Mitigation of Beyond Design Basis Events (MBDBE) Rule Implementation 2017 Emergency Preparedness Working Meeting November 8, 2017

10 CFR 50.155 Requirements for the mitigation of beyond-design-basis events Integrated response capability, including the integration of BDB event response strategies and guidelines with emergency operating procedures Addresses training, drills/exercises; staffing and communications; and documentation of changes Rule will become effective in 2018

NOT included in 10 CFR 50.155 SAMGs and Multi-Source Term Dose Assessment NRC Commissioners directed removal of proposed requirements from the rule in response to industry comments about inadequate bases The NEI Nuclear Strategic Issues Advisory Committee (NSIAC) approved an Industry Initiative on SAMGs Maintain updated SAMGs and integrate with other guideline sets and EOPs; perform SAMG validations; and consider SAMGs within configuration management processes Both implemented/controlled as site commitments

NRC Endorsement of Industry Guidance Regulatory Guide 1.228, Integrated Response Capabilities for Beyond-Design-Basis Events, endorses: NEI 12-01, Guidelines for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents

NEI 17-03 Mitigation of Beyond Design Basis Events Rule Implementation Guidance Provides a roadmap for the implementation of 10 CFR 50.155 through matrices that cross reference the rule and its statements of consideration with existing NEI guidelines and other applicable references Matrices assess potential gaps that a licensee may encounter during rule implementation

Who Owns MDBDE Program? MBDBE Program Owner? Program Implementer? Mitigation Strategies for Beyond Design Basis Events (FLEX) Reevaluated Flooding and Seismic Hazards Extensive Damage Mitigation Guidelines Integration of mitigating strategies with Emergency Operating Procedures Staffing Organization Structure Equipment Capacity and Capability Equipment Reasonable Protection Communications Training Drills or exercises Spent Fuel Pool monitoring Documentation of Changes Industry Response and / or Commitments Associated with MBDBEE SAMG Multi-Source Term Dose Assessment Hardened Vents

Guidance on BDB Event Response Drills

Four Drill Types in NEI 13-06 Integrated use of FLEX strategies under the control of an Abnormal Operating Procedure (AOP) or Emergency Operating Procedure (EOP) Transition from a AOP, EOP or Extensive Damage Mitigation Guidelines (EDMG) into SAMGs, and the selection of appropriate severe accident strategies Use of EDMG strategies Capability to utilize equipment/methods necessary to implement BDB response strategies

FLEX Strategy Drills Scenario must include an extended loss of AC power affecting all onsite units Must demonstrate command and control Include the control room staff(s) and any offsite ERO facilities that can reasonably be expected to be activated within the first 6 hours +/- of the initiating event (e.g., an alternate facility or EOF) Use of installed or portable FLEX equipment may be included or performed in separate activities

EDMG Strategy Drills The initiating event occurs during a period of minimum on-shift staffing, i.e., during an assumed backshift, weekend or holiday Event involves a loss of large areas of the plant due to explosions or fire 10 CFR 50.54(hh)(2)  10 CFR 50.155(b)(3) Conditions result in operators or other available on-shift personnel implementing EDMGs Specify whether there is a concurrent loss of the normal on-shift command and control structure

Severe Accident Strategy Drills Initial conditions reflect the occurrence of an accident or event that resulted in the onset of conditions leading to fuel damage, and driving entry into SAMGs for at least one unit Specify the operating mode(s) of each unit prior to the accident or event based on the actions to be demonstrated All ERO facilities may be assumed to be activated Demonstrate transition into SAMGs

Strategy Equipment Drills Demonstrate use of installed or portable equipment to implement FLEX, SAMG and EDMG strategies NEI 13-06, Appendix B, provides example/generic strategy lists Each site will need to make a site-specific strategy listing Many opportunities to credit performance, including: Mini-drill within a larger EP, FLEX, SAMG or EDMG drill Performance during a training or surveillance activity Actual equipment placement (e.g., outage or plant mod support)

Common Drill Guidance Generic drill objectives and evaluation criteria are included in NEI 13-06, Appendix A Modify to incorporate fleet or site-specific information It is not necessary to demonstrate all the objectives in one drill If the simulator cannot support a drill due to model limitations, then “best estimate” data can be generated and provided manually (e.g., hard-copy/paper data sheets) or using other methods

Common Drill Guidance Drills must demonstrate: Procedure and guideline transitions Communications capabilities Turnover of command and control To support subsequent inspection, audit and review activities, a drill report must be prepared for each drill

Ultimate Decision Maker (UDM) ERO position with ultimate authority for making decisions on implementation of emergency response procedures and guidelines UDM authority and responsibilities should be integrated into ERO command and control structures and protocols; not necessary to create a new ERO position or title Initial UDM is Shift Manager Function can be transferred to TSC and/or EOF

NEI Support and a Reminder Help is available when planning and preparing for your first BDB event drill . . . contact: David Young; 202-739-8127; dly@nei.org BDB event response drill program should be controlled in accordance with documents not described in (part of) the site emergency plan NEI recommends considering the BDB Event Response Program Manual template for this purpose

NEI 17-03 Workshop Washington DC January 30 and 31, 2018 For More Information . . . NEI 17-03 Workshop Washington DC January 30 and 31, 2018

Questions David Young John Egdorf 202-739-8127 dly@nei.org 202-739-8021 jre@nei.org