Issue Date: 10/30/08 1 65001.18 

ATTACHMENT 65001.18 

INSPECTION OF EMERGENCY PLANNING ITAAC 

PROGRAM APPLICABILITY: 2503 

65001.18-01 INSPECTION OBJECTIVES 

To provide inspection guidance to verify that the acceptance criteria have been met for the 

applicant=s site-specific emergency planning (EP) Inspections, Tests, Analyses, and 

Acceptance Criteria (ITAAC) approved by the NRC. 

65001.18-02 INSPECTION REQUIREMENTS AND GUIDANCE 

The onsite emergency response plans (i.e., emergency plans) must meet the standards 

established in 10 CFR 50.47(b) and applicable requirements of Appendix E to 10 CFR Part 

50. Compliance with these regulations is determined by using the guidance in Regulatory 

Guide (RG) 1.101, Revision 4, which endorses NUREG-0654/FEMA-REP-1, ACriteria for 

Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness 

in Support of Nuclear Power Plants,@ Revision 1 (hereinafter referred to as NUREG-0654). 

The criteria and recommendations in RG 1.101 are methods that the NRC staff considers 

acceptable for complying with the requirements in Appendix E to 10 CFR Part 50 and the 

planning standards in 10 CFR 50.47(b) that must be met in onsite and offsite emergency 

response plans. These criteria provide a basis for NRC licensees and State and local 

governments to develop acceptable radiological emergency plans and improve emergency 

preparedness. Additionally, this regulatory guide describes a voluntary method that the 

NRC staff considers acceptable for complying with the amended regulations in Appendix E 

to 10 CFR Part 50, as they relate to NRC approval of licensee changes to emergency 

action levels and exercise requirements for co-located licensees. Compliance with this 

regulatory guide is not a requirement, and licensees and applicants may choose this or 

another method to achieve compliance with these rules. 

As previously noted, licensees compliance with 10 CFR 50.47(b) and applicable 

requirements of Appendix E to 10 CFR Part 50 is determined by using the guidance in RG 

1.101, Revision 4, and through it NUREG-0396, APlanning Basis for the Development of 

State and Local Government Radiological Emergency Response Plans in Support of Light 

Water Nuclear Power Plants,@ and NUREG-0696, AFunctional Criteria for Emergency 

Response Facilities.@ (herein after referred to as NUREG-0696). Additional guidance is 

provided in NUREG-0737 and Supplement to NUREG-0737, “Clarification of TMI Action 

Plan Requirements.” 

10 CFR 52.80(b) requires the combined license (COL) applicant to include proposed EP 

ITAAC in the application, which are necessary and sufficient to provide reasonable 

assurance that, if the inspections, tests and analyses are performed and acceptance 

criteria are met, the facility has been constructed and will operate in conformity with the 

COL, the provisions of the Atomic Energy Act, and NRC regulations. The COL applicant 
Issue Date: 10/30/08 2 65001.18 

shall develop EP ITAAC to address the implementation of emergency plan elements and 

reference them in the Final Safety Analysis Report (FSAR). 

This procedure includes inspection guidance for an acceptable set of generic EP ITAAC 

that an applicant may use to develop application-specific ITAAC tailored to the specific 

reactor design and EP program requirements. These generic ITAAC are contained in 

NUREG-0800, AStandard Review Plan for the Review of Safety Analyses for Nuclear 

Power Plants,@ Table 14.3.10-1, AGeneric Inspections, Tests, Analyses, and Acceptance 

Criteria.@ This Standard Review Plan will be used by the staff to review an applicant=s 

emergency planning, as described in the FSAR for a COL application submitted under 10 

CFR Part 52. 

A smaller set of EP ITAAC is acceptable if the COL application contains information that 

fully addresses EP requirements associated with any of the generic ITAAC included herein, 

which are not all-inclusive. Additional plant-specific EP ITAAC may be proposed, and they 

will be examined for acceptability on a case-by-case basis. Guidance regarding the 

information to be submitted in a COL application for a nuclear power plant may be found in 

Regulatory Guide 1.206, ACombined License Applications for Nuclear Power Plants (LWR 

Edition),@ Revision 0. 

As preparation, the inspector should review the COL, and in particular the FSAR which 

contains the site Emergency Plan. The inspector should also review the safety evaluation 

report (SER) which approved the COL application since it contains the bases for 

acceptance of the EP program elements. If the COL application was for an additional 

reactor at an operating reactor site, the existing EP program elements should be 

acceptable and there will not be any ITAAC to review. (Note: This procedure verifies 

acceptance criteria for an approved COL application and therefore the applicant will be 

referred to as the licensee.) 

The alphanumeric reference at the end of each inspection requirement (and before the 

inspection guidance) is the associated evaluation criteria in Section II of NUREG-0654. 

02.01 Assignment of Responsibility (Organization Control). Review the licensee=s closeout documentation of this ITAAC to verify that sufficient staff exists to provide 24-hour per 

day emergency response and staffing of communications links, and that the applicant=s 

staff is of sufficient depth to be capable of continuous (24-hour) operations for a protracted 

period. (A.1.e, A.4) 

Guidance. The inspector should obtain and review the NRC-approved ITAAC pertaining to 

organization control, and the Emergency Plan, which are both contained in the COL. 

Review the Plan sections which describe the licensee=s emergency response organization 

(ERO). 

Verify through inspection of available documentation (Emergency Plan Implementing 

Procedures (EPIPs), Administrative Procedures, staffing rosters, training records, etc.) that 

there are sufficient trained staff to fill all positions specified by the licensee on a 24-hour 

basis for a protracted period (a number of days), including the staffing of communications 

links. The licensee shall be able to provide staff rosters which list sufficient staff by 
Issue Date: 10/30/08 3 65001.18 

position, to demonstrate that the acceptance criteria have been met. 

02.02 Onsite Emergency Organization. Review the licensee=s close-out documentation of 

this ITAAC to verify that sufficient staff exists to provide minimum on-shift and augmented 

staffing levels, consistent with the COL and NUREG-0654, Table B-1, AMinimum Staffing 

Requirements For NRC Licensees For Nuclear Power Plant Emergencies.@ (B.5, B.7) 

Guidance. The inspector should obtain and review the NRC-approved ITAAC concerning 

onsite emergency organization, and the Emergency Plan, which describe the staffing 

positions in the licensee=s ERO. Review the Plan section which describes the licensee=s 

implementation of NUREG-0654, Table B-1. 

Verify that there are sufficient numbers of trained personnel to fill each emergency position 

within the times specified in the licensee=s COL Emergency Plan. The inspector should 

determine this by viewing staffing rosters of personnel who have been previously verified 

by the licensee to live within a geographic area such that they can meet the time 

constraints of Table B-1. The licensee may have documentation of pager tests or 

augmentation Areport-in@ drills which would provide further assurance that the 

augmentation staff are capable of meeting the required response times. 

If the licensee has proposed an alternative process to ensure sufficient ERO staff other 

than that prescribed by NUREG-0654, then verify that there are sufficient numbers of 

trained staff to meet the commitments of the alternative process. The inspector should 

determine that there are sufficient trained staff who live within the vicinity of the plant such 

that they can respond in the required time-frame. 

02.03 Emergency Response Support and Resources. There are no generic ITAAC 

specified for this planning standard. Review for acceptability will be on a case-by-case 

basis if included in the COL application. 

02.04 Emergency Classification System. Review the licensee=s close-out documentation 

of this ITAAC to verify that the facility system and effluent parameters used as the bases 

for the standard emergency classification and emergency action level (EAL) scheme are 

retrievable in the Control Room (CR), Technical Support Center (TSC), and the Emergency 

Operations Facility (EOF); and that the ranges of displays of those parameters encompass 

the values specified in that EAL scheme. (D.1) 

Guidance. The inspector should obtain and review the NRC-approved ITAAC concerning 

system and effluent parameters used as the bases for the emergency classification and 

EAL scheme; and the Emergency Plan and/or EPIPs which describe the emergency 

classification and EAL scheme. 

Verify that the parameters associated with the licensee=s EAL scheme are consistent in 

range, units, and conversion factors with appropriate CR instrumentation used for 

measuring those parameters. Also verify by visual inspection that the CR, TSC, and EOF 

have adequate displays for retrieving facility system and effluent parameters specified in 

the EALs (i.e., ranges of displays encompass the values specified in the emergency 

classification and EAL scheme) such that decision-makers can use those displays to 
Issue Date: 10/30/08 4 65001.18 

accurately classify emergency events. 

02.05 Notification Methods and Procedures. Review the licensee=s close-out 

documentation of this ITAAC to verify that the licensee has the capability to notify State 

and local agencies within 15 minutes of declaring an emergency, to notify and mobilize 

emergency response personnel, and to notify and provide instructions to the public to meet 

the design objectives stated in the Emergency Plan. (E.1, E.2, E.6) 

Guidance. 

 a. Notification of State and local agencies (E.1) 

The inspector should obtain and review the NRC-approved ITAAC concerning the 

notification of State and local agencies within 15 minutes of an emergency 

declaration. Verify that the licensee has established the administrative and 

physical means for this notification and that the communications links and 

equipment are as described in the Emergency Plan. 

 Verify by test documentation review or observation of an actual test of the 

licensee=s notification capabilities, that communication systems will enable the 

licensee to notify State and local agencies within 15 minutes after declaring an 

emergency. 

 b. Notification of emergency response personnel (E.2) 

The inspector should obtain and review the NRC-approved ITAAC concerning the 

notification of the ERO for mobilization in an emergency. Verify that the licensee 

has established the administrative and physical means for this notification, and that 

the communication links and equipment are as described in the Emergency Plan. 

Also verify that the equipment (e.g., pagers, cell phones, automated telephone 

systems) is available and functional. 

Verify by test documentation review or observation of an actual test of the 

licensee=s ERO notification system, that it is capable of alerting the ERO such that 

responders are capable of achieving the response times required by the 

Emergency Plan. 

 c. Notification of the public within the plume exposure emergency planning zone 

(EPZ) (E.6) 

The inspector should obtain and review the NRC-approved ITAAC concerning the 

notification of, and provision of instructions to the public in the event of an 

emergency. Verify that the licensee has established administrative and physical 

means for prompt notification of the public as described in the Emergency Plan. 

The system for public notification (i.e., Prompt Notification System - PNS) usually 

consists of pole-mounted sirens, sometimes complemented by devices such as 

tone alert radios in remote areas of the EPZ. These devices alert the public to go 

indoors and tune to their pre-determined radio and/or television stations for 
Issue Date: 10/30/08 5 65001.18 

emergency instructions. It shall be the licensee=s responsibility to demonstrate that 

such means exist, regardless of who implements this requirement. 

Verify by test documentation review or observation of an actual test of the 

licensee=s PNS that it is capable of alerting the public per the design objectives 

stated in the Emergency Plan. 

02.06 Emergency Communications. Review the licensee=s close-out documentation of 

this ITAAC to verify that prompt communications exist among principal response 

organizations to emergency personnel and to the public. (F.1.d, F.1.f) 

Guidance. The inspector should obtain and review the applicable NRC-approved ITAAC 

concerning the provision of prompt communications among principal response 

organizations to emergency personnel and to the public. 

a. Verify that communications have been established between the CR, TSC, EOF, 

principal State and local Emergency Operations Centers (EOCs), and field 

radiological assessment teams (RATs). Verify that the licensee has established 

the administrative and physical means for these communication links and that the 

equipment is as described in the Emergency Plan. Also, verify that the equipment 

is available and functional. 

b. Verify that communications have been established from the CR, TSC, and EOF to 

the NRC headquarters and regional office emergency response centers (ERCs) 

and that an access port for the licensee=s Emergency Response Data System 

(ERDS), or its successor system, has been provided. Verify that this equipment is 

available and functional. 

 Verify by test documentation review or observation of an actual test of the 

licensee=s emergency communications links that the equipment has the capabilities 

delineated in the Emergency Plan. 

02.07 Public Education and Information. Review the licensee=s close-out documentation 

of this ITAAC to verify that the licensee has provided space which may be used for the 

number of news media specified in the COL. (G.3.b) 

Guidance. The inspector should obtain and review the applicable NRC-approved ITAAC 

pertaining to the provision of space for news media personnel. Verify by visual inspection 

that the appropriate amount of space has been made available. Also, verify that any 

location provided in the EOF for news media briefings is outside the controlled access 

area. 

02.08 Emergency Facilities and Equipment. Review the licensee=s close-out 

documentation of this ITAAC to verify that the acceptance criteria for emergency facilities 

and equipment have been met. (H.1, H.2, H.5, H.6, H.7, H.8, H.9) 

Guidance. 
Issue Date: 10/30/08 6 65001.18 

a. Technical Support Center (TSC) (H.1) 

 The inspector should obtain and review the NRC-approved ITAAC concerning the 

establishment of a TSC in accordance with NUREG-0696. 

 The inspector shall verify the following by visual inspection and/or review of design 

specifications: 

1. The total floor space is at least 1875 square feet, i.e., 75 ft2 per person for a 

minimum of 25 persons, including 20 persons designated by the licensee 

and five NRC personnel. This minimum size shall be increased appropriately 

if the maximum staffing level specified by the licensee=s Emergency Plan is 

greater than 20 persons. There shall also be a separate room adequate to 

be used by at least three persons for private NRC consultations. 

2. The TSC is located close to the Control Room (CR) such that the walking 

time from the TSC to the CR should not exceed two minutes. Advanced 

communication capabilities may be used to satisfy the two-minute travel time 

if approved in the COL. (The licensee will adopt design certification criteria, 

if applicable, or otherwise specify TSC location) 

3. The TSC shall have the same radiological habitability as the CR under 

accident conditions. That is, adequate radiation protection shall be provided 

to ensure that radiation exposures shall not exceed 0.05 Sv (5 Rem) total 

effective dose equivalent (TEDE) for the duration of any radiological accident 

(per 10 CFR 50, Appendix A, AGeneral Design Criteria For Nuclear Power 

Plants,@ Criterion 19). (The licensee will adopt design certification criteria, if 

applicable, or otherwise identify specific capabilities) 

4. The TSC ventilation system shall function in a manner comparable to the CR 

ventilation system. 

5. As a minimum, the TSC ventilation system shall include high-efficiency 

particulate air (HEPA) and charcoal filters. 

6. Communications equipment is installed, and voice transmission and 

reception are accomplished. Verify that the TSC has reliable voice 

communications with the CR, OSC, EOF, and the NRC (i.e., NRC 

Emergency Telecommunications System - ETS). There shall also be 

provisions for communications with State and local operations centers to 

provide early notification and recommendations to offsite authorities prior to 

EOF activation. Voice communications facilities shall include means for 

reliable primary and backup communication. 

7. Verify by test documentation review or observation of an actual test or 

demonstration of voice communications equipment that the equipment has 

the capabilities delineated in the Emergency Plan and/or COL. (The licensee 

will adopt design certification criteria, if applicable, or otherwise identify 
Issue Date: 10/30/08 7 65001.18 

specific capabilities) 

8. The TSC has the means to receive, store, process, and display plant and 

environmental information, to initiate emergency measures, and to conduct 

emergency assessment per COL commitments. 

9. As a minimum, the set of Type A, B, C, D, and E variables specified in 

Regulatory Guide (RG) 1.97, AInstrumentation for Light-Water-Cooled 

Nuclear Power Plants to Assess Plant and Environs Conditions During and 

Following an Accident,@ Revision 2, shall be available for display and printout 

in the TSC. 

10. A sufficient number of data display and printout devices shall be provided to 

allow all TSC personnel to perform their assigned tasks with unhindered data 

access. 

11. TSC displays shall include, but not be limited to, alphanumeric and/or 

graphical representations of: plant systems variables, in-plant radiological 

variables, meteorological information, and offsite radiological information. 

12. The Safety Parameter Display System (SPDS) shall be displayed in the TSC. 

b. Operational Support Center (OSC) (H.9) 

 The inspector should obtain and review the NRC-approved ITAAC concerning the 

establishment of an OSC in accordance with NUREG-0696. (The licensee will 

adopt design certification criteria, if applicable, or otherwise specify OSC location 

and identify specific capabilities) 

 The inspector shall verify the following by visual inspection: 

1. The OSC is located onsite, and may be combined with the TSC at a single 

location. 

2. OSC communications equipment is installed, and voice transmission and 

reception are accomplished. 

3. The communication system, as a minimum, shall consist of one dedicated 

telephone extension to the CR, one dedicated telephone extension to the 

TSC, and one dial telephone capable of reaching onsite and offsite locations. 

 Verify by test documentation review or observation of an actual test or 

demonstration of voice communications equipment that the equipment has 

the capabilities delineated in the Emergency Plan and/or COL. (The licensee 

will adopt design certification criteria, if applicable, or otherwise identify 

specific capabilities) 

c. Emergency Operations Facility (EOF) (H.2) 
Issue Date: 10/30/08 8 65001.18 

The inspector should obtain and review the NRC-approved ITAAC concerning the 

establishment of an EOF in accordance with NUREG-0696. 

The inspector shall verify the following by visual inspection: 

1. The total floor space is at least 2625 square feet, i.e., 75 ft2 per person for a 

minimum of 35 persons, including 25 persons designated by the licensee, 9 

persons from the NRC, and 1 person from the Federal Emergency 

Management Agency (FEMA). This size shall be increased appropriately if 

the staffing level specified in the Emergency Plan, including representatives 

from State and local agencies, is greater than 25 persons. There shall also 

be separate office space to accommodate at least five NRC personnel during 

periods that the EOF is activated for emergencies. (The licensee will identify 

EOF size characteristics) 

2. The EOF habitability is consistent with Table 2 of NUREG-0696. Note that 

the ventilation system shall function in a manner comparable to the CR and 

TSC, but need not have charcoal filters, and need not be seismic Category I 

qualified, redundant, instrumented, or automatically activated. (The licensee 

will specify the acceptance criteria for EOF habitability) 

3. EOF communications equipment is installed, and voice transmission and 

reception are accomplished with the CR, TSC, NRC (i.e., NRC ETS), and 

State and local agencies. Voice communications facilities shall include 

means for reliable primary and backup communication. 

4. Verify by test documentation review or observation of an actual test or 

demonstration of voice communications equipment that the equipment has 

the capabilities delineated in the Emergency Plan and/or COL. (The licensee 

will identify specific capabilities.) 

5. The EOF has the capability to acquire, display and evaluate radiological, 

meteorological, and plant system data pertinent to determining offsite 

protective measures. (The licensee will identify specific capabilities) 

6. As a minimum, sensor data of the Type A, B, C, D, and E variables specified 

in RG 1.97, and of those meteorological variables specified in RG 1.23, 

Revision 1, AMeteorological Monitoring Programs for Nuclear Power Plants,A

and in NUREG-0654, Appendix 2, shall be available for display in the EOF. 

7. A sufficient number of data display devices shall be provided in the EOF to 

allow all EOF personnel to perform their assigned tasks with unhindered 

access to alphanumeric and/or graphical representations of: plant systems 

variables, in-plant radiological variables, meteorological information, and 

offsite radiological information. 

8. The SPDS shall be displayed in the EOF. 
Issue Date: 10/30/08 9 65001.18 

d. Onsite Monitoring Systems (H.5) 

 The inspector should obtain and review the NRC-approved ITAAC concerning the 

establishment of onsite monitoring systems such that the licensee has the 

capability to initiate emergency measures consistent with the NRC-approved EAL 

scheme. (The licensee will identify specific capabilities) 

 The onsite monitoring equipment shall include, as a minimum: 

1. Geophysical phenomena monitors (e.g., meteorological, hydrological, 

seismic) 

2. Radiological monitors (e.g., process, area, emergency, effluent, portable 

monitors, sampling equipment) 

3. Process monitors (e.g., reactor coolant system temperature/pressure, 

containment temperature/pressure, liquid levels, flow rates, status or lineup 

of equipment components) 

4. Fire and combustion products detectors 

Verify that installed monitoring equipment provides the facility system and 

effluent parameters used as the bases for the licensee=s standard 

emergency classification and EAL scheme, and that the ranges of displays of 

those parameters encompass the values specified in that EAL scheme. 

 e. Data Acquisition From Offsite Monitoring and Analysis Equipment (H.6) 

The inspector should obtain and review the NRC-approved ITAAC concerning the 

establishment of offsite monitoring and analysis equipment such that the licensee 

has the capability to acquire data from, or have emergency access to, offsite 

monitoring and analysis equipment. (The licensee will identify specific capabilities) 

 The offsite monitoring and analysis equipment shall include, as a minimum: 

1. Geophysical phenomena monitors (e.g., meteorological, hydrological, 

seismic) 

2. Radiological monitors including rate meters and sampling devices. 

Dosimetry shall be provided which meets the NRC criteria for the 

Environmental Radiological Monitoring Program 

3. Laboratory facilities for radiological sample analysis 

4. Verify that this equipment is available and functional. 

f. Provision of Offsite Monitoring Equipment (H.7) 
Issue Date: 10/30/08 10 65001.18 

The inspector should obtain and review the NRC-approved ITAAC concerning the 

establishment of offsite monitoring and analysis equipment such that the licensee 

has the capability to provide for offsite monitoring in the vicinity of the nuclear 

facility. (The licensee will identify specific capabilities) 

Verify that the equipment specified in the licensee=s Emergency Plan is available 

and functional. 

g. Provision of Meteorological Instrumentation and Procedures (H.8) 

The inspector should obtain and review the NRC-approved ITAAC concerning the 

provision of meteorological instrumentation and procedures which satisfy the 

criteria in NUREG-0654, Appendix 2, and provisions to obtain representative 

current meteorological information from other sources. (The licensee will identify 

specific capabilities) 

Verify that the applicant=s meteorological instrumentation is available and 

functional, and meets the following criteria: 

1. The licensee shall have a primary and backup meteorological measurement 

system. 

2. The meteorological measurement system shall be capable of making current, 

site-specific estimates of atmospheric effluent transport and diffusion during 

and immediately following an accidental airborne radioactivity release. 

3. The meteorological measurement system shall have the capability of being 

remotely interrogated. 

02.09 Accident Assessment. Review the licensee=s close-out documentation of this 

ITAAC to verify that the acceptance criteria for the methods, systems, and equipment for 

assessing radiological consequences of a radiological emergency, have been met. (I.2, I.3, 

I.4, I.5, I.6, I.7, I.8, I.9, I.10) 

Guidance. The inspector should obtain and review the applicable NRC-approved ITAAC 

pertaining to the methods, systems, and equipment necessary for assessing and 

monitoring radiological consequences of an emergency condition at the nuclear plant. 

a. Verify that the onsite radiation monitoring equipment, instrumentation, and 

resources specified in the COL are available and functional, and have been tested 

to provide the capability for radiological assessment throughout the course of an 

accident. (I.2) 

b. Verify that the established methods and techniques specified in the COL for 

determining the source term of releases of radioactive material within plant 

systems, and the magnitude of radioactive releases based on plant system 

parameters and effluent monitors, are available and functional, and have been 
Issue Date: 10/30/08 11 65001.18 

tested to provide the capability specified in the application. (I.3) 

c. Verify that the established relationship between effluent monitor readings and 

onsite/offsite exposures and contamination for various meteorological conditions 

specified in the COL provides the capability to continuously assess the impact of a 

release of radioactive material to the environment. (I.4) 

d. Verify that the licensee has the capability of acquiring and evaluating 

meteorological information, as specified in the COL, and that this information is 

available at the EOF, TSC, CR, an offsite NRC center, and to the affected State(s). 

(I.5) 

e. Verify that the licensee has the capability, as specified in the COL application, to 

determine the radiological release rate and projected doses if the instrumentation 

used for assessment is off-scale or inoperable. (I.6) 

f. Verify that the licensee has the capability and resources, as specified in the COL, 

for field radiological monitoring within the plume exposure EPZ. (I.7) 

g. Verify that the licensee possesses the methods, equipment, and expertise, as 

specified in the COL, to make rapid assessments of the actual or potential 

magnitude and locations of any radiological hazards through liquid or gaseous 

release pathways. (I.8) 

h. Verify that the licensee has the capability, as specified in the COL, to detect and 

measure radioiodine concentrations in air in the plume exposure EPZ as low as 

10-7

FCi/cc. (I.9) 

 

i. Verify that the licensee has the capability, as specified in the COL, to estimate 

integrated dose from the projected and actual dose rates, and for comparing these 

estimates with the EPA protective action guidelines. (I.10) 

02.10 Protective Response. Review the licensee=s close-out documentation of this ITAAC 

to verify that the acceptance criteria for the development of (1) a range of protective 

actions (PA) for the plume exposure pathway EPZ, and (2) guidelines for the choice of PAs 

during an emergency, including PAs for the ingestion exposure pathway EPZ, have been 

met. (J.1, J.3, J.5, J.10) 

Guidance. The inspector should obtain and review the applicable NRC-approved ITAAC 

pertaining to the range of protective actions for the plume exposure pathway EPZ and the 

guidelines for the choice of PAs. 

a. Verify that the licensee has the capability to warn or advise onsite individuals and 

 individuals who may be in areas controlled by the applicant of an emergency, 

including: (1) employees not having emergency assignments, (2) visitors, (3) 

contractor and construction personnel, and (4) other persons who may be in the 

public access areas on or passing through the site or within the owner-controlled 

area. (J.1) 
Issue Date: 10/30/08 12 65001.18 

b. Verify that the licensee has the capability to radiologically monitor people 

evacuated from the site. (J.3) 

c. Verify that the licensee has the capability to account for all individuals onsite at the 

time of the emergency and ascertain the names of missing individuals within 30 

minutes of the start of any emergency. (J.5) 

d. Verify that the licensee has the capability to implement protective measures to 

notify and protect all segments of the transient and resident populations. The 

applicant shall utilize the methods specified in NUREG-0654, Section II.J.10, or 

acceptable alternative methodology detailed in the COL application. (J.10) 

02.11 Radiological Exposure Control. Review the licensee=s close-out documentation of 

this ITAAC to verify that the acceptance criteria have been met for controlling radiological 

exposures for emergency workers in an emergency. (K.2, K.3, K.5.b, K.6, K.7) 

Guidance. The inspector should obtain and review the applicable NRC-approved ITAAC 

pertaining to the licensee=s capability for controlling radiological exposures for emergency 

workers in an emergency. The capability for controlling radiological exposures shall 

include exposure guidelines consistent with EPA Emergency Worker and Lifesaving 

Activity Protective Action Guides. 

a. Verify that the licensee has established an onsite radiation protection program to 

be implemented during emergencies, including methods to implement exposure 

guidelines. Also, verify that the Emergency Plan identifies individuals by position or 

title, who can authorize emergency workers to receive doses in excess of 10 CFR 

20 limits. (K.2) 

b. Verify that the licensee has the 24-hour-per-day capability to determine radiation 

doses received by emergency personnel in a nuclear accident. Verify that the 

licensee has a sufficient quantity of self-reading and permanent dosimeters, and 

has made provision for their distribution. Determine if the licensee has a system 

for maintaining dose records for emergency workers. (K.3) 

c. Verify that the licensee has the capability for radiological decontamination of 

emergency personnel and their equipment, and relocated onsite personnel. Also, 

verify that there is provision for radioactive waste disposal. (K.5.b, K.7) 

d. Verify that the licensee has the capability to provide onsite contamination control 

measures to include area access control and control of drinking water and food 

supplies. (K.6) 

02.12 Medical and Public Health Support. Review the licensee=s close-out documentation 

of this ITAAC to verify that the acceptance criteria have been met for providing medical 

services for contaminated, injured personnel. (L.1, L.2, L.4) 

Guidance. The inspector should obtain and review the applicable NRC-approved ITAAC 
Issue Date: 10/30/08 13 65001.18 

pertaining to the licensee=s capability for providing medical services for contaminated, 

injured personnel. 

a. Verify that the licensee has made arrangements for local and backup hospital and 

medical services having the capability for evaluation of radiation exposure and 

uptake. Verify that the persons providing these services are adequately prepared 

to handle contaminated individuals. (L.1) 

b. Verify that the licensee has made provision for onsite first aid capability. (L.2) 

c. Verify that the licensee has made provision for transporting victims of radiological 

accidents, including contaminated injured individuals, from the site to offsite 

medical support facilities. (L.4) 

02.13 Recovery and Re-entry Planning and Post-Accident Operations. There are no 

generic ITAAC specified for this planning standard. Review for acceptability will be on a 

case-by-case basis if included in the COL. 

02.14 Exercises and Drills. Review the licensee=s NRC-approved ITAAC concerning the 

performance of a full-participation exercise within two years of the scheduled date for initial 

loading of fuel and operation under 10 CFR 52.103. Determine the exercise date and plan 

to observe the exercise for evaluation. (N.1) 

Guidance. The inspector should obtain and review the applicable NRC-approved ITAAC 

pertaining to the licensee=s conduct of a full-participation exercise within two years of the 

scheduled date for initial loading of fuel and operation, and shall include participation by 

each State and local government within the plume exposure pathway EPZ. If the first fullparticipation exercise is conducted more than one year before the scheduled date for initial 

loading of fuel and operation, the licensee shall conduct an exercise which tests the onsite 

Emergency Plan within one year before the scheduled date for initial loading of fuel and 

operation, which need not have State or local government participation. The NRC shall 

observe and evaluate both of these exercises, if applicable. See Inspection Procedure 

Attachment 71114.01, AExercise Evaluation,@ for further guidance on evaluating exercises. 

The exercise(s) is a test of major portions of the licensee=s emergency response 

capabilities, and is evaluated by NRC to determine if there is reasonable assurance that 

adequate protective measures can be taken in the event of a radiological emergency. As 

such, the inspectors shall evaluate the licensee=s response, including whether onsite 

emergency response personnel were mobilized in sufficient numbers to fill emergency 

response positions, and that they successfully performed their assigned responsibilities. 

The inspector should review other NRC-approved ITAAC to determine if there are other 

ITAAC acceptance criteria which may be demonstrated during the exercise. 

If there is already an operating reactor at the site, the licensee shall conduct either a full or 

partial participation exercise for each subsequent reactor constructed on the site. This 

exercise may be incorporated into the site exercise requirements described in Appendix E 

to 10 CFR 50, Sections IV.F.2.b and c, which requires each licensee to conduct an 

exercise of its onsite Emergency Plan every two years. 
Issue Date: 10/30/08 14 65001.18 

Verify that the licensee has scheduled a full-participation exercise within two years of initial 

fuel loading. Subsequently, the licensee shall schedule an exercise which tests the onsite 

emergency plans within one year of initial fuel loading if the full-participation exercise was 

conducted more than one year prior to initial fuel loading. 

Review the onsite exercise objectives for the full-participation exercise and, if applicable, 

the exercise performed to test onsite emergency plans. Verify by exercise observation and 

personnel interviews that all onsite exercise objectives have been met. Any unmet 

exercise objectives should be documented in the corrective action program. 

Verify by exercise observation and/or personnel interviews that ERO personnel were 

mobilized in sufficient numbers to fill all emergency response positions within the time 

limitations specified in the NRC-approved Emergency Plan. Also, verify that emergency 

responders successfully performed their assigned responsibilities. 

Evaluate if EP weakness(es) identified by the inspectors were appropriately identified by 

the licensee=s formal critique and entered into the corrective action program. All 

weaknesses must be identified and corrected. Any disagreement with the licensee=s staff 

concerning EP weaknesses should be reported to NRC management for resolution. 

Verify by conferring with the appropriate FEMA staff personnel that all offsite objectives for 

the full-participation exercise have been met and that there are no uncorrected offsite 

exercise deficiencies. If there are outstanding offsite deficiencies, verify that the licensee 

either limited operation to 5% of rated thermal power, or a license condition exists which 

requires that those deficiencies be corrected prior to operation above 5% of rated thermal 

power. 

02.15 Radiological Emergency Response Training. Review the licensee=s close-out 

documentation of this ITAAC to verify that the acceptance criteria have been met for the 

provision of training to those personnel who may be called upon to provide assistance in 

the event of an emergency. (O.2, O.4) 

Guidance. .The inspector should obtain and review the applicable NRC-approved ITAAC 

pertaining to the licensee=s training program for instructing and qualifying personnel who 

will implement radiological emergency response plans. 

Verify by documentation review and/or personnel interviews that the licensee has 

established a training program per its COL and is providing specialized initial training to 

response personnel which includes classroom training and practical drills, in which 

responders demonstrate their ability to perform their assigned emergency functions. 

02.16 Responsibility for the Planning Effort: Development, Periodic Review and 

Distribution of Emergency Plans. Review the licensee=s close-out documentation of this 

ITAAC to verify that the acceptance criteria have been met for the distribution of 

emergency response plans and approved changes to those plans. (P.5) 

Guidance: The inspector should obtain and review the applicable NRC-approved ITAAC 
Issue Date: 10/30/08 15 65001.18 

pertaining to the distribution of emergency response plans and approved changes to those 

plans, to all organizations and appropriate individuals with responsibility for implementation 

of the plans. 

Verify by distribution list review and direct observation that the licensee has forwarded 

emergency response plans, and approved plan changes, to all organizations and 

appropriate individuals with responsibility for plan implementation. 

02.17 Implementing Procedures. Review the licensee=s close-out documentation of this 

ITAAC to verify that the acceptance criteria have been met for the submission of detailed 

emergency plan implementing procedures (EPIPs). (10 CFR 50, Appendix E, Section V) 

Guidance. The inspector should obtain and review the applicable NRC-approved ITAAC 

pertaining to the submission of detailed EPIPs no less than 180 days prior to initial loading 

of fuel in the reactor vessel. 

Verify by submittal letter review and direct observation of procedures that the licensee has 

submitted detailed EPIPs within the required time. 

02.18 Problem Identification and Resolution: The inspector should confirm that problems 

identified during the inspection are entered into the licensee=s corrective action program in 

accordance with program requirements. The inspector may review licensee actions to 

address similar or related problems that were previously identified, in order to check the 

extent of condition and confirm the effectiveness of the licensee=s corrective measures. 

Guidance. This inspection is to ensure that problems are entered into the applicable 

process to assure that corrective actions appropriate to the circumstances are developed 

and prioritized. 

65001.18-03 RESOURCE ESTIMATE 

The average resource expenditure for this inspection procedure is estimated to be 140 

direct inspection hours per Unit. 

65001.18-04 REFERENCES 

NUREG-0654/FEMA-REP-1, Revision 1, ACriteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power 

Plants,@ November, 1980. 

Regulatory Guide 1.101, Revision 4, AEmergency Planning and Preparedness for Nuclear 

Power Reactors,@ October, 1981. 

NUREG-0396, EPA 520/1-78-016, APlanning Basis for the Development of State and Local 

Government Radiological Emergency Response Plans in Support of Light Water Nuclear 

Power Plants,@ December, 1978. 
Issue Date: 10/30/08 16 65001.18 

NUREG-0696, AFunctional Criteria for Emergency Response Facilities,@ February, 1981. 

NUREG-0737 and Supplement 1, “Clarification of TMI Action Plan Requirements,” 

November, 1980. 

NUREG-0800, Revision 3, AStandard Review Plan for the Review of Safety Analyses for 

Nuclear Power Plants,@ March, 2007. 

Regulatory Guide 1.206, Revision 0, ACombined License Applications for Nuclear Power 

Plants (LWR Edition),@ April, 2007. 

END 
Issue Date: 10/30/08 Att1-1 

Attachment 1 

Revision History For 65001.18 

Commitment Tracking Number 

Issue Date Description of Change Training 

Needed 

Training Completion Date 

CoAc

N/A 10/30/08 

CN 08-030 

Initial issuance to support ITAAC related inspections under 10CFR part 52. Researched commitments for 4 years and found none. 

None N/A ML