POLICY ISSUE 

INFORMATION 

October 12, 2012 SECY-12-0139

FOR: The Commissioners 

FROM: James T. Wiggins, Director 

Office of Nuclear Security and Incident Response 

SUBJECT: ANNUAL UPDATE ON THE STATUS OF EMERGENCY 

PREPAREDNESS ACTIVITIES 

PURPOSE: 

To update the Commission on the U.S. Nuclear Regulatory Commission’s (NRC’s) emergency 

preparedness (EP) program activities. This paper does not address any new commitments or 

resource implications. 

BACKGROUND: 

In the Staff Requirements Memorandum (SRM) responding to SECY-05-0010, “Recommended 

Enhancements of Emergency Preparedness and Response at Nuclear Power Plants in the 

Post-9/11 Environment,” the Commission directed the staff to provide a semiannual report on 

important EP activities (see Agencywide Documents Access and Management System 

[ADAMS] Accession No. ML051250012). In SECY-07-0182, “Semi-Annual Update on the 

Status of Emergency Preparedness Activities,” dated October 19, 2007, the staff requested the 

Commission approve a change in the frequency of this report from semiannual to annual. In the 

SRM to SECY-07-0182, dated December 21, 2007, the Commission approved the request and 

provided the following direction (ADAMS Accession No. ML072500323): 

CONTACT: Patti Swain, NSIR/DPR 

 (301) 415-5405
The Commissioners 2 

The annual paper should become more of a self-assessment and communication 

tool, perhaps summarizing accomplishments and providing a status on 

improvement initiatives within our EP programs. Such an assessment should be 

coordinated with and not overlap the ROP self-assessment of the EP 

cornerstone, and should be designed to aid the staff in effecting continuous and 

coordinated improvements to the overall emergency program, as well as to 

inform the Commission and public of progress. 

SECY-11-0146, “Annual Update on the Status of Emergency Preparedness Activities” 

provides the staff’s fiscal year (FY) 2011 status of the EP program (ADAMS 

Accession No. ML112101486). 

In FY2012, the staff coordinated its assessment activities with those involving the EP 

cornerstone as part of the ROP annual self-assessment documented in SECY-12-0055, 

“Reactor Oversight Process Self-Assessment for Calendar Year 2011” (ADAMS 

Accession No. ML12053A201). The staff’s efforts to improve and enhance the EP 

program focused on the effectiveness of EP inspection procedures and the amended EP 

regulations. 

DISCUSSION: 

The NRC’s EP program provides reasonable assurance that licensees can and will take 

adequate protective measures in the event of a radiological emergency at a nuclear power plant 

to reduce possible radiation doses to members of the public, and to ensure effective emergency 

response by the agency. In summary, significant EP program accomplishments include 

publication of the new EP rule and associated guidance, development of an approach to 

address Fukushima Near Term Task Force recommendations specific to the EP functional area, 

and the introduction of a scalable approach for the emergency planning zone for small modular 

reactors (SMRs). The following paragraphs summarize key activities that led to these 

accomplishments as well as others, that collectively demonstrate the effectiveness of the EP 

program. 

Status of Key Activities 

EP Rulemaking and Guidance Development 

The NRC achieved the first major revision to the regulatory framework for EP by publishing the 

EP rule in the Federal Register on November 23, 2011 (76 FR 72560), which became effective 

December 23, 2011. In 2011, the NRC also published the following four guidance documents in 

support of the EP rule: 

(1) NUREG/CR-7002, “Criteria for Development of Evacuation Time Estimate Studies” 

(ADAMS Accession No. ML11329A053) 

(2) Regulatory Guide 1.219, “Guidance on Making Changes to Emergency Plans for 

Nuclear Power Reactors” (ADAMS Accession No. ML102510626) 

(3) NUREG-0654/FEMA-REP-1, Rev. 1, Supplement 3 “Guidance for Protective Action 

Strategies” (ADAMS Accession No. ML113010596) 

(4) NSIR/DPR-ISG-01, “Interim Staff Guidance – Emergency Planning for Nuclear Power 

Plants” (ADAMS Accession No. ML113010523) 
The Commissioners 3 

In response to lessons learned and in connection with the new EP rule, the staff reviewed and 

revised eight EP inspection procedures as well as the basis for the significance determination 

process contained in Inspection Manual Chapter 0609, Appendix B, “Emergency Preparedness 

Significance Determination Process.” The NRC and the Federal Emergency Management 

Agency (FEMA) jointly held five public meetings related to the EP rule and associated guidance. 

The NRC staff also participated in several FEMA workshops held with State and local agencies 

to address site-specific implementation questions. 

Revision of NUREG-0654/FEMA-REP-1, Rev. 1, “Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power 

Plants” 

In SECY-06-0200, “Results of the Review of Emergency Preparedness Regulations and 

Guidance,” dated September 20, 2006, the staff identified high-, medium-, and low-priority EP 

rule change initiatives (ADAMS Accession No. ML061910707). The EP rule addressed the 12 

high-priority initiatives described in the SECY paper, and the staff plans to further explore the 

remaining medium- and low-priority EP rulemaking initiatives through the revision of NUREG0654/FEMA-REP-1, Rev.1. A joint FEMA-NRC multiyear initiative to author the revision began 

in FY 2012 and will continue through the end of calendar year (CY) 2016. The agencies held 

two public meetings (one in Kansas City, Missouri, and one at NRC headquarters in 

Rockville, Maryland) to obtain stakeholder input on the scope of topics for the revision. 

Risk-Informed, Performance-Based EP 

The NRC staff continued to develop a technical basis for a more risk-informed and 

performance-based regulatory approach for nuclear power plant EP programs. The focus areas 

for this initiative are exercise scenarios, emergency action levels (EALs), and offsite programs. 

The staff is attempting to quantify the benefit of EP programs, to risk-inform EALs, and to apply 

a performance-based approach to offsite EP programs. However, because of higher priority 

work associated with the response to the Near-Term Task Force (NTTF) recommendations 

concerning the Fukushima event, the agency has deferred the completion of this work to 2013. 

In CY 2013, the staff plans to submit a SECY paper to the Commission which will discuss a 

proposed regulatory structure, options, and estimated resources for the performance-based 

rulemaking. 

Emergency Planning and Preparedness Framework for SMRs 

On October 28, 2011, Office of Nuclear Security and Incidence Response (NSIR) staff, in 

coordination with staff from the Office of New Reactors (NRO), issued SECY-11-0152, 

“Development of an Emergency Planning and Preparedness Framework for Small Modular 

Reactors,” to inform the Commission of the staff’s activities in this area (ADAMS Accession No. 

ML112570439). To promote further discussion with stakeholders, the staff indicated support for 

a “scalable approach” to the size of the emergency planning zone (EPZ). Under such an 

approach, the size of the EPZ would be commensurate with offsite dose considerations 

associated with the size and source term of the SMR. 
The Commissioners 4 

The staff engaged stakeholders on their views with respect to EP for SMRs at the Federal 

Radiological Preparedness Coordinating Committee meeting, the winter American Nuclear 

Society meeting, and the National Radiological Emergency Preparedness conference, and will 

continue stakeholder outreach on this topic. In recent interactions, stakeholders have 

expressed an interest for the staff to develop a technology-neutral, dose-based EP framework 

that takes into account the SMR modular design and its collocation with industrial processes to 

determine the appropriate size of the EPZ. The specific areas of focus are staff positions 

regarding new policies or revised regulations for the EPZ size, protective action guidelines, and 

guidance for a graded approach to specific 10 CFR Part 50 EP requirements. The staff 

informed the stakeholders that the NRC’s existing regulatory structure provides the framework 

for the development of an emergency plan for an SMR. The staff informed industry that future 

EP work on SMRs will consider the various designs, modularity, and collocation, as well as the 

size of the EPZ, once an application has been received. The results of the staff’s review of an 

SMR application could serve as the basis for regulatory revisions. The staff anticipates that 

applicants will file SMR design certification applications in the third and fourth quarters of 2013, 

and that the nuclear industry could separately submit EP position, topical, and technical papers 

for NRC review. The staff will provide a status update on these activities in the summer of 2013 

as indicated in WITS 201100071, “Office of New Reactors Response to Staff Requirements 

Memorandum – Briefing on Small Modular Reactors (M110329).” 

Other Activities 

• Fukushima Support 

The staff has primarily focused its emergency preparedness activities regarding the Fukushima 

Dai-ichi response on the Near Term Task Force (NTTF) Recommendation 9.3, concerning 

communication and staffing. The staff issued 50.54(f) letters to all licensees to better 

understand the existing capabilities and plans for staffing during an event involving multiple 

reactor units and regarding the ability of licensees to maintain communications during a 

prolonged station blackout. The staff will evaluate the responses to these letters in determining 

the need for further regulatory action. The staff is also focusing its efforts on the Tier 2 NTTF 

EP recommendations of multiunit dose assessment, equipment and facilities, and training and 

exercises. The staff provided the program plans for the remaining NTTF Tier 3 EP 

recommendations in SECY-12-0095, “Tier 3 Program Plans and 6-Month Status Update in 

Response to Lessons Learned from Japan’s March 11, 2011, Great Tohoku Earthquake and 

Subsequent Tsunami,” dated July 13, 2012 (ADAMS Accession No. ML12208A208). 

• Freedom Of Information Act

To facilitate the agency response to a Freedom of Information Act (FOIA) request related to the 

emergency event at the Fukushima Dai-ichi sites, a task force, comprised of subject matter 

experts, was established. To date the staff has reviewed approximately 200,000 out of an 

estimated 1,000,000 pages of information, to preclude the inadvertent release of sensitive 

information. The staff has released approximately 100,000 pages of information to the public. 

NSIR continues to review this information for either public release or for referral to other Federal 

agencies, industry, or private entities. The staff is exploring various options to streamline the 

review process while ensuring that no sensitive information will be released. 
The Commissioners 5 

• SOARCA

The staff intends to use insights from the SOARCA project to refine and enhance the EP 

program to better evaluate licensees’ plans for emergency response actions in the event of a 

severe accident. This project modeled accidents with the latest plant-specific information. The 

staff is using SOARCA techniques to model evacuations and to provide risk-informed insights 

on the contributions of the EP program with respect to avoided population doses. 

EP Self-Assessment 

The staff conducted a self assessment (enclosed) to evaluate the NRC’s EP program in five 

areas which support the agency’s safety goal in its Strategic Plan: (1) managing reviews of 

licensing requests to ensure safety, (2) sharing information in an accurate and timely manner, 

(3) engaging external stakeholders, (4) effectively implementing EP, and (5) addressing the riskinformed performance-based EP concept. The results of the self assessment indicate that the 

staff: (1) successfully maintained an effective EP program for issuing and updating licensing 

actions, (2) the staffs outreach and communications activities provided accurate and timely 

information, (3) the staff fostered and maintained effective partnerships with key stakeholders 

which led to effective engagement of external stakeholders, (4), the issuance of the EP rule led 

to effective implementation of EP requirements, and (5) the staffs planned activities for the risk 

informed performance based concept should result in effective execution to risk inform EP. 

CONCLUSION: 

The staff continues to ensure that adequate protective measures can and will be implemented 

by licensees through the effective review and inspection of licensees EP programs. In addition, 

the staff has an effective outreach program in the area of EP. The staff continues its 

engagement on issues related to EP for small modular reactors and is working to establish the 

framework for the implementation of the NTTF EP Recommendations. 

COORDINATION: 

The Office of the General Counsel reviewed this package and has no legal objection. NSIR 

coordinated the paper with the Office of the Chief Financial Officer for resource implications. 

 /Marc Dapas RA for/ 

James T. Wiggins, Director 

Office of Nuclear Security and Incident Response 

Enclosure: 

Self-Assessment of the 

 Emergency Preparedness Program
The Commissioners 5 

• SOARCA

The staff intends to use insights from the SOARCA project to refine and enhance the EP 

program to better evaluate licensees’ plans for emergency response actions in the event of a 

severe accident. This project modeled accidents with the latest plant-specific information. The 

staff is using SOARCA techniques to model evacuations and to provide risk-informed insights 

on the contributions of the EP program with respect to avoided population doses. 

EP Self-Assessment 

The staff conducted a self assessment (enclosed) to evaluate the NRC’s EP program in five 

areas which support the agency’s safety goal in its Strategic Plan: (1) managing reviews of 

licensing requests to ensure safety, (2) sharing information in an accurate and timely manner, 

(3) engaging external stakeholders, (4) effectively implementing EP, and (5) addressing the riskinformed performance-based EP concept. The results of the self assessment indicate that the 

staff: (1) successfully maintained an effective EP program for issuing and updating licensing 

actions, (2) the staffs outreach and communications activities provided accurate and timely 

information, (3) the staff fostered and maintained effective partnerships with key stakeholders 

which led to effective engagement of external stakeholders, (4), the issuance of the EP rule led 

to effective implementation of EP requirements, and (5) the staffs planned activities for the risk 

informed performance based concept should result in effective execution to risk inform EP. 

CONCLUSION: 

The staff continues to ensure that adequate protective measures can and will be implemented 

by licensees through the effective review and inspection of licensees EP programs. In addition, 

the staff has an effective outreach program in the area of EP. The staff continues its 

engagement on issues related to EP for small modular reactors and is working to establish the 

framework for the implementation of the NTTF EP Recommendations. 

COORDINATION: 

The Office of the General Counsel reviewed this package and has no legal objection. NSIR 

coordinated the paper with the Office of the Chief Financial Officer for resource implications. 

 

 /Marc Dapas RA for/

James T. Wiggins, Director 

Office of Nuclear Security and Incident Response 

Enclosure: 

Self-Assessment of the 

 Emergency Preparedness Program 

ADAMS Accession No.: ML12188A587 EDATS: SECY-2010-0541 (*concurrence received via email) WITS: 200500137 

OFFICE NSIR/DPR Tech Editor 

via e-mail 

NSIR/DPR:BC NSIR/DPR:DDEP NSIR/DPR:D NSIR/PMDA:D 

NAME PSwain CHsu KWilliams MThaggard RLewis CRheaume 

DATE 7/9/2012 7/18/2012 7/13/2012 7/27/2012 8/6/2012 8/9/2012 

OFFICE CFO OE NRR NRO RES RI 

NAME JDyer* 

(KKline for) 

RZimmerman* ELeeds* 

(SBahadur for) 

GTracy* 

(MMayfield for) 

BSheron* 

(BRini for) 

CMiller* 

DATE 8/17/12 8/13/12 8/17/12 8/20/12 8/17/12 8/10/2012 

OFFICE RII RIII RIV OGC NSIR 

NAME TReis* SReynolds* TBlount* HBenowitz JWiggins 

(MDapas for) 

DATE 8/10/12 8/9/12 8/9/12 9/28/12 10/12/12 

OFFICIAL RECORD COPY
Enclosure 

Self-Assessment of the Emergency Preparedness Program 

The self-assessment evaluated the production and efficiency of the U.S. Nuclear Regulatory 

Commission’s (NRC’s) emergency preparedness (EP) program in the following areas: 

(1) managing reviews of licensing requests, (2) sharing information in an accurate and timely 

way, (3) engaging external stakeholders, (4) implementing EP, and (5) addressing the riskinformed performance-based EP concept. The criteria used to assess the program correlate 

directly with the agency’s Strategic Plan. 

Managing Reviews of Licensing Activities 

The staff demonstrated the ability to maintain an effective EP licensing program by completing 

all licensing actions in accordance with agreed-upon schedules. Since the last annual report to 

the Commission, the agency has processed 21 licensing actions from power reactor and fuel 

cycle licensees. These documents were of high quality (accurate, thorough, and well 

organized) such that the Office of New Reactors (NRO) and the Office of Nuclear Reactor 

Regulation (NRR) could meet their goals and objectives. The Office of Nuclear Security and 

Incident Response staff has continued to engage NRR staff to promptly discuss and resolve 

issues related to the quality and timeliness on proposed requests for additional information and 

safety evaluation inputs. 

In the area of new reactor licensing, the staff continued to support the review of two early site 

permit applications, 13 COL applications, and three design certification reviews. Staff 

completed all tasks within expected schedule due dates. The agency adjusted some review 

schedules to accommodate the staff’s support of the ongoing Fukushima-related Freedom of 

Information Act activities; however, the staff will complete work within NRO’s project milestones. 

In addition, the EP rule has the potential to impact four new reactor applications. If these 

applicants do not receive a COL by December 31, 2013, they would have to amend their 

applications, which would extend their schedules by a minimum of 6 months. Although the EP 

rule anticipated this situation, the staff has continually engaged stakeholders to address this 

challenge. The staff also provided support in the development, issuance, and testimony 

regarding the review and subsequent issuance of new reactor licenses for Vogtle and Summer. 

The staff continued to use the Federal Emergency Management Agency (FEMA)/NRC EP 

Steering Committee to facilitate interagency dialogue and to coordinate joint activities related to 

EP licensing actions and the EP rule implementation; to evaluate performance-based offsite EP 

regulations; and to discuss comments on EP-related NRC-sponsored studies and proposed 

guidance changes. 

Staff has successfully maintained a highly effective EP program for issuing and updating 

licensing actions. 

Accurate and Timely Information Sharing 

The staff used both conventional and social media to provide accurate and timely information 

regarding the NRC EP regulatory program. The staff continued to publish the quarterly EP 

newsletter to communicate the status of the EP rule and proposed guidance changes and to 

note opportunities for public participation. The staff also used two public Web sites 
2 

(www.regulations.gov and www.nrc.gov/about-nrc/emerg-preparedness.html) to disseminate 

information about the EP rule and associated guidance, to perform outreach, and to provide 

interested stakeholders an avenue to ask questions. Further, a dedicated EP resource mailbox 

(emergencypreparedness.resource@nrc.gov) received numerous emails providing suggestions 

related to the Fukushima event and inquiries about public meetings, among other topics. The 

staff also embraced the agency’s use of social media by writing NRC blog posts which 

announced the EP rule, announced associated public meetings, and discussed hurricane 

preparedness. The NRC staff also used Twitter to provide updates on EP activities. 

Additionally, the staff supported the development of both the Fukushima video posted to 

YouTube and the 9/11 commemoration video. 

At the biennial 2012 National Evacuation Conference in New Orleans, LA, the staff discussed 

the incorporation of evacuation time estimates into evacuation strategies, evacuation time 

estimates study development and updates, and NRC insights gained from the Fukushima 

Daiichi emergency. Conference attendees indicated that they would be able to apply 

information from NRC studies and guidance to other evacuation studies. 

Staff public outreach and communication activities have successfully provided accurate and 

timely information to the public regarding the EP program. This has resulted in an open and 

transparent program. 

Engaging External Stakeholders 

The staff continued to engage external stakeholders using multiple methods: participation in 

national meetings and forums, providing training, enhancing Government-to-Government 

discussions, and using Web-based technologies to facilitate communication. In coordination 

with FEMA, the NRC staff participated in five forums which occurred over several days at five 

geographic locations. These forums updated licensees and the emergency management 

community on the status of the EP rule, its implementing guidance, and various EP-related 

initiatives. The staff also participated in eight national meetings, including the National 

Emergency Management Association (NEMA) Mid-Year and Annual Conferences, the National 

Radiological Emergency Preparedness (NREP) Conference, the Nuclear Energy Institute (NEI) 

EP Forum, the Health Physics Society Mid-Year and Annual Meetings, and the American 

Nuclear Society Winter Meeting. An open forum following the NREP Conference provided an 

opportunity for further outreach to State stakeholders. NRC personnel also attended and 

staffed an information booth at the International Association of Emergency Managers (IAEM) 

Annual Conference to engage local emergency management officials. 

The staff provided training at both the Institute of Nuclear Power Operations New EP Manager 

Seminar, and at the Harvard School of Public Health EP course, and received feedback that this 

type of grass roots stakeholder involvement was effective in engaging external stakeholders and 

providing for more in-depth conversations with emergency management professionals. 

The staff continued to work with FEMA and the NRC regions on a revision to Manual Chapter 

1601, “Communication and Coordination Protocol for Determining the Status of the Offsite 

Emergency Preparedness Following a Natural Disaster, Malevolent Act, or Extended Plant 
3 

Shutdown,” related to communication and coordination with FEMA based on post-Hurricane 

Irene lessons learned. The staff also provided input on the revision to the FEMA’s Disaster 

Initiated Review Process. 

To further enhance Government-to-Government relations, the staff, in coordination with FEMA, 

maintained an effective working relationship with the NEMA REP subcommittee to facilitate 

open dialogue on key EP initiatives. Based on the success with NEMA, the staff is also working 

with FEMA to establish a comparable IAEM REP subcommittee. The staff’s goal is to leverage 

the expertise of these organizations and to engage their respective memberships. To that end, 

the staff hosted the NEMA Chairman and key REP subcommittee members on a tour of the 

NRC Operations Center to discuss the agency’s incident response activities. 

Staff activities have fostered and maintained effective partnerships with key stakeholders 

involved in NRC activities which have lead to effective engagement of external stakeholders. 

Effective Implementation of EP 

The staff completed significant rulemaking activities with the publication of the EP rule and joint 

publication of NRC and FEMA guidance documents. In addition, the staff endorsed NEI 10-05 

(Revision 0), “Assessment of On-Shift Emergency Response Organization Staffing and 

Capabilities” to implement the staffing analysis requirement of the EP rule and Appendix A, 

“Recommended Drill and Exercise Objectives” of NEI 06-04 (Revision 2), “Conduct of Hostile 

Action-Based Emergency Response Drill.” 

The NRC and FEMA jointly held a series of public meetings (forums) related to the 

implementation of the EP rule. The staff discussed the basis for the rule and subsequent 

implementation expectations as well as challenges to ensuring that licensees would develop 

effective strategies. Stakeholders commented that this early engagement served to ensure 

consistent implementation, inspection, and predictability of NRC regulations. In addition to 

maximizing transparency and encouraging external stakeholder participation, EP staff also 

followed open Government principles in communications within the agency. NSIR staff provided 

an overview of changes to the EP rule and EP inspection program to NRC staff from each 

region during the December 2011 annual counterpart meeting. Finally, from February through 

April 2012, the NRC EP staff participated in FEMA workshops held with State and local 

agencies to address site-specific implementation questions. 

Staff activities which included completing a significant rulemaking and associated guidance, 

have resulted in the effective implementation of EP requirements. 

Risk-Informed, Performance based EP 

The staff intends to use state-of-the-art methods (such as the State-of-the-Art Reactor 

Consequence Analyses project) to risk inform the regulatory oversight of EP, to risk inform 

EALs, and to risk inform the performance-based offsite responsive evaluation. 

Staff planned activities should result in the effective execution of strategies to risk inform EP.