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

2. 10 CFR
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

3. NOT included in 10 CFR
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

4. 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

5. NEI 17-03
Mitigation of Beyond Design Basis Events Rule Implementation Guidance
Provides a roadmap for the implementation of 10 CFR 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

6. 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

7. Guidance on BDB Event Response Drills

8. 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

9. 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

10. 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 (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

11. 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

12. 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)

13. 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

14. 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

15. 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

16. NEI Support and a Reminder
Help is available when planning and preparing for your first BDB event drill contact:
David Young; ;
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

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

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