Regulatory Guide 1.101: Difference between revisions

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{{Adams
{{Adams
| number = ML13350A291
| number = ML21111A090
| issue date = 11/30/1975
| issue date = 06/30/2021
| title = Emergency Planning for Nuclear Power Plants.
| title = Rev. 6, Emergency Response Planning and Preparedness for Nuclear Power Reactors
| author name =  
| author name = Murray C
| author affiliation = NRC/OSD
| author affiliation = NRC/RES/DE/RGDB
| addressee name =  
| addressee name =  
| addressee affiliation =  
| addressee affiliation =  
| docket =  
| docket =  
| license number =  
| license number =  
| contact person =  
| contact person = Bayssie M
| document report number = RG-1.101
| document report number = RG-1.101, Rev. 6
| package number = ML21111A075
| document type = Regulatory Guide
| document type = Regulatory Guide
| page count = 15
| page count = 11
}}
}}
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION                                                                                                                       November 1975 REGULATORY GUIDE
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION
        OFFICE OF STANDARDS DEVELOPMENT
                              REGULATORY GUIDE 1.101, REVISION 6 Issue Date: June 2021 Technical Lead: Charles Murray EMERGENCY RESPONSE PLANNING AND PREPAREDNESS FOR
                                                                              REGULATORY GUIDE 1.101 EMERGENCY PLANNING FOR NUCLEAR POWER PLANTS
                                      NUCLEAR POWER REACTORS


==A. INTRODUCTION==
==A. INTRODUCTION==
create a high order of preparedness and ensure an orderly and timely decision-making process at times of Section 50.34, "Contents of Applications; Technical                                  stress, as well as the availability of necessary equipment.
Purpose This regulatory guide (RG) describes an approach that is acceptable to the staff of the U.S. Nuclear Regulatory Commission (NRC) to meet the regulatory requirements for emergency response planning and preparedness. This revision updates the list of NRC-developed and NRC-endorsed guidance documents acceptable to meet the regulatory requirements of Title 10 of the Code of Federal Regulations
(10 CFR) 50.47, Emergency Plans (Ref. 1), and 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities (Ref. 2).
Applicability This RG applies to all holders of, or applicants for, a power reactor operating license or construction permit under 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, except those that have certified that they have permanently ceased operations and have permanently removed all fuel from the reactor vessel, as well as all holders of, or applicants for, a power reactor early site permit or a combined license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants (Ref. 3). This RG is for light water reactors, including those of an advanced design (e.g., AP1000 design).
Applicable Regulations
    *  10 CFR Part 50 provides regulations for licensing production and utilization facilities.


*        Information." of I0 CFR Part 50, "Licensing of                                            supplies, and services.
Written suggestions regarding this guide or development of new guides may be submitted through the NRCs public Web site in the NRC Library at https://nrcweb.nrc.gov/reading-rm/doc-collections/reg-guides/, under Document Collections, in Regulatory Guides, at https://nrcweb.nrc.gov/reading-rm/doc-collections/reg-guides/contactus.html.


Production and Utilization Facilities," requires that each application for a license to operate a facility                                              A iptt..
Electronic copies of this RG, previous versions of RGs, and other recently issued guides are also available through the NRCs public Web site in the NRC Library at https://nrcweb.nrc.gov/reading-rm/doc-collections/reg-guides/, under Document Collections, in Regulatory Guides. This RG is also available through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under ADAMS Accession Number (No.) ML21111A090. The regulatory analysis may be found in ADAMS under Accession No. ML21004A168. The associated draft guide DG-1357 may be found in ADAMS under Accession No. ML21007A330, and the staff responses to the public comments on DG-1357 may be found under ADAMS Accession No. ML21111A091.
                                                                                                          An    imlportant element o                                planning for of emergency`,:'p.lanning        fur include in a Final Safety Analysis Report (FSAR), along                                        uwe nuflear                      ..... is t..                      "m          -
        with other information,          ...    thc    applicant's  plans    for coping pin,      prpr    lrepareto tocpcope with wtvv a ier"
                                                                                                                                          c"rY*        byati6onrum of potential
                                                                                                                                                          ,b4*ctmofpoenia with emergencies. including the itemns specified in                                       consequences. Federal $tHIeý1`"aIdW5'Vagencics, as well Appendix E, "Emergency Plans for Production and                                            as the licensee, have r                      l,'-ýes
                                                                                                                                                ..           to play in both. t.e Utilization Facilities," to 10 CFR Part 50. Appendix E                                    planning and the. iinle*entationh of emergency preo refers to a document entitled "Guide to the Preparation                                    paredness procedif''s 'redcrflinteragenc y responsibili- of Emergency Plans for Production and Utilization                                          ties for nuclear'lniAzc-t 'pInning were set fortli by the Facilities,"' which    *~~~~fwa', developed.         .   to ...help applicants          Of.c  ic o, U/'fOt,*..eKy            re. , teparedness r edness iin a      a F.D.   RA. R.G-
                                                                                                                                                                FDR=U.AL.    REGt.-
        establish adequateS" plans for coping with emergencies.                                      ST F Knol;  o 0STI" ." 3aF,..I  2356)      us
                                                                                                                                          36 publishled I .January                January 24      .
                                                                                                                                                                          24, 1973J.


This regulatory guide provides more complete guidance                                      To                  e9iii
o  10 CFR 50.47(a)(i) provides, in part, that no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency o  10 CFR 50.47(b) provides 16 standards that must be met by licensees or applicants for the NRC to make a finding of reasonable assurance o  10 CFR 50.47(b)(4) requires that onsite and offsite emergency response plans contain a standard emergency classification and action level scheme o  10 CFR 50.54(t)(1) requires licensees to provide for the development, revision, implementation, maintenance, and periodic independent review of its emergency preparedness program o  Appendix E to 10 CFR Part 50 establishes minimum requirements for emergency plans for use in attaining an acceptable state of emergency preparedness o  Section IV.B.1 of Appendix E provides that emergency action levels (EALs) should be established as part of the emergency plan and should be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring o  Section IV.C.1 of Appendix E requires each emergency plan to define the emergency classification levels and the corresponding extent of response participation by the emergency response organization o  Section IV.F. of Appendix E establishes the requirements for the training-related content of emergency plans Related Guidance This RG provides a list of guidance documents to aid in the development and review of emergency preparedness and response plans. The following documents are acceptable guidance when developing emergency preparedness and response plans:
                                                                                                                          '-
   *  NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, issued November 1980 (Ref. 4), which provides specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47
                                                                                                                          "I*-t      these respn                are diecedto
  *  NUREG-0654/FEMA-REP-1, Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, issued December 2019 (Ref. 5), which provides specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47
  *      indeveloping emergency plans for nuclear power plants. .r ,,ard                                      ~et"Od nation of efforts to provide assistance to It describes a miethod acceptable ...                     to the NRC staff. for    re-.. r,"* a .W..',"Am* t -01oc,'
  *   NUREG-0396/EPA 520/1-78-016, Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants, issued December 1978 (Ref. 6)
                                                                                                                            coal gove governm entsn iin their    ip planning.
                                          RG 1.101, Rev. 6, Page 2


n..     Thi Th is complying with the Commission's regulations with -                                                           ased on the recognition that State and local gard to adequate content of emergency plans
*  NUREG-0696, Functional Criteria for Emergency Response Facilities, issued February 1981 (Ref. 7)
     .rtctne                                                            p      for f nuel~t..,,-    go nments            .,,..have the necessary authority to implement power plants, primarily in the FSAR stage                                              n*:,mergency measures in their jurisdiction
    *  NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies, issued November 2011 (Ref. 8)
    *  NUREG/CR-7002, Revision 1, Criteria for Development of Evacuation Time Estimate Studies, issued February 2021 (Ref. 9)
     *  NSIR/DPR-ISG-01, Interim Staff Guidance: Emergency Planning for Nuclear Power Plants, issued November 2011 (Ref. 10)
    *  NSIR/DPR-ISG-02, Interim Staff Guidance: Emergency Planning Exemption Request for Decommissioning Nuclear Power Reactors issued May 11, 2015 (Ref. 11)
    *  RG 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, issued July 2018 (Ref. 12)
Purpose of Regulatory Guides The NRC issues RGs to describe to the public methods that are acceptable to the staff for implementing specific parts of the agencys regulations, to explain techniques that the staff uses in evaluating specific issues or postulated events, and to describe information that the staff needs in its reviews of applications for permits and licenses. Regulatory guides are not NRC regulations and compliance with them is not required. Methods and solutions that differ from those set forth in RGs are acceptable if supported by a basis for the issuance or continuance of a permit or license by the Commission.


====s. Although ====
Paperwork Reduction Act This RG provides voluntary guidance for implementing the mandatory information collections in
10 CFR Part 50 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved by the Office of Management and Budget (OMB), approval numbers 3150-0011. Send comments regarding this information collection to the FOIA, Library, and Information Collections Branch (T6-A10M), U.S. Nuclear Regulatory Commission, Washington, DC
20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the OMB reviewer at: OMB Office of Information and Regulatory Affairs (3150-0011), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 17th Street, NW Washington, DC 20503; e-mail: oira_submission@omb.eop.gov.


==B. DISCUSSION==
Public Protection Notification The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the document requesting or requiring the collection displays a currently valid OMB
'.                              ',,            'ederal agencies can and will respond to emergencies
control number.
                                                                                          ".,     arising from nuclear power plant activities if necessary, The Commission's interest in cergen                                  jiang is      :;uch response should be regarded primarily as supportive focused primarily focused      primarilyions          intuaet ions that on situations                may c .'-r may teamergyn                      ay    of, licenseesand notand State as a substitute          for, responsible action by and local governments.


threaten to cause radiological hazards affecting the health and safety of workers'                          ie public or resulting in damage to property. Em                          nc I ns should be directed                        In the preparation or an emergency plan for a specific toward mitigating the con                          ni of emergencies and                  nuclear power plant, the applicant should be guided by should provide r                        ' le          rance that appropriate              the following criteria to clarify the scope, content, and measures can an, will                          talk      to protect health and            purpose of the document that describes the plan.
RG 1.101, Rev. 6, Page 3


safety and p;*en ,mag                          o property in the event of an emergency                   u thd.oj                  not practicable to develop a                        I. Although considered a part or the Final Safety completely              iiled plan encompassing every conceiv-                             Analysis Report, the plan should be prepared as a able type of              ,gency situation, advance planning can                          separate document.
==B. DISCUSSION==
 
Reason for Revision The staff is issuing Revision 6 of RG 1.101 to endorse and update guidance that is available to licensees and applicants on methods acceptable to the NRC staff for complying with the NRCs regulations for emergency response plans and preparedness at nuclear power reactors. This revision endorses Revision 0 of the Nuclear Energy Institute (NEI) white paper, Implementing a 24-Month Frequency for Emergency Preparedness Program Reviews, issued November 2019 (Ref. 13) and Appendix A, Recommended Drill and Exercise Objectives, to NEI 06-04, Conducting a Hostile Action-Based Emergency Response Drill, Revision 3, issued September 2016 (Ref. 14). This revision of the RG also consolidates previously developed and endorsed guidance documents into a single revision of the RG.
ICopies may be obtained by request to the U.S. Nuclear Rcgulatory Commission, Washington, D.C. 20555, Attention:                                      2. The plan should be an expression of the overall Director, Office of Nuclear Rcaclor Regulation.                                         "concept of operation" that describes the essential USNRC REGULATORY GUIDES                                                Comments should be sent to the Secretary of the Commission. U S Nuclear Rngulatoty Guides are issued to describe and minke available to the P                        Regular'e Commisson. Washington. DC. 205%. Attention. OockSteng and methods acceptable to the NRC stalf of imptlernrtling specific                                Stce Section.


Comamnssion's tequaltolt. to delineate techntiques used be the stall in evalu                "he guides ate issued in the following ten broad divisions atInq specil.c problenms a postulated accidents. at to provide guidance to appl, cant" Regulatory Guides are not substitute% for regulations. and co,,opliance                  I Powet Reactors                        6  Products with them is oit required Methnds and sotutions difterent from those %et out in                2 Research and Test Reactors            7  Transporitaton the guides wilt be a,c.eplthltt if they provide a basis tor the Indinga requisite to         .3. Fuels and Matetials Factlities        B. Occupational Health the~tsunefat, ton.tintidlit!OfA(Permit Oflicense by the Commnission..                      . 4. Environiental and Siting                9  Antitust Review Comn.rnt% and %uqqentiaon lotimproveaie.,lt It1these guides ate encouraged                      r, Materials and Plant Protection    10  General at alt times. ad guides wlt          ,evised. an aptpropriate. to accommodate cam.
Background In November 1980, the NRC published Revision 1 to NUREG-0654/FEMA-REP-1 to provide specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47. NUREG-
0654/FEMA-REP-1, Revision 1, is a joint NRC NUREG-series publication and Federal Emergency Management Agency (FEMA) guidance document. The NRC uses this document to evaluate the adequacy of the emergency plans and preparedness of nuclear power plant licensees while FEMA, as well as other Federal agencies, use this document to review and approve state, local, and tribal government radiological emergency plans. In October 1981, the NRC endorsed NUREG-0654/FEMA-REP-1 in Revision 2 of this guide.


rlr Imenit and to fellect new  Inte-     rn*itlo,, or elpaetir.nr. However. cmrnments an          Copies of published guides may be obtained by written request indicating the this guide, it ,ectved w-tlri .. t..  ut two ntnnths After its issuance. will be par          divisions dr.%tred to the U.S Nuclear Regulatoty Comnmlision, Washinglon. D C.
Planning standard 10 CFR 50.47(b)(4) requires that the emergency plan include a standard EAL
scheme. An EAL is a predetermined, site-specific, observable threshold for a plant condition that results in an emergency classification. The NRC initially established guidance for the development of EALs in Generic Letter (GL) 79-50, Emergency Plans Submittal Dates, issued 1979 (Ref. 15). Revision 2 of this guide endorsed subsequent guidance in Appendix 1 to NUREG-0654, which became the primary standard for the NRCs review of EAL schemes.


ltcularlt usetul it, ewdluahiJ the on..d rotan eatly rr*vision                                20555, Attention Ditectot. Otlice of Standards Development.
As the industry gained experience with the implementation and use of EAL schemes, it issued revised guidance documents on EAL scheme development to reflect lessons learned. The industry-developed guidance built upon and enhanced the foundation set forth in NUREG-065


elements  of advance planning that have been considered and the provisions that have been made to cope with that recommended in Annex A to this guide. "Organiza- tion and Content of Emmergency Plans for Nuclear Power emergency situations. The plan should incorporate infor-       Plants." Provision should be made for an annual review mation about the emergency response roles of support-          of the emlergency plan and for updating and improving ing organizations and agencies. That information should        procedures based on training, drills, and changes onsitc be sufficient tO enable a determination of the interface      or in the environs.
===4. Revision===
3 of this RG endorsed Nuclear Management and Resources Council (NUMARC)/NESP-007, Revision 2, Methodology for Development of Emergency Action Levels, issued January 1992 (Ref. 16), and RG
1.101, Revision 4, endorsed NEI 99-01, Revision 4, Methodology for Development of Emergency Action Levels, issued January 2003 (Ref. 17) as acceptable methods for licensees to consider in the development of their plant-specific EAL schemes.


and coordination required among the supporting groups and between them and the licensee.                                  3. Features and candidate subjects that should be considered in the preparation of specific procedures for
Revision 5 of RG 1.101 issued in June 2005 provided guidance for co-located licensees on conducting emergency response planning activities and interactions in the years between participation in offsite full- or partial-participation exercises. Since the publication of Revision 5, the NRC has developed or endorsed several new or revised emergency planning guidance documents described in Section C of this RG.
    3. Details that can reasonably be expected t, change      implementing the emergency plan are described in fromltime to time, e.g., names and telephone numbers.          Annex B to this guide. "Implementing Procedures for specific items of equipment and supplies, inventory lists,      E-mergency Plans." Implementing procedures should not and step-by-step procedures or checklists that may be          be incorporated into the plan and are not required to he altered as a result of experience or test exercises, should    submi:ted as part of the Final Salety Analysis Report to not be incorporated into the plan.                             the Commission. These procedures should, however, be available for review by the Oflfice of Inspection and
    4. The plait should not, by itself, be considered a        Enforcement during its prelicensing and routine inspec- primary working document to be used during an                  tions.


emergency. Detailed procedures that will ensure timely and effective implementation of various aspects of the emergency plan should be prepared. These procedures, however, should not be incorporated into iie document.
In December 2019, the NRC published Revision 2 of NUREG-0654/FEMA-REP-1, which integrates nearly 35 years of lessons learned in radiological emergency preparedness and consolidates and clarifies previous guidance related to the development of emergency plans. The planning criteria and RG 1.101, Rev. 6, Page 4


==D. IMPLEMENTATION==
guidance contained in Revision 2 of NUREG-0654/FEMA-REP-1 reflect changes to both NRC and FEMA regulations, guidance, policies, and doctrine, as well as advances in technology and best practices that have occurred since the document was originally issued in 1980. The NRC staff considers these criteria and guidance to be acceptable methods for complying with the onsite and offsite emergency response planning standards in 10 CFR 50.47.


==C. REGULATORY POSITION==
Revision 2 of NUREG-0654/FEMA-REP-1 also defines the review period for emergency preparedness program reviews conducted in accordance with 10 CFR 50.54(t)(1) such that 12 months in 10 CFR 50.54(t)(1) and annual in NUREG-0654/FEMA-REP-1 both mean 365 days. Thus, the program review should not exceed 365 days from the end date of the prior review to the completion of the next program review, which includes issuance of the review report. The requirement for all elements of the emergency preparedness program to be reviewed at least once every 24 months should not exceed 730
The purpose of this seclion is to pi'ovide infoimation to applicants and licensees regarding the NRC staff's I. Each applicant's emergency plan should !iclude          plans fot utilizing this regulatory guide.
days from the end of the prior review to the completion of the next program review, which includes issuance of the review report.


provisions for coping with emergencies, both within the boundary of the plant site and in the environs of the              With the exception. of Annex B, this guide reflects site. Responsibility for planning and implementing all          current Nuclear Regulatory Comttmissiot practice iLs emergency measures within the site boundaries rests            outlined in the USNRC Standard Review Plan. Except in with the licensee. Planning and implementation of              those cases in which the applicant proposes an accept- measures to cope with plant.related emergencies outside        able alternative metlhod for complying with specified the site boundary should be a coordinated effort                portions of the Comnmission's regulations, the method involving the licensee and local, county, State, and           described in Annex A is being and will continue to be Federal agencies having emergency responsibilities. The         used in the evaluation of Final Safety Analysis Reports emergency plan should describe this coordination, that          until this guide is revised as a result of suggestions fromn is. the arrangements and agreements between the                 the public or additional staff"review.
Consideration of International Standards The International Atomic Energy Agency (IAEA) works with member states and other partners to promote the safe, secure, and peaceful use of nuclear technologies. The IAEA develops Safety Standards and Safety Guides for protecting people and the environment from harmful effects of ionizing radiation.


licensee and these supporting agencies.
This system of safety fundamentals, safety requirements, safety guides, and other relevant reports reflects an international perspective on what constitutes a high level of safety. To inform its development of this RG, the NRC considered IAEA Safety Requirements and Safety Guides pursuant to the Commissions International Policy Statement (Ref. 18) and Management Directive and Handbook 6.6 (Ref. 19). In development of this RG, the staff considered IAEA Safety Guide GS-R-2, Preparedness and Response for a Nuclear or Radiological Emergency, issued November 2015 (Ref. 20).
        The NRC staff did not identify any IAEA Safety Requirements or Guides with information related to the topic of this RG.


Annex B is being published now for comment and
Documents Discussed in Staff Regulatory Guidance This RG endorses the use of one or more guidance documents developed by external organizations, and other third-party guidance documents. These codes, standards and third-party guidance documents may contain references to other codes, standards or third-party guidance documents (secondary references). If a secondary reference has itself been incorporated by reference into NRC
    2. The scope and content of a nuclear powei plant          review; it may be revised as a result of suggestions from emergency plan should be substantially equivalent to           the public or additional staff review.
regulations as a requirement, then licensees and applicants must comply with that standard as set forth in the regulation. If the secondary reference has been endorsed in a RG as an acceptable approach for meeting an NRC requirement, then the standard constitutes a method acceptable to the NRC staff for meeting that regulatory requirement as described in the specific RG. If the secondary reference has neither been incorporated by reference into NRC regulations nor endorsed in a RG, then the secondary reference is neither a legally-binding requirement nor a generic NRC approved acceptable approach for meeting an NRC requirement. However, licensees and applicants may consider and use the information in the secondary reference, if appropriately justified, consistent with current regulatory practice, and consistent with applicable NRC requirements.


1.101-2
RG 1.101, Rev. 6, Page 5


ANNEX A
C. STAFF REGULATORY GUIDANCE
                                ORGANIZATION AND CONTENT OF EMERGENCY PLANS
        This section includes industry-developed guidance documents that the NRC staff has previously determined to be acceptable to meet regulatory requirements for emergency response planning and preparedness for nuclear power plants and an industry-developed guidance document that the NRC is endorsing as a method that the staff also considers acceptable to meet regulatory requirements for emergency response planning and preparedness for nuclear power plants.
                                            FOR NUCLEAR POWER PLANTS
  I.  DEFINITIONS                                                (3) other emergency plans of the company (e.g., an overall corporate plan I, and (4) emergency plans of This section should provide definitions of any terms        other participating agencies, particularly the responsible (hat are unique to the power plant under consideration          State agency or other governmental authority having or are given conrotations that differ from normally              emergency planning responsibilitics in the immediate ucceptcd usage. Listed below are some terms used in this          offsite area.


guide along with the definitions that should be applied to these terms when they are used in emergency plans.
Previously Endorsed NEI Guidelines
1.      NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (Ref. 21), which is acceptable for use by licensees and applicants as a methodology to develop or upgrade EAL schemes in accordance with the requirements of 10
        CFR 50.47(b)(4), related sections of Appendix E to 10 CFR Part 50, and the associated planning standard evaluation elements of NUREG-0654/FEMA-REP-1, Revision 1. The NRC endorsed this guidance in a memorandum to NEI, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, March 28, 2013. (Ref. 22)
2.      NEI 99-01, Revision 5, Methodology for Development of Emergency Action Levels, February
        2008 (Ref. 23), which is acceptable for use by licensees and applicants as a methodology to develop or upgrade EAL schemes in accordance with related sections of Appendix E to 10 CFR
        Part 50. In addition to clarifying certain sections of previous revisions, Revision 5 of NEI 99-01 formalizes enhancements to emergency planning associated with hostile action events for emergency preparedness programs. The NRC endorsed this guidance in a memorandum to NEI,
        U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 5, February 22, 2008. (Ref. 24)
3.      NEI 07-01, Revision 0, Methodology for Development of Emergency Action Levels Advanced Passive Light Water Reactors, July 2009 (Ref. 25), which is an acceptable reference for applicants to review in the development of new reactor applications if they are using the AP1000
        or Economic Simplified Boiling Water Reactor design. Additionally, applicants may consider the template provided in NEI 07-01 as a reference for the development of an EAL scheme for any design using digital instrumentation and control, including licensed power reactors considering upgrading to digital instrumentation and control. The NRC endorsed this guidance in a memorandum to NEI, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI
        07-01, August 12, 2009. (Ref. 26)
4.      NEI 10-05, Revision 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, issued June 2011 (Ref. 27), which is acceptable for use by licensees and applicants as a methodology to perform a detailed staffing analysis for on-shift personnel assigned emergency plan implementation duties as required by Section IV.A.9 of Appendix E to 10 CFR
        Part 50. The NRC endorsed the on-shift staffing method of NEI 10-05 in Section IV.C of the interim staff guidance (ISG), NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, November 2011.


3.   SUMMARY OF EMERGENCY PLAN
5.     Appendix A, Recommended Drill and Exercise Objectives, to NEI 06-04, Conducting a Hostile Action-Based Emergency Response Drill, Revision 2, issued July 2011 (Ref. 28), which is acceptable for use by licensees and applicants for the development and conduct of hostile action-based emergency response drills. The NRC endorsed Appendix A to NEI-06-04, Rev. 2, by letter dated September 19, 2011. (Ref. 29)
        I. Assessment actions - those actions taken during or after an accident which are collectively necessary to                This section should describe the key elements of make decisions to implement specific emergency mea-               overall emergency planning logic, incorporating graded Sures.                                                           emergency classifications of increasing severity and their relationship to the participating status of onsite and
                                          RG 1.101, Rev. 6, Page 6
        2. Corrective actions - those emergency measures          offsite personnel and agencies.


taken to ameliorate or terminate an emergency situation at or near the source of the problem.
6.    NEI 13-01, Reportable Action Levels for Loss of Emergency Preparedness Capabilities, Revision 0, issued July 2014 (Ref. 30), which is acceptable for use by licensees and applicants as a methodology that provides specific guidance for reporting the loss of emergency preparedness capabilities under 10 CFR 50.72(b)(3)(xiii). The NRC endorsed NEI 13-01 in NUREG-1022, Rev. 3, Supplement 1, Event Report Guidelines 10 CFR 50.72(b)(3)(xiii), September 2014.


===4. EMERGENCY CONDITIONS===
(Ref. 31)
      3. Protective actions - those ."mergency measures taken after an uncontrolled release of radioactive mate-         4.1 Classification System rial has occurred for the purpose of preventing or minimizing radiological exposures to persons that would                An emergency plan should characterize several be likely to occur if the actions were not taken.                classes of emergency situations. The system of classifica- tion employed should consist of mutually exclusive
Endorsement of NEI Guidelines
      4. Popula:ion at risk - those persons for whom              groupings (to avoid ambiguity) but should cover the protective actions are or would be taken.                         entire spectrum of possible situations. Succinct verbal rather than numerical or alphabetical classification desig-
1.   The NRC staff endorses Revision 0 of the NEI white paper, Implementing A 24-Month Frequency for Emergency Preparedness Program Reviews, which is acceptable for use by licensees and applicants as a methodology to adopt the voluntary option for conducting periodic emergency preparedness program reviews at a 24 month frequency as allowed by 10 CFR
      5. Affected persons - individuals who have been            nations are recommended to give better immediate
      50.54(t)(1)(ii).
.radiologically exposed or physically injured as a result of       information to personnel as to the scope and character an accident to a degree requiring special attention, e.g.,       of the situation.
2.   The NRC staff endorses Appendix A, Recommended Drill and Exercise Objectives, to NEI 06-
       04, Conducting a Hostile Action-Based Emergency Response Drill, Rev. 3, which is acceptable for use by licensees and applicants for the development and conduct of hostile action-based emergency response drills.


decontamination, first aid, or medical services.
RG 1.101, Rev. 6, Page 7


The plan should describe the limiting scope consid-
==D. IMPLEMENTATION==
      6. Recovery actions - those actions taken after the        ered for each identified class of emergency, that is, the eniergeney to restore the playi .ts nearly as possible to its    area and/or persons affected by the consequences. The preemergency condition.                                          plan should also describe, for each class, the preliminary actions to be taken to cope with the situation, the
The NRC staff may use this RG as a reference in its regulatory processes, such as licensing, inspection, or enforcement. However, the NRC staff does not intend to use the guidance in this RG to support NRC staff actions in a manner that would constitute backfitting as that term is defined in 10 CFR
      7. Protective action guides - projected radiological        authority or title of the individual responsible for dose or dose commitment values to individuals in the              initiating these actions, and the organizations and general population that warrant protective action follow-        agencies that would be alerted and mobilized.
50.109, Backfitting, and as described in NRC Management Directive 8.4, Management of Backfitting, Forward Fitting, Issue Finality, and  
 
ing a release of radioactive material.
 
Specific implementing procedures slhuld be pre-
      8. Emergency action levels - radiological dose              pared for each identified class of emergency (see Annex rates; specific contamination levels of airborne, water-          B).
borne, or surface-deposited concentrations of radio- activity; or specific .instrument readings that may be                  An acceptable classification scheme is described in used as thresholds for initiating specific emergency              qualitative terms in Sections 4.1.1 through 4.1.5. This measures.                                                        part of the emergency plan should describe the criteria for recognizing and declaring each class, including
2.    SCOPE AND APPLICABILITY                                    specific emergency action levels for the last three classes.
 
This section of the plan should define the unit,                  4.1.1 Personnel Emergency plant, station, or area to which the plan is applicable and present a summary of the plan's interrelationships with                        This class involves accidents or occurrences (I) its implementing procedures, (2) plant operating,            onsite in which emergency treatment of one or more radiological control, and industrial security procedures,        individuals is required. It includes those situations that
                                                            1.101-3
 
ANNEX A
                              ORGANIZATION AND CONTENT OF EMERGENCY PLANS
                                            FOR NUCLEAR POWER PLANTS
I.  DEFINITIONS                                                (3) other emergency plans of the company (e.g., an overall corporate plan), and (4) emergency plans of This section should provide definitions of any ternis      other participating agencies, particularly, the responsible that arc unique to the power plant under consideration          State agency or other governmental authority having or are given conr.otations that differ from normally            emergency planning responsibilities in the immediate accepted usage. Listed below are some terms used in this        offsite area.
 
guide along with the definitions that should be applied to these lerms when they are used in emergency plans.
 
3.    SUMMARY OF EMERGENCY PLAN
      I. Assessment actions - those actions taken during or after an accident which are collectively necessary to                This section should describe the key elements of Make decisions to implement specific emergency mea-              overall emergency planning logic, incorporating graded sures.                                                            emergency classifications of increasing severity and their relationship to the participating status of onsite and
      2. Corrective actions - those emergency measures          offsite personnel and agencies.
 
taken to ameliorate or terminate an emergency situation at or near the source of the problem.
 
===4. EMERGENCY CONDITIONS===
      3. Protective actions - those ,'mergency measures taken after an uncontrolled release of radioactive mate-        4.1 Classification System rial has occurred for the purpose of preventing or minimizing radiological exposures to persons that would                An emergency plan should characterize several be likely to occur if the actions were not taken.                classes of emergency situations. The system of classifica- tion employed should consist of mutually exclusive
      4. Popula:ion at risk - those persons for whom              groupings (to avoid ambiguity) but should cover the protective actions are or would be taken.                        entire spectrum of possible situations. Succinct verbal rather than numerical or alphabetical classification desig-
      5. Affected persons - individuals who have been            nations are recommended to give better immediate radiologically exposed or physically injured as a result of      information to personnel as to the scope and character an accident to a degree requiring special attention. e.g.,        of the situation.
 
decontainination, first aid, or medical services.
 
The plan should describe the limiting scope consid-
      6. Recovery actions - tthose actions taken after the        ered for each identified class of emergency, that is, the emergency to restore the pla!I i ,s nearly as possible to its    area and/or persons affected by the consequences. The preemergency condition.                                          plan should also describe, for each class, the preliminary actions to be taken to cope with the situation, the
      7. Protective action guides - projected radiological        authority or title of the individual responsible for dose or dose commitment values to individuals in the              initiating these actions, and the organizations and general population that warrant protective action follow-        agencies that would be alerted and mobilized.
 
ing a release of radioactive material.
 
Specific implementing procedures should be pre-
      8. Emergency action levels - radiological dose              pared for each identified class of emergency (see Annex rates; specific contamination levels of. airborne, water-        B).
borne, or surface.deposited concentrations of radio- activity; or specific instrument readings that may be                  An acceptable classification scheme is described in used as thresholds for initiating specific emergency              qualitative terms in Sections 4.1.1 through 4.1.5. This measures.                                                        part of the emergency plan should describe the criteria for recognizing and declaring each class, including
2.    SCOPE AND APPLICABILITY                                    specific emergency action levels for the last three classes.
 
This section of the plan should define the unit,                  4.1.1 Personnel Emergency plant, station, or area to which the plan is applicable and present a summary of the plan's interrelationships with                        This class involves accidents or occurrences
(1) its implementing procedures, (2) plant operating,            onsite in which emergency treatment of one or more radiological control, and industrial security procedures,        individuals is required. It includes those situations that
                                                            1.101-3
 
have no potential for escalation to morc severe emer-            Qualitative criteria should he added for other candidate gency conditions. There may be no effect on thie plant,          situations to guide the decisions of onsite supervisory and immediate operator action to alter plant status is            personnel.
 
not necessarily required. A Personnel Emergency does not activate the entire emergency organization but may                  4.1.3 Plant (Unit) Emergency activate such teams as thc first aid team. It may also require special local services such as ambulance and                          This class includes physical occurrences medical.                                                          within the plant requiring full plant staff emergency organization response. The initial information and assess- hmplemcnting procedures for the handling of          ment indicates that it is very unlikely that an offsitc this class of' emergency may also be incorporated in the          hazard will be created. Hlowever, substantial modifica- plant's radiation protection procedures and general              tion of plant operating status is a highly probable industrial safety procedures.                                    corrective action if this has not already taken place by the actions of automatic protective systems. Although it Included in this class are injuries that may be      is judged that the emergency situation can be corrected complicated by contamination problems or excessive                and controlled by the plant staff. nolification of radiation exposures t) onsite personnel.                        corporate headquarters staff' to put them on an alert status is prudent. Notification of appropriate offsite The recognition of this class of emergency is        agencies as to the nature and extent of the incident is primarily a judgment matter for plant supervisory or              also advisable. Evacuation of the plant is not anticipated management personnel. Its importance as part of the              in this class of emergency, although protective evacua- classification scheme rests to some extent on its "nega-          tions or isolations of certain plant areas may be tive'" information content, viz, that the incident giving        necessary.
 
rise to the emergency is restricted in its scope of involvement. This section of the plan should designate                        Examples of situations that might fall into the classification criteria and should enumerate discrete          this class are those accidents analyzed in the FSAR as accident situations that could give rise to this class.            events that are predicted to have no radiological conse- quences offsite. Fires, explosions or explosive gas re-
      4.1.2 Emergency Alert                                        leases, or in-plant flooding conditions may fall into this class.
 
This class involves specific situations that.can be recognized as creating a hazard potential that was                          Activation levels for declaring Plant Emergen- previously nonexistent or latent. The situation has not            cies should be based on the recognition of an immediate yet caused damage to the plant or harm to personnel and            need to implement in-plant emergency measures to does not, necessarily require an immediate change in              protect or provide aid to affected persons in the plant or plant operating status. Inherently, however, this is a            to mitigate the consequences of damage to plant situation in which time is available to take precautionary        equipment, coupled with a positive observation that (I)
and constructive steps to prevent an accident and to              effluent and other radiological monitors do not indicate mitigate the consequences should it occur. An Emer-                the possibility of a Site Emergency and (2) there is no gency Alert situation may be brought on by either                  apparent breach of any fuel cladding, primary system man-made or natural phenomena.                                    boundary, or containment. This section should describe the alarm conditions or combinations of alarm condi- Emergency Alert conditions imply a rapid              tions and the emergency action levels for initiating a transition to a state of readiness by the plant personnel,        Plant Emergency.
 
the possible cessation of certain routine functions or activities within the plant that are not immediately                    4.1.4 Site (Station) Emergency essential, and possible precautionary actions that a specific situation may require. Examples of situations                        This class involves an uncontrolled relcase of that might be placed in this class are threats to or              radioactive materials into the air, water, or ground to an breaches of plant security measures such as bomb threats          extent that initial information and assessment indicate or civil disturbance, severe natural phenomena in the              protective actions offsite may be desirable. Mobilization plant environment such as floods, earthquakes, tsunami,          and readiness of offsite emeigency organizations is hurricanes, or tornadoes; emergency situations such as            prudent. Protective actions are likely to include evacua- fires at adjacent locations; or release of a toxic or              tion of plant areas other than control rooms and noxious gas in or near the plant. This section of the            emergency stations and should include the evacuation of emergency plan should identify specific candidate situa-          construction personnel when additional units are under tions for Emergency Alerts and the quantitative criteria          construction on the same site. Assessment actions will that would guide the decision to implement each.                  include monitoring of the environment.
 
101-4 IJ
 
MEM
            Situations likely to fall into this class include      taken and evaluated rapidly enough to permit adequate those accidents analyzed in the FSAR that are predicted            time for the protective actions to be accomplished. In to have small to moderate releases at the exclusion                either event, the bases and criteria used to define the radius. It should be anticipated that Site Emergencies              action levels should be described in the plan.
 
would not normally be preceded by a Plant Emergency, although the possibility of this evolution should not be            4.2 Spectrum of Postulated Accidents excluded.
 
Emergency action levels for declaring a Site                Accident analysis scclions of Safety Analysis Re- Emergency should be defined in terms of instrument                ports are primarily concerned with the dcsign responses readings or alarms in the control room, including                  of a plant to postulated malfunctions or equipment indications from effluent monitors. To avoid false alarms          failure and include estimates of the radiological conse- or to minimize their frequency of occurrence, the levels            quences of discrete accidents. By contrast, emergency may be defined so as to require corroborating evidence              planning is concerned with individual and organizational from two independent sources that provide input to the              responses to the continuum of potential accident situa- control room. Site Emergencies should also be declared              tions, including those discrete accidents that have been on the basis of evidence of apparent breaches in fuel              hypothesi7ied. This section of the emergency plan should cladding, primary system bound4Wl,':, or containment.              show that each postulated accident is encompassed The bases and criteria used to divf= the instrument                within the emergency characterization classes and should alarm levels should be described. Suitable criteria would          provide a summary analysis of their implications for be protective action guide values at a security fence,              emergency planning. Implications to be considered exclusion area, or site boundary, and the bases would               should :-'Jiude:
show how the effluent monitor readings relate to such                    I. Instrumentation capability for prompt detection values. Federal agency guidance' 2 is available to assist          and continued assessment, including functional applica- in the selection of acceptable protective action guides.          bility, range, response time, locations of sensing and
      4.1.5 General Emergency                                      readout elements (including alarms), and backup or redundant capability;
            This is an occurrence characterized by conse- quences lequiring that protective actions be taken in                  2. Manpower requirements for assessment, includ- offsite areas as a matter of prudence or necessity.              ing recordkeeping; for corrective actions- for protective Evacuation of the site may also be necessary under                actions, including communications requirements; and for extreme circumstances.                                            aid to affected persons; and Action levels for declaring the General Emer-              3. The timing of and the time required for the gency case should be defined. The action levels should          implementation of each emergency measure that may be recognize bo.li short-term and long-term hazards. The            brought into play.
 
selection of action levels for the former should be guided by direct radiation hazards and inhalation hazards that            S. ORGANIZATIONAL CONTROL OF EMERGEN-
may be presented by the passage of a cloud of                            CIES
radioactive material released from the plant. The selec-                Starting with the normal operating organization as a tion of action levels for the long-term hazards should be          base, this section of the plan should describe the guided by contamination hazards that could result from            emergency organization that would be activated on the fallout or deposition of radioactive materials released          site and its augmentation and extension offsitc. Authori- from the plant.                                                    ties and responsibilities of key individuals and groups Protective actions should be planned and            should be delineated. The communication links estab- implemented at the prescribed action levels. Action              lished for notifying, alerting, and mobilizing emergency levels for severe short-term situations requiring rapid          personnel should be identified.
 
implementation of protective actions should be defined in terms of readily available information such as readings        5.1 Normal Plant Organization of effluent monitors or other onsite monitor indications.                Both day and night shift staffs (crews) should be Implementation of protective actions may also be based            described, indicating clearly who is in the immediate on confirmatory measurements taken in the field to the            onsite position of responsibility for the plant or station extent it can be shown that field measurements can be              (normally a shift supervisor) and his authority and
"Background Material for the Development of Radiation Pro-        responsibility for declaring an emergency.
 
tection Standards," Federal Radiation Council, Report No. 5, July 1964, and Report No. 7, May 1965.                            5.2 Onsite Emergency Organization
2
"Emergency Response Protective Action Guides-Airborne                    This section should describe the mobilization billets Releases from Fixed Nuclear Facilities," Office of Radiation Programs, U.S. Environmental Protection Agency, January          of plant staff personnel for controlling each class of
  1975.                                                            emergency for both day and night shift situations.
 
1.101-5
 
5.2.1 Direction and Coordination                          an; emergency. The following special functions are considered appropriate for headquarters support and The' position title of utat person who is        should be incorporated in the overall plan, although designated to take charge of onsite emergency control          company policy and organizational features may dictate measures should be clearly identified. A specific line of    variations in modes of assigning responsibilities for these succession for this authority should also be given. A          functions among headquarters personnel, plant staff policy statement describing the scope of authority and        personnel, and outside support organizations:
responsibility vested in that role by the company (applicant) should be included. Functional responsibili-                  I. Environs monitoring, ties assigned to this individual should be described and should include a summary of those preliminary assess-                      2. Logistics support for emergency person- ment procedures that would be followed to prescribe or        nel, e.g., transportation, temporary quarters, food and guide his decision to classify and declare an emergency.      water, sanitary facilities in the field, and special equip.
 
ment and supplies procurement,
      5.2.2 Plant Staff Emergency Assignments                              3. Technical    support    for  planning  and The plan should specify the iunctional areas      reentry/recovery operations, of emergency activity to which members of the plant staff are assigned, including an indication of how the                    4. Notification of governmental authorities, assignments are made for both day and night shifts and        and for plant staff members both onsite and away from the site. Functional areas should include:                                    5. Public relations and information release, coordinated with governmental authorities, including
              1..Plant systems operations,                    steps taken to inform visitors to the plant, site, or information center and occupants in the environs of the
              2. Radiological survey and monitoring,          site how the emergency plans provide for notification to them and how they can expect to be advised what to do.
 
3. Firefighting, The emergency organization status of sup.
 
4. Rescue operations,                            porting headquarters personnel should be specified, relative particularly to the person directing the plant
              5. First aid,                                    emergency organization.
 
6. Decontamination,                                          In some instances, companies may provide for certain emergency supporting services to their plants by
              7. Security of plant and access control,        contracts with private organizations. Where this is the case, the nature and scope of the support services should
              8. Repair and damage control,                    be characterized here. (The Commission may find it necessary to request evidence of the qualifications of
              9. Personnel accountability,                    such contractors.) Specific services by contractors should be identified at the appropriate places in the
            10. Recordkeeping,                                emergency plan.
 
11. Communications.                                    5.3.2 Local Services Support This section should identify the extension of
5.3 Augmentation of Onsite Emergency Organization              the organizational capability for handling emergencies to be provided by ambulance, medical, hospital, fire, and This section should describe two categories of          police organizations. Evidence of the arrangements and offsite support assistance to the plant staff emergency        agreements reached with such organizations should be organization. These can be either directed, authorized,        included in an appendix. This section should contain or requested by the company management to perform            references to that appendix and to thio parts of the plan special emergency assistance functions.                        in which the functions of these *,rganizations are described.
 
5.3.1 Licensee Headquarters Support
                                                              5.4 Coordination with Participating Agencies Headquarters management, administrative, and technical personnel should be prepared to augment              This section should identify the principal State the plant staff, both in emergency planning and in the        agency (designated state authority) and other govern- performance of certain functions required to cope with        mental agencies (local, county, State, and Federal)
                                                        1.101-6
 
having planning or action responsibilities for emergen-          6.1 Activation of Emergency Organization cies, particularly for radiological emergencies, in the area in which the plant is located. If the boundary linec                    The emergency conditions classified in Section 4.1 between two political chtilies, e.g., counties or states,        involve the alerting or activation of progressively larger passes within the low-population zone or within appioxi-          segments of the total emergency organization. This mately fciir miles of the site, agencies from both                section should describe how the necessary communica- governmental entities should bc included. Subsections            lion steps are taken to alert or activate emergency for each such agency should include:                              personnel under each class of emergency. including, in.
 
particular, action levels for oolification of offsite agen- I. The identity of the agency.                            cies.
 
2. A summary of tlhe written agreement wiltl the            6.2 Assessment Actions agency that clearly defines the authority and icsponsi- bility of the agency for emergency preparedness plan-                    FEffective co*rditiatiion and direction of all elements ning and for emergency response, particularly in relation        of the emergency organization require continuing assess- to those of" the licensee and to those of other agencies.        ment throughout the duration of art emergency situa- Copies of such agreements should be included in an                lion. Assessinent functions should be incorporated in appendix, along with a copy or summary of relevant                explicit p,,)cedures for each emergency classification.
 
parts of that agency's "minergency plan.                          They should be identified in this section and may include the following:
      3. Activation uf the agency function. including titles and alternates for both ends of the communication                1. Surveillance of control room instruments and links, and primary and alternative means of communica-            emergency control center, radiological and nmctcorolomri- lion.                                                            cal monitors.
 
4. The designation and location of the Emergency                  2. Surveillance of containment integrity.
 
Operations Center of each agency.
 
3. in.plant radiological surveys.
 
5. Support of the agency function that may be provided by the company emergency organization,                        4. Site and site boundary surveys.
 
which may include (a) information on plant status, monitoring results, dose predictions, (b) recommenda-                  5. Environs surveys and monitoring.
 
tions or requests for specific actions, and (c) logistics support.                                                                    a. Plume and other effluent surveillance for short-term assessment. Planning should consider type of'
      Typical agencies to be included here are law                data sought- instrument and equipment requirements:
enforcement agencies not included above (e.g., State              Iransportation facilities for monitoring team (e.g.. air- Police/Highway Patrol), departments of health or envi-          craft, boats, other vehicles): methods and accuracy of ronmental protection, civil defense or emergency/                plume location: and potential use of fixed offsite disaster control agencies, and the Regional Coordinating        monitoring facilities.
 
Offices of USERDA's Radiological Assistance Program.
 
b. Contamination surveillanc
 
====e. Planning should====
6.   EMERGENCY MEASURES                                        consider the tinting, frequency, and types of samples to he collected, such as soil, vegetation, food, milk, and Specific emergency measures should be identified in        water supplies, and potential locations for reconcenira- this section and related to action levels or criteria that      lion, e.g., in air intake filters.
 
specify when the measures are to be implemented. They should be organized with respect to each emergency                      6. Data reporting, reduction, and analysis.
 
classification. Preplanned action levels and criteria should be designed to assist and guide, or in some cases                7. Interviewing of evacuees or other witnesses of specify, the decision-making functions.                          the accident.
 
8. Notification of assessment results for modifica- The planning represented by this section should lead to more detailed emergency procedures and assignments            tion of emergency measures in progress, if necessary.
 
for executing tasks by appropriate members of the total emergency organization. Emergency measures begin with            6.3 Corrective Actions the activation of an emergency class and its associated emergency organization. The additional measures may                    Many emergency situations involve actions that can be organized into assessment actions, corrective actions,        be taken to correct or mitigate the situation at or near protective actions, and aid to affected persons.                the source of the problem. This section should identify
                                                          1.101-7
 
those actions, e.g., fire control,. repair, and damage                            d. The means and the time required to control, that would be implemented when necessary..              notify the persons involved and their expected response.
 
Emergency exposure criteria for personnel undertaking            These should include:
corrective actions should be included.
 
(1) Adjacent      businesses,  property
6.4 Protective Actions                                            owners, and tenants, This section should describe the nat:-j'e of protective                        (2) Nearby schools        or recreational actions that the plan contemplates, the emergency                facilities, action. levels, the area involved, and the means of notification to the population at risk. Protective actions                          (3) General public in the environs.
 
to be taken offsite by other agencies should be dc- scribed.                                                                6.4.2 Use of Protective Equipment and Supplies Additional protective actions that should be
      6.4.1 Protective Cover, Evacuation, Personnel Ac-            considered in emergency planning include measures for countability                                          minimizing the effects of radiological exposures or contamination problems by the distribution of special The emergency plan should provide for                  equipment or supplies. Measures that should be consid- timely relocation of persons to prevent or minimize                ered include:
exposure to radioactivity. The following items should be included:                                                                      I. Individual respiratory protection.
 
1. Plant Site                                                    2. Use of protective clothing.
 
a. Action criteria.                                            3. Use of radioprotective drugs, e.g., indi- vidual thyroid protection.
 
b. The means and the time required to notify persons involved. These should include:                                For each measure that might be used, a description should be given of:
                  (1) Employees not having emergency assignments,                                                                  1. Criteria for issuance,
                  (2) Working and nonworking visitors,                        2. Locations of items, and
                  (3) Contractor and construction per-                        3. Means of distribution to onsite and offsite sonnel.                                                          persons.
 
c. Control of public access areas on or                6.4.3 Contamination Control Measures passing through the site or within the exclusion area.
 
Provisions should be made for preventing or d. Evacuation routes, transportation of          minimizing exposure to radioactive materials. Control of personnel, and reassembly areas, including alternatives          in-plant contamination should be described in specific for inclement weather and high traffic density.                  radiological protection procedures and need not be repeated here. Measures for the protection of offsite e. Missing persons check.                        persons and onsite persons outside of fenced security areas should include:
                f. Radiological monitoring of evacuees.
 
9. Offsite Areas                                                  1. Isolation or quarantine and area access control.
 
a. Action criteria, including inclement                        2. Control of the distribution of affected weather alternatives.                                              commercial agricultural products.
 
b. Responsibilities of company emergency                      3. Control of public water supplies.
 
organization.                                                                  4. Means for providing advisory information regarding the use of potentially affected home food and c. Agency responsibilities.                      water supplies.
 
1.101-8
 
5. Criteria fur permitting return to normal        identified below. Where appropriate, references may be use.                                                            made to applicable. sections of the Safety Analysis Report for additional oetail.
 
Action levels and responsibility for execution of each mcasure contemplated should be described.
 
7.1 Emergency Control Centers
6.S Aid to Affected Personnel This should include the principal and, if provided This section of the emergency plan should describe        for, alternative onsite locations from which effective measures thai will be used to provide necessary assist-        emergency control direction is given, One alternative ancc to persons injured or exposed to radioactivity. The        offsite location under the jurisdiction of the applicant should also be de:cribed. Their locations should be following mat lers should bc included:
                                                                related to the reactors, prevailing wind direction, and
      6.5.1 Emergency Personnel Exposure Criteria              evacuation routes.
 
This should specify exposure limits for entry      7.2 Communications Systems or reentry to areas to remove injured persons and limits for emergency personnel who may provide first aid,                  This should give brief descriptions of both oisite decontamination, ambulance, or medical treatment serv.          and offsitc communications systems, including redun- ices to injured persons. An individual or authority            dant power sources that would be required to perform should be designated it) autlhorize or approve the              vital functions in transmitting and receiving information acceptancc of emergency radiation exposure for life-            throughout the course of an emergency.
 
saving purpo,:es.
 
6.5.2 Decontamination and First Aid                      7.3 Assessment Facilities Capabilities for dccontaminating personnel                Many of the emergency measures described in for their own protection and to prevent or minimize            Section 6 wiil depend on the availability of monitori;ig fuirther spread of contamination should be included.            instruments and laboratory facilities. This section should along with a brief description of first aid training and        list monitoring systems that are to be used to initiate capabilities of appropriate members of the emergency            emergency measures, as well as those to be used for organization.                                                  continuing assessment. The listing should be organized as follows:
      6.5.3 Medical Transportation Arrangements for transporting injured person-            7.3.1 Onsite Systems and Equipment nel, who may also be radiologically contaminated, to
                                                                            1. Natural phenomena monitors, e.g.. mete- medical treatment facilities should be specified.
 
orological, hydrologic, seismic.
 
6.5.4 Medical Treatment
                                                                            2. Radiological monitors, e.g.. process. area.
 
emergency, effluent, and portable monitors and sam- Arrangements made for local and backup pling equipment.
 
hospital atid medical services and the capability for the evaluation of radiation exposure and uptake should be                        3. Nonradiological monitors, e.g., reactor described.
 
coolant system pressure and temperature. containment pressure and temperature, liquid levels, flow rates, status For both hospital and medical services, the or lineup of equipment components.
 
plan should incorporate assurance not only that the required services are available, but also that persons                      4. Fire detection devices.
 
providing them are prepared and qualified to handle radiological emergencies. Written agreements with re-                7.3.2 Facilities and Equipment for Offsite Monitor- spect to arrangements made by the applicant, which should be included in the appendix. would facilitate this                  ing determination.
 
I. Natural phenomena monitors.
 
7.    EMERGENCY FACILITIES AND EQUIPMENT
                                                                            2. Radiological monitors.
 
This section of the emergency plan should identify, describe briefly, and give the locations of the items                      3. Laboratory facilities, fixed and mobile.
 
I0                                      1.101-9
 
7.4 Protective Facilities .                                          8.1.2 Drills
 
* Specific facilities that are intended to serve a                        Periodic (at least annual) announced drills protective function should bedcscribed with emphasis          should be incorporated in the emergency plan. These on those features of each facility that ensure its            should be preplanncd simulations of accidents to test the
  "j  adequacy with respect to capacity for accommodating            adequacy of tinting and content of specific implement- the number of. persons expected and with respect to            ing procedures and to test cmergency equipment. Ar- shielding, ventilation, and inventory of supplies. Such        -angem...1ts should be made for critiques of the drills.
 
facilities might include fallout shelters or similar areas    Coordinating drills should be held with participating and reassembly points. If design details have been            agencies at least annually; as a mininimum, the communi- provided elsewhere in the Safety Analysis Report, only a      cations links and notificafion procedures with those brief summary need be given here, along with a reference      agencies should be tested. An initial coordinated drill to the detailed information.                                  with participating agencies should be planned and carried out prior to fuel loading of the first unit at'any site.
 
7.5 First Aid and Medical Facilities
                                                                    8.2 Review and Updating of the Plan and Procedures A summary description of onsite facilities should be provided. (Offsite medical facilities should be described            Provision should be made for aai annual review of in the appendix, along with the agreements providing for        tile emergency plan and for updating and improving their use.)                                                    procedures to incorporate results of training and drills and to account for changes onsite or in the environs.
 
Means for maintaining all coordinate elements of the
*    8.    MAINTAINING EMERGENCY PREPAREDNESS                        total emergency organization informed of revisions to the plan or relevant procedures should be described.
 
This section of the plan should describe the means to be employed to ensure that the plan will continuc to        8.3 Emergency Equipment and Supplies be effective throughout the lifetime of the nuclear facility.                                                            The operational readiness of all items of emergency equipment and supplies should be ensured. The plans and schedules for performing maintenance, surveillance
    8.1 Organizational Preparedness                                testing, and inventory on emergency equipment and supplies should be described.
 
8.1.1 Training
 
===9. RECOVERY===
                  This should include a description of periodic training programs to be given to all categories of                    This section should describe general plans, including emergency personnel. Specialized training for the follow-      applicable criteria, for restoring the plant as nearly as ing categories should be included:                              may be possible to its preemergcncy status.
 
I. Directors or coordinators of the plant          1


===0. APPENDIX===
===
    emergency. organization.


The appendix should include the following items:
===Information Requests===
                  2. Personnel responsible for accident assess- ment, including control room shift personnel.                         1. Copies of agency agreement letters and copies or summaries of interfacing emergency plans.
===
(Ref. 32), nor does the NRC staff intend to use the guidance to affect the issue finality of an approval under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants. The staff also does not intend to use the guidance to support NRC staff actions in a manner that constitutes forward fitting as that term is defined and described in Management Directive 8.4. If a licensee believes that the NRC is using this RG in a manner inconsistent with the discussion in this Implementation section, then the licensee may file a backfitting, or forward fitting, appeal with the NRC in accordance with the process in Management Directive 8.4.


3. Radiological monitoring teams.
RG 1.101, Rev. 6, Page 8


2. Plots of calculated time.distanc
REFERENCES 1
1.       U.S. Code of Federal Regulations (CFR), Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy.


====e. dose for the====
2.       CFR, Emergency Planning and Preparedness for Production and Utilization Facilities, Appendix E, Part 50, Chapter I, Title 10, Energy.
                  4. Fire control and repair and damage con.        most serious design basis accident. as called for in the trol teams.                                                    latest revision of Regulatory Guide 1.70, "Standard Format and Content of Safety Analysis Reports for
                  5. First aid and rescue team members.              Nuclear Power Plants."
                  6. Local services personnel.                            3. Listings, by title, of written procedures that implement the plan.


7. Medical support personnel.
3.       CFR, Licenses, Certifications, and Approvals for Nuclear Power Plants, Part 52, Chapter I,
        Title 10, Energy.


4. Listings, by general category, of emergency kits,
4.       U.S. Nuclear Regulatory Commission (NRC) and Federal Emergency Management Agency (FEMA), Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Revision 1, November 1980.
                  8. Licensee's headquarters support personnel.     protective equipment, and supplies that are stored and
                                                              1.101-10


maintained for emergency purposes. A detailed catalog        available at the plant site for inspection at any time by a of individual items should not be included in the plan.
5.       NRC and FEMA, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Revision 2, December 2019.


The written                                              representative of the Commission's Office of Inspection procedures themselves and a detailed      and Enforcement.
6.      NRC and the U.S. Environmental Protection Agency (EPA), Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants, NUREG-0396/EPA 520/1-78-016, December 1978.


catalog of protective equipment and supplies should be
7.       NRC, Functional Criteria for Emergency Response Facilities, NUREG-0696, February 1981.
                                                        1.101-11


ANNEX B
8.       NRC, Criteria for Development of Evacuation Time Estimate Studies, NUREG/CR-7002, November 2011.
                              IMPLEMENTING PROCEDURES FOR EMERGENCY PLANS
  . This annex provides guidance regarding the prepa ra-         fled actions or operations are performed. These should tion and content of procedures that implement the                be in the form of action levels or protective action emergency plan.                                                  guides.


1. CONTENT AND FORMAT OF PROCEDURES                                  1.4.3 Actions and Limitations This section describes desirable features that shot ild                Procedures should present the required be incorporated, where appropriate, into individt jal            actions in a succinct and concise manner and in implementing procedures.                                        step-by-step order and logical sequence. The instructions should be sufficiently detailed for a qualified individual
9.       NRC, Criteria for Development of Evacuation Time Estimate Studies, NUREG/CR-7002, Revision 1, February 2021.
1.1 Organization and Responsibilities                            to perform the required actions without supervision but need not provide a completely detailed description of Wherever appropriate, each procedure shot ild              the actions, methods, or processes.


specify the individual or organizational element havi ng the authority and responsibility for performing speci fic                    If the user is given the latitude to exercise critical tasks covered by the procedure.                        judgment in implementing specific actions or parts of the procedure, guidelines should be provided in the
10.      NRC, Interim Staff Guidance: Emergency Planning for Nuclear Power Plants, NSIR/DPR-ISG-01, November 2011.
1.2 Action Levels                                                procedure to aid the user in making decisions.


Emergency action levels and protective actiion                  1.4.4 Cautions and Precautions guides should be specified in procedures, along with the emcrgency actions or protective actions required and the                      Important steps or precautions should be individuals or organizational units responsible for thieir        noted or highlighted within the procedure.
11.      NRC, Interim Staff Guidance: Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants, NSIR/DPR-ISG-02, May 11, 2015
12.      NRC, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Regulatory Guide 1.219, July 2018.


implementation.
1  Publicly available NRC published documents are available electronically through the NRC Library on the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/ and through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html. The documents can also be viewed online or printed for a fee in the NRCs Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD. For problems with ADAMS, contact the PDR staff at 301-415-4737 or (800) 397-4209; fax (301) 415-3548; or e-mail pdr.resource@nrc.gov.


1.4.5 References
RG 1.101, Rev. 6, Page 9
1.3 Actions by Support Agencies When procedural steps require other func- The specific actions to be performed by suppt )rt          tions or jobs to be performed, the controlling procedure groups should .be identified in the procedures deali ng          should contain the reference to other applicable proce- with their activities. If the emergency actions perform ed        dures.


by these groups require coordination with other e le- ments of the emergency organization, the particulars a nd              1.4.6 Signoff Sheets and Checklists requirements of this coordination should be specified in the controlling procedure.                                                    Complex or lengthy controlling procedures should have provisions for signoff sheets or checklists to
13.      Nuclear Energy Institute (NEI), white paper, Implementing a 24-Month Frequency for Emergency Preparedness Program Reviews, Rev. 0, November 2019.2
1.4 Procedure Format document the fact that required actions havy been taken or have been completed. Examples include notification A rigid format for implementing procedures is niot        call lists and personnel accountability checks.
14.     NEI, Conducting a Hostile Action-Based Emergency Response Drill, NEI 06-04, Revision 3, Appendix A, Recommended Drill and Exercise Objectives, September 2016.


suggested in this guide. An acceptable format shot mid display the action steps so the user of the procedure c an clearly understand his duties. The format of procedu!res          2.    SCOPE OF IMPLEMENTING PROCEDURES
15.     NRC, Emergency Plans Submittal Dates, Generic Letter 79-50, 1979.
that specify immediate actions to be taken has spec ial significance because the user needs brief and expli cit instructions that can be followed easily and quickly.            2.1 Immediate Action Procedures
      1.4.1 Title and Purpose                                          There should be a separate procedure for each identified class of emergency to specify and implement Eacth procedure should have a title that is        the preplanned response actions required for that emer- descriptive of its purpose. The purpose of the procedt ire        gency condition. Each procedure should (I) clearly should be stated separately, however, if the title is rlot        identify the action level, the protective action guide, or sufficiently descriptive.                                        the conditions for declaring the emergency condition,
                                                                  (2) list the individuals and elements of the emergency
      1.4.2 Conditions and Prerequisites                        organization that are to be notified and mobilized, and
                                                                  (3) specify the emergency actions that are to be taken Each procedure should specify the prereq ui-        by designated individuals and elements of the emergency sites and conditions that should exist before the spe'ci-        organization.


1.101-12
16.     Nuclear Management and Resources Council (NUMARC), Methodology for Development of Emergency Action Levels, NUMARC/NESP-007, Revision 2, January 1992.


2.2 Emergency Action Procedures                                  within areas and buildings within the site. The proce- dures should contain appropriate checksheets and sign- The following sections list subjects that should be          offs and should provide for reporting of information to covered by written procedures. The titles (f specific              the central authority in charge of the emergency procedures, as well as their contents, may vary among              response actions.
17.     NEI, Methodology for Development of Emergency Action Levels, NEI 99-01, Revision 4, January 2003.


licensees, but the actions or subjects described below should be covered within the group of procedures that implement the emergency plan.                                            2.2.6 Asse.,sment Actions
18.     NRC, Nuclear Regulatory Commission International Policy Statement, Federal Register, Vol.
      2.2.1 Notifications                                                      Procedures should describe the system for gathering information and data on which to base Call lists to alert and mobilize the emergency          decisions to escalate or deescalate emergency response organization and. supporting agencies should be specified          actions. They should identify the types and sources of for each identified class of emergency. If call lists are not    information available such as control room radiological too lengthy or complex, they should be incorporated              and meteorological instruments and radiation and con- into the immediate action procedure.                                tamination levels as defined by in-plant, site boundary, and onsite and offsitr. surveys The procedures should
      2.2.2 Radiological Surveys                                  specify action levels, protective action guides, and other guidelines as a basis for decisions to initiate emergency Procedures should specify the methods, and            measures and actions or to terminate or otherwise preplanned locations if feasible, for emergency radio-            modify emergency actions in progress. The procedures logical surveys in the plant and in the environs of the            should assign responsibilities for gathering and using plant. The rocedures should include or refer to require-          assessment data and information.


ments for 'oviding collected data and information to the individual or organizational element responsible for                2.2.7 First Aid and Medical Care emergency assessment functions.
79, No. 132, July 10, 2014, pp. 39415-39418.


The procedures that specify the methods
19.     NRC, Management Directive 6.6, Regulatory Guides.
      2.2.3 Personnel Monitoring and Decontamination              and instructions for receiving, transporting, handling, and: providing medical treatment of injured persons The procedures should require monitoring of            should specifically include the prezautions and special individuals leaving restricted areas or other areas known          handling required for contaminated paticnts. The proce- or suspected to be contaminated. The procedures should            dures should cover separately the provisions for, and use specify contamination levels that require decontamina-            of, medical treatment facilities in both onsite and offsite tion actions. They should also include or refer to                areas.


decontamination procedures for various types and levels of radioactive contamination.                                           2.2.8 Firefighting
20.     International Atomic Energy Agency (IAEA), Preparedness and Response for a Nuclear or Radiological Emergency, IAEA Safety Guide GS-R-2, Vienna, Austria, November 2015.3
      2.2.4 Evacuation of Oasite Areas                                        The procedures should cover precautions for fighting fires involving radioactive materials and for Procedures for evacuation should include the          situations where firefighters may otherwise be exposed action levels that require evacuation of specified areas,          to radiation. They should cover the responsibilities and buildings, and the site. Primary and secondary evacua-             capabilities of both' in-house and offsite firefigh!ing tion routes and assembly areas should be designated.               teams and equipment. They should include specific These procedures should be related to or refer to those            instructions for monitoring the exposure to radiation of procedures for personnel accountability and personnel              offsite personnel involved in firefighting.
21.     NEI, Development of Emergency Action Levels for Non-Passive Reactors, NEI 99-01, Revision 6, November 2012.


monitoring.
22.      NRC, memorandum to the NEI, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, March 28, 2013 (ADAMS Accession No. ML12346A463).
23.      NEI, Methodology for Development of Emergency Action Levels, NEI 99-01, Revision 5, February 2008.


2.2.9 Reentry
24.     NRC, memorandum to the NEI, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 5, February 22, 2008. (ADAMS Accession No. ML080430535).
      2.2.5 Personnel Accountability Procedures and guidelines should be devel- A method of personnel accountability should            oped for reentry to previously evacuated areas for the be specified in procedures to ensure that, at all times, all      purposes of saving lives, search and rescue of missing and individuals within the site confines and areas and                injured persons, or manipulation, repair, or recovery of buildings within the site are warned of imminent threats          critical equipment or systems. Specific guidelines should or hazardous conditions and evacuated from affected                be included in these procedures for maximum emer- areas if required.                                                 gency radiation exposures for reentry and rescue person- nel. The procedures should designate the individual or The procedures should designate individuals          authority having the responsibility for approving the having the responsibility of accounting for persons              voluntary acceptance of emergency exposures.
25.     NEI, Methodology for Development of Emergency Action Levels Advanced Passive Light Water Reactors, NEI 07-01, Revision 0, July 2009.


1.101-13
26.     NRC, memorandum to the NEI, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 07-01, August 12, 2009. (ADAMS Accession No. ML092190035).
2  Publications from the NEI are available at its Web site http://www.nei.org or by contacting the headquarters at Nuclear Energy Institute, 1201 F Street, NW, Suite 1100, Washington DC 20004-1218; by phone at 202-739-8000, or by fax at 202-
    785-4019.


2.2.10 Plant Security                                              2.3.3 Equipment and Instrumentation The normal plant security proceduwes should                      Operating instructions for equipment and powidC f'o security and access control during emergency            ins!rumentation should be prepared and stored with the co ild iorls.                                                       equipment. Procedures should include inventory lists of kits, equmipment, and ittstrumnents and provisions ftor periodic inventory, inspection, calibration, and nainlten-
3   IAEA Safety Requirements and Guides may be found at www.IAEA.org/ or by writing the International Atomic Energy Agency, P.O. Box 100 Wagramer Strasse 5, A-1400 Vienna, Austria; telephone (+431) 2600-0; fax (+431) 2600-7; or e-mail Official.Mail@IAEA.Org. It should be noted that some of the international recommendations do not correspond to the requirements specified in the NRCs regulations, and the NRCs requirements take precedence over the international guidance.
      2.2.1  Recovery                                            arict.


Actioln lovels .autd guidClines should be devel-            2.3.4 Training op.d I'M restoring operations and propierty as nearly as possible to their preenmergency status. The less complex                        The training program for thec cnergency tpcr:ations such as personnel enlergencics and emergency            organization should be documented in the form of al-ius should require only brief recovery action proce-            schedules and lesson plans or lesson outlines. The dures. The more complex emergency operations, how-                  program should include training for licensee employees ever I(site .and geoeral emergencies I'or eample). will            and for offsite organizations and personnel who are to gene.rally require !urrvspondingly conmphlex recovery              provide support in the emergency response.
RG 1.101, Rev. 6, Page 10


:ictions. It is not practicable to plan detailed recovery actL ionS for all conceivable situations, but procedures                  2.3.5 Tests and Drills that include at least the initial planning considerations fOr recovering. repairing, de,:ontaininating. etc. poten-                        Procedures should provide for practice drills tiaily affIected portions of the facility should be devel-         to test the state of preparedness of the emergency organization. The procedures should include guidance for the development oft detailed scenarios to test both During recovery operations, personnel cx-            specific procedures and implementation of the major posures to radiation should be maintained within 10                aspects of the emergency plan. The scenarios should be C(FR Part 20 limits.                                                preplanned simulations of emergency situations, arid they should be approved by plant management after they have been reviewed for scope and adequacy.
27. NEI, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, NEI 10-05, Revision 0, June 2011.


2.3 Supplemental Procedures This section lists subjects for procedures that The procedures should consider t(le utility of @1 testing on both an announced and unannounced basis.
28. NEI, Conducting a Hostile Action-Based Emergency Response Drill, NEI 06-04, Revision 2, Appendix A, Recommended Drill and Exercise Objectives, July 2011.


supplement those covering emergency resl'onse actions.             They should require the use of an observer staff during rhc specific titles and contents may vary, but the                tie conduct of test drills and should contain provisions described subjects should be covered in the licensee's              for appropriate checklists or critique sheets to be used proccedural system.                                                by the observer staff.
29. NRC, Letter to NEI, NRC Endorsement of Revised NEI 06-04 Rev. 2, Conducting a Hostile Action-Based Emergency Response Drill Appendix A, Exercise Objectives, September 19,
    2011 (ADAMS Accession No. ML112570092).
30. NEI, Reportable Action Levels for Loss of Emergency Preparedness Capabilities, NEI 13-01, Revision 0, July 2014.


The procedur6s for practice drills should
31. NRC, Event Report Guidelines 10 CFR 50.72(b)(3)(xiii) NUREG-1022, Revision 4, Supplement
      2.3.1 Communications include coordinatiun with offsite support organizations.
    1-Final Report, September 2014.


Communications drills with support organizations are Procedures should be available for activating,       sufficient to test the licensee's notification procedures.
32. NRC, Management Directive 8.4, Management of Backfitting, Forward Fitting, Issue Finality, and


operating. testing, and maintaining the emergency com- umnlications svsye ins.                                          3.    REVIEW AND APPROVAL OF PROCEDURES
===
                                                                          The procedural system used by licensees should
      2.3.2 Documentation and Records contain written rules and instructions- governing the writing, revising, and updating of implementing proce- Procedures should include requirements for            dures. The instructions should specify the methods to be iecording the implementation and completion or termi-              used to ensure that procedures, revisions, and changes nation of emergency response actions, logging assess-              are reviewed for adequacy, approved for use, and nenl data, reports of personnel accountability, and                distributed to user organizations and individuals having maintenance of required ;ecords and log.                            the responsibility for implementing the procedures.


1.101-14 S}}
===Information Requests===
===
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                                  RG 1.101, Rev. 6, Page 11}}


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Revision as of 13:58, 2 June 2021

Rev. 6, Emergency Response Planning and Preparedness for Nuclear Power Reactors
ML21111A090
Person / Time
Issue date: 06/30/2021
From: Charles Murray
NRC/RES/DE/RGDB
To:
Bayssie M
Shared Package
ML21111A075 List:
References
RG-1.101, Rev. 6
Download: ML21111A090 (11)


U.S. NUCLEAR REGULATORY COMMISSION

REGULATORY GUIDE 1.101, REVISION 6 Issue Date: June 2021 Technical Lead: Charles Murray EMERGENCY RESPONSE PLANNING AND PREPAREDNESS FOR

NUCLEAR POWER REACTORS

A. INTRODUCTION

Purpose This regulatory guide (RG) describes an approach that is acceptable to the staff of the U.S. Nuclear Regulatory Commission (NRC) to meet the regulatory requirements for emergency response planning and preparedness. This revision updates the list of NRC-developed and NRC-endorsed guidance documents acceptable to meet the regulatory requirements of Title 10 of the Code of Federal Regulations

(10 CFR) 50.47, Emergency Plans (Ref. 1), and 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities (Ref. 2).

Applicability This RG applies to all holders of, or applicants for, a power reactor operating license or construction permit under 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, except those that have certified that they have permanently ceased operations and have permanently removed all fuel from the reactor vessel, as well as all holders of, or applicants for, a power reactor early site permit or a combined license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants (Ref. 3). This RG is for light water reactors, including those of an advanced design (e.g., AP1000 design).

Applicable Regulations

  • 10 CFR Part 50 provides regulations for licensing production and utilization facilities.

Written suggestions regarding this guide or development of new guides may be submitted through the NRCs public Web site in the NRC Library at https://nrcweb.nrc.gov/reading-rm/doc-collections/reg-guides/, under Document Collections, in Regulatory Guides, at https://nrcweb.nrc.gov/reading-rm/doc-collections/reg-guides/contactus.html.

Electronic copies of this RG, previous versions of RGs, and other recently issued guides are also available through the NRCs public Web site in the NRC Library at https://nrcweb.nrc.gov/reading-rm/doc-collections/reg-guides/, under Document Collections, in Regulatory Guides. This RG is also available through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under ADAMS Accession Number (No.) ML21111A090. The regulatory analysis may be found in ADAMS under Accession No. ML21004A168. The associated draft guide DG-1357 may be found in ADAMS under Accession No. ML21007A330, and the staff responses to the public comments on DG-1357 may be found under ADAMS Accession No. ML21111A091.

o 10 CFR 50.47(a)(i) provides, in part, that no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency o 10 CFR 50.47(b) provides 16 standards that must be met by licensees or applicants for the NRC to make a finding of reasonable assurance o 10 CFR 50.47(b)(4) requires that onsite and offsite emergency response plans contain a standard emergency classification and action level scheme o 10 CFR 50.54(t)(1) requires licensees to provide for the development, revision, implementation, maintenance, and periodic independent review of its emergency preparedness program o Appendix E to 10 CFR Part 50 establishes minimum requirements for emergency plans for use in attaining an acceptable state of emergency preparedness o Section IV.B.1 of Appendix E provides that emergency action levels (EALs) should be established as part of the emergency plan and should be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring o Section IV.C.1 of Appendix E requires each emergency plan to define the emergency classification levels and the corresponding extent of response participation by the emergency response organization o Section IV.F. of Appendix E establishes the requirements for the training-related content of emergency plans Related Guidance This RG provides a list of guidance documents to aid in the development and review of emergency preparedness and response plans. The following documents are acceptable guidance when developing emergency preparedness and response plans:

  • NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, issued November 1980 (Ref. 4), which provides specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47
  • NUREG-0654/FEMA-REP-1, Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, issued December 2019 (Ref. 5), which provides specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47
  • NUREG-0396/EPA 520/1-78-016, Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants, issued December 1978 (Ref. 6)

RG 1.101, Rev. 6, Page 2

  • NUREG-0696, Functional Criteria for Emergency Response Facilities, issued February 1981 (Ref. 7)
  • NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies, issued November 2011 (Ref. 8)
  • NUREG/CR-7002, Revision 1, Criteria for Development of Evacuation Time Estimate Studies, issued February 2021 (Ref. 9)
  • NSIR/DPR-ISG-01, Interim Staff Guidance: Emergency Planning for Nuclear Power Plants, issued November 2011 (Ref. 10)

Purpose of Regulatory Guides The NRC issues RGs to describe to the public methods that are acceptable to the staff for implementing specific parts of the agencys regulations, to explain techniques that the staff uses in evaluating specific issues or postulated events, and to describe information that the staff needs in its reviews of applications for permits and licenses. Regulatory guides are not NRC regulations and compliance with them is not required. Methods and solutions that differ from those set forth in RGs are acceptable if supported by a basis for the issuance or continuance of a permit or license by the Commission.

Paperwork Reduction Act This RG provides voluntary guidance for implementing the mandatory information collections in

10 CFR Part 50 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved by the Office of Management and Budget (OMB), approval numbers 3150-0011. Send comments regarding this information collection to the FOIA, Library, and Information Collections Branch (T6-A10M), U.S. Nuclear Regulatory Commission, Washington, DC

20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the OMB reviewer at: OMB Office of Information and Regulatory Affairs (3150-0011), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 17th Street, NW Washington, DC 20503; e-mail: oira_submission@omb.eop.gov.

Public Protection Notification The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the document requesting or requiring the collection displays a currently valid OMB

control number.

RG 1.101, Rev. 6, Page 3

B. DISCUSSION

Reason for Revision The staff is issuing Revision 6 of RG 1.101 to endorse and update guidance that is available to licensees and applicants on methods acceptable to the NRC staff for complying with the NRCs regulations for emergency response plans and preparedness at nuclear power reactors. This revision endorses Revision 0 of the Nuclear Energy Institute (NEI) white paper, Implementing a 24-Month Frequency for Emergency Preparedness Program Reviews, issued November 2019 (Ref. 13) and Appendix A, Recommended Drill and Exercise Objectives, to NEI 06-04, Conducting a Hostile Action-Based Emergency Response Drill, Revision 3, issued September 2016 (Ref. 14). This revision of the RG also consolidates previously developed and endorsed guidance documents into a single revision of the RG.

Background In November 1980, the NRC published Revision 1 to NUREG-0654/FEMA-REP-1 to provide specific acceptance criteria for complying with the standards set forth in 10 CFR 50.47. NUREG-

0654/FEMA-REP-1, Revision 1, is a joint NRC NUREG-series publication and Federal Emergency Management Agency (FEMA) guidance document. The NRC uses this document to evaluate the adequacy of the emergency plans and preparedness of nuclear power plant licensees while FEMA, as well as other Federal agencies, use this document to review and approve state, local, and tribal government radiological emergency plans. In October 1981, the NRC endorsed NUREG-0654/FEMA-REP-1 in Revision 2 of this guide.

Planning standard 10 CFR 50.47(b)(4) requires that the emergency plan include a standard EAL

scheme. An EAL is a predetermined, site-specific, observable threshold for a plant condition that results in an emergency classification. The NRC initially established guidance for the development of EALs in Generic Letter (GL) 79-50, Emergency Plans Submittal Dates, issued 1979 (Ref. 15). Revision 2 of this guide endorsed subsequent guidance in Appendix 1 to NUREG-0654, which became the primary standard for the NRCs review of EAL schemes.

As the industry gained experience with the implementation and use of EAL schemes, it issued revised guidance documents on EAL scheme development to reflect lessons learned. The industry-developed guidance built upon and enhanced the foundation set forth in NUREG-065

4. Revision

3 of this RG endorsed Nuclear Management and Resources Council (NUMARC)/NESP-007, Revision 2, Methodology for Development of Emergency Action Levels, issued January 1992 (Ref. 16), and RG

1.101, Revision 4, endorsed NEI 99-01, Revision 4, Methodology for Development of Emergency Action Levels, issued January 2003 (Ref. 17) as acceptable methods for licensees to consider in the development of their plant-specific EAL schemes.

Revision 5 of RG 1.101 issued in June 2005 provided guidance for co-located licensees on conducting emergency response planning activities and interactions in the years between participation in offsite full- or partial-participation exercises. Since the publication of Revision 5, the NRC has developed or endorsed several new or revised emergency planning guidance documents described in Section C of this RG.

In December 2019, the NRC published Revision 2 of NUREG-0654/FEMA-REP-1, which integrates nearly 35 years of lessons learned in radiological emergency preparedness and consolidates and clarifies previous guidance related to the development of emergency plans. The planning criteria and RG 1.101, Rev. 6, Page 4

guidance contained in Revision 2 of NUREG-0654/FEMA-REP-1 reflect changes to both NRC and FEMA regulations, guidance, policies, and doctrine, as well as advances in technology and best practices that have occurred since the document was originally issued in 1980. The NRC staff considers these criteria and guidance to be acceptable methods for complying with the onsite and offsite emergency response planning standards in 10 CFR 50.47.

Revision 2 of NUREG-0654/FEMA-REP-1 also defines the review period for emergency preparedness program reviews conducted in accordance with 10 CFR 50.54(t)(1) such that 12 months in 10 CFR 50.54(t)(1) and annual in NUREG-0654/FEMA-REP-1 both mean 365 days. Thus, the program review should not exceed 365 days from the end date of the prior review to the completion of the next program review, which includes issuance of the review report. The requirement for all elements of the emergency preparedness program to be reviewed at least once every 24 months should not exceed 730

days from the end of the prior review to the completion of the next program review, which includes issuance of the review report.

Consideration of International Standards The International Atomic Energy Agency (IAEA) works with member states and other partners to promote the safe, secure, and peaceful use of nuclear technologies. The IAEA develops Safety Standards and Safety Guides for protecting people and the environment from harmful effects of ionizing radiation.

This system of safety fundamentals, safety requirements, safety guides, and other relevant reports reflects an international perspective on what constitutes a high level of safety. To inform its development of this RG, the NRC considered IAEA Safety Requirements and Safety Guides pursuant to the Commissions International Policy Statement (Ref. 18) and Management Directive and Handbook 6.6 (Ref. 19). In development of this RG, the staff considered IAEA Safety Guide GS-R-2, Preparedness and Response for a Nuclear or Radiological Emergency, issued November 2015 (Ref. 20).

The NRC staff did not identify any IAEA Safety Requirements or Guides with information related to the topic of this RG.

Documents Discussed in Staff Regulatory Guidance This RG endorses the use of one or more guidance documents developed by external organizations, and other third-party guidance documents. These codes, standards and third-party guidance documents may contain references to other codes, standards or third-party guidance documents (secondary references). If a secondary reference has itself been incorporated by reference into NRC

regulations as a requirement, then licensees and applicants must comply with that standard as set forth in the regulation. If the secondary reference has been endorsed in a RG as an acceptable approach for meeting an NRC requirement, then the standard constitutes a method acceptable to the NRC staff for meeting that regulatory requirement as described in the specific RG. If the secondary reference has neither been incorporated by reference into NRC regulations nor endorsed in a RG, then the secondary reference is neither a legally-binding requirement nor a generic NRC approved acceptable approach for meeting an NRC requirement. However, licensees and applicants may consider and use the information in the secondary reference, if appropriately justified, consistent with current regulatory practice, and consistent with applicable NRC requirements.

RG 1.101, Rev. 6, Page 5

C. STAFF REGULATORY GUIDANCE

This section includes industry-developed guidance documents that the NRC staff has previously determined to be acceptable to meet regulatory requirements for emergency response planning and preparedness for nuclear power plants and an industry-developed guidance document that the NRC is endorsing as a method that the staff also considers acceptable to meet regulatory requirements for emergency response planning and preparedness for nuclear power plants.

Previously Endorsed NEI Guidelines

1. NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (Ref. 21), which is acceptable for use by licensees and applicants as a methodology to develop or upgrade EAL schemes in accordance with the requirements of 10

CFR 50.47(b)(4), related sections of Appendix E to 10 CFR Part 50, and the associated planning standard evaluation elements of NUREG-0654/FEMA-REP-1, Revision 1. The NRC endorsed this guidance in a memorandum to NEI, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, March 28, 2013. (Ref. 22)

2. NEI 99-01, Revision 5, Methodology for Development of Emergency Action Levels, February

2008 (Ref. 23), which is acceptable for use by licensees and applicants as a methodology to develop or upgrade EAL schemes in accordance with related sections of Appendix E to 10 CFR

Part 50. In addition to clarifying certain sections of previous revisions, Revision 5 of NEI 99-01 formalizes enhancements to emergency planning associated with hostile action events for emergency preparedness programs. The NRC endorsed this guidance in a memorandum to NEI,

U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 5, February 22, 2008. (Ref. 24)

3. NEI 07-01, Revision 0, Methodology for Development of Emergency Action Levels Advanced Passive Light Water Reactors, July 2009 (Ref. 25), which is an acceptable reference for applicants to review in the development of new reactor applications if they are using the AP1000

or Economic Simplified Boiling Water Reactor design. Additionally, applicants may consider the template provided in NEI 07-01 as a reference for the development of an EAL scheme for any design using digital instrumentation and control, including licensed power reactors considering upgrading to digital instrumentation and control. The NRC endorsed this guidance in a memorandum to NEI, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI

07-01, August 12, 2009. (Ref. 26)

4. NEI 10-05, Revision 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, issued June 2011 (Ref. 27), which is acceptable for use by licensees and applicants as a methodology to perform a detailed staffing analysis for on-shift personnel assigned emergency plan implementation duties as required by Section IV.A.9 of Appendix E to 10 CFR

Part 50. The NRC endorsed the on-shift staffing method of NEI 10-05 in Section IV.C of the interim staff guidance (ISG), NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, November 2011.

5. Appendix A, Recommended Drill and Exercise Objectives, to NEI 06-04, Conducting a Hostile Action-Based Emergency Response Drill, Revision 2, issued July 2011 (Ref. 28), which is acceptable for use by licensees and applicants for the development and conduct of hostile action-based emergency response drills. The NRC endorsed Appendix A to NEI-06-04, Rev. 2, by letter dated September 19, 2011. (Ref. 29)

RG 1.101, Rev. 6, Page 6

6. NEI 13-01, Reportable Action Levels for Loss of Emergency Preparedness Capabilities, Revision 0, issued July 2014 (Ref. 30), which is acceptable for use by licensees and applicants as a methodology that provides specific guidance for reporting the loss of emergency preparedness capabilities under 10 CFR 50.72(b)(3)(xiii). The NRC endorsed NEI 13-01 in NUREG-1022, Rev. 3, Supplement 1, Event Report Guidelines 10 CFR 50.72(b)(3)(xiii), September 2014.

(Ref. 31)

Endorsement of NEI Guidelines

1. The NRC staff endorses Revision 0 of the NEI white paper, Implementing A 24-Month Frequency for Emergency Preparedness Program Reviews, which is acceptable for use by licensees and applicants as a methodology to adopt the voluntary option for conducting periodic emergency preparedness program reviews at a 24 month frequency as allowed by 10 CFR

50.54(t)(1)(ii).

2. The NRC staff endorses Appendix A, Recommended Drill and Exercise Objectives, to NEI 06-

04, Conducting a Hostile Action-Based Emergency Response Drill, Rev. 3, which is acceptable for use by licensees and applicants for the development and conduct of hostile action-based emergency response drills.

RG 1.101, Rev. 6, Page 7

D. IMPLEMENTATION

The NRC staff may use this RG as a reference in its regulatory processes, such as licensing, inspection, or enforcement. However, the NRC staff does not intend to use the guidance in this RG to support NRC staff actions in a manner that would constitute backfitting as that term is defined in 10 CFR 50.109, Backfitting, and as described in NRC Management Directive 8.4, Management of Backfitting, Forward Fitting, Issue Finality, and

=

Information Requests

=

(Ref. 32), nor does the NRC staff intend to use the guidance to affect the issue finality of an approval under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants. The staff also does not intend to use the guidance to support NRC staff actions in a manner that constitutes forward fitting as that term is defined and described in Management Directive 8.4. If a licensee believes that the NRC is using this RG in a manner inconsistent with the discussion in this Implementation section, then the licensee may file a backfitting, or forward fitting, appeal with the NRC in accordance with the process in Management Directive 8.4.

RG 1.101, Rev. 6, Page 8

REFERENCES 1

1. U.S. Code of Federal Regulations (CFR), Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy.

2. CFR, Emergency Planning and Preparedness for Production and Utilization Facilities, Appendix E, Part 50, Chapter I, Title 10, Energy.

3. CFR, Licenses, Certifications, and Approvals for Nuclear Power Plants, Part 52, Chapter I,

Title 10, Energy.

4. U.S. Nuclear Regulatory Commission (NRC) and Federal Emergency Management Agency (FEMA), Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Revision 1, November 1980.

5. NRC and FEMA, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Revision 2, December 2019.

6. NRC and the U.S. Environmental Protection Agency (EPA), Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants, NUREG-0396/EPA 520/1-78-016, December 1978.

7. NRC, Functional Criteria for Emergency Response Facilities, NUREG-0696, February 1981.

8. NRC, Criteria for Development of Evacuation Time Estimate Studies, NUREG/CR-7002, November 2011.

9. NRC, Criteria for Development of Evacuation Time Estimate Studies, NUREG/CR-7002, Revision 1, February 2021.

10. NRC, Interim Staff Guidance: Emergency Planning for Nuclear Power Plants, NSIR/DPR-ISG-01, November 2011.

11. NRC, Interim Staff Guidance: Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants, NSIR/DPR-ISG-02, May 11, 2015

12. NRC, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Regulatory Guide 1.219, July 2018.

1 Publicly available NRC published documents are available electronically through the NRC Library on the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/ and through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html. The documents can also be viewed online or printed for a fee in the NRCs Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD. For problems with ADAMS, contact the PDR staff at 301-415-4737 or (800) 397-4209; fax (301) 415-3548; or e-mail pdr.resource@nrc.gov.

RG 1.101, Rev. 6, Page 9

13. Nuclear Energy Institute (NEI), white paper, Implementing a 24-Month Frequency for Emergency Preparedness Program Reviews, Rev. 0, November 2019.2

14. NEI, Conducting a Hostile Action-Based Emergency Response Drill, NEI 06-04, Revision 3, Appendix A, Recommended Drill and Exercise Objectives, September 2016.

15. NRC, Emergency Plans Submittal Dates, Generic Letter 79-50, 1979.

16. Nuclear Management and Resources Council (NUMARC), Methodology for Development of Emergency Action Levels, NUMARC/NESP-007, Revision 2, January 1992.

17. NEI, Methodology for Development of Emergency Action Levels, NEI 99-01, Revision 4, January 2003.

18. NRC, Nuclear Regulatory Commission International Policy Statement, Federal Register, Vol.

79, No. 132, July 10, 2014, pp. 39415-39418.

19. NRC, Management Directive 6.6, Regulatory Guides.

20. International Atomic Energy Agency (IAEA), Preparedness and Response for a Nuclear or Radiological Emergency, IAEA Safety Guide GS-R-2, Vienna, Austria, November 2015.3

21. NEI, Development of Emergency Action Levels for Non-Passive Reactors, NEI 99-01, Revision 6, November 2012.

22. NRC, memorandum to the NEI, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, March 28, 2013 (ADAMS Accession No. ML12346A463).

23. NEI, Methodology for Development of Emergency Action Levels, NEI 99-01, Revision 5, February 2008.

24. NRC, memorandum to the NEI, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 5, February 22, 2008. (ADAMS Accession No. ML080430535).

25. NEI, Methodology for Development of Emergency Action Levels Advanced Passive Light Water Reactors, NEI 07-01, Revision 0, July 2009.

26. NRC, memorandum to the NEI, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 07-01, August 12, 2009. (ADAMS Accession No. ML092190035).

2 Publications from the NEI are available at its Web site http://www.nei.org or by contacting the headquarters at Nuclear Energy Institute, 1201 F Street, NW, Suite 1100, Washington DC 20004-1218; by phone at 202-739-8000, or by fax at 202-

785-4019.

3 IAEA Safety Requirements and Guides may be found at www.IAEA.org/ or by writing the International Atomic Energy Agency, P.O. Box 100 Wagramer Strasse 5, A-1400 Vienna, Austria; telephone (+431) 2600-0; fax (+431) 2600-7; or e-mail Official.Mail@IAEA.Org. It should be noted that some of the international recommendations do not correspond to the requirements specified in the NRCs regulations, and the NRCs requirements take precedence over the international guidance.

RG 1.101, Rev. 6, Page 10

27. NEI, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, NEI 10-05, Revision 0, June 2011.

28. NEI, Conducting a Hostile Action-Based Emergency Response Drill, NEI 06-04, Revision 2, Appendix A, Recommended Drill and Exercise Objectives, July 2011.

29. NRC, Letter to NEI, NRC Endorsement of Revised NEI 06-04 Rev. 2, Conducting a Hostile Action-Based Emergency Response Drill Appendix A, Exercise Objectives, September 19,

2011 (ADAMS Accession No. ML112570092).

30. NEI, Reportable Action Levels for Loss of Emergency Preparedness Capabilities, NEI 13-01, Revision 0, July 2014.

31. NRC, Event Report Guidelines 10 CFR 50.72(b)(3)(xiii) NUREG-1022, Revision 4, Supplement

1-Final Report, September 2014.

32. NRC, Management Directive 8.4, Management of Backfitting, Forward Fitting, Issue Finality, and

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Information Requests

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