12-06 R2 or R4 using Appendix E.

A Validation GAP Review Table is provided below.

Editorial None Editorial None Incorporate the requirements of Requires FLEX be evaluated against new hazards Appendix G and Appendix H.

103

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Changed Guidance for U.S. EPRTM Design Appendix G:

to Mitigation Strategies Assessment for Mitigation Strategies New Flood Hazard Information. Changed Mitigation to Mitigating in Assessment for New Section G.4.4, first sentence.

Flood Hazard New Appendix for performing MSA for new Information flooding hazard information.

104

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action New Guidance for performing Flooding Hazard evaluation The Mitigating Strategies Assessment (MSA) determines if the FLEX strategies can be implemented given the impact Validate sites Flooding MSA has been of the reevaluated flood hazard information. If it is determined the FLEX strategies cannot be implemented, performed as described in Appendix G.

the MSA considers other options such as plant modifications, modifications to strategies or different If the MSA concluded the FLEX Strategies mitigation strategies. The MSA process provides multiple can be implemented without change due assessment Paths to accommodate site specific differences to the impact of the reevaluated flood between their design basis flood hazard and their hazard information, a basis reevaluated flood hazard. documentation update will be required.

Implementation of any FLEX Strategy changes or facility If the MSA concluded a change is needed, changes (physical or technical basis) indicated by the MSA would be governed by Section 11.8, Configuration Control. the change would be implemented with station procedures and as described in The MSA document itself is not required to be maintained. Section 11.8 including the determination However, Section 11.8.1 requires the basis of the FLEX if the change can be made without NRC Strategies be maintained and Section 11.8.2 requires approval.

configuration control processes will be used to ensure changes to the facility will not adversely impact the FLEX Implementation of these changes is Strategies. As such, ensuring the controlling performance required to achieve compliance with the criteria or margin for flood protection features that were implementation of 10 CFR 50.155.

established during the MSA are not reduced via replacement and/or plant modification will provide the on-going basis that the FLEX Strategies are not impacted by the reevaluated flood hazard.

105

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change H.4.3, Path 3, Introduction. Addition of provision that it is not necessary to maintain the IPEEE used for the MSA provided the seismic capacity of any mitigating strategy SSC is not reduced below the IHS level.

H.4.3 Background and Discussion - Deleted and SFP level instrumentation from the Spent Fuel Pool Cooling Evaluation section H.4.4 Path 4, changed presentation of process sequence resulting in 4 Steps otherwise no change in process H.4.4, Step 2, added (including buried New Appendix for performing MSA for new tanks)

Seismic Hazard information. Path 5 for plants performing an SPRA will be added to this Appendix later.

Appendix H, H. 6.2 - editorial changes and clarification Mitigation Strategies that FLEX strategies or F L E X strategies Note - In accordance with JLD-ISG-2012-Assessment for New with modifications may be used to address 01, Section H.4.5 of Appendix H to NEI 12-Seismic Hazard the effects of the MSSHI.

06, R2, discusses a methodology to Information develop an AMS that is under H. 6.3 - changed mitigate to address the development. This methodology has not effects of the MSSHI. Added as yet been reviewed by the NRC and is not appropriate to the last bullet for yet endorsed for use.

p er fo rm i ng validations in accordance with Appendix E.

H. 6.4 - new section for documenting MSSHI impact evaluations.

H. 6.5 - new section for documenting conclusions of the selected strategy that addresses the MSSHI effects on mitigation strategies.

Additional References 24, 25, and 26 added to listing in Section H.7 106

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action New Guidance for performing Seismic Hazard Validate sites Seismic MSA has been evaluation. performed as described in Appendix H.

The Mitigating Strategies Assessment (MSA) If the MSA concluded the FLEX Strategies determines if the FLEX strategies can be can be implemented without change due implemented given the impact of the reevaluated to the impact of the reevaluated seismic seismic hazard information. If it is determined the hazard information, a basis FLEX strategies cannot be implemented, the MSA documentation update will be required.

considers other options such as plant modifications, modification to strategies or different mitigation If the MSA concluded a change is needed, strategies. The MSA process provides multiple the change would be implemented with assessment Paths to accommodate site specific station procedures and as described in differences between their design basis seismic hazard Section 11.8 including the determination and their reevaluated seismic hazard. if the change can be made without NRC approval.

Implementation of any FLEX Strategy changes or facility changes (physical or technical basis) indicated Implementation of these changes is by the MSA would be governed by Section 11.8, required to achieve compliance with the Configuration Control. implementation of 10 CFR 50.155.

The MSA document itself including the underlying risk analyses such as the SPRA is not required to be maintained. However, Section 11.8.1 requires the basis of the FLEX Strategies be maintained and Section 11.8.2 requires configuration control processes will be used to ensure changes to the facility will not adversely impact the FLEX Strategies.

As such, ensuring the controlling seismic capacity or margin of any of the mitigating strategy SSCs is not reduced via replacement and/or plant modification will provide the on-going basis that the FLEX Strategies are not impacted by the reevaluated seismic hazard.

107

June 8, 17 NEI 17-03, [Rev A]

NEI 12-06, Appendix E - Validation Guidance Section R-2 Change R-4 Change Added "or the sequence of events associated with the Mitigating Strategies Flood Hazard Information (MSFHI)" This E.1 Purpose No Change adds the expectation that actions associated with flooding (MSFHI) will be validated per this guidance.

Added "Validation also includes actions E.2 Scope that are time constraints required to No Change mitigate the MSFHI."

Added:

Anticipatory Actions - Actions completed in preparation for the occurrence of an event based upon the receipt of notification of the event due to the availability of warning No Change time.

E.3 Terms and Definitions Reactive Actions- Actions completed after the event starts or after warning time ends.

Added "or the sequence of events associated with the MSFHI" to definition of No Change Time Sensitive Actions.

Deleted OIP, FIP, and Program Document. No Change 108

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Editorial None New recommendation to perform validation for Confirm strategy validation and MSFHI (Reevaluated Flood Hazard) documents include MSFHI.

Editorial None Editorial None Editorial None 109

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change E.4.F Removed BDB and added For FLEX implementation Expanded to clarify anticipatory actions that have a warning were excluded from the validation process during the implementation of FLEX because these actions would have been validated as part of the design basis event response.

No Change E.4 Assumptions and Considerations E.4.G Inserted new consideration for validation of FLEX anticipatory actions as well as No Change existing design basis anticipatory actions.

Previous consideration on qualitative assessment of TSA margin relocated to E.4.H 110

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action Confirm strategy validation and documents Provides guidance for validation of anticipatory actions include MSFHI.

Note: Anticipatory Actions were not included in the white paper validation process.

Provides guidance for validation of anticipatory actions Confirm strategy validation and documents include triggering event notification and anticipatory actions 111

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change E.4.H Qualitative assessment of TSA margin relocated from 4.G to E.4.H. No Change Removed introductory statement regarding environmental factors cannot be ignored.

E.4.I Previous focus of validation relocated from 4.H to E.4.I No Change Removed phrase were integrated into structure/implementation requirements of NEI 12-06 from last sentence.

E.4.J Previous shutdown mode strategy validation relocated from 4.I to E.4.J. No Change Added reference to Section 3.2.3 and last sentence This does not include E.4.K Previous personnel discussion relocated from 4.J to E.4.K.

No Change Removed Adequate E.4 Assumptions and Considerations E.4.L No Change Previous personnel discussion relocated from 4.Kto E.4.L with no change in wording.

Previous E.L referencing NEI 12-06, Section 11.8 was not relocated to Appendix E.

No Change 112

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action This section provides guidance that the qualitative Review validation documentation to assessment of margin is documented in the ensure this assessment is documented conclusions of the validation plan Editorial None Clarification None Clarification None Editorial None Editorial None 113

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Changed occur shortly after the event to have limited available margin.

E.5.1 Overall No Change Validation Process Changed source of TSAs to be included in E.5.1.1 Identification validation to the OIP/FIP and the MSFH. No Change Removed TSAs within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Guidance added for anticipatory actions.

Defined Level A for warning less than 6 E.5.1.2 Graded hours and Level B for warning greater than 6 No Change Approach Selection hours. .

• time is greater than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

114

June 8, 17 NEI 17-03, [Rev A]

Impact/Interpretation Action This section changes the graded approach from Review validation documentation to evaluating TSAs that occur shortly after the event ensure this guidance is met.

to TSAs that have limited available margin Clarification Review validation documentation to Note: JLD-ISG-2012-01 R1 Section 1.1.c)1 and JLD- ensure this guidance is met.

ISG-2012-01 R2 Section 1.1.3.a provides additional guidance on validation for tasks performed mare than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the event.

Provides guidance for validation of anticipatory Review validation documentation to actions ensure this guidance is met 115

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change E.5.1.2 Graded Reworded Note o n t a s k s Approach Selection that do not require No Change (Continued) validation E.5.1.3 Conduct of Updated example location from No Change Validation Attachment 2 to Attachment 3 Editorial change to the Validation being E.5.1.4 i n c l u d e d or incorporated by reference No Change Documentation in the Program Document.

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Impact/Interpretation Action Clarification None Editorial None Editorial None 117

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Reworded listing of items to be validated for No Change E.6.1 Identification of consistency with remainder of Appendix.

Items to be Validated Removed reference to Phase 1 and Phase 2 shutdown mode tasks, added reactive TSAs and added anticipatory TSAs.

Changed from listing criteria for level E.6.2 Selection of selection to referencing back to Section No Change Validation Methods E.5.1.2.

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Impact/Interpretation Action Clarification and provides guidance for validation of anticipatory actions. Review validation documentation to ensure this guidance is met Note: JLD-ISG-2012-01 R1 Section 1.1.c)1 and JLD-ISG-2012-01 R2 Section 1.1.3.a provides additional guidance on validation for tasks performed mare than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the event.

Editorial None 119

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Updated example location from Attachment 2 to Attachment 3 Updated Table A and Table C to include MSFHI in source of items to be validated.

5.

Updated references to other sections within Appendix for consistency.

E.6.3 Conduct of No Change Validation Level A Reasonable Judgment: Added the following sentence.

E.6.3.1 Validation for A brief justification should be provided to No Change Level A TSAs support non-performance of a task and to provide confidence of feasibility of the task performance during a BDBEE.

Added E.6.3.2.2 Validation

• Use of any of the Level A methods No Change Confidence described above.

Changed SAFER National Response E.6.3.3.1 Resources Centers personnel to National SAFER No Change Response Centers personnel.

Added Attachment 4 and Attachment 5 to E.7 ATTACHMENTS list. Were previously Appendix A and No Change Appendix B ATTACHMENT 1 Added the sequence of events associated ITEMS TO BE No Change with the MSFHI.

VALIDATED ATTACHMENT 2 Minor formatting changes No Change VALIDATION PLAN 120

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Impact/Interpretation Action Clarification and provides guidance for validation of Review validation documentation to anticipatory actions. ensure this guidance is met Added an additional guidance to provide a brief justification to support non-performance of a task Review validation documentation to and to provide confidence of feasibility of the task ensure this guidance is met.

performance during a BDBEE Editorial, allows use of Level A validation method for None validating a Level B action Editorial None Editorial None Clarification and provides guidance for validation of Review validation documentation to anticipatory actions. ensure this guidance is met See Editorial None 121

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change Minor formatting changes Note: Tables D and E include user notes ATTACHMENT 3 on the expected level of No Change EXAMPLES detail/clarifications for information intended to be captured in the tables.

Changed from APPENDIX A to ATTACHMENT 4. Minor editorial No Change enhancements.

AMS is alternate mitigating strategy. THMS is Targeted Hazard Mitigating Strategy.

Procedures - Added If the same procedure framework is not used for an AMS/THMS, ATTACHMENT 4 then this attribute would need to be GUIDANCE ON THE addressed in Table E.

CONSIDERATION OF Training - Added If the SAT process is not PERFORMANCE used for an AMS/THMS, then this attribute ATTRIBUTES would need to be addressed in Table E.

No Change Stress - Added If the features of this guide described in Attachment 5 are not implemented for an AMS/THMS, then this attribute would need to be addressed in Table E.

Staffing - Added If the staffing study is not updated for an AMS/THMS, then this attribute would need to be addressed in Table E.

ATTACHMENT 5 INHERENT FLEX Changed from APPENDIX B to ATTRIBUTES THAT ATTACHMENT 5.

ENHANCE HUMAN No Change Minor editorial enhancements.

RELIABILITY IN THE Removed reference to Order EA-12-049.

EVENT OF A BEYOND DESIGN BASIS EVENT 122

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Impact/Interpretation Action Review validation documentation for Changes in the expected level of detail needed. possible additional detail/clarifications required.

Editorial None Review MSFHI to determine if an AMS and/or THMS were required.

If required, determine if a revision to the site specific Validation Plan is needed to Added specific Performance Attributes requirements capture specific Performance Attributes for an AMS/THMS. guidance as detailed in NEI 12-06 R4 Appendix E, Attachment 4 Guidance on the Consideration of Performance Attributes Editorial None 123

June 8, 17 NEI 17-03, [Rev A]

Section R-2 Change R-4 Change This is not a change. ,

No Change ATTACHMENT 5 INHERENT FLEX ATTRIBUTES THAT ENHANCE HUMAN RELIABILITY IN THE EVENT OF A BEYOND DESIGN BASIS EVENT (Continued)

Environmental Factors and Accessibility -

Added Where environmental conditions can be more specifically determined from the mechanistic evaluation of the event No Change performed in support of an AMS/THMS, this information should be taken into account in this assessment.

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Impact/Interpretation Action Requirement for format operating aids (Hard Cards)

This is not a change, but it is important to realize going forward: Review to confirm equipment operating Special Equipment: Equipment operating instructions, aids (Hard Cards) were developed and prepared per the industry writers guide Emergency printed using the INPO developed Response Training Development (ERTD), are printed standardized format on colored paper with a standardized font determined to be the optimal combination for readability. This standardized operating aid format is applied throughout the industry, and allows equipment to be supplied from one utility to another without requiring extensive familiarization.

Review to determine if an AMS and/or Added statement, where environmental conditions THMS were required.

can be more specifically determined from the If required, ensure environmental mechanistic evaluation of the event performed in conditions identified in the AMS/THMS support of an AMS/THMS, this information should be were taken into account as part of the taken into account in this assessment validation 125

June 8, 17 NEI 17-03, [Rev A]

NEI FLEX FAQs FAQ Number Subject Disposition for NEI 12-06 Revisions 2 and 4 Screening for High Wind FAQ-2012-01 Retain. Supports NEI 12-06 Section 7.2.1 Conditions N+1 Applicability to offsite FAQ-2012-02 Retain. Supports NEI 12-06 Section 3.2.2 equipment Close. Common connections have been defined for FAQ-2012-03 Common connections NSRC equipment as part of the procurement process and are beyond the scope of NEI 12-06 guidance.

FAQ-2012-04 Drills for FLEX deployment Retain. Supports NEI 12-06 Section 11.6.5 Unavailability of FLEX FAQ-2012-05 Close. Included in NEI 12-06 Section 11.5.4 connections Staffing considerations-FAQ-2012-06 Retain. Supports NEI 12-06 Section 11.7 personnel injuries FAQ-2012-07 Loss of normal access to the UHS Close. Included in NEI 12-06 Section 3.2.1.3(4)

Starting battery capacity for FAQ-2012-08 Close. Included in NEI 12-06 Section 3.2.1.2(2) battery calcs Availability of ac distribution FAQ-2012-09 Close. Included in NEI 12-06 Section 3.2.2(17) equipment FAQ-2012-10 Screening for Flooding Retain. Supports NEI 12-06 Section 6.2.1 Impact of EDG Field Flash on FAQ-2012-11 Retain. Supports NEI 12-06 Section 3.2.2(6)

Battery loading calculations FAQ-2012-12 Wind load combinations Close. Included in NEI 12-06 Section 7.3.1 Close. Included in NEI 12-06 Section 6.2.2 and Appendix FAQ-2012-13 Flooding Event Timeline G

FAQ-2012-14 High Wind Hazards Retain. Supports NEI 12-06 Section 7.3.1(1.b)

FAQ-2012-15 High Temperatures Retain. Supports NEI 12-06 Section 9.2 FAQ-2012-16 Fire Ring Header Availability Close. Included in NEI 12-06 Section 3.2.1.3(10)

Seabrook Supplemental FAQ-2012-17 Retain. Supports NEI 12-06 Section 11.3 Emergency Power System FAQ-2012-18 Seabrook Backup UHS Retain. Supports NEI 12-06 Section 3.2.1.3(6)

FAQ-2012-19 Implementation in all modes Retain. Supports NEI 12-06 Section 2 and Table D-1 Close. Included in NEI 12-06 various sections by the use of the terms plant equipment and FLEX equipment FAQ-2012-20 Backup Diesel Generator and the change in terms from portable FLEX equipment to FLEX equipment which may be installed or portable.

FAQ-2013-01 Rev 1 Tornado Missile Separation Close. Included in NEI 12-06 Section 7.3.1(1.c)

High Wind Loading Reasonable FAQ-2013-02 Close. Included in NEI 12-06 Section 7.3.1(1.c)

Protection SFP Timeline Based on Makeup or FAQ-2013-03 Retain. Supports NEI 12-06 Section 3.2.1.6 Spray Pre-staged diesel pump access to FAQ-2013-04 Close. Included in NEI 12-06 Section 3.2.1.3(4) the UHS 126

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FAQ Number Subject Disposition for NEI 12-06 Revisions 2 and 4 Sequence of Events Timeline FAQ-2013-05 Close. Included in NEI 12-06 Section 3.2.2(14)

(SFP)

Use of installed equipment for Close. Included in NEI 12-06 Section 3.2.2(13) and Table FAQ-2013-06 RCS Inventory D-1 Control/Subcriticality FAQ-2013-07 Reasonable Protection Close. Included in NEI 12-06 Section 7.3.1 Close. This question has been addressed through FAQ-2013-08 Maintenance Rule Applicability revisions to NUMARC 93-01 Spent Fuel Pool Make-Up and FAQ-2013-09 Retain. Supports NEI 12-06 Tables 3-1, 3-2, C-3 and D-3.

Spray Strategy[1]

Shutdown mode capability FAQ-2013-10 Close. Included in NEI 12-06 Section 3.2.3 requirements FAQ-2013-11 Raw Water Close. Included in NEI 12-06 Section 3.2.2(5)

FAQ-2013-12 Indefinite Coping Close. Included in NEI 12-06 Section 3.3 Use of FLEX equipment for non-FAQ-2014-01 Close. Included in NEI 12-06 Section 1 and 11.4.1(2)

BDBEE's FFAQ-2014-01 Alternate Instrument Readings Close. Included in NEI 12-06 Section 5.3.3(1)

FAQ system was changed to FLEX FAQ (FFAQ)

[1] Note that the SFP spray capability is not required for plants that have SFPs that are below ground and cannot be drained as determined during the implementation of B.5.b/10 CFR 50.54(hh)(2) [10 CFR 50.155(b)(3)] or for plants that have demonstrated spent fuel pool integrity by performing a seismic spent fuel pool integrity evaluation for their mitigating strategies seismic hazard using EPRI 3002007148, Seismic Evaluation Guidance:

Spent Fuel Pool Integrity Evaluation, or other NRC endorsed guidance.

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8 NEI 12-01 COMPARISON Introduction To assist in implementing 10 CFR 50.155, a gap assessment of NEI 12-01, Revision 0 has been performed. That process involved preparing a matrix to facilitate review of the following references to assess potential gaps that a licensee may encounter during implementation of 10 CFR 50.155 and identify the recommended actions to close those gaps:

• 10 CFR 50.155 sections applicable to Beyond Design Basis (BDB) event response staffing and communications capabilities including the applicable portions of the associated statements of consideration (ADAMS Accession No. ML16292A026).

• Regulatory Guide (RG) 1.228 Revision 0, Integrated Response Capabilities for Beyond-Design-Basis Events, endorses NEI 12-01 Revision 0 as an acceptable method to assess staffing and communication capabilities and needs when responding to a beyond-design-basis event. There are no exceptions or clarifications to NEI 12-01 Revision 0 guidance in RG 1.228. Therefore, there are no additional gaps specific to RG 1.228 that need to be addressed for compliance with staffing and communications requirements of the rule.

• NEI 12-01 Revision 0, Guidelines for Assessment Beyond Design Basis Accident Response Staffing and Communications Capabilities.

• Other NRC requirements or guidance supporting the development of NEI 12-01 Revision 0 as listed in the Other Requirement or Guidance column of the gap assessment matrix.

All power reactor licensees and holders of Construction Permits in Active or Deferred Status received a 10 CFR 50.54(f) letter regarding NTTF recommendation 9.3, dated March 12, 2012. See Attachment 6 of the 10 CFR 50.54(f) letter for a listing of addressees. In response to the March 12, 2012 letter, addressees performed staffing and communication assessments using the guidance provided in NEI 12-01 Revision 0. 10 CFR 50.155 does not require these assessments to be re-performed, but addressees need to review commitments made in those assessment submittals and determine which of the commitments are necessary for rule compliance and need to be treated as obligations. In addition, the following need to be maintained per the change control process in 10 CFR 50.155(g):

• Documentation of sufficient staffing to support the strategies required by 10 CFR 50.155(b)(1) through (b)(3).

• Documentation of the communications capability to support the strategies required by 10 CFR 50.155(b)(1) and (b)(2).

Summary of Major Gap Assessments / Recommended Actions NOTES: 1. 10 CFR 50.155(b)(5) requirements for staffing capabilities are applicable to the requirements of 10 CFR 50.155(b)(1) through (b)(3).

2. 10 CFR 50.155(c)(4) requirments for communications capabilities are applicable to the requirements of 10 CFR 50.155 (b)(1) and (b)(2).

3. Although the requirements for communications capabilities contained in 10 CFR 50.155(c)(4) are not applicable to paragraph 10 CFR 50.155(b)(3) (EDMGs), all licensees have existing communications capabilities supporting EDMGs at the guidance level. See the B.5.b Phase 1 guidance letter dated February 25, 2005, Items B.1.i and B.2.b. Further details are available in NUREG 0800, Standard Review Plan, Section 19.4, Acceptance Criteria Item 12.

The recommended actions identified by the gap assessment review are provided in the GAP Assessment /

Recommended Action column of the matrix and are summarized below.

1. Verify drill or exercise critiques and training feedback mechanisms include consideration of staffing and communications capabilities and assessments in the performance of 10 CFR 50.155 related drills, exercises and training.

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2. Verify the applicable change control process (e.g., 10 CFR 50.155(g) as implemented in the FLEX program document) contains adequate administrative controls for the identification of p o t e n t i a l impacts to staffing and communications c a p a b i l i t i e s r e q u i r e d t o implement of 10 CFR 50.155(b) strategies.

Specific elements to consider as it relates to a BDB event include:

a. Utilization of RP, Security and administrative support resources

b. Changes to work areas to be utilized by staff responding to an event

c. Changes to expanded response capabilities and procedures

d. Changes to access enhancing measures

e. Changes to capabilities and use of the plant paging system

f. Changes to communications capabilities to off-site response organization facilities Change control processes defined by 10 CFR 50.54(p), 10 CFR 50.54(q) and 10 CRF 73.58 in addition to 10 CFR 50.155(g) should also be considered for the above changes.

3. Include a demonstration of the associated communications capability when conducting the initial drill or exercise that demonstrates the capability to transition to and use one or more of the strategies and guidelines in either paragraphs (b)(1), (b)(2) or (b)(3) of 10 CFR 50.155. This drill or exercise must be completed within four years of the effective date of the rule.

4. Confirm communications capabilities committed to in response to the 50.54(f) letter comply with the requirements of 10 CFR 50.155(c)(4).

a. Determine which commitments will remain commitments subject to licensee control per NEI 99-04 and the site specific commitment change process.

b. Determine which commitments should be treated as obligations subject to the change control process defined in 10 CFR 50.155(g).

c. Treat as obligations all communications capabilities credited with supporting 10 CFR 50.155(b)(1) and (b)(2) strategies, although not necessarily included in the communications assessments (e.g., may be included in the Final Integrated Plan (FIP) or Mitigation Strategies Assessment (MSA)) )performed in response to the 50.54(f) letter necessary for compliance with 10 CFR 50.155(c)(4).

d. Treat all communications capabilities credited with supporting 10 CFR 50.155(b)(3) strategies as obligations subject to the change control process in 10 CFR 50.155(g).

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2. Verify that communications equipment necessary to implement 10 CFR 50.155(c)(4) (or to implement 10 CFR 50.155(b)(3) strategies) is included in inventory checklists and is periodically verified functional with periodic maintenance tasks and frequencies defined.

3. Verify that communications equipment contracts with vendors supporting communications equipment necessary to implement 10 CFR 50.155(c)(4) are maintained current and periodically verified.

4. Verify that communications equipment procurement specifications or purchasing documents are consistent with requirements normally applied to other EP equipment and should be commonly available, commercial grade with readily available parts and replacement.

5. Verify agreements with communications service providers that enable access to Government Emergency Telecommunications Service (GETS), the Telecommunications Service Priority (TSP) programs and the Wireless Priority Service (WPS) are maintained current and periodically verified. Information related to these services may be obtained from https://www.dhs.gov/office-emergency-communications, under the Response Support section of the web page. Note that the National Communications Service (NCS) referenced in NEI 12-01 was disbanded by Executive Order 13618 on July 6, 2012 and the cited website is no longer functional. See matrix NEI 12-01 Section 4.9 for additional information addressing this action.

6. Verify agreements with communications providers of Emergency Services (e.g., satellite phone service) are maintained current and periodically verified.

Users Notes Due to the large size of this matrix, it has been formatted to extend across two adjacent facing pages The matrix follows the outline of NEI 12-01. An explanation of the information in each column of the matrix follows:

• 10 CFR 50.155 Section - Sections of the rule that are applicable to the guidance in the section of NEI 12-01 being addressed.

• Other Requirement or Guidance - Other documents that relate to the guidance in the section of NEI 12-01 being addressed.

• Section Guidance - A general description or outline of the information provided in the section of NEI 12-01 being addressed.

• Statements of Consideration - Provides the Statements of Consideration (SOC) section number and title when a SOC passage provides information relevant to the section of NEI 12-01 being addressed. In addition, a page reference is sometimes provided to indicate where the discussion on the specific subject can be found.

• Interpretation - Background or further explanation of the guidance in NEI 12-01.

• Proposed Action - Captures any generic actions being undertaken by the industry to address the item or recommends actions that should be taken by a utility.

Also see Section 3.0, General Matrix Usage, for general usage information.

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Statements of Other 10CFR 50.155 Consideration Requirement or NEI 12-01 Section Guidance Section (ADAMS Accession No.

Guidance ML16292A026)

SECTION 1 INTRODUCTION 1.1 - Response Staffing Assessment None Background Information 1.2 - Communications During an None Extended Loss of AC Power Assessment None Background Information 1.3 - Approach to Information None Request Responses Background Information discussing phased approach for information responses 1.3.1 - Staffing None Two phased approach for staffing None assessments for single and multi-unit sites 1.3.1.1 - Phase 1 Staffing Assessment None Complete and submit multi-unit EP Rule ISG Phase 1 staffing assessment by April NSIR/DPR-ISG-01 30, 2013 NEI 10-05 10 CFR 50.54(f) 1.3.1.2 - Phase 2 Staffing Assessment None letter Complete and submit Phase 2 staffing assessment no later than 4 months prior to beginning of second refueling outage associated with EA-12-049 compliance.

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Interpretation Gap Assessment / Recommended Action SECTION 1 INTRODUCTION None None None None None None None None. Action completed None None. Action completed None None. Action completed. Note that for multi-unit sites with dissimilar units and strategies, multiple Phase 2 Staffing Assessments may have been submitted.

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Statements of Other 10CFR 50.155 Consideration Requirement or NEI 12-01 Section Guidance Section (ADAMS Accession No.

Guidance ML16292A026)

SECTION 1 INTRODUCTION 1.3.2 - Communications None B.5.b Phase 1 Guidance Letter Background information on timing of issued 2/25/2005 communications assessments NUREG 0800 Section 19.4 1.4 - Tracking of Assessment Results None Describes expectations for tracking 10 CFR 50 corrective actions and enhancements Appendix B in either the corrective action program or as commitments as applicable.

Table 1.1 - Summary of Licensee Actions for None None Responding to NRC Information Requests Related to EP

1. Assess staffing for responding to events defined in EP Rule Interim Staff Guidance (ISG) (see Note 2); assessment performed in accordance with NEI 10-05. December 24, 2012 per EP Rule ISG EP Rule ISG 2. Provide an alternative course of action for NSIR/DPR-ISG-01 responding to the Letter. Consider use of NEI 10-05 standard response template from NEI.

10 CFR 50.54(f) Provide within 60 days of the 10 CFR 50.54(f) letter.

letter

3. Communications - provide information on interim actions; respond to Information Request #2. Provide within 90 days of the 10 CFR 50.54(f) letter.

4. Staffing - provide information on augmented staff notifications, methods of site access and interim actions; respond to Information Requests #3, #4 and #5. Provide within 90 days of the 10 CFR 50.54(f) letter.

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Interpretation Gap Assessment / Recommended Action SECTION 1 INTRODUCTION While not specifically addressed in regulation, the None, unless changes are made to communications communications capabilities consistent with capabilities supporting (b)(3) strategies. Changes established guidance are essential elements of should follow the change control process defined in compliance with (b)(3) unless a licensee 10 CFR 50.155(g).

implements an alternate method of compliance.

Review site specific B.5.b SER for details on site specific communications capabilities supporting (b)(3) strategies.

None None. Action completed None None. Action completed Single-unit sites did not need to provide a Phase 1 staffing assessment in response to the 10 CFR 50.54(f) letter as performance of this activity is governed by the recent EP Rule and the existing license requirements.

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Statements of Other 10CFR 50.155 Consideration Requirement or NEI 12-01 Section Guidance Section (ADAMS Accession No.

Guidance ML16292A026)

SECTION 1 INTRODUCTION

5. Communications - perform and provide an None assessment to identify enhancements that may be needed to ensure communications are maintained during a large-scale external event meeting the conditions described in the standard assumptions. Refer to Section 4 of this document [NEI 12-01] for assessment guidance. Develop an implementation schedule. Respond to Requests #1 and #3.

Provide by October 31, 2012.

6. Staffing (phase 1) - perform and provide an assessment of the on-site and augmented staff needed to respond to a large-scale external event meeting the conditions described in the standard assumptions, NOT including staffing needed to implement actions that address NRC Order Modifying Licenses with Regard to Requirements for EP Rule ISG Mitigation Strategies for Beyond-Design-Basis NSIR/DPR-ISG-01 External Events (EA-12-049). Refer to Section 3 NEI 10-05 of this document [NEI 12-01] for guidance.

None 10 CFR 50.54(f) Develop an implementation schedule for staffing changes, and identify changes to the letter emergency plan. Respond to Requests #1, #2 and #6. Provide by April 30, 2013

7. Staffing (phase 2) - perform and provide an assessment of the staffing necessary to implement actions that address NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (EA 049). Perform assessment in conjunction with the development of procedures or guidelines that address the Order. Refer to Section 3 of this document [NEI 1201] for guidance.

Develop an implementation schedule for staffing changes, and identify changes to the emergency plan. Respond to Requests #1, #2 and #6. Provide no later than four (4) months prior to the beginning of the second refueling outage associated with Order EA-12-049 compliance.

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Interpretation Gap Assessment / Recommended Action SECTION 1 INTRODUCTION None None. Action completed Single-unit sites did not need to provide a Phase 1 staffing assessment in response to the 10 CFR 50.54(f) letter as performance of this activity is governed by the recent EP Rule and the existing license requirements.

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Statements of Other 10CFR 50.155 Consideration Requirement or NEI 12-01 Section Guidance Section (ADAMS Accession No.

Guidance ML16292A026)

SECTION 2 ASSESSMENT ASSUMPTIONS 2.1 - Purpose VI. Section-by-Section Analysis, Paragraphs 10 10 CFR 50.54(f) Use assumptions from NEI 12-01 to CFR 50.155(g)(1) and (2),

letter, perform staffing and communication Documentation of Enclosure 5 assessments Changes, pages 132 and 133 Communications guidance for (b)(3) strategies is found in the B.5.b Phase 1 guidance letter dated 2/25/2005 , 2.2 - Assumptions Common to Both Items B.1.i and Assessments B.2.b and NUREG 0800 Section 19.4 Provides specific assumptions to be Acceptance used in the staffing and Criteria Item 12. communications assessments None A staffing assessment may utilize a no site access end time of less than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and greater than or equal to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, if supported by a documented basis. This basis should include a discussion of the site-specific transportation-related resources and capabilities, and related supporting arrangements, which provide assurance that augmented staff would be available on the site starting at the time.

2.3 - Assumptions for Staffing Assessment Provides specific assumptions to be used in the staffing assessments 141

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Interpretation Gap Assessment / Recommended Action SECTION 2 ASSESSMENT ASSUMPTIONS The same assumptions should be used if changes None unless changes are made to 10 CFR are made to 10 CFR 50.155(b)(1) through (b)(3) 50.155(b)(1) through (b)(3) mitigation strategies mitigation strategies that may impact staffing that impact staffing or communications required and/or communications required by the by the respective strategy. Addressed in the respective strategies evaluation of NEI 12-01 Section 3.10 of this matrix, Considerations for Program Documents. Note (c)(4) communications capabilities do not apply to (b)(3) strategies. See guidance documents for EDMG communications capabilities and the NRC SER for EDMGs for assumptions related to communications needed for EDMGs.

The same assumptions should be used if changes None unless changes are made to 10 CFR are made to 10 CFR 50.155(b)(1) through (b)(3) 50.155(b)(1) through (b)(3) mitigation strategies mitigation strategies that may impact staffing that impact staffing or communications required and/or communications required by the by the respective strategy. Addressed in the respective strategies evaluation of NEI 12-01 Section 3.10 of this matrix, Considerations for Program Documents. Note (c)(4) communications capabilities do not apply to (b)(3) strategies. See guidance documents for EDMG communications capabilities and the NRC SER for EDMGs for assumptions related to communications needed for EDMGs.

The same assumptions should be used if changes None unless changes are made to 10 CFR are made to 10 CFR 50.155(b)(1) through (b)(3) 50.155(b)(1) through (b)(3) mitigation strategies mitigation strategies that may impact staffing that impact staffing required by the respective required by the respective strategies strategy. Addressed in the evaluation of NEI 12-01 Section 3.10 of this matrix, Considerations for Program Documents.

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Statements of Other 10CFR 50.155 Consideration Requirement or NEI 12-01 Section Guidance Section (ADAMS Accession No.

Guidance ML16292A026)

SECTION 2 ASSESSMENT ASSUMPTIONS 2.4 - Assumptions for Communications Assessment 10 CFR 50.54(f)

None letter, Provides specific assumptions to be Enclosure 5 used in the communication assessment.

SECTION 3 STAFFING STUDY None 3.1 - Overview of a Beyond Design Basis External Event Response None Background information 10 CFR 50.54(f) 3.2 - Assessment of On-Shift Staffing letter, for a Beyond Design Basis External Enclosure 5 Event Affecting Multiple Units None None Staffing Assessment Phase 1 staffing assessment guidance Action 1 for on-shift minimum staffing.

3.3 - Existing Augmented Staffing for 10 CFR 50.54(f) Responding to a Multi-Unit Event letter, Enclosure 5 Discussion of existing augmented None staffing (ERO) capabilities and that Staffing Assessment they are sufficient to perform Action 1 required functions during a multi-unit beyond design basis event.

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Interpretation Gap Assessment / Recommended Action SECTION 2 ASSESSMENT ASSUMPTIONS The same assumptions should be used if changes None unless changes are made to 10 CFR are made to 10 CFR 50.155(b)(1) and (b)(2) 50.155(b)(1) and (b)(2) mitigation strategies that mitigation strategies that may impact impact communications required by the respective communications required by the respective strategy. Addressed in the evaluation of NEI 12-01 strategies Section 3.10 of this matrix, Considerations for Program Documents.

SECTION 3 STAFFING STUDY None None.

None None. Action completed None None.

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Guidance ML16292A026)

SECTION 3 STAFFING STUDY 3.4 - Expanded Response Capability VI. Section-by-Section for Responding to a Multi-Unit Event Analysis, Paragraph 10 CFR 50.155(b), Integrated Provides guidance for performing Response Capability, page staffing assessments for expanded 113 response capability for responding to a multi-Unit Event. Table 3.1 provides VI. Section-by-Section staffing considerations to support the Analysis, Paragraph 10 CFR 10 CFR 50.54(f) Phase 1 staffing assessment while 50.155(b)(5), Integrated letter, Table 3.2 provides staffing Response Capability, Enclosure 5 considerations to support the Phase 2 Staffing, pages 119 and staffing assessment. 120 Staffing Assessment Actions 1, 2, 5 and 6 10 CFR 50.155(b) 10 CFR 50.155(b)(5) 3.5 - Position-Specific Assessment Guidance Section title, no guidance or actions None 145

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 3 STAFFING STUDY Staffing assessments were completed under the None unless changes are made to 10 CFR 10 CFR 50.54(f) letter and submitted per the 50.155(b)(1) through (b)(3) mitigation strategies required actions of that letter. From the that impact staffing required by the respective Statement of Considerations, there is no intent to strategy. Addressed in the evaluation of NEI 12-01 require current licensees to re-perform those Section 3.10 of this matrix, Considerations for staffing assessments as part of 10 CFR 50.155 Program Documents.

implementation. However, current licensees that performed these staffing assessments should maintain any commitments made in the responses submitted under the 10 CFR 50.54(f)) letter required responses. Changes to those commitments should follow the commitment change process established by the Licensee.

Additionally, Licensees should address the potential impact of changes to the 10 CFR 50.155(b)(1) through (b)(3) mitigation strategies on the staffing assessments that were performed to ensure that staffing remains adequate. The need for this evaluation could come about in one of several ways:

1. Changes to the 10 CFR 50.155(b)(1) through None.

(b)(3) mitigation strategies that involve additional actions, action complexity or that change the sequence of required actions.

2. Changes to minimum staffing requirements that impact the number of staff available to perform required actions.

146

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Guidance ML16292A026)

SECTION 3 STAFFING STUDY 3.5.1 - On-Site Radiation Protection VI. Section-by-Section Technicians Analysis, Paragraph 10 CFR 10 CFR 50.54(f) 50.155(b), Integrated letter, Provides guidance for utilizing RP Response Capability, page Enclosure 5 Technicians to support 113 implementation of coping strategies Staffing Assessment while ensuring other RP Technician VI. Section-by-Section Actions 1, 2, 5 and 6 functions can be maintained. Analysis, Paragraph 10 CFR 50.155(b)(5), Integrated Response Capability, 3.5.2 - Administrative Support Staffing, pages 119 and Personnel 120 10 CFR 50.54(f) letter, Determine if current assignments and Enclosure 5 locations of administrative support personnel are adequate for Staffing Assessment implementation of the expanded Actions 1, 2, 5 and 6 10 CFR response capability, and identify 50.155(b) necessary changes.

10 CFR 3.6 - Staffing for Expanded Response 50.155(b)(5) Functions Ensure the availability of a sufficient number of personnel to perform expanded response functions. This may be done using one or more of 10 CFR 50.54(f) the methods provided in NEI 12-01 letter, Section 3.6.

Enclosure 5 Personnel identified by the staffing Staffing Assessment assessment as necessary for Actions 1, 2, 5 and 6 performing a planned or expected response action should be provided with appropriate training. Consider the applicability of the training requirements specified in 10 CFR 50, Appendix E and related guidance.

147

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Interpretation Gap Assessment / Recommended Action SECTION 3 STAFFING STUDY

3. Changes in how minimum staff are utilized (e.g., None unless changes are made to 10 CFR staffing assessment may have included or 50.155(b)(1) through (b)(3) mitigation strategies excluded security personnel and the Licensee that impact staffing and utilization of RP resources changes that approach). See NEI white paper that impact staffing required by the respective guidance in "Generic Basis for Responses to strategy. Addressed in the evaluation of NEI 12-01 Staffing Assessment Questions Related to Use of Section 3.10 of this matrix, Considerations for Security Personnel during a BDB Event Response" Program Documents.

dated November 20, 2013 for changes related to the use of Security personnel None unless changes are made to 10 CFR

4. Feedback from drills or exercises may also 50.155(b)(1) through (b)(3) mitigation strategies prompt a staffing re-evaluation. that impact staffing and utilization of administrative support personnel that impact staffing required by the respective strategy.

Addressed in the evaluation of NEI 12-01 Section 3.10 of this matrix, Considerations for Program Documents.

None unless changes are made to 10 CFR 50.155(b)(1) through (b)(3) mitigation strategies that impact staffing required by the respective strategy. Addressed in the evaluation of NEI 12-01 Section 3.10 of this matrix, Considerations for Program Documents.

For drills, exercises and training conducted to meet the requirements of 10 CFR 50.155, verify that critique and training feedback mechanisms include consideration of staffing and communications capabilities.

148

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SECTION 3 STAFFING STUDY 3.7 - Work Areas for Personnel Continued from previous Performing Expanded Response page Statement of 10 CFR 50.54(f) Functions Consideration letter, Identify additional work areas Enclosure 5 necessary for the performance of expanded response functions. The Staffing Assessment use of alternate emergency response 10 CFR facilities should be considered.

Actions 2 through 6 50.155(b) 10 CFR 50.155(b)(5) 3.8 - Activating an Expanded Continued from previous Response Capability page Statement of Continued Consideration from previous 10 CFR 50.54(f) Develop an implementing strategy to page letter, integrate the expanded response Enclosure 5 capability into the existing augmented ERO. Such a strategy would include Staffing Assessment decision making criteria for initiating Actions 2 through 6 the actions necessary to ensure timely performance of expanded response functions.

149

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 3 STAFFING STUDY Continued from previous page Interpretations None unless changes are made to 10 CFR 50.155(b)(1) through (b)(3) mitigation strategies or to work areas that impacts or changes the work areas required by the respective strategy.

Addressed in the evaluation of NEI 12-01 Section 3.10 of this matrix, Considerations for Program Documents.

Continued from previous page Interpretations None unless changes are made to 10 CFR 50.155(b)(1) through (b)(3) mitigation strategies or to the activation of expanded response capability that impacts or changes the activation of integrated response capability required by the respective strategy. Addressed in the evaluation of NEI 12-01 Section 3.10 of this matrix, Considerations for Program Documents.

150

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SECTION 3 STAFFING STUDY Continued 3.9 - Mobilization of Expanded from previous Response Capability Staffing page Identify appropriate alternate transportation resources and access enhancing measures that would be used to facilitate timely staff 10 CFR 50.54(f) augmentation during or following an letter, event that cause impeded access to Enclosure 5 the site.

Staffing Assessment A listing of resource providers should Actions 2 through 6 be developed and made available to appropriate ERO personnel.

Some arrangements may require a written agreement.

3.10 - Considerations for Program Documents Development of, and changes to, procedures 10 CFR 73.58 or guidelines that implement extended loss of AC power and SAM strategies should be 10 CFR 50.54(p) assessed to determine if emergency response 10 CFR 50.54(q) staffing levels are impacted. The establishment of appropriate administrative 10 CFR 50.54(f) controls should be considered.

letter, Enclosure 5 Determine if any changes are necessary to documents describing the emergency response drill and exercise program. In Staffing Assessment particular, standard objectives and extent-of-Actions 2, 5 and 6 play may need to be revised to clarify the expected demonstration of functions that are NUREG 0800 dependent up the type of scenario event or Section 19.4 accident. Note - guidance to meet the drill and exercise requirements of 10 CFR 50.155(e) was subsequently issued in NEI 13-B.5.b Phase 1 06. Sites should follow guidance in that Guidance Letter document, including any changes to Dated 2/25/2005 objectives to extent-of-play.] For example, functions associated with an expanded response capability would not be demonstrated during a drill or exercise that involved a design basis accident affecting only one unit.

151

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 3 STAFFING STUDY Continued from previous page None unless changes are made to 10 CFR 50.155(b)(1) through (b)(3) mitigation strategies or Although this section of NEI 12-01 applies to to the access enhancing measures put in place to staffing, the section itself addresses program support the respective strategies that impacts or document considerations including the control of changes the access enhancing measures required changes. NEI 12-01 Section 4, Communications by the respective strategy. Addressed in the during an Extended Loss of AC Power, does not evaluation of NEI 12-01 Section 3.10 of this matrix, contain an equivalent section. The new rule, 10 Considerations for Program Documents.

CFR 50.155, imposes requirements on the configuration control of communications equipment supporting the various strategies of the rule. The use of this section to address communications is a logical extension of its purpose.

Changes impacting staffing or staffing assessments Verify the applicable change control process (e.g., 10 supporting (b)(1) through (b)(3) strategies should CFR 50.155(g) as implemented in the FLEX program be evaluated per the following change control document) contains adequate administrative controls processes as applicable:

for the identification of impacts to staffing and

• 10 CFR 50.155(g) communications assessments that may impact the

• 10 CFR 50.54(p) implementation of 10 CFR 50.155(b) strategies.

• 10 CFR 50.54(q) Specific elements to consider as it relates to a BDB

• 10 CFR 73.58 event:

Changes impacting communications capabilities

- Utilization of RP, Security and administrative support supporting (b)(1) through (b)(3) strategies should resources be evaluated per the 10 CFR 50.155(g) and if - Changes to work areas to be utilized by applicable, 10 CFR 50.54(q). However, the staff responding to an event evaluation of changes supporting (b)(1) and (b)(2) - Changes to expanded response capabilities strategies must continue to comply with 10 CFR and procedures 50.155(c)(4) while changes supporting (b)(3) - Changes to access enhancing measures strategies must continue to conform with applicable EDMG guidance such as the B.5.b Phase Change control processes defined by 10 CFR 50.54(p),

1 guidance letter dated February 25, 2005, Items 10 CFR 50.54(q) and 10 CFR 73.58 in addition to 10 CFR B.1.i and B.2.b or NUREG 0800 Section 19.4, 50.155(g) should also be considered for the above Acceptance Criteria 12. Licensees should refer to changes.

site specific NRC SER for EDMGs when evaluating what constitutes a change in communication capability supporting (b)(3) strategies.

152

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SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.1 - Required Emergency None Communications Capabilities Ensure availability of existing capabilities consistent with the assumptions listed in NEI 12-01 Section 2, in particular the availability 10 CFR 50.54(f) of primary and backup power sources letter, for each communication system or Enclosure 5 piece of equipment identified.

Communications Ensure each piece of Assessment Action 1 equipment/communications channel is used solely for the purpose indicated (don't double credit available equipment).

None Consider some communications capabilities in alternate facilities at offsite locations instead of their normal locations in on-site facilities.

4.1.1 - Notifications to, and None None communications with OROs Provides minimum communications links for Control Room, TSC and EOF 4.1.2 - Notifications to, and None communications with the Nuclear None Regulatory Commission Provides minimum communications links for Control Room, TSC and HPN 153

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER existing capabilities as used in the context of NEI None 12-01 Section 4.1 means the capabilities that existed prior to communications capability enhancements made in response to the 10 CFR 50.54(f) letter.

This section is intended to define minimum Use 10 CFR 50.155(g) to evaluate changes in communications capabilities supporting the capability supporting strategies required by (b)(1)

Emergency Plan. though (b)(3). Use 10 CFR 50.54(q) to evaluate changes in capability supporting the Emergency Plan, if applicable.

This section is intended to define minimum Use 10 CFR 50.155(g) to evaluate changes in communications capabilities supporting the capability supporting strategies required by (b)(1)

Emergency Plan. though (b)(3). Use 10 CFR 50.54(q) to evaluate changes in capability supporting the Emergency Plan, if applicable.

154

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SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.1.3 - Communications between None licensee emergency response facilities None Provides minimum communications links for Emergency Response Facilities (Control Room, TSC, OSC, EOF and JIC) 4.1.4 - Communications with None None field/offsite monitoring teams Provides minimum communications links for field teams None 4.1.5 - Communications with other None Federal agencies as described in the site emergency plan None Provides minimum communications links with other Federal agencies (as needed to provide coordination with Federal agencies) 4.1.6 - Communications with on-site None and inplant response teams None Assessment conducted in two phases as described in subsection 4.1.6.1 and 4.1.6.2 155

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER This section is intended to define minimum None. Use 10 CFR 50.155(g) to evaluate changes in communications capabilities supporting the capability supporting strategies required by (b)(1)

Emergency Plan. though (b)(3). Use 10 CFR 50.54(q) to evaluate changes in capability supporting the Emergency Plan, if applicable.

This section is intended to define minimum None. Use 10 CFR 50.155(g) to evaluate changes in communications capabilities supporting the capability supporting strategies required by (b)(1)

Emergency Plan. though (b)(3). Use 10 CFR 50.54(q) to evaluate changes in capability supporting the Emergency Plan, if applicable.

This section is intended to define minimum None. Use 10 CFR 50.155(g) to evaluate changes in communications capabilities supporting the capability supporting strategies required by (b)(1)

Emergency Plan. though (b)(3). Use 10 CFR 50.54(q) to evaluate changes in capability supporting the Emergency Plan, if applicable.

None None 156

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SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.1.6.1 - Phase 1 assessment None 10 CFR 50.54(f)

Provides minimum communications letter, links necessary to support the Enclosure 5 functions of radiological monitoring, Communications firefighting, search and rescue, None Assessment emergency repairs and any two Action 1 severe accident mitigation strategies 10 CFR 50.54(f) 4.1.6.2 - Phase 2 assessment VI. Section-by-Section letter, Analysis, Paragraph 10 CFR Enclosure 5 Provides site specific minimum 50.155(C)(4),

Communications communication links needed to Communications Equipment, Assessment implement any two strategies pages 125 and 126 Actions 1, 2 and 3 developed in response to NRC Order VI. Section-by-Section EA-12-049 for the OSC and other site-NEI 99-04 Analysis, Paragraph 10 CFR specific locations as necessary 50.155(e), Drills or 10 CFR Exercises, pages 127 and 50.155(c)(4) 130 10 CFR 50.155(e) 10 CFR 50.155(g) 4.1.7 - Other communications links based on site-specific needs None identified during the [Phase 2]

assessment 157

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER None None. Action completed in licensee response described in Action #5 in NEI 12-01 Table 1.1 Communications assessments were completed under the 10 1. Verify drill or exercise critiques and training feedback CFR 50.54(f) letter and submitted per the required actions of mechanisms include consideration of staffing and that letter. From the Statement of Considerations, there is communications capabilities and assessments in the performance of 10 CFR 50.155 related drills, exercises and no intent to bind current Licensees to providing the training.

communications capabilities discussed in responses to the 2. Verify the applicable change control process (e.g., 10 CFR 50.54(f) letter as part of 10 CFR 50.155 implementation. 50.155(g) as implemented in the FLEX program document)

However, licensees that performed these communication contains adequate administrative controls for the assessments should review commitments made in the identification of potential impacts to communications responses submitted under the 10 CFR 50.54(f) letter and capabilities required t o implement of 10 CFR 50.155(b) strategies. Specific elements to consider as it relates to a BDB confirm they comply with 10 CFR 50.155(c)(4). Commitments event include:

found to meet the communications requirements of the rule

• Changes to capabilities and use of the plant paging system should be treated as obligations subject to the 10 CFR

• Changes to communications capabilities to off-site 50.155(g) change control process while remaining response organization facilities commitments remain under licensee control per NEI 99-04 Change control processes defined by 10 CFR 50.54(p), 10 CFR and site specific commitment control process. Additionally, 50.54(q) and 10 CFR 73.58 in addition to 10 CFR 50.155(g)

Licensees should address the potential impact of plant should also be considered for the above changes.

changes on communications capabilities needed to support 3. Include a demonstration of the associated communications capability when conducting the initial drill or exercise that 10 CFR 50.155(b)(1) through (b)(3) mitigation strategies to demonstrates the capability to transition to and use one or ensure the capabilities remain adequate. more of the strategies and guidelines in either paragraphs (b)(1), (b)(2) or (b)(3) of 10 CFR 50.155. This drill or exercise Licensees that make changes to communications capability must be completed within four years of the effective date of the related commitments should consider the acceptable rule.

approaches for addressing the communications 4. Confirm communications capabilities committed to in response to the 50.54(f) letter comply with the requirements of 10 CFR requirements of 10 CFR 50.155(c)(4) provided in RG 1.228, 50.155(c)(4).

"Integrated Response Capabilities for Beyond Design-Basis a. Determine which commitments will remain commitments Events". subject to licensee control per NEI 99-04 and the site specific commitment change process.

Feedback from drills or exercises may also prompt a b. Determine which commitments should be treated as communications re-evaluation. obligations subject to the change control process defined in 10 CFR 50.155(g).

c. Treat as obligations all communications capabilities credited with supporting 10 CFR 50.155(b)(1) and (b)(2) strategies, although not necessarily included in the communications assessments (e.g., may be included in the Final Integrated Plan (FIP) or Mitigation Strategies Assessment (MSA)) )performed in response to the 50.54(f) letter necessary for compliance with 10 CFR 50.155(c)(4).

d. Treat all communications capabilities credited with supporting 10 CFR 50.155(b)(3) strategies as obligations subject to the change control process in 10 CFR 50.155(g).

None unless changes are made to 10 CFR 50.155(b)(1) through (b)(3) mitigation strategies that impact communications required by the respective strategy. Changes are addressed under NEI 12-01 Section 4.1.6.2, Phase 2 Assessment.

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SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.2 - Plant Paging (Announcement) (continued from previous 10 CFR 50.54(f) System Page Statements of letter, Consideration)

Enclosure 5 Perform this assessment if the plant paging (announcing) system is Communications described in the site emergency plan Assessment as a method to communicate initial Actions 1, 2 and 3 response instructions to the plant B.5.b Phase 1 staff. After the initial announcement Guidance Letter for personnel to report to assigned Dated 2/25/2005 emergency response facilities or NUREG 0800 assembly area, the plant paging Section 19.4 system is no longer required.

4.2.1 - The following assessment 10 CFR None actions should be performed:

50.155(c)(4) 4.2.1.1 - Determine if the plant-paging system is powered from a 10 CFR battery-backed source and would 50.155(e) 10 CFR 50.54(f) remain available to provide the initial (continued letter, emergency declaration and direction from previous Enclosure 5 announcement to the plant staff.

page)

Communications 4.2.1.2 - If the plant-paging system is Assessment powered from a battery-backed Actions 1, 2 and 3 source, then no further action is required in this area.

B.5.b Phase 1 4.2.1.3 - If portions of the plant-Guidance Letter paging system are not powered from Dated 2/25/2005 a battery-backed source, then reasonable alternate methods should NUREG 0800 exist to provide emergency Section 19.4 notification to plant staff in the areas that would not receive an announcement. These methods should be capable of notifying essentially 100% of the plant staff within approximately 30 minutes 159

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER (continued from previous page) None unless the emergency plan is changed to include the plant paging system. Changes are addressed under N E I 1 2 - 0 1 Section 4.1.6.2, Phase 2 Assessment.

None None unless the emergency plan is changed to include the plant paging system or if the power supply to the plant paging system is changed in a way that impacts capabilities assumed in the assessment. Changes are addressed in the evaluation of NEI 12- 01 Section 4.1.6.2, Phase 2 Assessment.

160

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SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.2.1.4 - If the plant-paging system is (continued from previous 10 CFR 50.54(f) not powered from a battery-backed Page Statements of source, then perform some Consideration) letter, Enclosure 5 combination of the following actions:

1. Provide a battery-backed power Communications source for all portions of the plant-Assessment paging system Actions 1, 2 and 3

( 2. Establish reasonable alternate methods as needed to provide B.5.b Phase 1 emergency notification to the plant Guidance Letter staff. These methods should be Dated 2/25/2005 capable of notifying essentially 100%

of the plant staff within approximately NUREG 0800 30 minutes.

Section 19.4 10 CFR 50.155(c)(4) 4.3 - Communications Equipment at 10 CFR ORO Facilities 50.155(e)

(continued 10 CFR 50.54(f) Some communications capability from previous letter, should be available at the ORO page) Enclosure 5 facilities that normally receive licensee notifications of an emergency Communications declaration or a Protective Action Assessment Actions Recommendation (as described in the 1, 2 and 3 site emergency plan). Through discussions with ORO and other B.5.b Phase 1 appropriate personnel, identify the Guidance Letter communications equipment that Dated 2/25/2005 would remain operable during an extended loss-of-grid event. This NUREG 0800 determination should be made Section 19.4 consistent with the assumptions listed in Section 2.

161

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER (continued from previous page Interpretation) (continued from previous page Gap Assessment /

Recommended Action)

None unless changes are made to the communications capabilities to the ORO facilities that impacts this communication capability.

Changes are addressed in the evaluation of NEI 12-01 Section 4.1.6.2, Phase 2 Assessment.

162

June 8, 17 NEI 17-03, [Rev A]

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SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.4 - Notification of the Emergency (continued from previous Response Organization (ERO) Page Statements of Consideration)

To promote timely staff augmentation by the ERO, licensees should verify the following:

10 CFR ERO members can be notified of the 10 CFR 50.54(f) emergency using a method that 50.155(c)(4) letter, would be operable under the Enclosure 5 10 CFR 50.155(e) assumed event conditions (e.g.,

Communications (continued satellite pagers), AND/OR Assessment Actions from previous 1, 2 and 3 page) ERO members are trained to automatically respond to their B.5.b Phase 1 assigned facilities or a designated Guidance Letter staging area when made aware of an Dated 2/25/2005 area wide loss-of-grid (e.g., by direct observation, media reports, word-of-NUREG 0800 mouth, etc.).

Section 19.4 The information developed from this section should be included in the licensee response described in Action

1. 4 of Table 1.1.

163

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER (continued from previous page Interpretation) None unless changes are made to the communications capabilities, training or procedures that impacts the capability to notify the Emergency Response Organization during an area wide loss of grid. Changes are addressed in the evaluation of NEI 12-01 Section 4.1.6.2, Phase 2 Assessment.

164

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SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.5 - Equipment Location Requirements (continued from previous Page Statements of To be assumed operable, a piece of on-site Consideration) communications equipment should be in a location, and maintained in a manner, that maximizes survivability following a beyond design basis external event. In particular, the location or manner should reasonably preclude wetting from flooding or impact damage from a seismic event. The equipment itself does not need to be seismically qualified.

10 CFR 10 CFR 50.54(f) 50.155(c)(4) Equipment should be stored, or otherwise letter, available, in locations that can be readily Enclosure 5 accessed when needed. To the degree 10 CFR practical, consider potential constraints to 50.155(e)

Communications equipment access or movement when (continued Assessment Actions When selecting storage locations, consider from previous criteria presented in regulatory and industry 1, 2 and 3 page) guidance applicable to equipment associated with NRC Order Modifying Licenses with B.5.b Phase 1 Regard to Requirements for Mitigation Guidance Letter Strategies for Beyond-Design-Basis External Dated 2/25/2005 Events (e.g., FLEX equipment).

The above guidance applies to equipment at NUREG 0800 the point of use (e.g., a radio) as well as any Section 19.4 supporting infrastructure components. Such components may include portable power sources, and radio system repeaters and antennas.

165

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER (continued from previous page Interpretation) None unless changes are made to communications equipment storage locations for communications equipment needed to support 10 CFR 50.155(b)(1) through (b)(3) mitigation strategies that impact communication capabilities required by the respective strategy. Changes are addressed in the evaluation of NEI 12-01 Section 4.1.6.2, Phase 2 Assessment.

Licensees should review site specific NRC SERs for EDMGs when evaluating what constitutes a change in communication storage locations supporting (b)(3) strategies.

166

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SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.6 - Performance Characteristics (continued from previous Page Statements of The assessment should confirm that the Consideration) systems and equipment identified for usage will support communications among and between:

Licensee emergency response facilities, including Security Field/offsite monitoring teams and the location controlling deployment of the teams (e.g., the EOF)

The Shift Communicator, Key TSC and EOF Communicators, and the ORO contact points.

10 CFR 10 CFR 50.54(f) ENS and HPN communicators and the NRC 50.155(c)(4) letter, staff.

Enclosure 5 10 CFR On-site and in-plant teams and the location 50.155(e) controlling deployment of the teams (e.g., the Communications OSC)

(continued Assessment Actions from previous 1, 2 and 3 The assessment should also verify that a radio page) system(s) used by ERO personnel possesses B.5.b Phase 1 the necessary design and operating characteristics to adequately support Guidance Letter Dated 2/25/2005 Expected reliance upon multi-use equipment should be minimized. This means NUREG 0800 that communications equipment used to implement emergency response functions Section 19.4 should not be relied upon to simultaneously support other functions (e.g., Security). In cases where multiple-usage is unavoidable, the assessment should consider the capability of the equipment to effectively perform under the expected conditions and the need for specific multi-use protocols.

167

June 8, 17 NEI 17-03, [Rev A]

Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER (continued from previous page) None unless changes are made to communications equipment performance characteristics for communications equipment needed to support 10 CFR 50.155(b)(1) through (b)(3) mitigation strategies that impact communication capabilities required by the respective strategy. Changes are addressed under NEI 12-01 Section 4.1.6.2, Phase 2 Assessment.

Licensees should review site specific NRC SERs for EDMGs when evaluating what constitutes a change in communication performance characteristics supporting (b)(3) strategies.

168

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SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.7 - Other Assessment Considerations (continued from previous Page Statements of A portable backup AC power source for Consideration) communications systems and components may be credited as operable provided that it is consistent with the assumptions and requirements discussed above, including location requirements. The assessment 10 CFR 50.54(f) should consider the amount of power source letter, fuel available on-site (e.g., available fuel will Enclosure 5 support the expected run time).

10 CFR 50.155(c)(4) Communications For battery-operated equipment, there Assessment Actions should be a sufficient number of on-site and 10 CFR 1, 2 and 3 charged batteries to support operation of 50.155(e) required equipment. This number should be determined with consideration given to the (continued B.5.b Phase 1 following items.

from previous Guidance Letter page) Dated 2/25/2005 A sufficient number of charged batteries should be available at the start of an event to support performance of the required NUREG 0800 emergency response functions listed in Section 19.4 Section 4.1, Required Emergency Communications Capabilities.

Use the vendors stated minimum reliable operability period for a fully-charged battery.

This information may be modified if supported by a documented basis.

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Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER These additional assessment considerations are only None unless changes to communications capability applicable to communications capabilities supporting requires an assessment of the modified capability.

(b)(1) and (b)(2). Considerations for communications If an assessment is required, these considerations capabilities supporting (b)(3) are contained in NUREG 0800 Section 19.4 Acceptance Criteria Item 12 and the should be considered. Addressed in the evaluation B.5.b Guidance Letter dated 2/25/2005, Items B.1.i and of NEI 12-01 Section 4.1.6.2, Phase 2 Assessment.

B.2.b.

Licensees should review site specific NRC SERs for EDMGs when evaluating what constitutes a change in communication assessment considerations such as power supplies, quantity of batteries and radios and functionality duration for fully charged batteries supporting (b)(3) strategies.

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Statements of Other 10CFR 50.155 Consideration Requirement or NEI 12-01 Section Guidance Section (ADAMS Accession No.

Guidance ML16292A026)

SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.7, Continued from the previous page: (continued from previous Page Statements of The availability of on-site battery charging Consideration) capability. Credit may be given to power source(s) and battery charging equipment consistent with the assumptions and requirements discussed above, including location requirements.

Delivery of replacement batteries may be assumed to occur any time after T + 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The assessment should consider whether the batteries are delivered in a charged or uncharged state, and if uncharged, the time 10 CFR 10 CFR 50.54(f) required for on-site charging.

50.155(c)(4) letter, Enclosure 5 Manual actions taken by emergency 10 CFR responders to facilitate the use of a particular 50.155(e) Communications means of communication may be credited Assessment Actions provided that these actions are described in a response procedure or guideline. For Continued 1, 2 and 3 example, radio communication relay zones from previous (continued from the may be employed if a procedure or guideline page previous page) provides direction on where personnel need to be located and their equipment. The B.5.b Phase 1 personnel necessary to implement these Guidance Letter manuals methods should be considered when determining required response staffing.

Dated 2/25/2005 NUREG 0800 A licensee should coordinate with the Section 19.4 Institute of Nuclear Power Operations (INPO) to identify communications equipment that may be obtained from industry sources and consider methods for making this information readily available to emergency managers.

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Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER (continued from previous page Interpretation) (continued from previous page Gap Assessment /

Recommended Action) 172

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Guidance ML16292A026)

SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.8 - Quality and Maintenance-Related (continued from previous Requirements Page Statements of Consideration)

Communications equipment, and related power sources and infrastructure, may be purchased and installed under the site requirements normally applied to other EP equipment. It is desirable that the equipment to be commonly available (e.g. commercial equipment) such that parts and replacements can be readily obtained.

Programmatic controls should be applied to all communications-related equipment to ensure availability and reliability, including the performance of periodic inventory checks 10 CFR and operability testing.

50.155(c)(4) 10 CFR 50.54(f)

Supporting contracts with vendors should be letter, periodically verified.

10 CFR Enclosure 5 50.155(e) The guidance contained in INPO 10-007, Communications Equipment Important to Emergency Continued Assessment Actions Response, should be reviewed for applicability.

from previous 1, 2 and 3 4.9 - National Communications System (NCS) page B.5.b Phase 1 Services Guidance Letter Dated 2/25/2005 To enhance overall communications capabilities, each licensee should verify that they have arrangements in place to utilize the NUREG 0800 services offered by the NCS to the degree Section 19.4 possible. These services include access to the Government Emergency Telecommunications Service (GETS), the Telecommunications Service Priority (TSP) program and the Wireless Priority Service (WPS). Information concerning these services may be obtained from their web site

- http://www.ncs.gov/

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Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER (continued from previous page) Verify that communications equipment procurement specifications or purchasing documents are consistent with The National Communications System (NCS) and the requirements normally applied to other EP equipment and associated website www.ncs.gov were disbanded by should be commonly available, commercial grade with Executive Order 13618 on July 6, 2012. The guidance in readily available parts and replacement.

NEI 12-01 states that licensees are to verify that they have arrangements in place to utilize the services Verify that communications equipment necessary to offered by the NCS to the degree possible. Information implement 10 CFR 50.155(c)(4) or to implement 10 CFR related to communications services provided through 50.155(b)(3) strategies in support of (b)(1) and (b)(2)

NCS may be obtained on the Department of Homeland strategies is included in inventory checklists and is periodically verified functional with periodic maintenance Security website https://www.dhs.gov/office-tasks and frequencies defined.

emergency-communications under the Response Support section of the web page. Verify communications equipment necessary to support (b)(3) is included in inventory checklists and is periodically Services that were provided through NCSS include verified functional with periodic maintenance tasks and access to: frequencies defined.

• Government Emergency Telecommunications Verify that communications equipment contracts with Service (GETS) vendors supporting communications equipment necessary to implement 10 CFR 50.155(c)(4) are maintained current

• Telecommunications Service Priority (TSP) and periodically verified.

• Wireless Priority Service (WPS) Verify agreements with communications providers of Emergency Services (e.g., satellite phone service) are maintained current and periodically verified.

Verify agreements with communications service providers that enable access to Government Emergency Telecommunications Service (GETS), the Telecommunications Service Priority (TSP) programs and the Wireless Priority Service (WPS) are maintained current and periodically verified. Information related to these services may be obtained from https://www.dhs.gov/office-emergency-communications, under the Response Support section of the web page. Note that the National Communications Service (NCS) referenced in NEI 12-01 was disbanded by Executive Order 13618 on July 6, 2012 and the cited website is no longer functional.

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Guidance ML16292A026)

SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER 4.10 - Communications Provider (continued from previous Emergency Services page Statements of Consideration)

To enhance overall communications capabilities, each licensee should verify that they have arrangements in place to utilize the emergency services offered by their 10 CFR communications service provider(s) to 50.155(c)(4) 10 CFR 50.54(f) the degree possible. As one example, letter, see services offered by Verizon -

10 CFR Enclosure 5 http://www.verizonbusiness.com/Pro 50.155(e) ducts/communications/emergency/

Communications Continued Assessment Actions from previous 1, 2 and 3 4.11 - Personnel Training page B.5.b Phase 1 Guidance Letter Response personnel should receive Dated 2/25/2005 periodic training on the location and use of communications systems and NUREG 0800 equipment.

Section 19.4 NOTES:

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Interpretation Gap Assessment / Recommended Action SECTION 4 COMMUNICATIONS DURING AN EXTENDED LOSS OF AC POWER (continued from previous page Interpretation) Verify agreements with communications providers of Emergency Services (e.g., satellite phone service) are maintained current and periodically verified.

There are no direct training requirements associated with communications equipment defined in 10 CFR 50.155. However, to the extent that the deployment and use of communications equipment is necessary to successfully implement the strategies required by 10 CFR 50.155(b)(1) through (b)(3), training on communications location, deployment and use should be considered under 10 CFR 50.155(d).

NOTES:

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9 NEI 13-06 COMPARISON Introduction To assist in implementing 10 CFR 50.155, a gap assessment of NEI 13-06, Revision 1 has been performed. That process involved preparing a matrix to facilitate review of the following references to assess potential gaps that a licensee may encounter during implementation of 10 CFR 50.155 and identify the recommended actions to close those gaps .

NRC R G 1.228 Integrated Response Capabilities for Beyond Design Basis Events identifies methods and procedures the NRC considers acceptable for compliance with 10 CFR 50.155 Mitigation of Beyond-Design-Basis Events. The staff position is that NEI 13-06 provides an acceptable method for enhancing the on-site emergency response capabilities for beyond-design-basis events through training, drills or exercises, and facilities and equipment to support a multi-unit event response. The NRC position does not include any exceptions or clarifications.

It is important to note that Revision 1 of NEI 13-06 was drafted based on an early v e rsion of the proposed 10CFR50.155 rule. As such, some sections of NEI 13-06 address proposed requirements of the early rule draft that do not exist in the final version. In particular, both the Multi Source Term Dose Assessment capability (MSTDA) and Severe Accident Mitigation Guideline (SAMG) requirements were removed from the draft final rule language. These capabilities have been implemented through the licensee Regulatory Commitment process,(i.e. process described in NEI 99-04) and are managed according to that process.

It should also be noted that NEI 12-06 has been revised since the publication of NEI 13-06. Changes to 12-06 have made some of the discussion in the Executive summary of 13-06 obsolete. Specifically, the sentence in the Executive Summary that quotes from NEI 12-06, Section 11.6, 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. This quote is no longer accurate, as it was removed in Revision 4 of 12-06. NEI 12-06 now refers back to 13-06 for guidance related to drills, noting that Industry guidance for conducting FLEX drills is provided in NEI 13-06.

Summary of GAP Assessment/Recommended Actions The recommended actions identified by the gap assessment review are provided in the Gap Assessment /

Recommended Action column of the matrix and are summarized below.

1. To meet the 13-06 guidance a site must have the capability to predict offsite doses (including dose from multiple source terms) during an event involving an extended loss of all AC power affecting all onsite units. Previously, the commitment to perform this did not require the assumption of an extended loss of AC power. Even though not required by the rule, licensee regulatory commitments include the capability to predict dose from multiple source terms.

2. An ERO role identified as Ultimate Decision Maker is defined. This individual is assigned authority and responsibility for providing overall direction on the implementation of EOPs, FSGs, EDMGs and SAMGs for a unit or set of units.

3. On an eight (8) year frequency, sites must conduct drills demonstrating BDB strategies (including communications capabilities), including;

a. 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.

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b. 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. Even though not required by the rule, licensee regulatory commitments include SAMGs to be integrated with the EOP network.

c. A drill that demonstrates the use of EDMG strategies.

d. 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.

It is important to note that while it is acceptable to use an EP exercise to accomplish the new drill requirements, it is recommended that exercises not be used to meet these requirements. Graded exercises serve a specific purpose to meet the regulatory required emergency planning requirements. Combining BDB drills with a graded exercise could lead to confusion and conflicts that interfere with objectives of either or both of the activities.

User Notes Due to the large size of this matrix, it has been formatted to extend across two adjacent facing pages Users performing gap assessments for implementation of 10 CFR 50.155 should consider the following guidance when performing their gap assessments:

• Information in the NEI 13-06 Section Guidance column of the matrix is only a summary of the guidance from the indicated section. Users are encouraged to refer to the specific section of NEI 13-06 for a full understanding of the fully stated guidance.

• The matrix follows the outline of NEI 13-06. An explanation of the information in each column of the matrix follows:

o 10 CFR 50.155 Section - Sections of the rule that are applicable to the guidance in the section of NEI 13-06 being addressed.

o Other Requirement or Guidance - Other documents that relate to the guidance in the section of NEI 13-06 being addressed.

o Section Guidance - A general description or outline of the information provided in the section of NEI 13-06 being addressed.

o Statements of Consideration - Provides the Statements of Consideration (SOC) section number and title when a SOC passage provides information relevant to the section of NEI 13-06 being addressed. In addition, a page reference is sometimes provided to indicate where the discussion on the specific subject can be found.

o Interpretation - Background or further explanation of the guidance in NEI 13-06.

o Proposed Action - Captures any generic actions being undertaken by the industry to address the item or recommends actions that should be taken by a utility.

Also see Section 3.0, General Matrix Usage, for general usage information.

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Section or Guidance ML16292A026)

SECTION 1 INTRODUCTION V.C "Applicability", pg. 60 V.C "EDMGs" pg. 79 (a)(1) NA 1.1 SCOPE AND PURPOSE OF NEI 13-06 VI "Paragraph 50.155(a) "Applicability"", pg.

111 SECTION 2 MULTI-UNIT DOSE ASSESSMENT 2.1 APPLICABLE ASPECTS OF NRC NTTF SECTION 2 MULTI-UNIT DOSE ASSESSMENT REPORT RECOMMENDATIONS IV.E "Multiple Source Term Dose Assessment",

pg. 28 2.1.1 Recommendation 9 2.2 RELATED REFERENCE DOCUMENTS 2.3 RECOMMENDED ACTIONS 2.3.1 Industry Performance Standard for Multi-Unit Dose Assessment Current release from all units/release MSTDA NA (1) points Commitment Computerized Alternate methods if normal data sources unavailable May develop backup methods (e.g.

manual)

May require backup power or capabilities at location away from site Review with ORO agencies 179

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Interpretation Gap Assessment / Recommended Action SECTION 1 INTRODUCTION None None SECTION 2 MULTI-UNIT DOSE ASSESSMENT Section IV Public Comment and Changes to the Rule All sites should have Multi Source Term Dose Assessment provides the NRC response to comments and the draft rule. (MSTDA) capability in place as a result of the industry-wide commitment. Controls to ensure this capability is maintained This requirement was removed from the final language as are typically managed through the Site commitment the NRC concluded that there is not sufficient risk management program.

associated with events that challenge multiple source terms to find that substantial additional protection to public Section 2.3.1 of 13-06 states that the capability should be health and safety could be achieved through the imposition available to support responses during events both within and of the subject requirements beyond the plant design basis. In particular, the capability should exist to project offsite doses during an extended loss of AC power affecting all onsite units. There exists a potential gap in that not all licensees provide this capability as part of their implementation of the multi-source term dose assessment commitment. This may require the addition of backup power to onsite dose assessment computing platforms or ensuring the availability of computing platforms away for the site.

Specific actions include;

1) Maintain MSTDA Commitment consistent with Licensee specific letter, and 2 confirm capability to project offsite doses during an extended loss of AC power (ELAP) 180

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SECTION 2 MULTI-UNIT DOSE ASSESSMENT 2.3.2 Emergency Classification and Continued from previous page Protective Action Recommendations Results should be assessed in accordance with the licensees existing emergency classification scheme and Protective Action Recommendation (PAR) decision-making process.

Verify that the capability exists to issue a PAR for areas beyond the (EPZ) boundary Address the following points in procedure or guideline that implements the multi-unit dose assessment capability.

• Projected doses should be compared against EALs to determine if a change in the emergency classification is MSTDA NA (1) warranted.

Commitment

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

2.3.3 Training None Training on MSTDA is to be per the SAT process 2.3.4 Performance Enhancing None Experience Periodic opportunities for a performance enhancing experience should be provided to personnel responsible for performing multi source term dose assessment 181

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Interpretation Gap Assessment / Recommended Action SECTION 2 MULTI-UNIT DOSE ASSESSMENT Continued from previous page Continued from previous page Training on new requirements should be performed per None the SAT process. However, per 3.3.1 and the SOC, elements already covered under other NRC regulations can be addressed in a non-SAT training program that is acceptable for meeting that specific regulatory requirement (e.g., 10 CFR part 50, appendix E, section IV.F)

None None 182

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10CFR Other Statements of Consideration 50.155 Requirement NEI 13-06 Section Guidance (ADAMS Accession No.

Section or Guidance ML16292A026) 2.3.5 Quality and Maintenance- None Related Requirements Programmatic equipment/software controls such as periodic inventory and MSTDA testing NA Commitment (1) 2.3.6 Considerations for Program Documents Capability described in a controlled document, but not necessarily in E plan SECTION 3 TRAINING 3.1 APPLICABLE ASPECTS OF NRC NTTF V.C "Final Rule Regulatory Bases", pg. 93 REPORT RECOMMENDATIONS Background information - no requirements 3.1.1 Recommendation 4 NA NA 3.1.2 Recommendation 8 3.1.2 Recommendation 8 3.1.3 Recommendation 9 3.2 RELATED REFERENCE DOCUMENTS 3.3 RECOMMENDED ACTIONS (d) 3.3.1 BDB Event Response Training

[Rule does not extend to NA Broad discussion of training SAMG expectations. Applies to FSG, EDMG, training(2)] SAMG 3.3.2 Plant-Referenced Simulator None Update simulator to reflect new equipment (d) NA Increasing the capability of the simulator to model a beyond design basis event or severe accident is not required 183

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Interpretation Gap Assessment / Recommended Action None The NEI BDB Program Manual template is intended to be the location to place the required material.

SECTION 3 TRAINING The SOC recognizes that training exists for elements of the Training on new requirements identified during the rule that have already been implemented. The SOC implementation of the MBDBE rule are required to be explains that the SAT process be used for any "newly performed per the SAT process.

identified training requirements supporting the effective use of the strategies and guidelines that are required by However, elements already covered under other NRC this rule". regulations can be addressed in a non-SAT training program that is acceptable for meeting that specific regulatory requirement (e.g., 10 CFR part 50, appendix E, section IV.F) 11.6 of NEI 12-06 states; "ANSI/ANS 3.5, Nuclear Power Plant As noted in the interpretation column, full scope simulators Simulators for use in Operator Training certification of are not required to be upgraded to accommodate FLEX simulator fidelity (if used) is considered to be sufficient for training or drills. As such, there should be no gap to address the initial stages of the beyond-design-basis external event within simulator capabilities.

scenario until the current capability of the simulator model is exceeded. Full scope simulator models will not be upgraded to accommodate FLEX training or drills."

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Section or Guidance ML16292A026)

SECTION 3 TRAINING 3.3.3 Ultimate Decision-Maker None Qualifications

1) UDM is to provide overall direction on implementation of EOPs, FSGs, EDMGs, and SAMGs

2) 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.

3) Qualification and Training will be (d) NA required 3.3.4 Training Development Guidance None from Regulatory Responses Training programs should also address training-related actions described in response to Order EA-12-049 and 50.54(f) responses 3.3.5 Considerations for Program None Documents T&Q for severe accident/BDB event should be described in a controlled document. Does not need to be described in Emergency Plan.

SECTION 4 EP FACILITIES AND EQUIPMENT 4.1 APPLICABLE ASPECTS OF NRC NTTF None REPORT RECOMMENDATIONS 4.1.1 Recommendation 4 NA NA 4.1.2 Recommendation 9 4.2 RELATED REFERENCE DOCUMENTS 185

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Interpretation Gap Assessment / Recommended Action SECTION 3 TRAINING Draft Reg Guide 1.228 notes that the UDM is part of the The function of the Ultimate Decision Maker (UDM) is defined Command and Control Structure required under in NEI 14-01. This is function and will require new training to

§50.155(b)(6) be developed per the SAT process. It is expected that most sites will incorporate the UDM role into an existing ERO position.

None None None If not already created, the BDB training program needs to be described in a controlled document.

SECTION 4 EP FACILITIES AND EQUIPMENT As used here, EP facilities and equipment refers to those None 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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SECTION 4 EP FACILITIES AND EQUIPMENT 4.3 RECOMMENDED ACTIONS V.C "Final Rule Regulatory Bases, Onsite and offsite communications capability", pg. 101 4.3.1 Industry Performance Standard for EP Facilities and Equipment VI "Paragraph 50.155(c) "Equipment"", pg.

125 Implement facility and equipment enhancements identified in 50.54(f) responses 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 (c)(4) NA 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 None Documents Facilities and equipment should be described in a controlled document.

Does not need to be described in Emergency Plan.

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Interpretation Gap Assessment / Recommended Action SECTION 4 EP FACILITIES AND EQUIPMENT Communication capability enhancements made by licensees Licensees have made these enhancement consistent with their in response to the § 50.54(f) request do not need to meet responses to the 50.54(f) letter, including responses to the NRC the design capabilities for the communications system Generic Technical Issues letter issued on January 23, 2013 required by Part 50, Appendix E or testing frequencies (ML13010A162).

described for primary and backup onsite and offsite communications systems. This section provides guidance on any additional facility enhancements not addressed by the site 50.54(f) response.

Unless a licensee has implemented communications Maintain enhancements made to EP facilities and equipment systems enhancements as a part of their emergency in response to the§ .54(f) letter consistent with the site plans, because enhancements in response to the commitment management program.

§ 50.54(f) assessment are intended as back up capabilities to the emergency plan communications capabilities, it is not necessary for the enhanced communications capabilities to meet the 15 minute notification requirement applicable to emergency plan communications capabilities.

None The NEI BDB Program Manual template provides a format that can be used to document this information 188

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SECTION 5 DRILLS AND EXERCISES 5.1 APPLICABLE ASPECTS OF NRC NTTF V.C. "Drills or exercises", Pg. 95 REPORT RECOMMENDATIONS VI. "Paragraph 50.155(e) "Drills or exercises"",

5.1.1 Recommendation 4 pg 127 5.1.2 Recommendation 8 VI. "10 CFR Part 50 Appendix E, Section IV, Training", pg. 137 NA NA 5.1.3 Recommendation 9 5.2 RELATED REFERENCE DOCUMENTS 5.3 RECOMMENDED ACTIONS 5.3.1 Industry Performance Standards for BDB Event Response Drills

1) 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.

2) A drill that demonstrates the transition from a controlling AOP, EOP or (e) Extensive Damage Mitigation Guidelines

[NOTE: Rule (EDMG) into Severe Accident does not NA Management Guidelines (SAMGs), and extend to the selection of appropriate severe SAMG drills(2)] accident management strategies. (note that this is not a regulatory requirement but instead is voluntary)

3) A drill that demonstrates the use of EDMG strategies.

4) A drill or drills to demonstrate the capability to utilize equipment necessary to implement strategies for responding to a beyond design basis event or severe accident.

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES Additional information is contained in Section VI. Section-by While Section 5 of NEI 13-06 is titled Drills and Exercises, it is Section Analysis, under § 50.155(e), "Drills or exercises "The important to note that the Rule language is Drills or Exercises.

SOC notes that the drills or exercises satisfy the SAT Graded EP Exercises should not be used to meet these element for evaluations and revision of the training based requirements.

on the performance of trained personnel in the job setting found in § 55.4. It is expected that for most sites Section 5 describes all new material that will need to be developed and implemented.

The rule requires drills or exercises that demonstrate;

1) 50.155(b)(1) [FLEX],

OR 50.155(b)(2) [Reevaluated Flood or Seismic hazard],

AND

2) 50.155(b)(3) [EDMG]

None Sections 5.3.1 through 5.3.3 contain general guidance for all BDB drills or exercises.

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SECTION 5 DRILLS AND EXERCISES 5.3.2 Common BDB Event Response V.C. "Drills or exercises", Pg. 95 (e) Drill Attributes

[NOTE: Rule VI. "Paragraph 50.155(e) "Drills or exercises"",

does not NA This section contains elements of the pg 127 extend to drills that are common to all the DBD SAMG drills(2)] drills. VI. "10CFR Part 50 Appendix E, Section IV, Training", pg. 137 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 In cases where the postulated drill scenario events exceed the limits of the simulator model, or such limits would be (e) NA exceeded soon after the drill is commenced, the simulator should not be used.

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).

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES None Sections 5.3.1 through 5.3.3 contain general guidance for all BDB drills or exercises.

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10CFR Other Statements of Consideration 50.155 Requirement NEI 13-06 Section Guidance (ADAMS Accession No.

Section or Guidance ML16292A026)

SECTION 5 DRILLS AND EXERCISES 5.3.4 Drill Demonstrating Integrated V.C. "Drills or exercises", Pg. 95 Use of FLEX Strategies Under the Control of an AOP or EOP VI. "Paragraph 50.155(e) "Drills or exercises"",

pg 127 5.3.4.1 Organizations and facilities VI. "10CFR Part 50 Appendix E, Section IV,

• A simulated Control Room for all on- Training", pg. 137 site units.

• The primary 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 (e) NA ERO would report during the period when the site is inaccessible, if the use of the facility is anticipated during the response to the postulated event.

• Offsite Response Organizations (OROs) 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.

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES The drill or exercise requirement extends to strategies and This section contains specific guidance on performing FLEX guidelines developed in response to the reevaluated seismic drills or exercises. These drills or exercises are required by the and or flooding hazard, as required by 50.155(b)(2). rule per 50.155 Licensees that comply with 50.155(b)(2) by developing event-specific approaches that rely on normal operating procedures or AOPs such as severe weather preparation procedures that are used routinely, would generally not treat these approaches as strategies and guidelines for the purposes of the drill requirements and would use the strategies and guidelines developed to comply with 50.155(b)(1) instead in their drills or exercises.

Conversely, licensees that comply with 50.155(b)(2) by developing targeted or scenario specific mitigation strategies, possibly including unconventional measures, would be expected to demonstrate these event-specific approaches under the drill requirements.

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SECTION 5 DRILLS AND EXERCISES 5.3.4.2 Scope and extent-of-play Continued from previous page Drill Manager should consider the following items when developing the drill.

• Drill means a performance enhancing experience

• Control Room players should process through the operating procedures and guidelines

• The drill duration need not exceed the assumed time necessary for augmented ERO personnel to access the site.

• The arrival times of response personnel should reasonably reflect the scenario.

• Sufficient time should be allowed for (e) NA the ERO 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.

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

• Appropriate personnel at ERO facilities should demonstrate requesting and coordinate the delivery of NSRC equipment. Activation of the NSRC is not required.

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES Continued from previous page Continued from previous page 196

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10CFR Other Statements of Consideration 50.155 Requirement NEI 13-06 Section Guidance (ADAMS Accession No.

Section or Guidance ML16292A026)

SECTION 5 DRILLS AND EXERCISES 5.3.4.3 Scenario and Continued from previous page implementation

• Determine the strategies and guidelines to be demonstrated during the drill.

• The initiating event should occur during minimum on-shift staffing.

• 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 scenario conditions should be generally consistent with the assumptions listed in NEI 13-06 and NEI (e) NA 12-06.

• Controllers should identify any instances where assignments/deployments exceed to the number of available individuals

• The scenario need not include failure of portable equipment.

• The drill scenario need not include a 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.

Rule does not 5.3.5 Drill Demonstrating the None extend to NA Transition from a Controlling AOP, EOP SAMG(2) or EDMG into SAMGs 197

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES Continued from previous page Continued from previous page SAMGs are not included in the final rule language. As such, None there is no regulatory requirement to conduct a SAMG drill 198

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10CFR Other Statements of Consideration 50.155 Requirement NEI 13-06 Section Guidance (ADAMS Accession No.

Section or Guidance ML16292A026)

SECTION 5 DRILLS AND EXERCISES 5.3.5.1 Organizations and facilities None

• A simulated Control Room for all on-site units.

• The emergency response facilities with personnel with responsibility for evaluation of SAMG strategies and related decision-making.

• 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 Scope and extent-of-play None

• "Drill means a performance enhancing experience during which Rule does not participant performance is assessed extend to NA against a certain standard.

SAMG(2)

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

• The drill should demonstration of the ability of the ERO decision-maker to assume command and control 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.

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

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

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES SAMGs are not included in the final rule language. As such, None there is no regulatory requirement to conduct a SAMG drill SAMGs are not included in the final rule language. As such, None there is no regulatory requirement to conduct a SAMG drill.

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10CFR Other Statements of Consideration 50.155 Requirement NEI 13-06 Section Guidance (ADAMS Accession No.

Section or Guidance ML16292A026)

SECTION 5 DRILLS AND EXERCISES 5.3.5.3 Scenario and None implementation

• The drill initial conditions should reflect the occurrence of an event that results in fuel damage, and driving entry into SAMGs for at least one unit.

Rule does not

• All ERO facilities may be assumed to be extend to NA activated.

SAMG(2)

• 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 V.C. "Drills or exercises", Pg. 95 EDMG Strategies 5.3.6.1 Organizations and facilities VI. "Paragraph 50.155(e) "Drills or exercises"",

pg 127

• Appropriate on-shift personnel should be selected based on whether or not the VI. "10CFR Part 50 Appendix E, Section IV, drill scenario assumes that the control Training", pg. 137 room command and control structure remains available.

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

o If not available, personnel should be those expected to respond to an event (e) NA 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 facilities that would be expected to be available.

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

• Participation by the NSRC is not required.

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES SAMGs are not included in the final rule language. As such, None there is no regulatory requirement to conduct a SAMG drill.

V.C Final Rule Regulatory Bases addresses drills or exercises This section provides specific guidance on the elements that in the section titled Drills or Exercises. should be included in an EDMG scenario drill or exercise.

The SOC notes that the drills or exercises satisfy the SAT element for evaluations and revision of the training based on the performance of trained personnel in the job setting found in § 55.4.

The rule specifically requires drills or exercises that demonstrate § 50.155(b)(3) [EDMG]

Section VI. Section-by-Section Analysis, provides additional information under § 50.155(e), "Drills or exercises" starting on page 127.

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10CFR Other Statements of Consideration 50.155 Requirement NEI 13-06 Section Guidance (ADAMS Accession No.

Section or Guidance ML16292A026)

SECTION 5 DRILLS AND EXERCISES 5.3.6.2 Scope and extent-of-play Continued from previous page

• Drill means a performance enhancing experience.

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

• The arrival times of response personnel 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 (e) NA assume command and control.

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

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

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

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES Continued from previous page Continued from previous page 204

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10CFR Other Statements of Consideration 50.155 Requirement NEI 13-06 Section Guidance (ADAMS Accession No.

Section or Guidance ML16292A026)

SECTION 5 DRILLS AND EXERCISES 5.3.6.3 Scenario and Continued from previous page implementation

• The start time should occur during a period of minimum on-shift staffing.

• The drill should be initiated by an event involving a loss of large areas of the plant due to explosions or fire.

• 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 individuals.

• The scenario need not include failure of portable equipment.

• The drill scenario need not include a (e) NA 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 V.C. "Drills or exercises", Pg. 95 Strategy-Related Equipment 5.3.7.1 Equipment capability VI. "Paragraph 50.155(e) "Drills or exercises"",

demonstration pg. 127 For each FSGs, SAMGs and EDMG VI. "10CFR Part 50 Appendix E, Section IV, strategy, the capability to utilize the key Training", pg. 137 equipment necessary for performing an implementing method should be periodically demonstrated.

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES Continued from previous page Continued from previous page None This involves the demonstration of the capability to use utilize key equipment necessary for the implementation of FLEX, EDMG, and SAMG. This includes both installed equipment, portable equipment, and debris removal equipment. Each of these must be demonstrated through a drill or out-of-sequence activity every 8 years.

The deployment of on-shift personnel must not exceed the number of available personnel.

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10CFR Other Statements of Consideration 50.155 Requirement NEI 13-06 Section Guidance (ADAMS Accession No.

Section or Guidance ML16292A026)

SECTION 5 DRILLS AND EXERCISES 5.3.7.2 Installed equipment V.C. "Drills or exercises", Pg. 95 demonstration VI. "Paragraph 50.155(e) "Drills or exercises"",

The capability to implement a strategy pg. 127 using installed plant equipment may be demonstrated during a drill or as an out- VI. "10CFR Part 50 Appendix E, Section IV, of-sequence activity. The licensee may Training", pg. 137 include an out-of-sequence demonstration within the scope of another scheduled activity. Actual manipulation or operation of equipment is not required.

5.3.7.3 Portable equipment demonstration 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 (e) NA another scheduled activity. Actual connection/hookup or operation of equipment is not required.

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

5.3.7.5 Debris removal equipment The capability to mobilize equipment used for debris removal may be demonstrated during a drill or as an out-of-sequence activity. 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).

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES None This involves the demonstration of the capability to use utilize key equipment necessary for the implementation of FLEX, EDMG, and SAMG. This includes both installed equipment, portable equipment, and debris removal equipment. Each of these must be demonstrated through a drill or out-of-sequence activity every 8 years.

The deployment of on-shift personnel must not exceed the number of available personnel.

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10CFR Other Statements of Consideration 50.155 Requirement NEI 13-06 Section Guidance (ADAMS Accession No.

Section or Guidance ML16292A026)

SECTION 5 DRILLS AND EXERCISES 5.3.7.6 Staffing assumptions Continued from previous page For a mitigating strategy expected to be implemented within the assumed elapsed time necessary for ERO personnel to access the site, the following 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.

(e) NA 5.3.8 BDB Event Response Drill None Objectives Appendix A, BDB Event Response Drill Objectives, presents generic drill objectives 5.3.9 Considerations for Program None 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 Notes: (1) In mid-2013 each site submitted a Commitment to the NRC for multi-source dose assessment capability. These Commitments were in response to a letter from Joseph E. Pollock (NEI) to James T. Wiggins (NRC) on January 28, 2013, and clarified in a letter dated March 14, 2013. Licensees should review the language of their specific commitment letter. (2)

SAMG requirements have been removed from the rule language.

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Interpretation Gap Assessment / Recommended Action SECTION 5 DRILLS AND EXERCISES Continued from previous page Continued from previous page None Utilize Appendix A when developing site specific BDB drill objectives.

None The NEI BDB Program Manual template is intended to be the location to place the required material.

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10 NEI 14-01 ICOMPARISON Introduction An assessment of NEI 14-01, Revision 1 guidance against the requirements in 10 CFR 50.155 was performed to assist in implementing the new rule. T The assessment involved preparing a matrix to facilitate review of the following references to assess potential gaps that a licensee may encounter during implementation of 10 CFR 50.155 and identify the recommended actions to close those gaps:

• 10 CFR 50.155 sections applicable to Beyond Design Basis (BDB) event integrated response capabilities including the applicable portions of the associated statements of consideration.

• NEI 14-01 Revision 1, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents.

• Other NRC requirements or guidance supporting the development of NEI 14-01 Revision 1 as listed in the Other Requirement or Guidance column of the gap assessment matrix.

The new rule limits the scope of the integrated response capability to the strategies, guidelines, and alternative approaches under § 50.155(b).

During the development of the rule, other guideline sets were considered for inclusion within the integrated response capability. The guideline sets considered included fire response procedures, alarm response procedures, and abnormal operating procedures (AOPs). These guideline sets are not included in the final rule.

In keeping with the basis for a functional integration of the strategies and guidelines with EOPs, 10 CFR 50.155 requires that the § 50.155(b) strategies, guidelines, and alternative approaches be integrated with the Emergency Operating Procedures (EOPs). The rule language is intended to communicate the NRCs expectation that the EOPs retain their role as the primary means of directing emergency operations and that the strategies and guidelines that are required under this rule are integrated with EOPs to support their implementation.

NEI 14-01 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.

As a result of the rulemaking the PWR Owners Group in conjunction with the BWR Owners Group developed a project plan to provide high level guidance to the industry. There are two major tasks of the project:

• Revise Procedure Usage Standard for Response to Plant Transients

• Develop Beyond Design Basis Events Guideline Standard Based upon the timeline associated with the project plan the guidance should be available for implementation when the rule becomes effective.

Summary of Major Gap Assessments / Recommended Actions The recommended actions identified by the gap assessment review are provided in the GAP Assessment /

Recommended Action column of the matrix and are summarized below.

• Verify Severe Accident Management Guidelines (SAMGs) are revised and maintained in accordance to the new Owners Group guidance by the utility commitment date in the letter sent to the NRC.

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• Integrate the appropriate guidelines (FSGs, EDMGs) with the EOPs in accordance with the revised Owners Group guidance. Provide the necessary training of any new tasks on the procedure integration using the SAT process.

• Designate a member of the Emergency Response Organization (ERO) as the Ultimate Decision Maker (UDM). Provide the necessary training required for the position to ERO personnel designated.

The Owners Group guidance mentioned in the bullets above was prepared by the PWROG and BWROG in support of NEI 14-01 and implementation of 10 CFR 50.155. The tasks and guidance undertaken by the Owners Groups are summarized below. Contact your PWROG and BWROG representatives to determine the status of this work and to obtain copies of the documents described.

PWROG Tasks Task 1: Revise Procedure Usage Standard for Response to Plant Transients This task reviews and revises Procedure Usage Standard for Response to Plant Transients developed under PA-OSC-295 to address certain requirements of 10 CFR 50.155 associated with integrated procedure response capabilities.

This task includes the following subtasks:

1. Describe usage differences between procedures and guidelines

2. Describe usage requirements for beyond design basis guidelines

3. Describe parallel usage requirements for the following:

a. Emergency Operating Procedures

b. Abnormal Operating Procedures

c. Severe Accident Management Guidelines

d. FLEX Support Guidelines

e. Extensive Damage Mitigation Guidelines

f. Targeted Hazard Mitigation Strategies for a BDB Hazard (e.g., special response measures for an extraordinary flooding or seismic event)

4. Provide discussion for prioritization of concurrent events (including a fire). Provide prioritization considerations to that will be used by the Ultimate Decision Maker during BDB Hazard.

Task 2: Develop Beyond Design Basis Events Guideline Standard This task develops a generic standard for addressing certain requirements of 10 CFR 50.155 with regards to integration of beyond design basis event mitigation guidance. This standard should not require the same degree of documentation and rigor as design basis procedures; however, it may provide a vehicle for detailing the history associated with development of various BDBE mitigation programs, integration of the programs and maintenance of the integrated program required by 10 CFR 50.155.

This task includes the following subtasks:

1. Documentation requirements for deviations from generic industry BDBE mitigation guidance

2. Development, Verification and Validation, and Maintenance of:

a. Severe Accident Management Guidelines

b. Flex Support Guidelines

c. Extensive Damage Mitigation Guidelines

d. Targeted Hazard Mitigation Strategies for a BDB Hazard (e.g., special response measures for an extraordinary flooding or seismic event)

e. User aid associated with SAMG/FSG/EDMG (or other BDBE guidelines which may combine the requirements of SAMG/FSG/EDMG to the extent possible) 212

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3. Describe framework for integration of mitigation strategies for transient procedures and BDBE guidelines (assume multiple events)

4. Describe documentation requirements for deviations from generic industry BDBE mitigation guidance.

BWROG Tasks Task 1: Revise BWROG Emergency Procedure Guideline/Severe Accident Guideline documents and/or develop standalone guidance documents to address certain requirements of 10 CFR 50.155 associated with integrated procedure response capabilities.

This task includes the following subtasks:

1. Describe usage differences between procedures and guidelines

2. Describe usage requirements for beyond design basis guidelines

3. Describe parallel usage requirements for the following:

a. Emergency Operating Procedures

b. Abnormal Operating Procedures

c. Severe Accident Management Guidelines

d. Flex Support Guidelines

e. Extensive Damage Mitigation Guidelines

f. Targeted Hazard Mitigation Strategies for a BDB Hazard (e.g., special response measures for an extraordinary flooding or seismic event)

5. Provide discussion for prioritization of concurrent events (including a fire). Provide prioritization considerations t h a t w i l l b e u s e d to by the Ultimate Decision Maker during BDB Hazard.

Task 2: Revise BWROG Emergency Procedure Guideline/Severe Accident Guideline documents and/or develop standalone guidance documents to address certain requirements of 10 CFR 50.155 with regards to integration of beyond design basis event mitigation guidance.

This task includes the following subtasks:

1. Documentation requirements for deviations from generic Owners Group guidance

2. Development, Verification and Validation, and Maintenance of:

a. Severe Accident Management Guidelines

b. Flex Support Guidelines

c. Extensive Damage Mitigation Guidelines

d. Targeted Hazard Mitigation Strategies for a BDB Hazard (e.g., special response measures for an extraordinary flooding or seismic event)

e. User aid associated with SAMG/FSG/EDMG (or other BDBE guidelines which may combine the requirements of SAMG/FSG/EDMG to the extent possible)

5. Describe framework for integration of mitigation strategies for transient procedures and BDBE guidelines (assume multiple events)

6. Describe documentation requirements for deviations from generic industry BDBE mitigation guidance.

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Task 3: Revise BWROG Emergency Procedure Guideline/Severe Accident Guideline documents and/or develop standalone guidance documents to address certain requirements of 10 CFR 50.155 with regards to integration of beyond design basis event mitigation guidance.

This task includes the following subtasks:

1. Programmatic Control Document guidance

2. SAMG Validation scenario set Users Notes The matrix follows the outline of NEI 14-01. Due to the large size of this matrix, it has been formatted to extend across two adjacent facing pages. An explanation of the information in each column of the matrix follows:

• 10 CFR 50.155 Section - Sections of the rule that are applicable to the guidance in the section of NEI 14-01 being addressed.

• Other Requirement or Guidance - Other documents that relate to the guidance in the section of NEI 14-01 being addressed.

• Section Guidance - A general description or outline of the information provided in the section of NEI 14-01 being addressed.

• Statements of Consideration - Provides the Statements of Consideration (SOC) section number and title when a SOC passage provides information relevant to the section of NEI 14-01 being addressed. In addition, a page reference is sometimes provided to indicate where the discussion on the specific subject can be found.

• Interpretation - Background or further explanation of the guidance in NEI 14-01.

• Proposed Action - Captures any generic actions being undertaken by the industry to address the item or recommends actions that should be taken by a utility.

ALSO SEE SECTION 3.0, GENERAL MATRIX USAGE, FOR GENERAL USAGE INFORMATION.

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10CFR Other 50.155 Requirement NEI 14-01 Section Guidance Section or Guidance SECTION 1 INTRODUCTION

1. INTRODUCTION Background information - no requirements b(4) RG1.228 SECTION 2 PROCEDURE INTEGRATION

2. PROCEDURE INTEGRATION 2.1 Overview 2.2 Procedures and Guidelines 2.3 Emergency Response Procedure and Guideline Sets Background information - no requirements 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 b(4) RG1.228 Group. Deviations from the generic technical guidance should be documented along with the supporting rationale.

Individual site

• Strategies should be available to address potential or actual fuel damaging conditions commitment present in the reactor core or the spent fuel pool.

letter based on 2.4 Integration of Procedure and Guideline Sets NEI Letter Each licensees emergency response procedure and guideline sets should address the dated 10/26/15 following considerations:

Project #689

• 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.

• Strategies should be available to address potential or actual fuel damaging conditions present in the reactor core or the spent fuel pool.

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Statements of Consideration Gap Assessment / Recommended (ADAMS Accession No. Interpretation Action ML16292A026)

SECTION 1 INTRODUCTION None None None SECTION 2 PROCEDURE INTEGRATION None None Ensure that you understand the context and cautions for applying the guidance.

V.C - Integrated Response Capability Each utility to develop an Use the guidelines developed by the respective Pages 66-84 overall integration strategy for Owners Group to achieve the procedural their different guidelines that integration required by the rule.

meets the intent of the rule.

Though not included in the final rule SAMGs are required to be integrated with the EOP network.

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10CFR Other 50.155 Requirement NEI 14-01 Section Guidance Section or Guidance SECTION 2 PROCEDURE INTEGRATION 2.4 Integration of Procedure and Guideline Sets (continued)

• 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.

• 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 b(4) RG-1.228 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

• 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.

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Statements of Consideration Gap Assessment / Recommended (ADAMS Accession No. Interpretation Action ML16292A026)

SECTION 2 PROCEDURE INTEGRATION V.C - Integrated Response Capability Each utility to develop an Use the guidelines developed by the respective Pages 66-84 overall integration strategy for Owners Group to achieve the procedural their different guidelines that integration required by the rule.

meets the intent of the rule.

V.B - Guideline Sets Excluded From Final None

• Follow guidance from Owners Group on fire Rule p. 59 response strategy

• Provide UDM training on selecting the appropriate strategy for the given situation.

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10CFR Other 50.155 Requirement NEI 14-01 Section Guidance Section or Guidance SECTION 3 3.1 Overview Background information - no requirements 3.2.1 Development of Generic Severe Accident Management Guidance Background information - no requirements.

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.

Individual site

• Any plant system, structure or component, and available portable equipment, may be commitment used to implement an accident management strategy, irrespective of safety classification letter (dated or other design-related criteria. In addition, the normally-applied controls on the use or 12/15) based on configuration of a plant system, structure or component may be altered if necessary to NEI Letter implement a strategy (e.g., establishing a system lineup not described in the facility dated 10/26/15 licensing basis).

Project #689

• The inclusion of a plant system, structure or component within a severe accident management strategy implementing method does not impose any additional design or NRC IP 71111, maintenance-related requirements on that item (i.e., beyond those associated with the ATT. 18 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 ROP 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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Statements of Consideration Gap Assessment / Recommended (ADAMS Accession No. Interpretation Action ML16292A026)

SECTION 3 V.B - Severe Accident Management None Sites to maintain SAMGs in accordance with Guideline and Multiple Source Term Dose their individual commitment letters to the NRC.

Assessment p.56 Reference NEI letter to the NRC.

Individual site commitment letter based on NEI Letter dated 10/26/15 Project #689 Licensees should reference NEI 14-01 SAMG requirements into their SAMG Program document.

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10CFR Other 50.155 Requirement NEI 14-01 Section Guidance Section or Guidance SECTION 3 3.2.2 Principles for SAMGs (continued)

• 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 Individual site calculations.

commitment

• The capability to assess decision-making criteria (e.g., a parameter value or trend that letter (dated prompts a given action) should accommodate the use of any available indications.

12/15) based on Potential uncertainties in instrumentation readings caused by anticipated severe NEI Letter accident environmental conditions should be considered during the development of dated 10/26/15 decision-making criteria.

Project #689

• SAMG strategies may employ implementing methods or capabilities described in FLEX Support Guidelines (FSGs) or Extensive Damage Mitigation Guidelines (EDMGs).

NRC IP 71111,

• Computational aides should be provided when direct diagnosis of key plant conditions ATT. 18 cannot be determined solely from instrumentation.

ROP 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.

3.2.3.2 Document Verification & Validation

• Guidelines for responding to a severe accident should be verified and validated in accordance with an applicable fleet or site procedure development process.

• Verification and validation processes should assess the technical accuracy and adequacy of the instructions, and the ability of personnel to follow and implement them.

• 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.

• The verification and validation process should accommodate the differences between non-severe and severe accident conditions.

Industry

• Due to the unbounded nature of severe accident sequences and potential resulting Commitment conditions, a limited number of scenarios should be developed for the SAMG validation process (i.e., a sample group).

3.2.3.3 Document Updating & Maintenance

• Review, revision, approval, distribution and placement of SAMGs should be performed in accordance with the appropriate fleet or site document control process.

• 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.

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Statements of Consideration Gap Assessment / Recommended (ADAMS Accession No. Interpretation Action ML16292A026)

SECTION 3 V.B - Severe Accident Management None Sites to maintain SAMGs in accordance with Guideline and Multiple Source Term Dose their individual commitment letters to the NRC.

Assessment p.56 Reference NEI letter to the NRC.

None None Sites to maintain SAMGs in accordance with their individual commitment letters to the NRC.

Reference NEI letter to the NRC.

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10CFR Other 50.155 Requirement NEI 14-01 Section Guidance Section or Guidance SECTION 3 Industry 3.2.3.5 Priority Setting for Document Changes Commitment

• 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.

3.3 Flex Support Guidelines (FSGs)

• The development, verification, validation and maintenance of FSGs should be b(1) RG 1.228 performed in accordance with each licensees procedure/guideline development processes, and the guidance provided in NEI 12-06.

3.4 Extensive Damage Mitigation Guidelines

• The development, verification, validation and maintenance of EDMGs should be b(3) RG 1.228 performed in accordance with each licensees procedure/guideline development processes, and the guidance provided in NEI 06-12.

SECTION 4 COMMAND AND CONTROL

4. Command and Control 4.1 Overview Background information - no requirements 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.

• 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:

o Selection of the procedure or guideline set(s) most appropriate to address the event b(5) and/or plant conditions.

b(6) o Determination of the strategy(ies) to be implemented, and the necessary conditions and timing for implementation.

o Direction of the onsite and offsite resources needed to implement the selected strategy(ies).

o 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.

o 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.

o The qualifications for an UDM are discussed in NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents.

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Statements of Consideration Gap Assessment / Recommended (ADAMS Accession No. Interpretation Action ML16292A026)

SECTION 3 None None Sites to maintain SAMGs in accordance with their individual commitment letters to the NRC.

Reference letter to the NRC.

See discussion above. None Implement Owner's Group guidance.

V.C - EDMGs None Depending upon the site-specific commitment, P.79 implement guidance in NEI 06-12 R2 or R3 for EDMG development. Individual Licensees should determine which version is applicable.

SECTION 4 COMMAND AND CONTROL V.C - Command and Control None Modify existing ERO structure to support Page 85 implementation of the BDBEE criteria (i.e.,

assign the UDM function and associated qualification requirement to the appropriate ERO position). Revise ERO and other procedures as needed to reflect the UDM assignment.

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10CFR Other 50.155 Requirement NEI 14-01 Section Guidance Section or Guidance SECTION 4 COMMAND AND CONTROL 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.

• 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.

• 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).

• 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 b(5) a UDM qualification.

b(6)

• 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

• 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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Statements of Consideration Gap Assessment / Recommended (ADAMS Accession No. Interpretation Action ML16292A026)

SECTION 4 COMMAND AND CONTROL V.C - Command and Control None Assess ERO and other procedures to ensure Page 85 that all considerations are addressed, or revise as needed.

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11 RG 1.226 TO JLD-ISG 1201-01 COMPARISON

==

Introduction:==

RG 1.226 will generally allow use of the same actions used by utilities for compliance with the NRC order EA 049.

On December 15, 2016, NRC issued SECY-16-0142, Draft Final Rule - Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49) to obtain Commission approval to publish a final rule that establishes requirements for nuclear power reactor licenses and applicants. As part of the draft final rule package, a pre-decisional version of Regulatory Guide (RG) 1.226, Flexible Mitigation Strategies for Beyond-Design-Basis Events was also issued.

RG 1.226 endorses, with clarifications, the methods and procedures promulgated by the Nuclear Energy Institute (NEI) in technical document NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 4, as a process the NRC considers acceptable for meeting, in part, the regulations in 10 CFR 50.155. Additionally, RG 1.226 provides guidance in areas that are not covered in NEI 12-06 for meeting 10 CFR 50.155.

On February 8, 2017, NRC issued Interim Staff Guidance (ISG) JLD-ISG-2012-01 Revision 2, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events. JLD-ISG-2012-01 endorses, with exceptions, additions and clarifications, the methodologies described in the industry guidance document, Nuclear Energy Institute (NEI) 12-06, Revision 4 as one acceptable approach for satisfying Order EA-12-049 requirements.

Summary of Major Gap Assessments/Recommended Actions:

Since both NRC guidance documents endorse, with exceptions, additions and clarifications, the same industry guidance document for satisfying essentially the same set of NRC requirements, it would be expected that the endorsements should be consistent, and for the most part they are. The table below summarizes the significant gaps identified in a detailed comparison of RG 1.226 with JLD-ISG-2012-01 Revision 2.

Description of Difference Impact to Licensees Recommended Resolution RG 1.226 endorses NEI 12-06, NEI 12-06 revision 0 and 2 do not Best Option: Comply with NEI 12-Revision 4, but its implementation include all the provisions included 06 revision 4 section allows use of other NRC in revision 4 relative to Change acceptable methods Control, MSA and Out of service Alternate Option: Document clearly time. Some plants that responded which sections of which revision the under licensing conditions for site is complying with and how that compliance with mitigating is consistent with the remainder of strategies actions per NEI 12-06, the selected compliance version of revision 0 will have to request NEI 12-06. An example is; JLD-ISG-approval to upgrade to revision 2 2012-01 Rev 2 did not take a or 4. position on the acceptability of 11.8.3.a.iii for change control.

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The ISG recognizes that FLEX During the ISG public comment Best Option:

equipment may be pre-staged for up period, the NRC Staff requested Utilize NEI-12-06, Revision 4 guidance to 45 days to reduce the risk of stakeholder feedback on the Alternate Option: Recognize and maintenance or outage activities. allowance of 45 days for All other instances of unavailability reasonable protection. From the due to the lack of reasonable comments received, the NRC Staff protection is limited to 14 days. The concluded that the 45 day 228

June 8, 17 NEI 17-03, [Rev A]

Description of Difference Impact to Licensees Recommended Resolution RG 1.226 discussion on this topic allowance was acceptable with no communicate the difference at the only includes the 14 day allowed change required to the ISG MBDBEE Rulemaking workshop and outage time with no mention of the because NEI 12-06 Rev 4 already emphasize that RG 1.226 endorses exception for 45 days if deployed to incorporates this guidance. The all of NEI 12-06 Rev 4 Section 11.5.4 reduce the risk of maintenance or NRC Staff felt it important enough which includes the 45 day allowed outage activities. However, in the to differentiate the two separate outage time for equipment NRC Staffs concluding position, the allowed outage times for protection when used to reduce Staff states that Section 11.5.4 reasonable protection of risk of maintenance or outage provides an acceptable method for equipment in the ISG, but makes activities controlling unavailability of the no such distinction in RG 1.226.

equipment to satisfy that element of This may lead to confusion during reasonable protection. FLEX inspections.

Note there is a distinction for deployed equipment for maintenance or outage activities with regard to reasonable protection.

Susquehanna Steam Electric Station No technical impact. Might be None is included as a separate bullet in harder for someone to find it the ISG but combined with the bullet when needed.

for Salem Nuclear Generating Station in RG 1.226 RG 1.226 adds a new Section 7, None. This added section Recognize and communicate the Coordination with Severe Accident endorses, with no exceptions, difference at the MBDBEE Management Guidelines. Section 7 clarifications or additions, NEI 12- Rulemaking workshop and in the ISG is Section 8 in RG 1.226. 06 Rev 4 Section 3.2.10 and 11.4. emphasize that RG 1.226 endorses NEI 12-06 Rev 4 Section 3.2.10 and 11.4. (reference SRM-COMSECY Users Notes:

Due to the large size of this matrix, it has been formatted to extend adjacent facing pages.

A detailed and systematic review of the two documents was performed to identify any substantial differences between them. The results of the gap analysis determined that the substantial differences are limited to the first two items documented in the Table above.

The following table contains only the changes identified in the review that might require an evaluation by utilities. The gap analysis showing all the results is not included herein due to its size and expected limited use by our members, but it is available on NEIs Member Website as Addendum 1 to NEI 17-03.

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ISG-2012-01 rev 2 RG 1.226 RATIONALE Reason for Issuance

1. Order EA-12-049 requires that licensees shall develop, One of the primary lessons learned from the accident at the implement, and maintain guidance and strategies to Fukushima Dai-ichi nuclear power plant was the significance maintain or restore core cooling, containment, and SFP of the challenge presented by a loss of multiple safety-related cooling capabilities following a beyond-design-basis systems following the occurrence of a BDBEE. In the case of external event. The three-phase approach described in the the Fukushima Dai-ichi accident, the loss of all alternating order is a conceptual framework built upon the need for a current power led to loss of core cooling, and ultimately to licensee to address challenges to the safety functions when core damage and a loss of containment integrity. The design they occur, using installed structures, systems, and basis for U.S. nuclear plants includes bounding analyses with components for a coping period until portable mitigating margin for external events expected at each site. Extreme equipment can be used to address those challenges. The external events (e.g., seismic events, external flooding, etc.)

finite level of resources on site makes the arrangement of beyond those accounted for in the design basis, while offsite resources necessary to address potential unlikely, could present challenges to nuclear power plants.

widespread catastrophes, such as the occurrence at In response to lessons learned from the Fukushima Dai-ichi Fukushima, where the restoration of offsite power is accident, the NRC promulgated 10 CFR 50.155, Mitigation of precluded by damage. Licensees emergency operating Beyond-Design-Basis Events, to improve the capability of procedures will provide the command and control nuclear power plants to address BDBEEs. As one method of structure in response to beyond-design-basis external addressing the challenges that may be presented by these events. Additional guidance documents will be developed types of events, this RG endorses, with clarifications as for deployment of the FLEX strategies in support of the detailed in this RG, the principles and processes in NEI 12-06, emergency operating procedures. Revision 4, as acceptable for use by applicants and licensees

2. The NRC has previously provided regulatory guidance for to define and deploy strategies that will enhance their ability the development, implementation, and maintenance of to cope with conditions resulting from BDBEEs.

guidance and strategies intended 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. This was done through the endorsement of NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, Revision 2, issued December 2006

[Reference 43], for holders of and applicants for operating licenses issued under 10 CFR Part 50, and Revision 3 of NEI 06-12, issued July 2009 [Reference 44], for holders of and applicants for combined licenses under 10 CFR Part 52. This regulatory guidance continues to provide an acceptable means of meeting the requirement to develop, implement, and maintain the necessary guidance and strategies for the subset of beyond-design-basis external events addressed by 10 CFR 50.54(hh)(2).

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RG 1.226 Differences Impact of Change

1. RG 1.226 changes the reference from EA-12-049 to 10 CFR 1. Regulation documentation change. Editorial, no 50.155, evaluation needed.

2. Both documents endorse NEI 12-06, revision 4. 2. Each site will need to evaluate NEI 12-06 rev 4 for

3. ISG notes that B5b (50.54)(hh)(2) requirements are not changes that may be required. Note that ISG-2012-01 contained in the guidance of NEI 12-06. (Note that 50.155 will allowed for previous revisions of NEI 12-06 to be now incorporate 50.54(hh)(2) within its scope) acceptable means. This remains an option as outlined below in Implementation section.

3. Sites should verify that they are in compliance with regulatory guidance pertaining to program currently known as B5b or 50.54(hh)(2).( reference phase I guidance letter of 2/25/2005, NEI 06-12, Revision 2, and SRP 19.4) 231

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ISG-2012-01 rev 2 RG 1.226 RATIONALE (continued) Continued from previous page

3. The approach described in NEI 12-06, Revision 4, for development, implementation, and maintenance of mitigating strategies for beyond-design-basis external events provides a framework and methodology for such strategies to address those events that are not covered within the requirements of 10 CFR 50.54(hh)(2), subject to the exceptions, additions, and clarifications in the enclosure to this ISG.

4. The approach described in NEI 12-06, Revision 4, and its Section H.4.5 for the performance of assessments of the mitigating strategies under the reevaluated seismic and flooding hazards developed in response to the March 12, 2012, 50.54(f) letter provides an appropriate methodology for licensees to address the reevaluated seismic and flooding hazards in a manner that aligns with the proposed mitigation of beyond-design-basis events rulemaking.

APPLICABILITY Applicability This ISG shall remain in effect until it has been superseded, This RG applies to applicants and licensees subject to 10 CFR withdrawn, or incorporated into a regulatory guide or the Part 50, Domestic Licensing of Production and Utilization Standard Review Plan (SRP). Facilities, and all applicants and licensees for a power reactor combined license under 10 CFR Part 52, Licenses, GUIDANCE Certifications, and Approvals for Nuclear Power Plants (Ref.

As discussed above, this ISG is applicable to holders of 3).

power reactor operating licenses, construction permits, or combined licenses. Applicable Regulations The NRC staff considers that the development, 10 CFR 50.155, Mitigation of Beyond-Design-Basis Events, implementation, and maintenance of strategies and requires nuclear power reactor guidance in conformance with the guidelines provided in licensees to develop, implement, and maintain an integrated NEI 12-06, Revision 4, are an acceptable means of meeting response capability that includes strategies and guidelines to the requirements of Order EA-12-049, subject to the mitigate a Beyond-Design-Basis External Event (BDBEE) exceptions, additions, and clarifications in the enclosure to this ISG. However, NRC endorsement of NEI 12-06, Revision 4, does not imply NRC endorsement of references listed in NEI 12-06, Revision 4.

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RG 1.226 Differences Impact of Change Continued from previous page Continued from previous page

1. Issuance of the RG will cause the ISG to be withdrawn 3 1. Evaluation will be necessary to ensure compliance with years after the Rule is in effect. the RG

2. ISG endorses NEI 12-06, rev 4. RG-1.226 also endorses rev 4 2. Need to understand how order inspections will occur if of NEI 12-06 (but not in this section). scheduled after ISG is no longer in effect. The population that could be impacted is small because of the ISG will remain in effect for 3 years after the Rule is effective.

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12 RG 1.227 TO JLD-ISG-2012-03 COMPARISON

==

Introduction:==

RG 1.227 will generally allow use of the same actions used by utilities for compliance with NRC order EA-12-051.

On December 15, 2016, NRC issued SECY-16-0142, Draft Final Rule - Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49) to obtain Commission approval to publish a final rule that establishes requirements for nuclear power reactor licenses and applicants. As part of the draft final rule package, a pre-decisional version of Regulatory Guide (RG) 1.227, Wide Range Spent Fuel Pool Level Instrumentation was also issued. RG 1.227 endorses, with clarifications, the methods and procedures promulgated by the Nuclear Energy Institute (NEI) in technical document NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 1, as a process the NRC considers acceptable for meeting, in part, the regulations in 10 CFR 50.155. Additionally, RG 1.227 provides guidance in areas that are not covered in NEI 12-02 for meeting 10 CFR 50.155.

On August 29, 2012, NRC issued Interim Staff Guidance (ISG) JLD-ISG-2012-03 Revision 0, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation. JLD-ISG-2012-03 endorses, with exceptions, additions and clarifications, the methodologies described in the industry guidance document, Nuclear Energy Institute (NEI) 12-02, Revision 1 as one acceptable approach for satisfying Order EA-12-051requirements.

Summary of Major Gap Assessments / Recommended Actions:

Since both NRC guidance documents endorse, with exceptions, additions and clarifications, the same industry guidance document for satisfying essentially the same set of NRC requirements, it would be expected that the endorsements should be consistent, and for the most part they are. A detailed and systematic review of the two NRC documents was performed and the differences are primarily editorial, changing the reference from order EA-12-051 (to be withdrawn) to the rule 10CFR50.155. There is, however, one difference with greater significance.

• The Applicable Regulations section of RG 1.227 explains a 10 CFR 50.155(f) requirement that each licensee provide reliable means to remotely monitor wide range water level for each spent fuel pool at its site until five years have elapsed since all of the fuel within that spent fuel pool was last used in a reactor vessel for power generation. . Paragraph 50.155(f) removes the requirement for operating nuclear power plants to provide wide-range spent fuel pool level monitoring capabilities for spent fuel pools that contain only fuel greater than five years old. This condition typically exists at plants with multiple spent fuel pools that use only one of the pools for freshly discharged fuel. Paragraph 50.155(a)(2)(i) removes the requirement for wide-range spent fuel pool level monitoring capabilities for all spent fuel pools at a nuclear power plant that has permanently ceased operation and removed all fuel from the reactor vessel once the NRC has docketed the appropriate certifications without regard to the age of the fuel in the pools.

Users Notes:

A detailed and systematic review of the two documents was performed to identify any substantial differences between them. The results of the gap analysis determined that the substantial differences are limited to the item documented above.

The following table contains only the changes identified in the review that might require an evaluation by utilities. The gap analysis showing all the results is not included herein due to its size and expected limited use by our members, but it is available on NEIs Member Website as Addendum 2 to NEI 17-03.

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ISG-2012-03 RG 1.227 APPLICABILITY Applicability This ISG shall remain in effect until it has been This RG applies to applicants and licensees subject superseded, withdrawn, or incorporated into a to 10 CFR Part 50, Domestic Licensing of regulatory guide or the standard review plan. Production and Utilization Facilities, and all applicants and licensees for a power reactor GUIDANCE combined license under 10 CFR Part 52, Licenses, This ISG is applicable to holders of power reactor Certifications, and Approvals for Nuclear Power operating licenses, construction permits, and Plants (Ref. 3).

combined licenses.

Applicable Regulations The NRC staff considers that the methodologies and 10 CFR 50.155(f) requires each licensee to provide guidance in conformance with the guidelines provided reliable means to remotely monitor wide range in NEI 12-02, Revision 1, subject to the clarifications water level for each spent fuel pool at its site until and exceptions in Attachment 1 to this ISG, are an five years have elapsed since all of the fuel within acceptable means of meeting the requirements of that spent fuel pool was last used in a reactor vessel Order EA-12-051. for power generation.

NEI 12-02, Revision 1 references other documents, but the NRCs endorsement of NEI 12-02, Revision 1 in this ISG should not be considered an endorsement of any of the referenced documents.

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13 REFERENCES 13.1 JLD-ISG-2012-01: Compliance with Order EA 12-049, Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond Design Basis External Events 13.2 JLD-ISG-2012-03: Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation 13.3 NEI 12-01: Guidance for Assessing Beyond Design Basis Accident Response Staffing and Communication Capabilities 13.4 NEI 12-02: Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation.

13.5 NEI 12-06: Diverse and Flexible Coping Strategies (FLEX) Implementation Guide 13.6 NEI 13-06: Elements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents 13.7 NEI 14-01: Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents 13.8 RG 1.226: Flexible Mitigation Strategies for Beyond Design Basis Events 13.9 RG 1.227: Wide Range Spent Fuel Pool Level Instrumentation 13.10 RG 1.228 13.11 Final Rule and Statements of Consideration (MLxxxxxx) 236