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EMERGENCY PREPAREDNESS FREQUENTLY ASKED QUESTION (EPFAQ) 

EPFAQ Number: 2015-015 Date Accepted for Review: 04-DEC-15 

Originator: DON JOHNSON 

Organization: NUCLEAR REGULATORY COMMISSION 

Relevant Guidance: NEI 99-01 REV. 6 

Applicable Section(s): EALs SA1, SS1, SG1, CU2, & CA2 

Status: Public Comment Period

QUESTION OR COMMENT: 

Should EALs SA1 and CU2 contain a list of power sources applicable for consideration and 

describe the criteria for what sources may be credited? In addition, should guidance be 

included to explain why a list of sources is not necessary for EALs SS1 (CA2) and SG1 as these 

EALs are for a loss of ALL sources? 

PROPOSED SOLUTION: 

The industry has no objection to including a list of applicable power sources in Initiating 

Conditions SA1 and CU2, and not including a similar list in Initiating Conditions SS1, CA2 and 

SG1. It appears that the proposed approach would also apply to Initiating Condition SG8. 

Following the selection of a solution by the staff, the industry would like to have an opportunity 

to provide input on recommended Basis and Developer Note information to be included in the 

final EP FAQ as these are important for consistent implementation. We anticipate providing this 

input during the public comment period. 

Consistent with the guidance in Regulatory Issue Summary (RIS) 2003-18, Supplement 2, Use 

of Nuclear Energy Institute (NEI) 99-01, “Methodology for Development of Emergency Action 

Levels,” Revision 4, dated January 2003, it is reasonable to conclude that the change proposed 

above would be considered as a “difference.” 

NRC RESPONSE: 

The staff agrees that a table listing available power sources is acceptable and expected for 

EALs CU2 and SA1 (from NEI 99-01 Revision 6) as long as these power sources are: 

• Adequately maintained in an appropriate maintenance program; 

• Are able to assume the full load of the (applicable) emergency buses within 

approximately 15-minutes. 

The staff understands that the primary point of emphasis for EALs CA2, SS1, SG1, and SG8 is 

a complete loss of power (for the applicable time duration) and that a list of readily available 

power sources may lead to event declarations when mitigative strategies are effective in 

reestablishing emergency power to these buses. In other words, if a list of power sources is 

provided for these EALs, and those sources are unavailable, then an EAL decision-maker would 

be compelled to declare events even if mitigative strategies using other power sources are 

effective. It is not necessary to document these power sources for these EALs as the EAL is 

not concerned with the power source as much as the power loss to the emergency bus. 

In summary, the staff only considers EALs SA1 and CU2, as numbered in NEI 99-01 Revision 6, 

as needing a table of readily available onsite AC power sources. EAL SU1 may list the offsite 

AC power sources if desired. EALs CA2, SS1, SG1, and SG8 do not need to list the sources. 

This is considered a “deviation” in accordance with Regulatory Issue Summary (RIS) 2003-18, 

Supplement 2, “Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of 

Emergency Action Levels, Revision 4,” dated January 2003, as it may impact EAL declaration 
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EMERGENCY PREPAREDNESS FREQUENTLY ASKED QUESTION (EPFAQ) 

timing for those licensees seeking to change the applicable EALs via 10 CFR 50.54(q). For 

those licensees seeking to adopt this EPFAQ when submitting a license amendment request for 

an EAL scheme change, via App. E to 10 CFR 50, then the distinction between a “difference” or 

a “deviation” is irrelevant as NRC approval is needed regardless.