ML080710029
| ML080710029 | |
| Person / Time | |
|---|---|
| Issue date: | 08/19/2009 |
| From: | Brach E, Dan Dorman, Mcginty T, Mike Norris NRC/NMSS/FCSS, NRC/NMSS/SFST, Division of Policy and Rulemaking, NRC/NSIR/DPR |
| To: | |
| Norris M, NSIR, 415-4098 | |
| References | |
| RIS-05-002, Rev 1 | |
| Download: ML080710029 (12) | |
See also: RIS 2005-02
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, DC 20555-0001
August xx, 2009
NRC REGULATORY ISSUE SUMMARY 2005-02, REVISION 1
CLARIFYING THE PROCESS FOR MAKING
EMERGENCY PLAN CHANGES
ADDRESSEES
All holders of licenses for nuclear power reactors under the provisions of Title 10 of the Code of
Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization
Facilities, including those that have permanently ceased operations and have certified that fuel
has been permanently removed from the reactor vessel.
All holders of licenses for research and test reactors under Part 50.
All holders of and applicants for nuclear power plant construction permits, early site permits and
limited work authorizations under Part 50.
All holders of a combined license for a nuclear power plant under the provisions of
10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
All holders of licenses for fuel facilities under the provisions of 10 CFR Part 40 Domestic
Licensing of Source Material required to have an emergency plan under § 40.31(j)(1)(ii).
All holders of licenses for fuel facilities under the provisions of 10 CFR Part 70 Domestic
Licensing of Special Nuclear Material required to have an emergency plan under
§ 70.22(i)(1)(ii).
All holders of certifications for gaseous diffusion plants under the provisions of 10 CFR Part 76
Certification of Gaseous Diffusion Plants required to have an emergency plan under § 76.35(f).
All holders of site-specific licenses for Independent Spent Fuel Storage Installations under
10 CFR Part 72 Licensing Requirements for the Independent Storage of Spent Nuclear Fuel
and High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
revision to inform stakeholders that reactor emergency plan changes that require prior NRC
RIS 2005-02, Revision 1
Page 2 of 11
approval, in accordance with 10 CFR 50.54(q), will need to be submitted as license amendment
requests in accordance with 10 CFR 50.90, Application for Amendment of License,
Construction permit, or Early Site Permit. In addition, this revision will (1) clarify the meaning of
Adecrease in effectiveness,@ as stated in 10 CFR 50.54(q); (2) clarify the process for evaluating
proposed changes to emergency plans; (3) provide a method for evaluating proposed changes
to emergency plans; (4) provide clarifying guidance on the appropriate content and format of
applications submitted to the NRC for approval prior to implementation; and (5) clarify what
constitutes a report of emergency plan changes to be submitted to the NRC in accordance with
10 CFR 50.54(q). This revision supersedes RIS 2005-02, dated February 14, 2005, in its
entirety.
1) For non-reactor facilities, the regulations in 10 CFR 40.35(f), 70.32(i), and 76.91(o) provide
direction to licensees seeking to revise their emergency plan. An emergency plan includes
the plan as originally approved by the NRC and all subsequent changes made by the
licensee with, and without, prior NRC review and approval under these regulations. The
current practice for non-reactor facilities concerning emergency plan changes that require
prior NRC approval is to submit the changes as a license amendment request. Current
regulatory guidance for non-reactor emergency plans is contained within Regulatory Guide
3.67, Standard Format and Content for Emergency Plans for Fuel Cycle and Materials
Facilities. The NRC staff is working on updating Regulatory Guide 3.67 to include applicable
elements of this RIS for fuel cycle facilities. The NRC will publish a Federal Register Notice
of the issuance for public comment and availability of the draft updated Regulatory Guide.
2) For Independent Spent Fuel Storage Installations (ISFSI), the emergency plan change
process should be followed in accordance with 10 CFR 72.44(f). The information in this RIS
provides useful examples of the type of evaluations NRC expects ISFSI licensees to conduct
in reviewing changes to their Part 72 approved emergency plans (refer to § 72.24(k) and
§ 72.32) and determining if the changes may be made without prior NRC approval as
required by § 72.44(f). The current practice for non-reactor facilities concerning emergency
plan changes that require prior NRC approval is to submit the changes as a license
amendment request. Additional guidance on emergency planning for ISFSI licensees is
provided in Spent Fuel Storage and Transportation Interim Staff Guidance - 16, Emergency
Planning.
This RIS revision requires no action or written response on the part of addressees.
BACKGROUND INFORMATION
The regulation in 10 CFR 50.54(q) provides direction to licensees seeking to revise their
emergency plan. The requirements related to nuclear power plant emergency plans are given in
the standards in 10 CFR 50.47, Emergency Plans, and the requirements of Appendix E,
Emergency Planning and Preparedness for Production and Utilization Facilities to 10 CFR
Part 50. The standards in § 50.54(q) and Appendix E to Part 50 also establish the requirements
related to emergency plans for research and test reactors. Based upon feedback from the
nuclear power industry, the research and test reactor community, and experience gained by the
NRC staff after reviewing emergency plan changes, the NRC staff has identified a need to clarify
the process for making changes to an emergency plan and to provide licensees with a
consistent method for evaluating proposed emergency plan changes.
RIS 2005-02, Revision 1
Page 3 of 11
In addition, the NRC staff clarifies herein that the license amendment process is the correct
process to use when reviewing decrease (reduction) in effectiveness submittals. Courts have
found that Commission actions that expand licensees authority under their licenses without
formally amending the licenses constitute license amendments and should be processed
through the Commissions license amendment procedures. See Citizens Awareness Network,
Inc. v. NRC, 59 F.3d 284 (1st Cir. 1995); Sholly v. NRC, 651 F.2d 780 (D.C. Cir. 1980) (per
curiam), vacated on other grounds, 459 U.S. 1194 (1983); and In re Three Mile Island Alert, 771
F.2d 720, 729 (3rd Cir. 1985), cert. denied, 475 U.S. 1082 (1986). See also Cleveland Electric
Illuminating Co. (Perry Nuclear Power Plant, Unit 1), CLI-96-13, 44 NRC 315 (1996). A
proposed emergency plan change that would reduce the effectiveness of the plan would give the
licensee a capability to operate at a level of effectiveness that was not previously authorized by
the NRC. In this situation, the licensees operating authority would be expanded beyond the
authority granted by the NRC as reflected in the emergency plan without the proposed change.
Thus, an emergency plan change that would reduce the effectiveness of the plan would expand
the licensees operating authority under its license. A change expanding the licensees
operating authority is, according to the courts, a license amendment and must be accomplished
through a license amendment process.
The staff also stated in SECY-08-0024, Delegation of Commission Authority to Staff to Approve
or Deny Emergency Plan Changes that Represent a Decrease in Effectiveness, dated
February 25, 2008, To make the process by which the NRC will address proposed 10 CFR
50.54(q) changes that represent a decrease in effectiveness clearer, the staff intends to
incorporate language similar to that which currently exists in 10 CFR 50.54(p)(1), as part of the
planned rulemaking. The current schedule for the staffs emergency preparedness (EP)
rulemaking calls for the final rule to be issued no earlier than the summer of 2010. Because of
the timeframe associated with the rulemaking, the staff has determined that the prudent action is
to issue a RIS to clarify that licensees must submit proposed emergency plan changes which
represent a decrease in effectiveness for NRC approval as specified in § 50.54(q), and the
license amendment process is the correct process for the staff to use in reviewing the proposed
change. For purposes of discussion and to incorporate the possibility of future regulatory
changes, the term decrease in effectiveness is considered synonymous with reduction in
effectiveness (RIE).
SUMMARY OF ISSUE
Licensees routinely evaluate proposed revisions to their emergency plan, to determine if these
changes reduce the effectiveness of their current approved emergency plan or adversely affect
their ability to implement the emergency plan. Clarification is needed of an acceptable method
for licensees to use in consistently evaluating proposed changes to the emergency plan to
ensure the licensees ability to maintain and implement the approved emergency plan.
Additionally, licensees should understand the process for submitting proposed emergency plan
changes to the NRC for approval prior to implementation when there is a determination of a
decrease (reduction) in effectiveness.
The change process is described below and clarified by providing a screening criterion that
would ensure consistency of emergency plan change determinations of a decrease (reduction)
in effectiveness. Enclosure 1, A10 CFR 50.54(q) Evaluation Procedure,@ presents a suggested
outline for applying the screening criteria for the evaluation of a proposed emergency plan
change, which is graphically depicted in Attachment 1 to Enclosure 1, A10 CFR 50.54(q)
Flowchart.@ In addition, Enclosure 2, AGuidance for Content of Emergency Plan Submittals to
RIS 2005-02, Revision 1
Page 4 of 11
NRC Requiring Prior NRC Approval,@ provides guidance to licensees in the development of their
application for NRC prior approval of proposed emergency plan changes. The information in
this RIS revision clarifies the process for changing emergency plans to ensure that licensees
maintain effective emergency plans thereby maintaining reasonable assurance that adequate
protective measures can and will be taken in the event of a radiological emergency. This RIS
revision also provides a consistent methodology for licensees to evaluate changes to their
emergency plans and provides clarifying guidance for the development of applications for NRC
prior approval. This will help ensure that NRC review activities and decisions are effective,
efficient, predictable, and consistent.
The regulations require licensees to submit a report of each change within a specified period of
time after the change is made. The NRC Inspectors use this report to evaluate the effectiveness
of a licensees emergency plan change management program in accordance with NRC
Inspection Procedures, and although not required, the inclusion of the applicable licensee
evaluation and justification for the change as part of this report would be beneficial to the staff.
Regulation
In part, 10 CFR 50.54(q) states the following:
The nuclear power reactor licensee may make changes to these plans without
Commission approval only if the changes do not decrease the effectiveness of the
plans and the plans, as changed, continue to meet the standards of § 50.47(b) and
the requirements of appendix E to this part. The research reactor and/or the fuel
facility licensee may make changes to these plans without Commission approval only
if these changes do not decrease the effectiveness of the plans and the plans, as
changed, continue to meet the requirements of appendix E to this part. Proposed
changes that decrease the effectiveness of the approved emergency plans may not
be implemented without application to and approval by the Commission.
Definitions
1) Decrease (Reduction) in Effectiveness (RIE)
a) A change in an emergency plan that results in reducing the licensees capability to
perform an emergency planning function in the event of a radiological emergency.
i)
Note that other licensee activities could affect the ability to implement the emergency
plan effectively. Licensees must maintain the effectiveness of their NRC approved
emergency plans, up to and including, ensuring that changes made to other
programs, structures, systems or components do not adversely impact the licensees
ability to effectively implement its emergency plan. See Information Notice 2005-19,
Effect of Plant Configuration Changes on the Emergency Plan, dated July 18, 2005,
for additional information.
(1) An RIE will occur if there is a change or reduction in an emergency planning
function without a commensurate reduction or change in the bases for that
emergency planning function or without measures put in place to reduce the
impact of the proposed change to the emergency plan. The overall impact of
proposed changes on the effectiveness of the emergency plan or its
RIS 2005-02, Revision 1
Page 5 of 11
implementation is to be determined, not just the effect that individual changes
have on a specific part of the emergency plan.
(2) The following provides some examples of RIEs that would require prior NRC
approval without a commensurate reduction or change in the bases for that
emergency planning function or without measures put in place to reduce the
impact of the proposed change to the emergency plan. These examples should
not be viewed as being all-inclusive or exclusive; rather, licensees should use
them to inform decisions involving various changes being considered. It is also
possible that site-specific situations may make a particular example inapplicable
to a site. Even if a particular example completely encompasses the change being
considered, the licensees emergency plan change evaluation should explain why
the site-specific implementation of the change would not be an RIE for that
particular site. It is not sufficient for such an analysis to simply cross-reference an
example in this RIS revision.
(a) A change that would cause any of the major functional areas or major tasks
identified in the emergency plans to be unassigned. An example of this would
be a technical specification change eliminating on-shift radiation technician
coverage without making an alternative arrangement for providing the
requisite technical expertise in a timely manner.
(b) A change that would impede site access for offsite assistance relied on in the
plan without viable alternate arrangements being made. An example would
be the closure or planned closure of a major river bridge in a case where the
route via the nearest available crossing would incur a substantial increase in
response time.
(c) A change to the emergency response organization (ERO) callout procedures
or hardware that would delay ERO notification such that the augmentation
times in the emergency plans can no longer be achieved. A change to
communications hardware that would reduce the capability to initiate and
complete required emergency notifications within 15 minutes of the
emergency declaration.
(d) A change to the onsite meteorological measurements program such that
meteorological data currently readily available in emergency response
facilities in accordance with the emergency plan would no longer be readily
available.
(e) A change to hazard assessment and radiation protection assignments in re-
entry and recovery procedures that would not provide an adequate level of
personal protection in uncertain reentry conditions.
(f) A change that reduces the availability of site familiarization training currently
presented to offsite assistance groups (e.g., firefighters, local law
enforcement, and medical services, including mutual aid companies that
would support these groups).
RIS 2005-02, Revision 1
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(g) A change that delegates the responsibility for performance of various aspects
of emergency plan maintenance to contractors or other external groups
without adequate supervisory oversight to ensure that program elements
continue to be met (e.g., a change delegating testing and maintenance of the
Alert and Notification System to an external group not subject to typical
nuclear facility work process and configuration controls).
(3) For proposed changes to individual emergency action levels (EALs) (i.e., not an
entire EAL scheme change), an RIE will occur in the following cases:
(a) The proposed change to the EAL would potentially cause an
underclassification, (e.g., what was considered an Alert in the approved
emergency plan would now be considered an Unusual Event or not classified
at all).
(b) The proposed change to the EAL would potentially cause an
overclassification, (e.g., what was considered a Site Area Emergency in the
approved emergency plan would now be considered a General Emergency
with potential consequences for public health and safety).
(c) If the proposed change to the EAL is to change an Initiating Condition
setpoint (or threshold) without a commensurate change in the regulatory basis
for the EAL Initiating Condition setpoint (or threshold).
(d) The actual numerical setpoint of a given EAL may be revised without prior
NRC approval under the following conditions via the 10 CFR 50.54(q)
emergency plan change process:
(i) The regulatory basis for the EAL setpoint has been revised and is
approved via a letter to the licensee or a Safety Evaluation (SE). For
example, a site receives NRC approval (via a SE) for power up-rate.
Power up-rate implementation causes the normal radiation levels to
increase, thus necessitating an increase in EAL setpoints based on
normal radiation levels. The regulatory basis for the setpoint has been
changed, thus this change can be processed via the emergency plan
change process because the effectiveness of the emergency plan has not
been reduced.
(ii) The regulatory basis for the EAL setpoint has not been changed but the
method for detection of the setpoint has been changed. For example, a
given EAL setpoint is based upon exceeding 1 Rem total effective dose
equivalent (TEDE). The radiation monitor reading setpoint is based upon
a reading that would give the equivalent of exceeding 1 Rem TEDE. The
radiation monitor is replaced and operates differently. The actual
numerical value of the EAL needs to be revised to that which is equivalent
to 1 Rem TEDE. The regulatory basis for the setpoint has not been
changed, thus this change can be processed via the emergency plan
change process as the effectiveness of the emergency plan has not been
reduced.
RIS 2005-02, Revision 1
Page 7 of 11
a) The document(s) prepared and maintained by the licensee that identify and describe the
licensees methods for maintaining and performing emergency planning functions. An
emergency plan includes the plans as originally approved by the NRC and all
subsequent changes made by the licensee with, and without, prior NRC review and
approval under 10 CFR 50.54(q).
i)
The licensee=s emergency plan consists of:
(1) The emergency plan as approved by the NRC via a Safety Evaluation Report, SE,
or license amendment (LA) from the Office of Nuclear Reactor Regulation (NRR)
or the Office of Federal and State Materials and Environmental Management
Programs (FSME).
(2) Changes to the emergency plan explicitly reviewed by the NRC through an SE, or
LA from NRR or FSME, and found to meet the applicable regulations.
(3) Changes to the emergency plan explicitly reviewed by the NRC through an SE, or
LA, and found to be an approved amendment to the licensees emergency plan.
(4) Changes made by the licensee without NRC review and approval after the
licensee concluded that the change(s) do not constitute a decrease RIE.
Emergency Plan Change Process
1.
Process Overview
Reasonable assurance that adequate protective measures can and will be taken in the event of
a radiological emergency is based on the licensee=s emergency plan, and the successful
implementation of that emergency plan. The body of an emergency plan contains statements
that describe how a licensee will meet regulatory requirements. The standards of 10 CFR
50.47(b) and the requirements of Appendix E to 10 CFR Part 50 establish the contents of the
nuclear power reactor emergency plan. The standards in § 50.54(q) and Appendix E to Part 50
establish the requirements related to emergency plans for research and test reactors.
Subsequent changes to the emergency plan must comply with § 50.54(q). Enclosure 1 outlines
the emergency plan change process, and Attachment 1 to Enclosure 1 graphically depicts the
process in a flowchart.
2.
Emergency Plan Review
Changes to an emergency plan may result from advances in technology, new or revised rules,
site-specific needs, processes, guidance (such as Nuclear Energy Institute guidance endorsed
by the NRC), technical specification changes, or modifications to instrumentation. Changes that
the licensee has identified as RIEs must be submitted to the NRC for review and prior approval.
The NRC staff will review the emergency plan change against the standards, regulations,
guidance documents and the approved emergency plan. The NRC will review and approve
RIS 2005-02, Revision 1
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submittals on a case-by-case basis. An emergency plan change approved for one licensee
does not mean that the same or similar change would be approved for another licensee.
For the purposes of determining whether a change to a licensee=s emergency plan constitutes
an RIE, the licensee should use the last emergency plan reviewed and approved by the NRC. If
the emergency plan change process has been properly implemented over the years, comparing
a proposed emergency plan change to either the latest emergency plan reviewed and approved
by the NRC or the emergency plan as changed by the licensee should result in the same RIE
determination. For example, if a licensee made a series of changes over time to the same
specific provision of the emergency plan, where each change was separately determined not to
constitute an RIE, then there should be no RIE. Therefore, there should be no RIE when
comparing the latest emergency plan to the emergency plan reviewed and approved by the
NRC. If a licensee or the NRC concludes that there is a RIE due to a series of changes over
time, then the provisions of the emergency plan change process have not been correctly
followed.
The EP requirements are a framework for how the licensee will meet the applicable standards
and requirements of the regulations. If a licensee has determined that an EP requirement
should be increased in order to meet the planning standards or Appendix E to Part 50
requirements, these changes must follow the emergency plan change process and revise the
emergency plan to reflect this increase to the EP requirement. Nevertheless, whether or not an
emergency plan change results in a RIE is not determined by assessing whether NRC regulatory
requirements continue to be met after the EP requirement has been changed. The licensees
emergency plan may include EP requirements that exceed the baseline standards and
requirements as set forth in § 50.47(b) and Appendix E to Part 50. For the RIE determination,
the change or changes should be evaluated against the capability to perform the functions and
the associated time requirement of performing the function, if applicable. The evaluation should
document whether the capability or timeliness to perform a function is lost and/or degraded. In
addition to the RIE determination, the change or changes should also be evaluated to verify that
they continue to meet the standards and requirements as set forth in § 50.47(b) and Appendix E
to Part 50.
The current Commission requirements for document retention in § 50.54(q), specify that
changes that do not warrant NRC approval must be retained for 3 years. The licensee must
retain changes that reduce the effectiveness of the emergency plan until the Commission
terminates the license. It may be prudent to save emergency plan change documentation to
show the historical progression of changes, since the Commission, through its staff, may review
at any time, the emergency plan changes that have been made.
Related Topics Regarding Emergency Plan Changes
1.
Regulatory Process for Evaluating Licensee Requests for NRC Prior Approval of
Emergency Plan Changes Determined To Be a RIE in Accordance with 10 CFR
50.54(q)
Similar to security plan changes submitted via 10 CFR 50.54(p)(1), emergency plan changes
that result in the reduction in the effectiveness of the approved emergency plan require prior
NRC approval, under § 50.54(q), and should to be submitted as license amendment requests
under § 50.90.
2.
Emergency Action Level Changes
RIS 2005-02, Revision 1
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A revision to an entire EAL scheme, from NUREG-0654, Criteria for Preparation and Evaluation
of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power
Plants, to another NRC-endorsed EAL scheme, must be submitted for prior NRC approval as
specified in Section IV.B. of Appendix E to 10 CFR Part 50. The Statement of Considerations
for the final rule amending the NRCs regulations relating to NRC approval of EAL changes,
dated January 26, 2005, stated in part, The Commission believes a licensee's proposal to
convert from one EAL scheme (e.g., NUREG-0654-based) to another EAL Scheme
(NUMARC/NESP-007 or NEI 99-01 based) ... is of sufficient significance to require prior NRC
review and approval. NRC review and approval for such major changes in EAL methodology is
necessary to ensure that there is reasonable assurance that the final EAL change will provide an
acceptable level of safety. Regulatory Guide 1.101, Revisions 3 and 4, Emergency Planning
and Preparedness for Nuclear Power Reactor, endorsed NUMARC/NESP-007 and NEI 99-01
EAL guidance, respectively, as acceptable alternatives to the guidance provided in NUREG-
0654 for development of EALs to comply with § 50.47 and Appendix E to Part 50. A change in
an EAL scheme to incorporate the improvements provided in NUMARC/NESP-007 or NEI 99-01
would not decrease the overall effectiveness of the emergency plan and would not expand a
licensees operating authority beyond that previously authorized by NRC, but due to the potential
safety significance of the change, the change needs prior NRC review and approval. This
approval is given via SE and letter.
Revisions of an individual EAL that results in a decrease in effectiveness must be submitted for
NRC approval as specified in § 50.54(q), and the license amendment process is the correct
process for the staff to use in reviewing the proposed change. As discussed previously, an
emergency plan change that would reduce the effectiveness of the plan would expand the
licensees operating authority under its license. A change expanding the licensees authority is,
according to the courts, a license amendment and must be accomplished through a license
amendment process. For research and test reactors, NUREG-0849, AStandard Review Plan for
the Review and Evaluation of Emergency Plans for Research and Test Reactors,@ issued
October 1983, provides guidance on EALs and how changes should be made on a case-by-
case basis with consideration of the provisions of § 50.54(q).
3.
Inspection Activities
For power reactors, the NRC inspectors use Inspection Procedure (IP) 71114.04 to conduct a
review of the effectiveness of the licensee=s implementation of the 10 CFR 50.54(q) change
process. For research and test reactors, the NRC inspectors use IP 69011, AClass I Research
and Test Reactor Emergency Preparedness,@ and IP 69001, AClass II Research and Test
Reactors. The inspector will perform a screening review of the change relative to the
emergency plan; however, this will not constitute NRC approval of the plan as changed.
The documentation of the change reviewed by the inspectors will be the report provided by the
licensee as stated in § 50.54(q). Although not required, the inclusion of the applicable licensee
evaluation and justification for the change as part of this report would assist the staff in the
review.
4.
Lower Tier Documents
If a licensee has incorporated a lower tier document into the emergency plan or the emergency
plan explicitly references a lower tier document as a method to implement a specific requirement
in the emergency plan, then, it is considered part of the plan and subject to §50.54(q) review.
Historically, some licensees have developed emergency plan implementing procedures that
RIS 2005-02, Revision 1
Page 10 of 11
included the necessary information needed for activities that are required to meet the
regulations, for example, procedures for notifications, dose assessment, protective action
recommendations, emergency classifications and emergency action levels. The staff is not
making the use of § 50.54(q) to review all changes to lower tier documents a requirement, but
acknowledges that using § 50.54(q) as the regulation to provide revision control of these lower
tier documents has been in place and supported by the NRC through the inspection and
licensing process.
BACKFIT DISCUSSION
This RIS revision does not require any action or written response. This RIS revision provides
non-regulatory review guidance for licensees and clarifies existing regulatory requirements
licensees must follow when proposing changes to their emergency plans. The NRCs Backfit
Rule, 10 CFR 50.109, applies to, among other things, the procedures necessary to operate a
nuclear power plant. To the extent that using a license amendment process for making
modifications to emergency plans that reduce the effectiveness of the plans is considered a
change, it would be a change to the NRCs regulatory process for addressing modifications to
the emergency plan. The NRCs regulatory review process is not a licensee procedure required
for operating a plant that would be subject to backfit limitations.
Further, the Backfit Rule protects licensees from Commission actions that arbitrarily change
license terms and conditions. In 10 CFR 50.54(q), a licensee requests Commission authority to
do what is not currently permitted under its license. The licensee has no valid expectations
protected by the Backfit Rule regarding the means for obtaining the new authority that is not
permitted under the current license. For these reasons, this RIS revision does not constitute a
backfit under 10 CFR 50.109, and the staff did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS revision was published in the Federal
Register on XXXX XX, 2009. There were xx comments from stakeholders, which were
considered before issuance of this RIS revision.
PAPERWORK REDUCTION ACT STATEMENT
This RIS revision does not contain information collections and, therefore, is not subject to the
requirements of the Paperwork Reduction Act of1995 (44 U.S.C. 3501 et seq.).
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for
information or an information collection requirement unless the requesting document displays a
currently valid Office of Management and Budget control number.
RIS 2005-02, Revision 1
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CONTACT
Please direct any questions about this matter to the technical contact listed below or to the
appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Timothy J. McGinty, Director
Daniel H. Dorman, Director
Division of Policy and Rulemaking
Division of Fuel Cycle Safety and Safeguards
Office of Nuclear Reactor Regulation
Office of Nuclear Materials Safety and Safeguards
E. William Brach, Director
Division of Spent Fuel Storage and Transportation
Office of Nuclear Materials Safety and Safeguards
Enclosures:
1. 10 CFR 50.54(q) Evaluation Procedure (typical)
2. Guidance for Content of Emergency Plan Submittals to the NRC Requiring
Prior NRC Approval
Note: NRC generic communications may be found on the NRC public Web site,
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
Technical Contact:
Don A. Johnson, NSIR/DPR/ONRLB
(301) 415-4040
Email: don.johnson@nrc.gov
s: Package: ML092260002 RIS- ML080710029 Non-Concurrence- ML092250622
- see previous concurrence
OFFICE
NSIR/DPR
TECH ED
TL:NSIR:DPR
BC:NSIR:DPR
DD:NSIR:DPR
NAME
- DJohnson
- DJ for MNorris
- KWilliams
- CMiller
Date
08/24/2008
04/07/2008
08/24/2008
12/02/2008
04/07/2009
OFFICE
D:NSIR:DPR
NRR/DIRS/IRIB (BC)
NRR/DORL
NRR/DORL
NSIR/PMDA
NAME
- CM for MLeach
JIsom for TKobertz
REnnis
Non-Concur
- JGitter
- VHuth
DATE
08/24/2008
REMOVE
04/24/2009
05/22/2009
04/14/2009
OFFICE
NRO/DNRL
NMSS (D)
FSME/WMEP
OIS (D)
OE (D)
NAME
- PMadden
- NMamish E-mail for
CHaney
- KMcConnell for
LCamper
- TBoyce
- GGulla for CCarpenter
DATE
03/25/2009
07/17/2009
06/02/2009
05/28/2009
06/05/2009
OFFICE
OGC/CRA
OGC/NLO
NRR/DPR/LA
NRR/DPR/PGCB
NRR/DPR/PGCB/BC
NRR/DPR
NAME
- SCroston
- BJones
CHawes
- SStuchell
MMurphy
T.McGinty
DATE
07/23/2009
07/29/2009
07/30/09
07/30/2009
Enclosure 1
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Enclosure 1: 10 CFR 50.54(q) Evaluation Procedure (typical)
1.0
Purpose
1.1.
This document is a compilation of best practices developed by licensees to implement an
effective emergency plan change management program. It is not intended to direct
licensees to develop their program as stated in this regulatory issue summary (RIS)
revision, nor to direct the U.S. Nuclear Regulatory Commission (NRC) inspectors on what
the regulatory requirements are for an emergency plan change management program. It is
intended to provide an example of a quality program for licensees to consider for their own
use.
1.1.1.
Note that many aspects of this procedure are not based upon explicit regulatory
requirements, but are rather based upon sound conservative decision making by licensees
to ensure a quality emergency plan change management program.
1.2.
This document provides instructions for performing an effectiveness review of proposed
changes that may affect the Emergency Preparedness (EP) Program.
1.2.1.
Changes to the emergency plan require a 10 CFR 50.54(q) evaluation to identify if those
changes decrease (reduce) the effectiveness (RIE) of the emergency plan.
1.2.2.
NRC Information Notice (IN) 2005-19, Effect of Plant Configuration Changes on the
Emergency Plan, dated July 18, 2005, was issued to inform licensees of inspection
findings related to licensees failure to properly evaluate the effect of plant configuration
changes (procedures, equipment and facilities) on the emergency plan. Changes to
emergency procedures, or modifications to equipment or facilities used to implement the
emergency plan, should be reviewed with a 10 CFR 50.54(q) screening process, and
possible evaluation, to ensure those changes do not directly or indirectly reduce the
effectiveness of the emergency plan. Some examples include, but are not limited to, the
following: emergency plan implementing procedures (EPIPs); emergency action level
(EAL) technical bases document (for sites that do not have NUREG-0654 EALs); site
staffing procedures; emergency response facility ventilation, power, and/or spacing
requirements; and modifications to equipment required to determine an EAL threshold.
1.2.3.
If a licensee has incorporated a lower tier document into the emergency plan or the
emergency plan explicitly references a lower tier document as a method to implement a
specific requirement in the emergency plan, then it is considered part of the plan and
subject to §50.54(q) review. Historically, some licensees have developed EPIPs that
included the necessary information needed for activities that are required to meet the
regulations, for example, procedures for notifications, dose assessment, protective action
recommendations, emergency classifications and emergency action levels. The staff is not
making the use of § 50.54(q) to review all changes to lower tier documents a requirement,
but acknowledges that using § 50.54(q) as the regulation to provide revision control of
these lower tier documents has been in place and supported by the NRC through the
inspection and licensing process.
2.0
Definitions & applicability of terms: {Implementation of the 10 CFR 50.54(q) process is
dependent upon the use of key terms. The following definitions have been identified as key
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terms necessary to complete a 10 CFR 50.54(q) evaluation that meets the intent of 10 CFR
50.54(q)}
2.1.
Activity: A series of events or actions that may result in a change to the emergency plan or
affect the implementation of the emergency plan.
An activity sets in motion the need to determine impact on certain licensing bases
documents using regulatory review criteria such as 10 CFR 50.54(q).
Activities may range from something as simple as making an editorial change or an
organizational change, to making complicated facility modifications.
For the purposes of 10 CFR 50.54(q), activities may also originate outside of the
licensees responsibility such as permanent road closings or substantive population
increases.
2.2.
Change: An action that results in modification or addition to, or removal from, the
licensees emergency plan, or the resources, capabilities and methods identified in the
plan, and affects an emergency planning requirement.
2.3.
Emergency Plan: The document(s) prepared and maintained by the licensee that identify
and describe the licensees methods for maintaining and performing emergency planning
functions. An emergency plan includes the plans as originally approved by the NRC and all
subsequent changes made by the licensee with, and without, prior NRC review and
approval under 10 CFR 50.54(q).
2.3.1.
The licensee=s emergency plan consists of:
The emergency plan as approved by the NRC via a Safety Evaluation Report (SER),
Safety Evaluation (SE), or license amendment (LA) from the Office of Nuclear Reactor
Regulation (NRR) or the Office of Federal and State Materials and Environmental
Management Programs (FSME);
Changes to the emergency plan explicitly reviewed by the NRC through an SE, or LA,
from NRR and found to meet 10 CFR 50.47(b) and the requirements of Appendix E to
Changes to the emergency plan explicitly reviewed by the NRC through an SE, or LA,
and found to be an approved amendment to the licensee=s emergency plan, and
Changes made by the licensee without NRC review and approval after the licensee
concluded the change(s) does not constitute a decrease (reduction) in effectiveness.
2.4.
Emergency Planning Function (Requirement): A capability or resource necessary to
prepare for and respond to a radiological emergency as set forth in the elements of Section
IV of Appendix E to 10 CFR Part 50 and, for nuclear power reactors, the planning
standards of 10 CFR 50.47(b).
2.4.1.
Note that other licensee changes, other than to the emergency plan, could adversely
impact an emergency planning function. The licensee is responsible for evaluating these
changes and for maintaining the ability to implement the approved emergency plan.
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2.5.
Decrease (Reduction) in Effectiveness (RIE): A change in an emergency plan that results
in reducing the licensees capability to perform an emergency planning function in the event
of a radiological emergency.
2.5.1.
Note that other licensee activities could affect the ability to implement the emergency plan
effectively. Licensees must maintain the effectiveness of their NRC approved emergency
plans, up to and including, ensuring that changes made to other programs, structures,
systems or components do not adversely impact the licensees ability to effectively
implement their emergency plan. Reference IN 2005-19 for additional information.
2.5.1.1.
An RIE will occur if there is a change or reduction in an emergency planning function
without a commensurate reduction or change in the bases for that emergency planning
function or without measures put in place to reduce the impact of the proposed change to
the emergency plan. The overall impact the proposed changes have on the effectiveness
of the emergency plan or its implementation is to be determined, not just the effect
individual changes have on a specific part of the emergency plan.
2.5.1.2.
For example, if a licensee proposes to remove an emergency response organization
position (function) that the approved emergency plan expects to respond in 30-minutes,
and no other measures are put in place to reduce the impact of the proposed change to the
emergency plan, the change may be considered an RIE.
2.5.1.3.
For proposed changes to individual EALs (i.e., not an EAL scheme change), an RIE will
occur if the proposed change to the EAL that would potentially cause an
underclassification, e.g., what was considered an Alert in the approved emergency plan
would now be considered an Unusual Event or not classified at all; an overclassification,
e.g., what was considered a Site Area Emergency in the approved emergency plan would
now be considered a General Emergency and may have potential consequences to public
health and safety; or, if the proposed change to the EAL is to change an setpoint (or
threshold) without a commensurate change in the regulatory basis for the EAL setpoint (or
threshold).
2.6.
Editorial Change: Editorial changes do not require a 10 CFR 50.54(q) review. The
following are examples of Editorial Changes:
Procedure title change
Reference or annotation change
Correction of location description
Correction of typographical errors and punctuation
Reformatting changes that do not change intent, purpose, or order of procedural steps
Changes on plant drawing grid coordinates
Change to position titles when no responsibilities for that position have changed
Correction in page or step numbering.
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3.0
Regulatory Guidance
3.1.
EP standards are provided in 10 CFR 50.47(b) and requirements are provided in
Appendix E to 10 CFR Part 50. Clarifications and expectations are provided in the various
guidance documents, particularly the following:
3.1.1.
NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency
Response Plans and Preparedness in Support of Nuclear Power Plants,
3.1.2.
NUREG-0696, Functional Criteria for Emergency Response Facilities,
3.1.3.
NUREG-0737, Clarification of TMI Action Plan Requirements, and
3.1.4.
Regulatory Guide 1.101, Emergency Planning and Preparedness for Nuclear Power
Reactors.
3.2.
A licensees emergency plan must meet the standards and requirements. The regulatory
guidance details the methods by which the staff verifies compliance and provides methods
that have been determined to be acceptable in the development and maintenance of an
effective EP program. The emergency plan therefore, becomes a culmination of various
requirements that the NRC will evaluate and determine whether the licensee has the
capability to provide reasonable assurance that adequate protective measures can and will
be taken in the event of a radiological emergency.
3.3.
Changes to the emergency plan must be evaluated to ensure that an emergency planning
function has not been modified, or if the function has been changed, that the basis for the
change is justifiable. Licensees need to determine if the proposed changes cause an RIE.
4.0
Qualifications
4.1.
Preparers, reviewers, and approvers of 10 CFR 50.54(q) evaluations should be qualified to
do so in order to ensure a consistent and effective program.
4.1.1.
A § 50.54(q) screening should be performed by personnel knowledgeable of the proposed
change and its potential impact on the EP Program. However, the EP Program Manager
should be consulted whenever questions as to applicability arise.
5.0
10 CFR 50.54(q) screening
5.1.
A 10 CFR 50.54(q) review should also be performed for proposed revisions to other plant
procedures or other non-EP documents that implement aspects of the sites EP program to
ensure that changes are not made to non-EP procedures that adversely impact the EP
program.
5.1.1.
The following screening criteria should be used to screen for 10 CFR 50.54(q) applicability:
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Is this a change to shift staffing levels?
YES
NO
Is this a reduction in department staffing
levels that impacts the emergency plans
24-hour staffing requirements?
YES
NO
Is this a change to systems, equipment,
setpoints, procedures, etc., that are used to
determine EAL Initiating Conditions?
YES
NO
Is this a change to site Operations, Fire
Brigade, and/or Security response protocols
(i.e., security events, medical response,
10 CFR 50.54(x) protocol, etc.)?
YES
NO
Is this a change to Emergency Response
Facilities or equipment?
YES
NO
Is this a change to non-EP procedures that
has the potential to affect the EP program?
YES
NO
If any are checked YES, a 10 CFR 50.54(q) review of the proposed change(s) is
needed.
6.0
10 CFR 50.54(q) review
6.1.
A 10 CFR 50.54(q) review shall be performed for all proposed revisions to emergency
plans and EALs that reduce the effectiveness of the emergency plans (except for EAL
scheme changes). Although not required, a § 50.54(q) review should be conducted for
applicable lower tier documents in accordance with Attachment 2, 10 CFR 50.54(q)
Review.
6.1.1.
Some changes to EP procedures/processes may potentially affect other departments
programs and may thus require a 10 CFR 50.59 Applicability Review, or other review based
upon the proposed activity.
6.1.1.1.
The following regulatory requirements must be addressed, when applicable, to the program
being affected:
QA Program:
ISI/IST Program:
Appendix J:
Security Program:
Maintenance Rule:
Fire Plan:
Site Fire Plan
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Changes, Tests, or Experiments: 10 CFR 50.59
6.2.
Perform the 10 CFR 50.54(q) review in accordance with the instructions contained in
Attachment 2, 10 CFR 50.54(q) Review.
7.0
References
10 CFR App. E. IV
10 CFR App. E. V
10 CFR App. E VI
NRC Significance Determination Process, Appendix B
FEMA-REP-10
8.0
Attachments
Attachment 1: 10 CFR 50.54(q) Review Flowchart
Attachment 2: 10 CFR 50.54(q) Review
Attachment 1
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ATTACHMENT 1: 10 CFR 50.54(q) FLOWCHART
Proposed plan or
EAL change(s).
(Not an EAL scheme
upgrade).
Perform 10 CFR 50.54(q) screening.
Require
review?
Perform a
review of the
proposed changes.
Do the proposed
changes result in an
RIE?
Submit to the NRC for prior
approval in accordance with
10 CFR 50.90 or
Appendix E to 10 CFR Part 50
for EAL scheme changes
Entire EAL scheme
upgrade
Yes
Implement the
change(s).
Submit report to the
NRC within 30-days
of the change in
accordance with
No
No
Yes
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ATTACHMENT 2: 10 CFR 50.54(q) REVIEW
1.0
On the 10 CFR 50.54(q) Form:
NOTE
This form should be complete and detailed enough to allow
an NRC Inspector or other reviewer to evaluate its merits
without referring to other documents or references.
1.1.
Briefly document a description of the change
1.2.
Check if this is change is due to a procedure change, modification or other.
1.3.
Check if this change is purely editorial in nature (see definition).
1.3.1.
If yes, document the Background and Scope of the change (Background & Scope: A
description of the reason for and scope of the change).
1.3.1.1.
Then the document may be revised, approved, and implemented.
1.3.1.2.
Submit to the NRC, as specified in 10 CFR 50.4, within 30 days of the effective date of
change.
2.0
Determine if the proposed change impacts the items that describe the Planning
Standards of 10 CFR 50.47(b) and requirements of Appendix E to 10 CFR Part 50.
2.1.
If any questions are checked YES, then a 10 CFR 50.54(q) review is required.
2.1.1.
Evaluate each change against the specific elements of 10 CFR 50.47(b), Appendix E to
10 CFR Part 50, the emergency plan and other applicable regulations and requirements.
2.1.2.
Determine if the proposed changes maintain or improve the capability to:
To respond to an emergency, or meet actions or other requirements described in
the Emergency Plan, Implementing Procedures, or EALs.
To protect the health and safety of plant personnel and the general public in the
event of an emergency.
To implement Federal regulations or requirements.
2.1.3.
Determine if the change reduces the effectiveness of the plan by the following:
If the change still implements the planning standard utilizing a different method,
then document the new method and state why the change does, or does not;
reduce the effectiveness of the plan.
If a setpoint was changed, then state why the change is, or is not, a reduction in
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the effectiveness of the plan.
If an instrument/tool type was substituted and the instrument still performs the
same function, then state why the change does, or does not; alter the
effectiveness of the plan.
NOTE
A reduction in effectiveness in the emergency plan/EAL
is determined to have occurred if there has been a
change to an EP requirement without a commensurate
change in the bases for that EP requirement.
2.1.4
Document the review in the outline format below:
2.1.4.1
Background and Scope: A description of the reason for and scope of the change.
2.1.4.2
Program Requirements: A description of the regulation standard or requirement for which
the EP program must demonstrate compliance.
NOTE
For changes that are large in scope, in which a one-to-
one comparison is not practical, a detailed discussion of
the change that compares the current content with the
proposed content may be developed.
2.1.4.3
Change Comparison: A comparison showing both old and new wording, including step or
section number references as applicable. Changes that incorporate new information are
marked as Added to Document. Changes that involve the deletion of information are
marked as Removed from Document.
NOTE
Ensure that the comparison also accounts for wording
from the APPROVED EMERGENCY PLAN/EALs to
ensure that a gradual relaxation in program standards or
requirements has not occurred.
2.1.4.4
Change Assessment: A discussion of how the change degrades, does not affect, or
enhances the effectiveness and abilities of the EP Program as it relates to the program
requirements.
2.1.4.5
Justification: A formal justification that describes the basis and reasons the change is
appropriate and necessary for any degradation (otherwise, not required). Sufficient level
of detail must be provided to support the basis for complex and significant changes and
conclusion regarding effectiveness.
2.1.4.6
References: A list of references such as regulations, guidance documents, information
notices, inspection reports or other sources which contain criteria incorporated by the
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emergency plan related to the change.
2.2.
If the proposed change is to the fleet/station emergency plan, EALs, EAL bases
document (if applicable), or a lower tier document, but does not reduce their
effectiveness, then,
2.2.1.
Submit to the NRC, as specified in 10 CFR 50.54(q) and Appendix E to 10 CFR Part 50, a
report of the change within 30 days of the effective date of change.
2.2.1.1.
Although not required, it would be beneficial to the staff for the report to include the 10
CFR 50.54(q) evaluation and justification for the applicable change(s).
2.3.
If the proposed change is to the emergency plan, EALs, EAL bases document (if
applicable), or a lower tier document that is incorporated into the emergency plan or is
explicitly referenced as a method to implement a specific requirement in the emergency
plan, and does, by definition, reduce the effectiveness of the emergency plan or EAL,
then:
2.3.1.
If the proposed change is to the emergency plan or a lower tiered document (if
applicable), submit the revised document and the 10 CFR 50.54(q) review to the NRC for
approval prior to implementation in accordance with 10 CFR 50.90.
2.3.2.
If the proposed change is to the EALs (not a scheme change) and/or EAL bases
document (if applicable), submit the revised document and the 10 CFR 50.54(q) review to
the NRC for approval prior to implementation in accordance with 10 CFR 50.90.
2.3.2.1.
If the proposed change is approved by the NRC, then the document may be revised,
approved, and implemented.
2.4.
If all questions are checked NO, then further review is not required.
2.4.1.
Document the Background and Scope of the change (Background & Scope: A
description of the reason for and scope of the change).
2.4.2.
Then the document may be revised, approved, and implemented.
2.4.2.1.
Submit to the NRC, as specified in 10 CFR 50.4, within 30 days of the effective date of
change.
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10 CFR 50.54(q) REVIEW FORM
Description of Change:
_________________________________________________________
_________________________________________________________
_________________________________________________________
Plan Sections/Procedure(s) #: __________________
Revision(s) #:
____________
Mod #:
_______________________________________________________________
Other:
_______________________________________________________________
Is the proposed change purely editorial in nature (see definition)? [If YES, discontinue review
process and process the procedure change.]
YES
NO
Does the proposed change affect any of the following: [Check yes or no. Reference the actual
standards/requirements.]
50.47
PARAPHRASED STANDARD
YES
NO
(b)(1)
Primary responsibilities of the {applicable site and offsite response}
organizations.
Responsibilities of supporting organizations.
Initial staffing or augmentation
(b)(2)
On-shift responsibilities for emergency response.
Staffing for initial accident response
Timely augmentation
Interfaces among onsite and offsite response activities.
(b)(3)
Arrangements for requesting and using assistance resources.
Accommodations at the EOF for {applicable site and offsite response}
staff.
Other organizations capable of augmenting response are identified.
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50.47
PARAPHRASED STANDARD
YES
NO
(b)(4)
Emergency classification and action level scheme.
State/county minimum response based on site information.
EAL Initiating Condition setpoints or thresholds.
(b)(5)
Process for notification of state/county response organizations.
Notification of emergency personnel.
Procedure for initial and follow-up messages.
ANS notification within the 10-mile EPZ
(b)(6)
Provisions for prompt communication among principal response
organizations to emergency response personnel and to the public.
(b)(7)
Public information distributed on a periodic basis.
News media points of contact established.
Procedures for coordinated dissemination of info to the public.
(b)(8)
Emergency response facilities, equipment, and maintenance.
(b)(9)
Methods, systems, or equipment for assessing and monitoring actual or
potential offsite consequences.
(b)(10)
Range of protective actions for the Plume EPZ established (offsite).
Guidelines for choice of PARs in place.
Protective actions for Ingestion Pathway EPZ established.
(b)(10)
Range of protective actions for the Plume EPZ established (onsite).
(b)(11)
Controlling radiological exposure for emergency workers.
(b)(12)
Arrangements for medical service for contaminated injured individuals.
(b)(13)
General plans for recovery and reentry.
(b)(14)
Exercise or drill conduct and corrective action system.
(b)(15)
Radiological emergency response training.
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50.47
PARAPHRASED STANDARD
YES
NO
(b)(16)
Responsibilities for plan development, review, and distribution of
emergency procedures established.
EP Staff is properly trained.
Implementation of other federal regulations and requirements related to
the Emergency Preparedness Program.
The operation, maintenance, or testing requirements of the ERDS.
App. E
PARAPHRASED REQUIREMENT
YES
NO
IV. A
Organization
IV. B
Assessment actions
IV. C
Activation of emergency response
IV. D
Notification procedures
IV E
Emergency facilities and equipment
IV. F
Training
IV. G
Maintaining emergency preparedness
IV. H
Recovery
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REDUCED
EFFECTIVENESS.
STANDARDS
AND/OR
ELEMENTS
EFFECTED
DESCRIPTION OF EFFECT
YES
NO
Background and Scope:
Program Requirements:
Change Comparison:
Change Assessment:
Justification:
YES
NO
This procedure change requires prior NRC approval.
Document all references used for this review:
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Prepared By:
Date:
Qualified Preparer
Reviewed By:
Date:
Qualified Reviewer
Approved By:
Date:
Manager - EP
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Enclosure 2: GUIDANCE FOR CONTENT OF EMERGENCY PLAN SUBMITTALS TO REQUIRING
PRIOR NRC APPROVAL
Note: The intent of this enclosure is to provide guidance to licensees in the development of their
application for NRC prior approval of proposed emergency plan changes
APPLICATION CONTENT
YES
NO
N/A
COVER LETTER
Specifically state what change(s) are requested for NRC
review and approval.
State why the change(s) are being requested.
Identify which regulation or NRC guidance document under
which the application is being submitted.
Provide the names of the licensing and technical contacts.
Request a specific date for NRC approval. If less than one
year, provide an acceptable reason.
Reference all attachments.
SUBMITTAL
BODY
State each proposed change and discuss the justification
for the change and any measures that will be
implemented.
State the basis for the proposed change and why it is
considered a reduction in effectiveness in sufficient detail
to support a technical review.
Define any terms that are unique to the site, related to
new technology, etc.
Provide a table showing the current approved wording, the
proposed wording, and the basis for the change(s).
Provide an acceptable level of detail to support a technical
review of the proposed change(s).
Discuss the use of any precedents and a justification for why
these stated precedents are applicable to this submittal.
For an EAL scheme upgrade from NUREG-0654, follow the
guidance from RIS 2003-18, including its supplements.
Provide discussion on any drills, table-tops, or walkthroughs
that validate these proposed change(s), if applicable.