U.S. NUCLEAR REGULATORY COMMISSION July 2016

OFFICE OF NUCLEAR REGULATORY RESEARCH Revision 1

 REGULATORY GUIDE Technical Lead 

Stephen F. LaVie 

Written suggestions regarding this guide or development of new guides may be submitted through the NRC’s public Web site under the RGs 

document collection of the NRC Library at http://www.nrc.gov/reading-rm/doc-collections/reg-guides/contactus.html. 

 

Electronic copies of this RG, previous versions of this guide, and other recently issued guides are available through the NRC’s public Web site 

under the Regulatory Guides document collection of the NRC Library at http://www.nrc.gov/reading-rm/doc-collections/. The RG is also available 

through the NRC’s Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under 

ADAMS Accession No. ML16061A104. The regulatory analysis may be found in ADAMS under Accession No. ML15054A368 and the staff 

responses to the public comments on DG-1324 may be found under ADAMS Accession No. ML16061A119. 

REGULATORY GUIDE 1.219

(Draft was issued as DG-1324, dated December 2015) 

GUIDANCE ON MAKING CHANGES TO EMERGENCY PLANS 

FOR NUCLEAR POWER REACTORS 

A. INTRODUCTION

Purpose 

This regulatory guide (RG) describes methods that the staff of the U.S. Nuclear Regulatory 

Commission (NRC) considers acceptable for use by nuclear power reactor licensees to change their 

emergency preparedness plans. 

Applicability 

This RG applies to all holders of operating licenses for nuclear power reactors under the 

provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, “Domestic Licensing of 

Production and Utilization Facilities” (Ref. 1) and all holders of combined licenses under 10 CFR Part 52, 

“Licenses, Certifications, and Approvals for Nuclear Power Reactors” (Ref. 2). 

Applicable Regulations 

• 10 CFR 50.54(q), discusses requirements applicable to emergency plans and changes thereto. 

• 10 CFR 50.82, “Termination of Licenses,” discusses requirements applicable to planning the 

termination of facility licenses. 

• 10 CFR 52.110 titled, “Termination of Licenses,” discusses requirements applicable to planning 

the termination of a licensed facility. 

• 44 CFR 350.14, “Amendments to State Plans” contains Federal Emergency Management Agency 

(FEMA) regulations on changes to the alert notification systems (ANS) (Ref. 3). 

Purpose of Regulatory Guides 

The NRC issues RGs to describe to the public methods that the staff considers acceptable for use 

in implementing specific parts of the agency’s regulations, to explain techniques that the staff uses in 

evaluating specific problems or postulated accidents, and to provide guidance to applicants. Regulatory 
Revision 1 to RG-1.219, Page 2 

guides are not substitutes for regulations and compliance with them is not required. Methods and 

solutions that differ from those set forth in RGs will be deemed acceptable if they provide a basis for the 

findings required for the issuance or continuance of a permit or license by the Commission. 

Paperwork Reduction Act 

This RG may contain or reference information collection requests covered by 10 CFR Part 50 and 

10 CFR Part 52 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); control 

numbers 3150-0011 and 3150-0151. 

Public Protection Notification 

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for 

information or an information collection requirement unless the requesting document displays a currently 

valid OMB control number. 
Revision 1 to RG-1.219, Page 3 

TABLE OF CONTENTS

Page 

A. INTRODUCTION ................................................................................................................................ ..1 

B. DISCUSSION ........................................................................................................................................ 5 

C. STAFF REGULATORY GUIDANCE .................................................................................................. 7 

 1. General Guidance ............................................................................................................... 7 

 1.1 Relationship between 10 CFR 50.54(q) and the NRC’s Reasonable Assurance 

Finding ................................................................................................................... 8 

 1.2 Role of Conservatism in 10 CFR 50.54(q) Change Evaluations ........................... 8 

 1.3 Role of Probabilistic Risk Assessment Insights in 10 CFR 50.54(q) Change 

Evaluations ............................................................................................................ 9 

 1.4 Timeliness as an Evaluation Consideration ........................................................... 9 

 1.5 Role of the NRC’s Review of Emergency Action Level and Emergency Plan 

Changes Submitted under 10 CFR 50.54(q)(5) ..................................................... 9 

 1.6 Role of the Facility Licensing Basis .................................................................... 10 

 1.7 Role of Emergency Preparedness Cornerstone Performance Indicators.............. 11 

 1.8 Role of Margin in the 10 CFR 50.54(q) Change Process........................... 12 

 1.9 Emergency Plan Changes at Decommissioning Facilities ................................... 12 

 2. Emergency Plan Changes for Which a Prior NRC Conference Is Recommended ........... 13 

 3. Emergency Plan Change Evaluation Terminology ........................................................... 14 

 3.1 Planning Standard ................................................................................................ 14 

 3.2 Emergency Planning Function ............................................................................. 14 

 3.3 Program Element ................................................................................................. 15 

 3.4 Regulatory Requirement ...................................................................................... 16 

 3.5 Emergency Plan ................................................................................................... 16 

 3.6 Change ................................................................................................................. 17 

 3.7 Reduction in Effectiveness .................................................................................. 18 

 4. Emergency Planning Functions ........................................................................................ 18 

 4.1 10 CFR 50.47(b)(1)—Assignment of Responsibility/Organizational Control .... 19 

 4.2 10 CFR 50.47(b)(2)—Onsite Emergency Organization ...................................... 19 

 4.3 10 CFR 50.47(b)(3)—Emergency Response Support and Resources ................. 21 

 4.4 10 CFR 50.47(b)(4)—Emergency Classification System .................................... 22 

 4.5 10 CFR 50.47(b)(5)—Emergency Notifications .................................................. 24 

 4.6 10 CFR 50.47(b)(6)—Emergency Communications ........................................... 25 

 4.7 10 CFR 50.47(b)(7)—Emergency Public Information ........................................ 26 

 4.8 10 CFR 50.47(b)(8)—Emergency Facilities and Equipment ............................... 27 

 4.9 10 CFR 50.47(b)(9)—Emergency Assessment Capability .................................. 28 

 4.10 10 CFR 50.47(b)(10)—Emergency Protective Actions ....................................... 29 

 4.11 10 CFR 50.47(b)(11)—Emergency Radiological Exposure Control ................... 31 

 4.12 10 CFR 50.47(b)(12)—Emergency Medical Support .......................................... 32 

 4.13 10 CFR 50.47(b)(13)—Recovery and Reentry Planning ..................................... 32 

 4.14 10 CFR 50.47(b)(14)—Drill and Exercise Program ............................................ 33 

 4.15 10 CFR 50.47(b)(15)—Emergency Responder Training ..................................... 34 

 4.16 10 CFR 50.47(b)(16)—Emergency Plan Maintenance ........................................ 35 

 5. Review Process ................................................................................................................. 36 
Revision 1 to RG-1.219, Page 4 

 5.1 Screening Changes ............................................................................................... 36 

 5.2 Evaluation Process ............................................................................................... 37 

 5.3 Approval for Changes That Reduce Effectiveness .............................................. 39 

 5.4 Documentation of Changes .................................................................................. 39 

D. IMPLEMENTATION .......................................................................................................................... 40 

REFERENCES ........................................................................................................................................... 42 

APPENDIX A: 10 CFR 50.54(q) PROCESS ........................................................................................... A-1 
RG-1.219, Rev. 1, Page 5 

B. DISCUSSION

Reason for Revision 

This revision of the guide (Revision 1) clarifies how the staff regulatory guidance applies to 

emergency plan changes at facilities that have certified permanent cessation of operation under 

10 CFR 50.82 or 10 CFR 52.110, as applicable. The NRC identified the need for this clarification as a 

result of the inappropriate application of the 10 CFR 50.54(q) change process at nuclear power reactor 

sites that had permanently ceased operations in 2013. In addition, the NRC made some clarifications and 

format changes that did not change the intent of the guidance. 

Background 

In 1980, the NRC adopted requirements for how power reactor licensees could change their 

emergency plans (45 FR 55409, August 19, 1980) (Ref. 4). The NRC amended the requirements in a final 

rule dated November 23, 2011 (76 FR 72560) (Ref. 5). The final rule, in part, revised the regulatory 

process for NRC approval of emergency plan changes. The regulations of 10 CFR 50.54(q) are a 

condition of all production and utilization facility licenses issued under Part 50 and to combined licenses 

issued under 10 CFR Part 52 . The regulations of 10 CFR 50.54(q)(2) 1 require licensees to follow and 

maintain the effectiveness of an emergency plan that meets the standards in 10 CFR 50.47(b) and the 

requirements in 10 CFR Part 50, Appendix E, “Emergency Planning and Preparedness for Production and 

Utilization Facilities.” Section 50.54(q) also contains requirements for the process by which the licensee 

may make changes to its emergency plan without prior application to, and approval by, the NRC. The 

licensee may make changes to its emergency plan only if the licensee performs and retains an analysis 

demonstrating that the change does not reduce the effectiveness of the plan and the plan, as changed, 

continues to meet the requirements in Appendix E and 10 CFR 50.47(b). Changes that do not meet this 

condition must be submitted to the NRC, as a license amendment request under 10 CFR 50.90, 

“Application for Amendment of License, Construction Permit, or Early Site Permit,” for prior NRC 

approval. Under 10 CFR 50.90, a licensee that seeks to amend its license must file a request fully 

describing the changes desired, following, as applicable, the form prescribed for original applications. 

The objectives of the change process established in 10 CFR 50.54(q) are to ensure that a licensee: 

1) evaluates proposed changes to its emergency plan for their effects on the effectiveness of the 

plan, 

2) obtains prior NRC approval for changes that are deemed to reduce the effectiveness of the plan, 

and 

3) documents and reports such changes and the evaluations of these changes. 

The 10 CFR 50.54(q)(3) process offers three possible outcomes: 

1) The change is such that the emergency plan, as modified, would no longer comply with one or 

more applicable regulations. The licensee would need to request a specific exemption under 

10 CFR 50.12, “Specific Exemptions.” 

 

1 For combined licenses under Part 52, 10 CFR 50.54(q)(2) becomes effective after the Commission makes the finding 

under 10 CFR 52.103(g).
RG-1.219, Rev. 1, Page 6 

For example, a licensee who seeks to cease periodic updates of evacuation time estimates would 

need to request specific exemptions from 10 CFR Part 50, Appendix E, Sections IV.2-7. 

2) Although the emergency plan would comply with the applicable regulations, the change involves 

a reduction in the effectiveness of the emergency plan. The licensee would need to request prior 

NRC approval through a license amendment request under 10 CFR 50.90. 

For example, the NRC-approved emergency plan at an operating reactor describes a fire 

department, located within the protected area, and staffed full-time 24/7 by qualified firefighters. 

The licensee seeks to replace this department with an onshift fire brigade staffed with personnel 

having other concurrent responsibilities, and augmented by a fire department located further away 

from the site. The licensee’s 10 CFR 50.54(q)(3) analysis determined that the proposed 

arrangement would delay fire suppression efforts as compared to that for the fire department 

described in the NRC-approved emergency plan, resulting in a reduction in effectiveness. 

3) The change does not involve a reduction in effectiveness and the emergency plan, as modified, 

continues to meet applicable regulations. The licensee may put this change into place without 

prior NRC approval. 

For example, a licensee seeks to remove two onshift positions identified in the emergency plan 

for supporting the fire brigade. The change process in 10 CFR 50.48(f)(3) allowed the licensee to 

reduce the size of the onshift fire brigade. The licensee re-analyzed the onshift staffing and 

determined that there would be no reduction in the capability to perform emergency planning 

functions assigned in the emergency plan and, hence, no reduction in effectiveness. Also, the 

relevant regulations are still met. It is important to note that the 10 CFR 50.54(q)(3) conclusion 

was not predicated on the 10 CFR 50.48(f)(3) analysis (a different change process) but, rather, on 

the onshift staffing analysis. However, this conclusion would not have been valid if the onshift 

staffing analysis had been based on a reduced suite of accident scenarios predicated on a 

permanent cessation of operation. 

The reduction in effectiveness evaluation is a comparison between the current NRC-approved 

emergency plan, and the emergency plan with the changes being considered. In other words, compare the 

licensee’s commitment in the current NRC-approved emergency plan with what would be the 

commitment after the plan is modified. Plant reconfigurations enabled by other change processes (e.g., 

10 CFR 50.59, 10 CFR 50.48(f), 10 CFR 50.82, 10 CFR 52.110, etc.) do not factor into this comparison. 

This is a yes-no decision: the change would reduce the effectiveness of the emergency plan or it would 

not. There are no degrees of reduction (e.g., “minor” reduction). It is inappropriate for a licensee to 

conclude that certain commitments made in the NRC-approved plan are no longer required and to then 

compare the emergency plan as modified to this conclusion, rather than the NRC-approved plan. 

The emergency planning functions were derived from the planning standard functions that subject 

matter experts from the nuclear power industry and the NRC established during the development of the 

emergency preparedness cornerstone of the reactor oversight process (ROP). Regulatory guidance 

position 4 of this RG tabulates the emergency planning functions, the supporting requirements in 

Appendix E to 10 CFR Part 50, and the informing criteria of NUREG-0654/Federal Emergency 

Management Agency (FEMA)-REP-1, “Criteria for Preparation and Evaluation of Radiological 

Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,” issued 

November 1980 (Ref. 6) (hereafter referred to as NUREG-0654), for each of the planning standards in 

10 CFR 50.47(b). It also offers examples of emergency plan changes that typically would require prior 

NRC approval through a license amendment and examples of changes that typically would not require 

prior NRC approval. Although the ROP does not apply to facilities that have been permanently shutdown, 
RG-1.219, Rev. 1, Page 7 

the emergency planning functions remain applicable to 10 CFR 50.54(q)(3) analyses unless the NRC has 

granted the licensee an exemption from the associated planning standard. 

In 2013 a few nuclear power plants permanently ceased operation. Some of these licensees 

experienced challenges in implementing the guidance of this RG, in part because Revision 0 focused on 

operating nuclear power reactors. In 2015, another reactor permanently ceased operations and additional 

plants announced their intent to permanently cease operations in the near future. The NRC decided that 

this RG needed to be revised to clarify the applicability of the 10 CFR 50.54(q) change process to 

facilities that have permanently ceased operation. 

Harmonization with International and Industry Standards 

 The International Atomic Energy Agency (IAEA) has established a series of safety guides and 

standards constituting a high level of safety for protecting people and the environment. IAEA safety 

guides present international good practices and increasingly reflect best practices to help users striving to 

achieve high levels of safety. Relative to this RG, IAEA Safety Guide GS-R-2, “Preparedness and 

Response for a Nuclear or Radiological Emergency,” (Ref. 7) generally addresses emergency 

preparedness plans and procedures, and IAEA Safety Standard GS-G-1.2, “Review and Assessment of 

Nuclear Facilities by the Regulatory Body,” (Ref. 8) generally addresses modifications to the approved 

facility. RG 1.219 is consistent with the recommendations and guidance in the cited IAEA guides. 

C. STAFF REGULATORY GUIDANCE 

1. General Guidance 

1.1 Relationship between 10 CFR 50.54(q) and the NRC’s Reasonable Assurance Finding 

a. The NRC’s emergency preparedness requirements in 10 CFR 50.47(a) preclude the issuance of an 

operating or combined license if the NRC cannot make a finding that it has reasonable assurance 

that adequate protective measures can and will be taken in the event of a radiological emergency. 

Once an operating license is issued, the licensee is required to maintain the effectiveness of its 

emergency plan (10 CFR 50.54(q)(2)). The emergency preparedness cornerstone of the ROP 

evaluates whether the licensee continues to be capable of implementing adequate protective 

measures. A permanently shutdown plant will transition from the ROP to an inspection program 

described in Inspection Manual Chapter (IMC) 2561, “Decommissioning Power Reactor 

Inspection Program” (Ref. 9). In either case, if at any time after the license is issued, the NRC 

determines that the licensee’s state of emergency preparedness does not offer such assurance and 

the licensee does not correct the deficiency within 4 months, the Commission will determine 

whether the plant will be shut down or whether other enforcement actions would be appropriate 

(see 10 CFR 50.54(s)(2)(ii)). 

b. Some changes that a licensee may make to its approved emergency plan warrant prior NRC 

approval to ensure that the changes would not adversely affect the NRC’s reasonable assurance 

determination. However, other general types of changes may have such a minimal effect on this 

determination that they would not warrant prior NRC approval. For example, changes that reduce 

the number of personnel available to respond to emergencies or lengthen the time it takes to staff 

and activate emergency response facilities (ERFs) could affect the NRC’s reasonable assurance 

determination and would require prior NRC staff approval. Minor administrative changes, such as 

correcting position titles and spelling errors and updating document numbers, would not warrant 
RG-1.219, Rev. 1, Page 8 

prior NRC staff review.” Between these extremes is a range of possible changes for which the 

licensee is required to perform and document a detailed, objective evaluation. 

c. The change process under 10 CFR 50.54(q) does not establish whether a proposed change would 

affect reasonable assurance determinations; the change process establishes only whether the 

licensee has the authority to carry out the proposed change without prior NRC approval. The 

change process uses the characteristic “reduction in effectiveness” to exclude from the 

requirement to seek prior NRC approval those changes that would not reduce effectiveness. 

Because these changes would not reduce the effectiveness of the licensee’s plan, the NRC expects 

the changes to have a minimal effect on the agency’s reasonable assurance determination. A 

licensee’s determination that the proposed change would reduce the effectiveness of its plan 

requires an NRC evaluation of the effect of the change on the reasonable assurance 

determination. A licensee’s determination that a proposed change would reduce the effectiveness 

of the emergency plan does not mean that the licensee could not or would not carry out 

appropriate protective measures to protect public health and safety during an accident, but that 

prior NRC review is required. As described in Regulatory Guidance Position 5.3, the licensee 

should submit a license amendment application in accordance with 10 CFR 50.90 for prior NRC 

approval of a change that it believes will reduce the effectiveness of its emergency plan. Based on 

its review, the NRC may conclude that the changes (1) do not reduce the effectiveness of the 

plan, (2) do reduce the effectiveness of the plan but that the NRC continues to have reasonable 

assurance that adequate protective measures can and will be taken, or (3) unacceptably affect the 

NRC’s reasonable assurance determination. 

1.2 Role of Conservatism in 10 CFR 50.54(q) Change Evaluations 

 The NRC has always expected, and continues to expect, licensees to make conservative decisions 

for the operation of nuclear power reactors. Conservative decision making is prudent when the 

data needed for the decision are unknown or uncertain. Nonetheless, licensees need to remain 

alert to the possibility of unintended consequences and consider these outcomes in their decisions. 

The emphasis in emergency preparedness is on prudent risk reduction measures. An overly 

conservative decision during an emergency response could trigger actions that could place the 

public at unnecessary risk, thus resulting in a non-conservative situation; “more” is not always 

“better.” For example, changing a protective action recommendation (PAR) procedure to mandate 

a default 5-mile, 360-degree evacuation in lieu of considering the actual wind variability at the 

time of the event may appear conservative because more people would be evacuated. However, 

the approach could expose individuals upwind of the plant to unnecessary evacuation risks 

without the benefits of the associated radiation dose avoidance, resulting in a non-conservative 

situation. 

1.3 Role of Probabilistic Risk Assessment Insights in 10 CFR 50.54(q) Change Evaluations 

 The NRC policy statement, “Safety Goals for the Operation of Nuclear Power Plants” 

(51 FR 30028; August 4, 1986) (Ref. 10), states that emergency preparedness is a 

“defense-in-depth measure.” Emergency preparedness is carried out as a matter of prudence 

rather than in response to a quantitative analysis of accident probabilities. The effectiveness of an 

emergency plan is independent of probability. The planning basis in NUREG-0654 states that the 

objective of emergency planning is to provide dose savings for a “spectrum” of accidents that 

could produce offsite doses in excess of those given in the U.S. Environmental Protection Agency 

(EPA) protective action guides (Ref. 11). The basis goes on to state that no “single specific 

accident sequence” should be chosen as the one for which to plan because each accident could 

have different consequences both in nature and degree. The selected planning basis described in 
RG-1.219, Rev. 1, Page 9 

NUREG-0654 is independent of specific accident sequences. The probability of a reactor accident 

requiring the implementation of a licensee’s emergency plan has no relevance in determining 

whether a particular change reduces the effectiveness of the emergency plan. Accordingly, 

licensees should not consider risk insights about specific accident initiation or progression in 

performing 10 CFR 50.54(q) evaluations. 

1.4 Timeliness as an Evaluation Consideration 

a. By its very nature, an emergency instills a sense of urgency and dictates the necessity for prompt 

action, which is a fundamental aspect of the licensee’s emergency plan. Consistent with this 

imperative, the NRC has specified timeliness criteria in regulations for three specific emergency 

response activities: emergency declaration, emergency notifications, and public alerts. The 

NRC’s emergency planning guidance provides other time-based criteria. Licensees commit to 

staff augmentation times for their ERFs as part of their compliance with the planning standard in 

10 CFR 50.47(b)(2). Licensees’ initial emergency notifications must contain a PAR. Because the 

licensee must make the notification within 15 minutes of the emergency declaration, it must also 

deliver a PAR within 15 minutes. Proposed changes that could delay emergency declarations, 

notifications, or PARs may reduce the effectiveness of the emergency plan in that subsequent 

emergency response actions may not be timely and emergency response personnel, facilities, and 

equipment may not be in position if it becomes necessary to carry out measures to protect the 

public health and safety. Generally, the licensee should view any change that could delay an 

activity or relax a timeliness criterion for the activity as a potential reduction in effectiveness and 

should evaluate it accordingly. This evaluation would include any change that modifies how the 

timeliness criterion is evaluated (e.g., “when the clock starts and stops”). For example, the 

purpose of the emergency response organization (ERO) activation is to augment the onshift staff 

and relieve it of those functions assigned to the technical support center (TSC), the operations 

support center (OSC), and the emergency operations facility (EOF). The ERO activation is not 

complete until the ERO is actively performing those functions at the TSC, OSC, and EOF, or is 

ready to perform the functions but awaiting turnover from the control room; actuating a “clock 

stop” before this would be premature. 

b. The capability to complete an activity within the specified timeframe depends on several factors, 

including the availability of adequate qualified personnel to perform the activity; the number of 

multiple duties assigned to these personnel; augmentation time by off shift personnel; and 

sufficient procedures, tools, instrumentation, equipment, and other material necessary to complete 

the activity. The licensee needs to evaluate the proposed changes that affect these factors for their 

effect on the timely completion of emergency planning functions during an emergency response. 

1.5 Role of the NRC’s Review of Emergency Action Level and Emergency Plan Changes 

Submitted under 10 CFR 50.54(q)(5) 

 NRC staff screens emergency plan changes, including emergency action level (EAL) changes, 

and reviews a sample of changes submitted under 10 CFR 50.54(q)(5), that could reduce 

effectiveness. These reviews do not constitute the NRC’s approval of the plan changes, and all 

such changes remain subject to future inspection and enforcement actions. The NRC documents 

its approval of plan changes under 10 CFR 50.54(q)(4) in its decisions to grant license 

amendment requests. 
RG-1.219, Rev. 1, Page 10 

1.6 Role of the Facility Licensing Basis 

a. The licensee cannot properly evaluate a proposed change to the emergency plan if it has not 

considered the basis for the staff’s approval of the original plan or the basis for any subsequent 

change, whether it has been approved by the staff or put into place by the licensee under 

10 CFR 50.54(q). For example, why did the licensee specify more onshift ERO staff than what 

was called for in NUREG-0654? Was it a matter of exceeding the regulatory minimum as an 

operating philosophy, or was it done to compensate for special circumstances that existed when 

the decision was made (e.g., lengthy ERO augmentation times because of the remoteness of the 

site)? A decrease in staffing in the first case might not reduce effectiveness; a decrease in staffing 

in the second case would reduce effectiveness if the special circumstances still existed. 

b. The NRC’s approval of the original emergency plan (or subsequent revisions to that plan), 

established the licensing basis of the emergency plan. The 10 CFR 50.54(q)(3) change process is 

the only means available to the licensee to change the NRC-approved emergency plan. Other 

regulatory change processes (e.g., 10 CFR 50.59, “Changes, Tests and Experiments) do not offer 

authorization for changes to the emergency plan or its licensing basis. According to 10 CFR 

50.59(c)(4), the provisions of 10 CFR 50.59 do not apply to changes to the facility or procedures 

when the applicable regulations establish more specific criteria (e.g., 10 CFR 50.54(q)(3)) for 

accomplishing such changes. 

c. The licensee should consider the following licensing-basis documents when informing a 

10 CFR 50.54(q) evaluation: 

1) Regulatory Requirements: The Commission’s emergency preparedness regulations in 

10 CFR Chapter I, “Nuclear Regulatory Commission,” are binding on the licensee unless 

the NRC explicitly exempts them. 

2) License, License Conditions, and License Amendments: The facility’s license may 

contain emergency preparedness commitments and requirements that are binding on the 

licensee. This includes commitments and requirements of early site permits, design 

certifications, and combined operating licenses issued under 10 CFR Part 52. 

3) Commission Orders: Commission orders may establish specific emergency plan 

requirements for a particular licensee. On October 31, 1980, the NRC issued Generic 

Letter 80-90, “Post-TMI Requirements” (Ref. 12), which requires licensees to confirm 

their commitments on various requirements imposed after the Three Mile Island (TMI) 

accident, including emergency preparedness items. The Commission issued confirming 

orders to mandate compliance with the commitments. Other Commission orders may 

apply. 

4) Final Safety Analysis Report (FSAR): Chapter 13.3 of FSARs that are formatted in 

accordance with the standard format addresses emergency preparedness. However, this 

discussion may have been replaced with a cross-reference to the standalone plan. 

Similarly, Chapter 1 of many FSARs contains tabulations of how various RGs (e.g., 

RG 1.101, “Emergency Planning and Preparedness for Nuclear Power Reactors” 

(Ref. 13), and NUREG-0800, “Standard Review Plan for the Review of Safety Analysis 

Reports for Nuclear Power Plants: LWR Edition,” Chapter 13, “Conduct of Operations,” 

Section 13.3, “Emergency Planning,” (Ref. 14), were put into place in the design of the 

plants and in the development of their operating programs. 
RG-1.219, Rev. 1, Page 11 

5) Upgraded Emergency Plans: Following the TMI accident, regulations required licensees 

to upgrade their emergency plans and to submit those plans to the NRC for review. 

A special inspection program involving onsite evaluations of the upgraded plan and 

facilities augmented these reviews. The submitted plan, NRC requests for additional 

information, commitments made in responses to the requests for additional information, 

NRC safety evaluations, NRC denials, and other correspondence between the licensee 

and the NRC may be useful in informing a 10 CFR 50.54(q) evaluation. 

6) Other Sources of Licensing Information: The following sources of licensing information 

may be useful in informing 10 CFR 50.54(q) evaluations: 

(a) Hearing Dockets (the Atomic Safety and Licensing Board and the Atomic Safety 

and Licensing Appeal Board). Emergency preparedness contentions have been 

raised in numerous proceedings associated with licensing and license 

amendments. The resulting board decision may have been based, in part, on the 

licensee’s (applicant’s) statements about its emergency plan made in testimony 

presented before the board. This testimony and that of the NRC staff witnesses 

and witnesses for the interveners and resulting board rulings may be useful in 

informing a 10 CFR 50.54(q) evaluation on a program element addressed in 

those hearings. 

(b) NRC Inspection Findings. Inspection findings, inspection reports, commitments 

made in licensee response letters, root cause analyses, and supplemental 

inspection results may be useful in informing a 10 CFR 50.54(q) evaluation of a 

program element addressed in those findings. 

(c) FEMA-Approved Alert and Notification System (ANS) Design Report. If the 

licensee has committed to install or maintain the ANS on behalf of State or local 

governments, changes to the licensee’s commitments on the design, testing, and 

maintenance of the ANS identified within the site’s FEMA-approved final ANS 

design report are evaluated against the criteria of 44 CFR 350.14, “Amendments 

to State Plans.” If warranted, the licensee must submit the proposed changes to 

FEMA via the responsible State official for review and approval. 

1.7 Role of Emergency Preparedness Cornerstone Performance Indicators 

 Representatives of the nuclear power industry developed the emergency preparedness cornerstone 

performance indicators, and the NRC endorsed them. The nuclear power industry developed these 

performance indicators and the supporting guidance to monitor licensee performance; however, 

compliance with a performance indicator does not necessarily demonstrate compliance with 

regulations. For example, opportunities for demonstrating the capability to notify offsite response 

organizations (OROs) are considered successful upon notification of the first ORO. However, the 

NRC expects the licensee to have the capability to notify all OROs within 15 minutes to be in 

compliance with regulations. Accordingly, the licensee cannot use performance indicators and 

their guidance as the sole basis for concluding whether a proposed change would reduce the 

effectiveness of its emergency plan; however, they may be useful in informing such 

determinations at operating reactors. 
RG-1.219, Rev. 1, Page 12 

1.8 Role of Margin in the 10 CFR 50.54(q) Change Process 

a. The 10 CFR 50.54(q) change process establishes a two-factor test to determine when a change to 

an emergency plan requires prior NRC approval. First, the test assesses whether the emergency 

plan, as modified, would continue to comply with the planning standards in 10 CFR 50.47(b) and 

the requirements in Appendix E to 10 CFR Part 50 unless the NRC has granted the licensee an 

exemption from the relevant planning standard(s) or requirement(s). Second, the test assesses 

whether the proposed change would reduce the effectiveness of the emergency plan. These two 

tests are separate and distinct. If the licensee does not meet one of the tests, it must obtain prior 

NRC approval. Meeting the first test does not imply that the licensee has met the second test, nor 

does meeting the second test imply that the licensee has met the first test. 

b. During licensing, a licensee may have committed to a greater level of capabilities, methods, and 

resources than what regulation and guidance had explicitly required and subsequently may seek 

to reduce that level of commitment. Because the original plan “exceeded” the explicit regulatory 

requirement, the licensee may believe that there is enough “margin” to reduce its commitment 

and still comply with the regulatory requirements. However, this rationale only considers the first 

test factor; the second test factor still needs to be evaluated. 

(1) If the licensee’s original commitment resulted from a conservative operating philosophy, 

the licensee may be able to show that the reduction in commitment would not reduce the 

effectiveness of its emergency plan. 

(2) If the licensee’s original commitment resulted from the need to compensate for 

preparedness or response constraints or vulnerabilities specific to the facility, emergency 

planning zone (EPZ), and jurisdiction, any reduction in commitment would likely result 

in a reduction in effectiveness if the constraints or vulnerabilities are still present. 

c. In either case, the conclusion is not based on whether “margin” exists but instead on whether the 

licensee can demonstrate that the change does not reduce the effectiveness of its emergency plan 

and the emergency plan, as modified, continues to comply with applicable regulations. In the case 

of Regulatory Position 1.8.b.(1), conditions may have developed since the original commitments 

were made, thus making them necessary to maintain the effectiveness of the emergency plan. As 

such, the concept of margin has no role in a 10 CFR 50.54(q) change evaluation. 

1.9 Emergency Plan Changes at Decommissioning Facilities 

a. The change process at 10 CFR 50.54(q)(3) and the guidance in this RG are applicable to holders 

of production and utilization facility licenses issued under 10 CFR Part 50 and 10 CFR Part 52. 

This includes those licensed facilities that have certified the permanent cessation of operations 

but have not had their license terminated. This section does not replace the guidance elsewhere in 

this guide, but clarifies the role of the 10 CFR 50.54(q)(3) change process at decommissioning 

facilities. 

(1) The plant configuration and design basis will change over the duration of the 

decommissioning as the licensee puts modifications into place authorized under the 

applicable change processes, such as 10 CFR 50.59. The 10 CFR 50.54(q)(2) requirement 

to maintain the effectiveness of the emergency plan that meets the requirements in 

Appendix E and the planning standards of 10 CFR 50.47(b) remains in force until the 

licensee receives an exemption under 10 CFR 50.12, or the license is terminated. During 

this period, the NRC must continue to have reasonable assurance that adequate protective 
RG-1.219, Rev. 1, Page 13 

measures can and will be taken in the event of a radiological emergency. See Section 1.1 

of this guide for additional information. 

(2) The planning basis for emergency preparedness was not based on any particular accident, 

but rather, a spectrum of accidents including minor transients, design-basis events, and 

severe accidents. The NRC’s emergency planning regulations, regulatory guidance, and 

the emergency plan approvals are rooted, in part, in this planning basis. The planning put 

in place to address design-basis accidents, such as the large break loss-of-coolant 

accident, provides a substantial base for responding to the more severe events 

encompassed in the emergency preparedness planning basis. 

(3) Although certain design-basis accidents analyzed in the facility’s licensing basis may no 

longer be applicable because of the permanent cessation of operation, or by changes to 

the FSAR, the need for emergency planning remains as long as licensed radioactive 

material remains onsite. A licensee considering reductions in resources, capabilities, and 

methods described in its emergency plan must consider whether these reductions involve 

a reduction in effectiveness of the emergency plan to maintain the capability to mount an 

adequate response to the remaining transients, design-basis accidents, and severe 

accidents (e.g., spent fuel pool fire). 

b. The reduction in effectiveness evaluation is a comparison between the current NRC-approved 

emergency plan, and the emergency plan with the changes being considered. In other words, 

compare the licensee’s commitment in the current NRC-approved emergency plan with what 

would be the commitment after the plan is modified. Plant reconfigurations enabled by other 

change processes (e.g., 10 CFR 50.59, 10 CFR 50.48(f), 10 CFR 50.82, 10 CFR 52.110, etc.) do 

not factor into this comparison. This is a yes-no decision: the change would reduce the 

effectiveness of the emergency plan or it would not. There are no degrees of reduction (e.g., 

“minor” reduction). It is inappropriate for a licensee to conclude that certain commitments made 

in the NRC-approved plan are no longer required and to then compare the emergency plan as 

modified to this conclusion, rather than the NRC-approved plan. 

2. Emergency Plan Changes for Which a Prior NRC Conference Is Recommended 

a. The NRC encourages, but does not require, licensees to arrange a conference call with NRC 

headquarters staff if the licensees are considering the emergency plan changes listed below. The 

call is to exchange information on technical issues related to these emergency plan changes 

before completing a change evaluation that concludes that the changes will not reduce the plan’s 

effectiveness. NRC staff recommends this approach based on its experience in reviewing such 

changes. The purpose of this call is to clarify the 10 CFR 50.54(q) requirements and the guidance 

in this RG. The staff cannot comment on whether a proposed change constitutes a reduction in 

effectiveness or whether it will find the change acceptable if the licensee submits it for review. 

Licensees should arrange a conference call with NRC headquarters for the following types of 

changes to their emergency plans: 

(1) changes that increase the activation time of licensee ERFs or a change in how the 

activation time is measured (e.g., when the activation period starts and when it ends), 

either of which results in a delay in those facilities’ provision of meaningful support to 

the control room consistent with the facilities’ assigned functions and responsibilities; 
RG-1.219, Rev. 1, Page 14 

(2) changes to ERO staffing that eliminate a key position2

 or reduce the licensee’s capability 

to staff those positions 24 hours a day, 7 days a week (i.e., 24/7 support), consistent with 

the fitness-for-duty requirements in 10 CFR Part 26, “Fitness for Duty Programs;” 

(3) changes that combine the plant-specific emergency plan for two or more noncontiguous 

plant sites into a common emergency plan; 

(4) changes that relocate the TSC to a location outside of the protected area for the plant site; 

and 

(5) any change to the current NRC-approved emergency plan for decommissioning plants for 

which the 10 CFR 50.54(q)(3) reduction in effectiveness evaluation relies, in part or in 

whole, on the permanent cessation of operations or on changes put into place under the 

authority of other change processes (e.g., 10 CFR 50.59, 10 CFR 50.48(f)). 

3. Emergency Plan Change Evaluation Terminology 

 This section provides a definition and discussion of key terms used in evaluating changes in an 

emergency plan. These definitions are ordered such that each definition builds on the preceding 

definitions. 

3.1 Planning Standard 

a. “Planning standards” mean the 16 standards delineated in 10 CFR 50.47(b) that onsite and offsite 

emergency plans must meet for the NRC to find reasonable assurance that adequate protective 

measures can and will be taken. Corresponding sections of Appendix E to 10 CFR Part 50 contain 

additional requirements applicable to licensees that are associated with these planning standards. 

b. The planning standards establish the minimum requirements that onsite and offsite emergency 

plans must meet. The language of the planning standards is intentionally broad because the 

planning standards are applicable to both the licensee for the onsite emergency plan and the State 

and local authorities for offsite emergency plans. The broad language also offers flexibility to 

address plant-specific, EPZ-specific, and jurisdictional-specific planning considerations. 

Individual facilities may have had to supply capabilities, methods, and resources different from 

those at another facility to compensate for facility-specific planning or response constraints or 

vulnerabilities in demonstrating compliance with the planning standards. These commitments are 

documented in the emergency plan. 

3.2 Emergency Planning Function 

a. “Emergency planning function” means a capability or resource necessary to prepare for, and 

respond to, a radiological emergency, as required by Section IV of Appendix E to 10 CFR Part 50 

and the planning standards in 10 CFR 50.47(b) for nuclear power reactors. See 

10 CFR 50.54(q)(1)(iii) for more information. 

b. During the development of the emergency preparedness cornerstone of the ROP, a group of 

emergency preparedness subject matter experts, including NRC staff and industry stakeholders, 

 

2 Key positions include those in the (1) control room (shift manager (emergency director) and shift communicator), 

(2) TSC (senior manager, operations support, radiological controls, TSC communicator, and technical support), 

(3) EOF (senior manager, protective measures, and EOF communicator), and (4) OSC (OSC operations manager).
RG-1.219, Rev. 1, Page 15 

with input from the public, developed the emergency preparedness significance determination 

process, Inspection Manual Chapter 0609, “Significance Determination Process,” Appendix B, 

“Emergency Preparedness Significance Determination Process,” (Ref. 15). During the 

development, the group determined that the planning standard language would not be sufficiently 

clear for use as a basis for significance determination and instead developed a series of planning 

standard functions. These planning standard functions are paraphrases of the planning standards 

in terms of the significant functions that need to be accomplished, or the capabilities that need to 

be in place, to maintain the effectiveness of the emergency plan and the emergency response 

capability. Within the emergency preparedness cornerstone, the significance of findings depends 

on whether the planning standards cannot be accomplished (i.e., loss of planning standard 

function) or can be accomplished only in a degraded manner (i.e., degraded planning standard 

function) with greater significance accorded to findings associated with certain planning 

standards deemed to have greater public safety significance.3

 Any degradation, or loss, of a 

planning standard function, renamed as an “emergency planning function,” corresponds to a 

reduction in effectiveness (defined below). 

3.3 Program Element 

a. “Program element” means the items that comprise the implementation aspects of an emergency 

planning function. These items correspond to the evaluation criteria in NUREG-0654 (or other 

alternative methods for which the licensee obtained approval) that identify specific acceptable 

methods for complying with an emergency planning function. 

b. NUREG-0654 provides acceptable methods for demonstrating compliance with the 

Commission’s emergency preparedness regulations. Section II of NUREG-0654 tabulates each of 

the 16 planning standards and a series of evaluation criteria for each standard. These evaluation 

criteria identify the minimum functions, resources, or capabilities that are required to demonstrate 

compliance with planning standards. As with all regulatory guidance, applicants and licensees 

may propose alternatives to the guidance identified in the guide. A licensee’s emergency plan 

describes how the licensee addresses these evaluation criteria in demonstrating compliance with 

the planning standards, including any approved alternatives. 

c. When considering the effect of a change to one or more program elements, note that a change to a 

single program element may not always reduce the effectiveness of the associated emergency 

planning function. This would need to be considered on a case-by-case basis. In addition, a 

change to a program element under one planning standard may reduce the effectiveness of a 

different planning standard. For example, a change to a training module for emergency 

classification could reduce the effectiveness of the emergency classification process if its content 

is inconsistent with the plan. 

3.4 Regulatory Requirement 

a. “Regulatory requirement,” as used in this guide, means any requirement related to emergency 

preparedness, including, the planning standards, Appendix E to 10 CFR Part 50, 

10 CFR 50.54(q), 10 CFR 50.54(t), commitments made in the emergency plan, Commission 

orders, and commitments made with regard to compensatory actions under 10 CFR 50.47(c) or 

10 CFR 50.54(s)(2)(ii). “Regulatory requirement” includes a licensee’s self-imposed 

 

3 These standards are 10 CFR 50.47(b)(4) for classification, 10 CFR 50.47(b)(5) for notification, 10 CFR 50.47(b)(9) for 

dose assessment, and 10 CFR 50.47(b)(10) for protective actions.
RG-1.219, Rev. 1, Page 16 

requirements necessary for demonstrating compliance with the planning standards and 

Appendix E to 10 CFR Part 50.

b. Any licensee that is considering a change to its emergency plan should first review the regulatory 

requirements (i.e., licensing basis) for its plan to ensure that it understands the basis of the 

existing program elements and why the elements were incorporated in the plan. In some cases, 

applicants for licenses may have committed to particular program elements in response to 

site-specific considerations. For example, a licensee may have increased its commitment for the 

numbers of onshift ERO personnel to compensate for long staff augmentation times because of 

the remoteness of a site from residential areas. A change to align the onshift staffing with that of 

sister plants without actions to address the long staff augmentation times could reduce the 

effectiveness of the emergency plan. 

c. Section IV.D.3 of Appendix E to 10 CFR Part 50 requires a licensee to demonstrate that it has 

established the administrative and physical capability necessary to alert and provide prompt 

instructions to the public within the plume exposure pathway. Many licensees have taken on the 

responsibility for the maintenance of the ANS on behalf of the offsite authorities. In these cases, 

commitments made in the FEMA-approved ANS design report constitute regulatory requirements 

as defined above.4

3.5 Emergency Plan 

a. “Emergency plan” means the document(s) that the licensee prepared and maintains that identifies 

and describes its methods for maintaining emergency preparedness and responding to 

emergencies. An emergency plan includes the plan that the NRC originally approved and all 

subsequent changes that the licensee made with and without prior NRC review and approval 

under 10 CFR 50.54(q). See 10 CFR 50.54(q)(1)(ii) for additional information. 

b. This definition highlights that “emergency plan” includes the documents that describes the 

programmatic methods that the licensee uses to maintain emergency preparedness and to respond 

to emergencies. These methods, or program elements, are the implementation aspects of the 

planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 

and generally correspond to the evaluation criteria of NUREG-0654 or approved alternatives that 

supply specific acceptable methods for complying with the planning standards in 

10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50. Such programmatic 

documents are subject to the 10 CFR 50.54(q) change process. Non-programmatic documents, 

such as training rosters, equipment and maintenance test reports, lesson plans, and other 

documents that “document the performance” of the program elements, as opposed to those that 

“establish” the program elements, are not included. 

c. Ordinarily, sub-tier documents such as emergency plan implementing procedures (EPIPs) are not 

considered to be part of an emergency plan for the purpose of evaluating proposed changes. If a 

licensee relocates a programmatic description from the emergency plan to a sub-tier document, 

that programmatic description continues to be subject to the 10 CFR 50.54(q) change process. For 

example, licensees have relocated the details of emergency classification schemes from the 

emergency plan to an EPIP or to large wall charts maintained in the control room. Because the 

EPIP or wall chart is now the means to demonstrate compliance with the planning standards in 

10 CFR 50.47(b)(4), these sub-tier documents are subject to 10 CFR 50.54(q). Repeating, as 

 

4 However, note that 44 CFR 350.14 describes the process used to effect changes to the FEMA-approved ANS or 

changes to testing and maintenance commitments made in the ANS design report. 
RG-1.219, Rev. 1, Page 17 

opposed to relocating, program element descriptions in sub-tier documents do not necessarily 

make the sub-tier documents subject to the 10 CFR 50.54(q) change process. However, the 

descriptions in the various documents must remain consistent. 

d. As a simple test, a licensee can consider what programmatic document(s), in addition to its 

emergency plan, it would supply during an inspection to demonstrate that its emergency plan 

meets the regulatory requirements, as informed by the evaluation criteria in NUREG-0654 or by 

approved alternatives. These documents would likely be subject to the 10 CFR 50.54(q) change 

process. 

e. This definition also highlights the need to consider the NRC-approved plan and the subsequent 

changes in reviewing against 10 CFR 50.54(q) to ensure that a series of incremental changes 

(each determined not to reduce the effectiveness of the plan) do not reduce the effectiveness of 

the plan when compared to the NRC-approved plan. 

3.6 Change 

a. “Change” means an action that results in modification or addition to, or removal from, the 

licensee’s emergency plan. All such changes are subject to the provisions of 10 CFR 50.54(q) 

except in cases in which the applicable regulations establish specific criteria for accomplishing a 

particular change. See 10 CFR 50.54(q)(1)(i) for additional information. 

b. This definition is used in conjunction with 10 CFR 50.54(q)(3), which allows a licensee to make 

changes to its emergency plan if it can demonstrate through analysis that the change does not 

reduce the effectiveness of the plan. The 10 CFR 50.54(q) change process starts when a licensee 

decides to make a change to its emergency plan; an intentional act on the part of the licensee. 

c. Typical emergency plans identify and rely on resources, capabilities, and methods that are not 

under the cognizance of the licensee’s emergency planning group but instead are maintained by 

other entities that may modify those resources, capabilities, and methods. (The effect of proposed 

plant modifications on the effectiveness of the licensee’s emergency plan should be considered by 

the plant change control processes.) If the licensee changes its emergency plan to reflect these 

modifications, the change process in 10 CFR 50.54(q)(3) would apply, and the change analysis 

would need to address whether the change constitutes a reduction in effectiveness. For example, 

an offsite fire department identified and relied upon in the licensee’s emergency plan is no longer 

able to respond to the plant site because of conflicting responsibilities assigned in the local ORO 

plans. When the licensee revises its emergency plan to identify a replacement response capability, 

the evaluation would need to address the differences in response time, equipment resources, and 

other elements on the effectiveness of the plan. 

d. Temporarily taking a resource, capability, or method out-of-service for maintenance or testing, or 

an unplanned outage thereof, does not constitute a change to the emergency plan if the language 

of the plan is not changed. To comply with 10 CFR 50.54(q)(2), the licensee should minimize the 

duration of the outage, or carry out viable compensatory measures. The 10 CFR 50.54(q)(3) 

process does not apply in these cases unless the emergency plan is changed to carry out 

short-term or long-term corrective actions.5

e. “Resources” mean personnel, procedures, equipment, communications, instrumentation, 

analytical equipment, transportation, supplies, and other items needed to carry out the response 

 

5 Reporting requirements may apply, see 10 CFR 50.72(b)(3)(xiii)
RG-1.219, Rev. 1, Page 18 

actions identified in the emergency plan. “Capabilities” means the capacity to put into place the 

response actions identified in the emergency plan (e.g., the ability to augment onshift personnel in 

a timely manner, generate timely and accurate PARs, complete notifications within 15 minutes, 

and maintain a protracted response). “Methods” means the procedural means or manner of 

carrying out the response actions identified in the emergency plan (e.g., emergency classification 

schemes, notification protocols, and emergency action level (EAL) threshold value bases). These 

elements are generally interdependent. For example, capability is lost if the needed resources are 

missing. 

3.7 Reduction in Effectiveness 

a. “Reduction in effectiveness” means a change to an emergency plan that results in reducing the 

licensee’s capability to perform an emergency planning function in the event of an emergency. 

See 10 CFR 50.54(q)(1)(iv) for more information. 

b. “Reduction in effectiveness” is an evaluation concept that is used with 10 CFR 50.54(q) to 

differentiate between changes that a licensee is allowed to make without prior NRC approval and 

those that require prior NRC approval (see Regulatory Position 1.1). As used here, “emergency” 

means any condition that would result in the declaration of any emergency classification level and 

the implementation of the licensee’s emergency plan. An emergency is not based on a single 

accident sequence but instead on the spectrum of accidents addressed in the planning basis 

described in NUREG-0654. As noted above, “capabilities” means the capacity to carry out the 

response actions identified in the emergency plan to meet the emergency planning functions 

(e.g., the ability to augment onshift personnel in a timely manner, generate timely and accurate 

PARs, complete notifications within 15 minutes, and maintain a protracted response). 

c. The linkage between a proposed change and a possible degradation in the licensee’s capability 

may not always be obvious, and many such decisions would involve a significant evaluation by 

the reviewer. 

4. Emergency Planning Functions 

a. Regulatory Guidance Position 3.2 defines emergency planning functions. Regulatory Guidance 

Position 4 provides the individual emergency planning functions along with explanatory 

guidance. Regulatory Guidance Position 4 provides and explains examples of changes that could 

require prior NRC approval and those that would generally not require prior NRC approval. 

Licensees should not view these examples as being all inclusive or exclusive; instead, they should 

use them to inform decisions involving various changes under consideration. Site-specific 

situations may possibly make a particular example inapplicable to that site. Even if a particular 

example completely encompasses the change under consideration, the licensee’s 10 CFR 50.54(q) 

evaluation must explain why the site-specific implementation of the change would not reduce the 

effectiveness of the emergency plan, as compared to the current NRC-approved plan, for that 

particular site. Such an analysis cannot simply cross-reference an example in this guide. 

b. In evaluating proposed plan changes, the licensee may need to consider the effect of the proposed 

changes on more than one emergency planning function. For example, an evaluation of a 

proposed change to the ERO that reduces the number of persons assigned to perform dose 

assessments needs to consider the potential effect not only on the emergency planning functions 

for the planning standard in 10 CFR 50.47(b)(2) but also on the functions for the accident 

assessment planning standard in 10 CFR 50.47(b)(9). If ERO personnel who perform emergency 

notifications are given the added responsibility of performing dose assessments, the licensee also 
RG-1.219, Rev. 1, Page 19 

needs to evaluate the potential effect of this added responsibility on the notification functions 

(10 CFR 50.47(b)(5)). 

c. The remainder of this section is arranged in the order of the planning standards in 

10 CFR 50.47(b). 

4.1 10 CFR 50.47(b)(1) Assignment of Responsibility/Organizational Control 

a. The regulation at 10 CFR 50.47(b)(1) states the following:

“Primary responsibilities for emergency response by the nuclear facility licensee 

and by State and local organizations within the Emergency Planning Zones have 

been assigned, the emergency responsibilities of the various supporting 

organizations have been specifically established, and each principal response 

organization has staff to respond and to augment its initial response on a 

continuous basis.” 

b. Two emergency planning functions have been defined for this planning standard: 

(1) Responsibility for emergency response is assigned. 

(2) The response organization has the staff to respond and to augment staff on a 

continuing basis (i.e., 24/7 support) in accordance with the emergency plan. 

c. Sections IV.A.1–IV.A.9 of Appendix E to 10 CFR Part 50 provide supporting requirements. 

Informing criteria appear in Section II.A of NUREG-0654 and the licensee’s emergency plan. 

The following are examples of changes to the licensee’s emergency plan that could require prior 

NRC approval: 

(1) A change could require prior NRC approval if it would reduce the authority and 

responsibility of persons filling key positions to perform their emergency assignments in 

accordance with the emergency plan. 

(2) A change could require prior NRC approval if it assigns major functional areas or major 

tasks to two or more onsite organizations simultaneously such that it would not be clear 

to ERO members and the OROs which organization has the authority and responsibility 

for the activity at any point in the response. An example of this type of change could be 

one in which the TSC and EOF would perform dose projection functions concurrently 

without assigned hierarchical responsibility. 

(3) A change could require prior NRC approval if it would reduce the licensee’s capability to 

staff key ERO positions identified in the plan on a 24/7 basis in accordance with the 

licensee’s fitness-for-duty requirements. 

d. Proposed changes to ERO names or titles would generally not require prior NRC approval if they 

do not change the functional relationships, authorities, competencies, or responsibilities for key 

positions identified in the plan. 

4.2 10 CFR 50.47(b)(2) Onsite Emergency Organization 

a. The regulation at 10 CFR 50.47(b)(2) states the following:
RG-1.219, Rev. 1, Page 20 

[Onshift] “...facility licensee responsibilities for emergency response are 

unambiguously defined, adequate staffing to provide initial facility accident 

response in key functional areas is maintained at all times, timely augmentation 

of response capabilities is available and the interfaces among various onsite 

response activities and offsite support and response activities are specified.” 

b. Two emergency planning functions have been defined for this planning standard: 

(1) The process ensures that onshift emergency response responsibilities are staffed 

and assigned. 

(2) The process for timely augmentation of onshift staff is established and 

maintained. 

c. Sections IV.A and IV.C of Appendix E to 10 CFR Part 50 provide supporting requirements. 

Informing criteria appear in Section II.B of NUREG-0654 and the licensee’s emergency plan. 

Changes to the ERO have the potential to affect its performance in the major functional areas and 

major tasks, and evaluations of the effect of such changes would necessarily involve other 

emergency planning functions. The following are examples of changes to the licensee’s 

emergency plan that could require prior NRC approval: 

(1) A change could require prior NRC approval if it would cause any of the major functional 

areas or major tasks identified in the emergency plan to be unassigned. An example of 

this type of change would be replacing qualified radiation protection technicians with 

other personnel who do not have the requisite qualification to offer radiation protection 

coverage to personnel other than themselves (e.g., coverage for an offsite fire department 

responding onsite). 

(2) A change that increases the ERO augmentation time or a change in how the augmentation 

time is determined (e.g., when the augmentation period starts and when it ends) could 

require prior NRC approval if either one would increase the delay in providing 

meaningful support to the onshift organization beyond the times established in the 

emergency plan. An example of this type of change would be one in which the committed 

augmentation time is extended by 10 minutes to account for traffic delays or ERO 

notification or one in which the EOF is relocated such that the augmentation times can no 

longer be met because of increased ERO travel distances. 

(3) A change could require prior NRC approval if it eliminates key positions identified in the 

plan and reassigns the responsibilities of the eliminated positions to other key positions 

(e.g., multiple functions) and if it would result in an ERO member being assigned duties 

that could be expected to be performed concurrently rather than sequentially. An example 

of this type of change would be one in which control room communicator responsibilities 

are assigned to a fire brigade member or one in which dose assessment responsibilities 

are assigned to a shift technical advisor. 

(4) A change could require prior NRC approval for a reduction in onshift staffing that is 

predicated on the results of an onshift staffing analysis that omits one or more of the 

accident sequences included in the staffing analysis submitted to the NRC under 

Section IV.A.9 of Appendix E of 10 CFR Part 50. 
RG-1.219, Rev. 1, Page 21 

(5) A change could require prior NRC approval if it would reduce the availability, or 

timeliness, of offsite corporate support resources relied on in the plan. An example of this 

type of change would be a consolidation of corporate entities that relocates material, 

equipment, or personnel relied on in the plan and that impedes the timely availability of 

these elements to the ERO. 

(6) A change could require prior NRC approval if it would reduce the availability of 

personnel relied upon in the plan. An example of this type of change would be a 

reduction in fire brigade staffing allowed under §50.48(f)(3) if those personnel had 

collateral duties assigned by the emergency plan. 

d. A change to ERO staffing levels resulting from changes in circumstances or gains in efficiency 

would generally not require prior NRC approval provided that it does not affect the timeliness 

and accuracy of the ERO’s performance of major functional areas or major tasks in accordance 

with the emergency plan. The installation of digital display screens that eliminate the need for 

status board keepers, the collocation of offsite personnel at the EOF that eliminates the need for 

liaison positions, and the installation of messaging systems that reduce the needed number of 

communicators are examples of this type of change. 

4.3 10 CFR 50.47(b)(3)—Emergency Response Support and Resources 

a. The regulation at 10 CFR 50.47(b)(3) states the following: 

“Arrangements for requesting and effectively using assistance resources have 

been made, arrangements to accommodate State and local staff at the licensee’s 

Emergency Operations Facility have been made, and other organizations capable 

of augmenting the planned response have been identified.” 

b. Two emergency planning functions have been defined for this planning standard: 

(1) Arrangements for requesting and using offsite assistance have been made. 

(2) State and local staff can be accommodated at the EOF in accordance with the 

emergency plan. 

c. Sections IV.A.6 and IV.A.7 of Appendix E to 10 CFR Part 50 provide supporting requirements. 

Informing criteria appear in Section II.C of NUREG - 0654 and the licensee’s emergency plan. 

The following are examples of changes to the licensee’s emergency plan that could require prior 

NRC approval: 

(1) A change could require prior NRC approval if it reduces the availability or scope of the 

onsite services supplied by local agencies (e.g., local law enforcement and firefighting). 

(2) A change could require prior NRC approval if it would delay the in-processing of offsite 

assistance relied on in the emergency plan. For example, health physics personnel are not 

available to provide radiological coverage to ambulance crews because of staffing 

changes. 

(3) A change could require prior NRC approval if it replaces an offsite radiological 

laboratory relied on in the emergency plan with a laboratory that does not have the 

capabilities or licenses that allow it to receive and analyze the radioactive samples 

anticipated in the emergency plan. 
RG-1.219, Rev. 1, Page 22 

d. A change to the EOF structure, organization, or location that would impede the principal OROs 

from participating in the response at the EOF would generally not require prior NRC approval 

provided that these organizations accept the availability of reliable telecommunications 

capabilities (e.g., videoconferencing, WebEOCTM, or digital display boards connected via a data 

link) as viable alternatives. 

4.4 10 CFR 50.47(b)(4)—Emergency Classification System 

a. The regulation at 10 CFR 50.47(b)(4) states the following: 

“A standard emergency classification and action level scheme, the bases of which 

include facility system and effluent parameters, is in use by the nuclear facility 

licensee, and State and local response plans call for reliance on information 

provided by facility licensees for determinations of minimum initial offsite 

response measures.” 

b. The following emergency planning function has been defined for this planning standard: 

 A standard scheme of emergency classification and action levels is in use. 

c. Sections IV.B and IV.C of Appendix E to 10 CFR Part 50 supply supporting requirements. 

Informing criteria appear in Section II.D of NUREG-0654 and the licensee’s emergency plan. 

d. When considering proposed changes associated with EALs, the licensee must consider the effect 

of the change on the accuracy of the classification and the timeliness of the classification. 

Section IV.C.2 of Appendix E to 10 CFR Part 50 requires the licensee to have the capability to 

assess, classify, and declare an emergency condition within 15 minutes after the availability of 

indications that an EAL has been exceeded and to declare the emergency as soon as possible 

following the identification of the appropriate emergency classification level. Accurate 

classifications are also important to avoid under-classifications and over-classifications. 

e. The following are examples of changes to the licensee’s emergency plan that could require prior 

NRC approval: 

(1) A change could require prior NRC approval if it would reduce the licensee’s capability to 

assess, classify, and declare an emergency condition within 15 minutes of the availability 

of indications that an EAL has been exceeded and to promptly declare the emergency 

condition as soon as possible following the identification of the appropriate emergency 

classification level. Examples include the following: 

(a) a change to the normal shift complement that would delay the licensee’s 

capability to classify an emergency condition by making the expertise to read or 

interpret a seismic instrument reading cited in the EAL scheme unavailable 

onshift; 

(b) a change to the EAL scheme that would eliminate all predetermined radiation 

monitor EAL thresholds and rely instead on manually initiated dose projections; 

(c) a change to ERO staffing that would affect the timeliness of emergency 

declaration by assigning competing duties to the ERO positions that are 

responsible for performing emergency classifications, and 
RG-1.219, Rev. 1, Page 23 

(d) a change to a facility procedure that directs that the 15-minute declaration period 

starts only after the duration of the condition incorporated in the EAL (e.g., a fire 

lasting for 10 minutes) has elapsed.

(2) A change to a particular EAL could require prior NRC approval if it renders it ineffective 

such that an accurate classification and timely declaration would not occur as required for 

an event. Examples include the following: 

(a) a change to mode applicability of the EAL that excludes an operating mode in 

which the EAL should be applicable; 

(b) a change to the logic of an EAL that would result in a particular event not being 

declared when the declaration would have occurred before the change; 

(c) a change that would replace a viable quantifiable EAL threshold (e.g., an 

instrument reading or alarm) with a qualitative EAL that relies on user judgment 

to reach a declaration; 

(d) a change to the EAL scheme that eliminates direct reading instrumentation EALs 

and relies instead on alternatives that cannot support timely and accurate 

classification (e.g., manual sampling and analysis); 

(e) a change that expresses field monitor EALs in radiation units (e.g., total effective 

dose equivalent) that could not be measured directly in the field and for which 

monitoring procedures offer no conversion algorithm; and 

(f) a change to the language of a particular EAL that would render the classification 

logic unclear and could result in an inaccurate classification (e.g., a site area 

emergency EAL that reads “vandalism to safety-related equipment” without 

further qualification or quantification could be applied to events as diverse as 

someone putting graffiti on an inverter cabinet surface or someone hitting a 

safety injection pump casing with a sledge hammer). 

(3) A change could require prior NRC approval if it would result in an EAL that is 

inconsistent with the meaning or intent of the approved EAL bases such that the 

classification of the event would be different from that approved by the NRC in a 

site-specific application or from an endorsed industry EAL scheme that had been 

approved for licensee use. 

f. The following examples would generally not require prior NRC approval: 

(1) A change to an EAL numeric threshold to reflect an approved change in a technical 

specification, provided that the basis of the approved EAL is unchanged (e.g., an EAL 

basis refers to a particular technical specification but not a limiting condition for 

operation value), and 

(2) A change to an EAL numeric threshold to reflect a change in a plant design parameter, 

instrument response characteristics, or design calculation, provided that the meaning or 

intent of the basis of the approved EAL is unchanged. 
RG-1.219, Rev. 1, Page 24 

(3) A change that differs in wording but agrees in meaning and intent of the NRC-approved 

EAL and its bases such that the classification of an event would remain the same. 

4.5 10 CFR 50.47(b)(5)—Emergency Notifications 

a. The regulation at 10 CFR 50.47(b)(5) states the following:

“Procedures have been established for notification, by the licensee, of State and 

local response organizations and for notification of emergency personnel by all 

organizations; the content of initial and followup messages to response 

organizations and the public has been established; and means to provide early 

notification and clear instruction to the populace within the plume exposure 

pathway Emergency Planning Zone have been established.”

b. Three emergency planning functions have been defined for this planning standard: 

(1) Procedures for notification of State and local governmental agencies are capable 

of alerting them of the declared emergency within 15 minutes after declaration of 

an emergency and providing follow-up notifications. 

(2) Administrative and physical means have been established for alerting and 

providing prompt instructions to the public within the plume exposure pathway. 

(3) The public ANS meets the design requirements of FEMA-REP-10, “Guide for 

Evaluation of Alert and Notification Systems for Nuclear Power Plants” 

(Ref. 16), or is compliant with the licensee’s FEMA-approved ANS design report 

and supporting FEMA approval letter. 

c. Sections IV.D.1 and IV.D.3 of Appendix E to 10 CFR Part 50 provide supporting requirements. 

Informing criteria appear in Section II.E and Appendix 3 to NUREG-0654 and the 

FEMA-approved ANS design report. 

d. Because the performance of an ANS is an offsite concern, FEMA has the primary responsibility 

and authority for evaluating the design of an ANS, including primary and backup means. If the 

licensee has assumed responsibility for the installation and maintenance of the ANS on behalf of 

the State or local government, the licensee will have prepared a site-specific ANS design report. 

The State would submit this report to FEMA for its review. The ANS design report defines the 

design of the ANS, including the alerting system (e.g., sirens, tone alert radio, and route alert) and 

the notification system. The ANS design report identifies commitments for testing and 

maintenance. The NRC considers the approved ANS design report to be part of the facility’s 

licensing basis because it establishes the basis of the NRC’s determination that the licensee has 

complied with Section IV.D.3 of Appendix E to 10 CFR Part 50. Changes to the licensee’s 

commitments documented in the approved ANS design report are evaluated against the criteria of 

44 CFR 350.14, “Amendments to State Plans.” If warranted, the responsible State official must 

submit the proposed changes to FEMA for review and approval in accordance with 

44 CFR 350.14. 

e. The following are examples of changes to the licensee’s emergency plan that could require prior 

NRC approval: 
RG-1.219, Rev. 1, Page 25 

(1) A change could require prior NRC approval if it would reduce the licensee’s capability to 

promptly alert responsible OROs of the declared emergency within 15 minutes after 

declaring an emergency. Examples include the following:

(a) a change to the notification process that reduces the accuracy or timeliness of 

emergency notifications; 

(b) a change to the description of communications hardware that would reduce the 

capability to initiate and complete required emergency notifications within 

15 minutes of the emergency declaration; 

(c) a change that directs the restart of the 15-minute criterion clock if the condition 

escalates before the notifications for the prior emergency level are made; 

(d) a change that eliminates one or more components of initial or followup 

notifications specified in Section II.E of NUREG-0654 or the licensee’s 

approved emergency plan (e.g., an omission of whether protective actions are 

necessary); and 

(e) a change to ERO staffing that affects the timeliness of emergency notifications 

by assigning collateral duties to the ERO positions that are responsible for 

performing emergency notifications.

f. The following examples would generally not require prior NRC approval: 

(1) A change to emergency notification forms to carry out an EAL designation scheme that 

was coordinated with the OROs, and 

(2) A change to emergency notification protocols requested by a State to have a follow-up 

verbal discussion between the licensee and the State to discuss the licensee’s PAR, 

provided that the initial notification, including the PAR, continues to be made promptly 

within 15 minutes of the emergency declaration. 

4.6 10 CFR 50.47(b)(6)—Emergency Communications 

a. The regulation at 10 CFR 50.47(b)(6) states the following: 

“Provisions exist for prompt communications among principal response 

organizations to emergency personnel and to the public.” 

b. Two emergency planning functions have been defined for this planning standard: 

(1) Systems are established for prompt communication among principal emergency 

response organizations. 

(2) Systems are established for prompt communication to emergency response 

personnel. 

c. Section IV.E.9 of Appendix E to 10 CFR Part 50 provides supporting requirements. Informing 

criteria appear in Section II.F of NUREG-0654 and the licensee’s emergency plan. The following 

are examples of changes to the licensee’s emergency plan that could require prior NRC approval: 
RG-1.219, Rev. 1, Page 26 

(1) A change could require prior NRC approval if it would reduce the availability and 

reliability of primary and backup communications systems used to (1) notify and activate 

State and local emergency response centers or (2) enable communications between the 

licensee’s ERFs and with ORO and Federal emergency operating centers in accordance 

with the emergency plan (e.g., replacing dedicated private lines with a public exchange 

service). 

(2) A change to ERO callout processes or hardware could require prior NRC approval if it 

would delay ERO notification such that the augmentation times in the emergency plan 

can no longer be achieved. 

(3) A change could require prior NRC approval if it adjusts the frequency of communication 

testing or maintenance to a level that the site’s experience with system reliability does not 

support. An example of this type of change would be a scheduled maintenance interval 

that is greater than the observed mean time between failures of the equipment or a 

reduction in the availability of backup capabilities. 

d. A change to replace the phone talker relay of inter-facility communications with digital data 

communication would generally not require prior NRC approval provided that the replacement is 

equivalent to, or better than, the current system with regard to timeliness, accuracy, and reliability 

(the licensee’s 10 CFR 50.54(q) evaluation should address the requisite equivalency). 

4.7 10 CFR 50.47(b)(7)—Emergency Public Information 

a. The regulation at 10 CFR 50.47(b)(7) states the following: 

“Information is made available to the public on a periodic basis on how they will 

be notified and what their initial actions should be in an emergency 

(e.g., listening to a local broadcast station and remaining indoors), the principal 

points of contact with the news media for dissemination of information during an 

emergency (including the physical location or locations) are established in 

advance, and procedures for coordinated dissemination of information to the 

public are established.” 

b. Two emergency planning functions have been defined for this planning standard: 

(1) Emergency preparedness information is made available to the public on a 

periodic basis within the plume exposure pathway emergency planning zone 

(EPZ). 

(2) Coordinated dissemination of public information during emergencies is 

established. 

c. Section IV.D.2 of Appendix E to 10 CFR Part 50 provides supporting requirements. Informing 

criteria appear in Section II.G of NUREG-0654 and the licensee’s emergency plan. The following 

are examples of changes to the licensee’s emergency plan that could require prior NRC approval: 

(1) A change could require prior NRC approval if it would reduce the licensee’s capability to 

disseminate information to the public in a timely and accurate manner during 

emergencies in accordance with the emergency plan. Examples include the following: 

(a) media contact lists would not be kept up-to-date; 
RG-1.219, Rev. 1, Page 27 

(b) procedural approval protocols cannot be carried out based on organizational 

changes; 

(c) corporate spokespersons would not be familiar enough with a particular site and 

its reactors to be credible spokespersons; 

(d) sufficient staffing would not be available to adequately perform assigned 

functions and tasks related to public information; 

(e) news release would not be released in a timely manner such that outdated 

information could be released after it has been superseded by subsequent events 

(e.g., a press release addressing the declaration of a notification of an unusual 

event would be released after the ERO has already declared a site area 

emergency); 

(f) the process for news releases and briefings would not be routinely coordinated 

with those supplied by OROs; and 

(g) annual media orientation (NUREG-0654 II.g.5) would not be conducted. 

(2) A change to annually disseminated public emergency information material or postings 

could require prior NRC approval if it would result in the material not containing the 

minimum information identified in Section II.G of NUREG-0654 or an NRC-approved 

alternative. 

(3) A change in the means of distributing the annual information materials could require 

prior NRC approval if it would reduce the assurance that the permanent and transient 

adult population within the plume exposure EPZ has been given an adequate opportunity 

to become aware of the information. 

d. A revision to the annual emergency information packet that changes the format from a brochure 

to a calendar would generally not require prior NRC approval provided that the calendar still 

includes all required information. 

4.8 10 CFR 50.47(b)(8)—Emergency Facilities and Equipment 

a. The regulation at 10 CFR 50.47(b)(8) states the following: 

“Adequate emergency facilities and equipment to support the emergency 

response are provided and maintained.” 

b. Two emergency planning functions have been defined for this planning standard: 

(1) Adequate facilities are maintained to support emergency response. 

(2) Adequate equipment is maintained to support emergency response. 

c. Sections IV.E.1–4, IV.E.8, and IV.G of Appendix E to 10 CFR Part 50 supply supporting 

requirements. Informing criteria appear in Section II.H of NUREG-0654; NUREG-0696, 

“Functional Criteria for Emergency Response Facilities,” issued February 1981 (Ref. 17); and the 
RG-1.219, Rev. 1, Page 28 

licensee’s emergency plan. The following are examples of changes to the licensee’s emergency 

plan that could require prior NRC approval: 

(1) A change could require prior NRC approval if it would reduce the capability of the ERO 

in the TSC, EOF, or OSC to perform assigned functions and tasks in accordance with the 

emergency plan. Examples include the following: 

(a) a reduction in the existing reliability or redundancy of data acquisition, display, 

and analysis equipment supplied in the ERFs; 

(b) a relocation of an EOF that makes it infeasible for State or local ORO personnel 

to respond to, and participate in, the EOF as they currently do without adequate 

compensatory measures; 

(c) a permanent substitution of personal protective equipment for installed 

engineered habitability features; 

(d) a reduction in the frequency of ERF equipment maintenance, calibration, or 

testing that is not supported by the site’s experience with equipment reliability 

(e.g., a frequency greater than the observed mean time between failures); 

(e) a change to an ERF use that allows nonemergency uses that would decrease the 

readiness of the ERF for emergency use; and 

(f) a change that reduces the inventory or availability of equipment. 

d. The following examples would generally not require prior NRC approval: 

(1) A change that replaces existing ERF equipment with equipment of like quality, 

reliability, performance, and user interface would generally not require prior NRC 

approval (The licensee’s 10 CFR 50.54(q) evaluation must document the basis of this 

equivalency conclusion). 

(2) A planned change to relocate the EOF that impedes the principal OROs from 

participating in the response at the EOF would generally not require prior NRC approval 

provided that these organizations accept the availability of reliable telecommunications 

capabilities (e.g., videoconferencing, WebEOCTM, or digital display boards connected via 

a data link) as viable alternatives. See Regulatory Position 2 for more information. 

4.9 10 CFR 50.47(b)(9)—Emergency Assessment Capability 

a. The regulation at 10 CFR 50.47(b)(9) states the following: 

“Adequate methods, systems, and equipment for assessing and monitoring actual 

or potential offsite consequences of a radiological emergency condition are in 

use.” 

b. The following emergency planning function has been defined for this planning standard: 

 Methods, systems, and equipment for assessment of radioactive releases are in 

use. 
RG-1.219, Rev. 1, Page 29 

c. Sections IV.B and IV.E.2 of Appendix E to 10 CFR Part 50 provide supporting requirements. 

Informing criteria appear in Section II.I of NUREG-0654 and the licensee’s emergency plan. The 

following are examples of changes to the licensee’s emergency plan that could require prior NRC 

approval: 

(1) A change could require prior NRC approval if it would reduce the capability of the ERO 

to assess imminent and ongoing radioactive releases in accordance with the emergency 

plan. Examples include the following: 

(a) a change that reduces the availability of meteorological data in ERFs where dose 

assessments are performed and PAR decisions are made; 

(b) a change in ERO staffing that would eliminate the onshift capability to make 

timely and accurate estimates of the actual or potential radiological hazards 

through liquid or gaseous release pathways; 

(c) the reassignment of dose assessment responsibilities from a site-specific EOF 

member to a common EOF manned with ERO personnel who are not sufficiently 

competent in the site’s radiation monitoring systems, ventilation systems, source 

terms, or potential release paths to perform a credible dose assessment; 

(d) the replacement of a site-specific dose assessment model with a generic model 

that offers results that have not been shown to be representative for the 

topography, meteorological regimes (e.g., valley effects or sea breeze), release 

pathways, or source terms applicable to that plant and its environs; 

(e) a change in field-monitoring air sampling media such that the requisite iodine 

sensitivity could not be met because of interference from the presence of noble 

gases; and 

(f) changes to dose assessment software that would reduce the options available to 

assessment personnel to assess releases that have not yet started or that could 

occur through unmonitored release paths. 

d. The following examples would generally not require prior NRC approval: 

(1) A change that replaces existing field monitoring equipment with equipment of like 

quality, reliability, performance, and user interface would generally not require prior 

NRC approval (the licensee’s 10 CFR 50.54(q) evaluation must document the basis of 

this equivalency conclusion). 

(2) A change to dose assessment software that updates site parameter files to reflect a change 

in detector isotopic efficiencies would generally not require prior NRC approval provided 

that it results from an approved upgrade to the effluent radiation monitoring system. 

4.10 10 CFR 50.47(b)(10)—Emergency Protective Actions 

a. The regulation at 10 CFR 50.47(b)(10) states the following: 

“A range of protective actions has been developed for the plume exposure 

pathway EPZ for emergency workers and the public. In developing this range of 

actions, consideration has been given to evacuation, sheltering, and, as a 
RG-1.219, Rev. 1, Page 30 

supplement to these, the prophylactic use of potassium iodide (KI), as 

appropriate. Evacuation time estimates have been developed by applicants and 

licensees. Licensees shall update the evacuation time estimates on a periodic 

basis. Guidelines for the choice of protective actions during an emergency, 

consistent with Federal guidance, are developed and in place, and protective 

actions for the ingestion exposure pathway EPZ appropriate to the locale have 

been developed.” 

b. Three emergency planning functions have been defined for this planning standard: 

(1) A range of public PARs is available for implementation during emergencies. 

(2) Evacuation time estimates for the population in the plume exposure pathway EPZ 

are available to support the formulation of PARs and have been supplied to State 

and local governmental authorities. 

(3) A range of protective actions is available for plant emergency workers during 

emergencies, including those for hostile action events. 

c. Appendix E to 10 CFR Part 50 does not contain any support requirements. Informing criteria 

appear in NUREG-0654 in Sections II.J.1–8, Section II.J.10, and Supplement 3 and in the 

licensee’s emergency plan. The following are examples of changes to the licensee’s emergency 

plan that could require prior NRC approval: 

(1) A change could require prior NRC approval if it would reduce the capability of the ERO 

to carry out timely and appropriate protective actions for onsite employees and other 

individuals present in the plant areas controlled by the licensee and to make timely and 

appropriate PARs to State and local officials in accordance with the emergency plans. 

Examples include the following: 

(a) a change that would result in unescorted persons onsite not receiving adequate 

instruction in site evacuation or site accountability; 

(b) a change that could result in personnel who are not qualified to wear respiratory 

protection devices being assigned to ERO positions with functions and tasks that 

could reasonably require using such equipment; 

(c) a change that would result in PARs that relax earlier PARs that have already been 

relayed to OROs and are being put into place by the public; 

(d) a change that reduces the availability of ERO personnel who are qualified to 

wear personal protection equipment (PPE) to function as assigned or that reduces 

the availability of PPE for use by these personnel; 

(e) a change to PAR decision logic that would mandate 5-mile, 360-degree 

evacuations as a minimum PAR even when the actual wind persistence and wind 

direction forecasts at the time of the emergency do not warrant such an action; 

(f) a change to PAR decision logic such that the range of protective actions 

considered by the ERO would be inappropriately restricted to the extent that the 
RG-1.219, Rev. 1, Page 31 

most effective PAR (lowest overall risk to the individual) might not be carried 

out; and 

(g) changes that reduce the control a licensee has over access to the owner-controlled 

area or exclusion area (e.g., a public roadway traversing the site or a public 

recreational area located within the exclusion area). 

d. The following examples would generally not require prior NRC approval: 

(1) A change that replaces existing PPE with equipment of like quality, reliability, 

performance, and operation would generally not require prior NRC approval (The 

licensee’s 10 CFR 50.54(q) evaluation must document the basis of this equivalency 

conclusion). 

(2) A change to a PAR decision that removes KI as a PAR option for the public following 

the decision by State officials to no longer issue KI to the public would generally not 

require prior NRC approval. 

4.11 10 CFR 50.47(b)(11)—Emergency Radiological Exposure Control 

a. The regulation at 10 CFR 50.47(b)(11) states the following: 

Means for controlling radiological exposures, in an emergency, are established 

for emergency workers. The means for controlling radiological exposures shall 

include exposure guidelines consistent with EPA Emergency Worker and 

Lifesaving Activity Protective Action Guides. 

b. The following emergency planning function has been defined for this planning standard: 

(1) The resources for controlling radiological exposures for emergency workers are 

established. 

c. Section IV.E.1 of Appendix E to 10 CFR Part 50 provide supporting requirements. Informing 

criteria appear in Section II.K of NUREG-0654 and the licensee’s emergency plan. The following 

are examples of changes to the licensee’s emergency plan that could require prior NRC approval: 

(1) A change could require prior NRC approval if it would reduce the capability of the ERO 

to control the radiological exposures of emergency workers in accordance with the 

emergency plans. Examples include the following: 

(a) radiation exposures incurred during an emergency not being recorded as 

occupational exposure under 10 CFR Part 20, “Standards for Protection against 

Radiation;” 

(b) radiation dosimetry not being issued in accordance with emergency plans to 

offsite assistance (e.g., ambulance, fire, or local law enforcement) entering the 

radiologically controlled area; 

(c) personnel decontamination materials and agents not being maintained in a ready 

state; and 

(d) authority to authorize emergency exposure limits not being available 24/7. 
RG-1.219, Rev. 1, Page 32 

d. A change that replaces existing radiological protection instrumentation (e.g., friskers, survey 

instruments, continuous air monitors, or dosimeters) relied on in the emergency plan with 

equipment of like quality, reliability, performance, and operation would generally not require 

prior NRC approval (The licensee’s 10 CFR 50.54(q) evaluation must document the basis of this 

equivalency conclusion). 

4.12 10 CFR 50.47(b)(12)—Emergency Medical Support 

a. The regulation at 10 CFR 50.47(b)(12) states the following: 

“Arrangements are made for medical services for contaminated injured 

individuals.” 

b. The following emergency planning function has been defined for this planning standard: 

 Arrangements are made for medical services for contaminated, injured 

individuals. 

c. Sections IV.E.5–7 of Appendix E to 10 CFR Part 50 supply supporting requirements. Informing 

criteria appear in Section II.L of NUREG-0654 and the licensee’s emergency plan. The following 

are examples of changes to the licensee’s emergency plan that could require prior NRC approval: 

(1) A change that terminates a letter of agreement with an offsite medical facility relied on in 

the emergency plan could require prior NRC approval if it would delay medical treatment 

for contaminated, injured individuals without a viable alternative facility accessible 

within a timeframe consistent with the urgency of emergency medical treatment. 

(2) A change in licensee training assistance to an offsite medical facility identified in the 

emergency plan could require prior NRC approval if it degrades the ability of hospital 

personnel to handle contaminated, injured individuals (e.g., training on radiological 

contamination control involving contaminated, injured individuals or the general primacy 

of trauma treatment over treatment for radiation exposure). 

(3) A change in ERO staffing or in the availability of emergency kits could require prior 

NRC approval if it would preclude site personnel from ensuring that the receiving 

medical facility has put adequate radiological contamination controls into place. 

(4) A change in ERO staffing or in the availability of emergency kits could require prior 

NRC approval if it would reduce onsite first aid capabilities identified in the emergency 

plan. 

d. A change in the designation of a replacement offsite medical facility would generally not require 

prior NRC approval provided that the new facility has equivalent capabilities and is accessible 

within a timeframe consistent with the urgency of emergency medical treatment (the licensee’s 

10 CFR 50.54(q) evaluation must document the basis of this equivalency conclusion). 

4.13 10 CFR 50.47(b)(13)—Recovery and Reentry Planning 

a. The regulation at 10 CFR 50.47(b)(13) states the following: 

“General plans for recovery and reentry are developed.” 
RG-1.219, Rev. 1, Page 33 

b. The following emergency planning function has been defined for this planning standard: 

 Plans for recovery and reentry are developed. 

c. Appendix E to 10 CFR Part 50 does not contain any supporting requirements. Informing criteria 

appear in Section II.M of NUREG-0654 and the licensee’s emergency plan. The following are 

examples of changes to the licensee’s emergency plan that could require prior NRC approval: 

(1) A change to the criteria for terminating the emergency and transitioning to a recovery 

organization could require prior NRC approval if it reduces the likelihood of an orderly 

transition, including coordination with State officials, to a recovery organization for the 

spectrum of accident scenarios enveloped by the NUREG-0654 planning basis. 

(2) A change could require prior NRC approval if it would not offer an adequate level of 

personal protection in uncertain reentry conditions. 

(3) A change could require prior NRC approval if it reduces the level of detail in plan 

provisions for the structure of the recovery organization and the authorities and 

responsibilities of key personnel assigned such that a reasonable general framework no 

longer exists. 

d. A proposed change to the general framework of a recovery organization to reflect changes in 

position titles made in the normal operating organizations would generally not require prior NRC 

approval. 

4.14 10 CFR 50.47(b)(14)—Drill and Exercise Program 

a. The regulation at 10 CFR 50.47(b)(14) states the following: 

“Periodic exercises are (will be) conducted to evaluate major portions of 

emergency response capabilities, periodic drills are (will be) conducted to 

develop and maintain key skills, and deficiencies identified as a result of 

exercises or drills are (will be) corrected.” 

b. Three emergency planning functions have been defined for this planning standard: 

(1) A drill and exercise program (including radiological, medical, health physics, or 

other program areas) is established. 

(2) Drills, exercises, and training evolutions that provide performance opportunities 

to develop, maintain, and demonstrate key skills, are assessed via a formal 

critique process to identify weaknesses. 

(3) Identified weaknesses are corrected. 

c. Sections IV.F.1–2 of Appendix E to 10 CFR Part 50 provide supporting requirements. Informing 

criteria appear in Section II.N of NUREG-0654 and the licensee’s emergency plan. The following 

are examples of changes to the licensee’s emergency plan that could require prior NRC approval: 

(1) A change in drills and exercise programs could require prior NRC approval if it would 

reduce the challenge to ERO personnel to the extent that they are not provided adequate 

opportunities over the exercise planning cycle to practice key functional areas and major 
RG-1.219, Rev. 1, Page 34 

tasks, including the use of the plan, procedures, and equipment associated with those 

functions and tasks. Examples include the following:

(a) use of the same general scenarios from exercise to exercise; 

(b) frequent reuse of a given scenario; 

(c) lack of sufficient detail in a scenario on an expected ERO response to the data 

and situations presented by the scenario; 

(d) scenarios and controller conduct that do not cause drill or exercise participants to 

“work for the information” as they would in an actual event; 

(e) an overreliance on player simulation when valid constraints to actual play do not 

exist (e.g., not obtaining the tools and parts for a simulated repair activity, not 

obtaining or reviewing the radiation work permit, not donning protective clothing 

and equipment, not going to the location of the repair, or returning to the OSC 

sooner than the actual repair would have taken); 

(f) scenarios that never allow ERO success to change the course of the exercise, and 

(g) scenario objectives that never exercise using backup capabilities (e.g., loss of the 

primary ring-down phone used for initial notifications). 

(2) A change in drill and exercise critiques could require prior NRC approval if it reduces the 

ability of the critique to adequately identify weaknesses in the ERO play and to carry out 

necessary corrective actions. An example would be a critique process that does not 

identify and formally evaluate any deviation in the ERO performance expected by the 

scenario. The licensee needs to evaluate such situations to determine whether the scenario 

was wrong or whether the ERO was wrong. In either case, the licensee needs to evaluate 

the situation and take the appropriate corrective actions. 

d. A change in the overall exercise program schedule would generally not require prior NRC 

approval provided that the program continues to meet the scheduling requirements in Appendix E 

to 10 CFR Part 50. 

4.15 10 CFR 50.47(b)(15)—Emergency Responder Training 

a. The regulation at 10 CFR 50.47(b)(15) states the following: 

“Radiological emergency response training is provided to those who may be 

called on to assist in an emergency.” 

b. The following emergency planning function has been defined for this planning standard: 

 Training is provided to emergency responders.

c. Sections IV.F.1–2 of Appendix E to 10 CFR Part 50 supply supporting requirements. Informing 

criteria appear in Section II.O of NUREG-0654 and the licensee’s emergency plan. The following 

are examples of changes to the licensee’s emergency plan that could require prior NRC approval: 
RG-1.219, Rev. 1, Page 35 

(1) A change in ERO training could require prior NRC approval if it does not provide ERO 

personnel sufficient training and other performance development opportunities related to 

their assigned functions and responsibilities to allow them to perform those functions and 

responsibilities acceptably before they are assigned to key ERO positions and 

periodically as long as they continue to be so assigned. Examples include the following: 

(a) a change that reduces the frequency of required training that is not supported by 

demonstrated ERO performance in drills and exercises or by the frequency of 

changes in the emergency plan and its supporting procedures: 

(b) a change that reduces the frequency at which training materials are updated to 

reflect changes in the emergency plan and procedures: 

(c) a change that lengthens the time to address ERO performance weaknesses 

attributed to training deficiencies, inconsistent with the significance of the 

weakness; 

(d) a change that eliminates training effectiveness measurements (tests and job 

performance measurements) that are required; and 

(e) a change that reduces the availability of site familiarization training that is 

currently presented to offsite assistance groups (e.g., firefighters, local law 

enforcement, and medical services, including mutual aid companies that would 

support these groups onsite). 

d. A change to emergency training program description to conform with approved changes in the 

emergency plan or to plant systems and equipment relied on in that plan would generally not 

require prior NRC approval. 

4.16 10 CFR 50.47(b)(16)—Emergency Plan Maintenance 

a. The regulation at 10 CFR 50.47(b)(16) states the following:

“Responsibilities for plan development and review and for distribution of 

emergency plans are established, and planners are properly trained.” 

b. Two emergency planning functions have been defined for this planning standard: 

(1) Responsibility for emergency plan development and review is established. 

(2) Planners responsible for emergency plan development and maintenance are 

properly trained. 

c. Appendix E to 10 CFR Part 50 does not contain any supporting requirements. Informing criteria 

appear in Section II.P of NUREG-0654 and the licensee’s emergency plan. The following are 

examples of changes to the licensee’s emergency plan that could require prior NRC approval: 

(1) A change could require prior NRC approval if it reduces management oversight and 

control over the emergency preparedness program to the extent that the effectiveness of 

the emergency plan may be reduced. Examples include the following: 
RG-1.219, Rev. 1, Page 36 

(a) a decrease in the scope, periodicity, or independence of the performance of 

emergency preparedness program reviews; 

(b) an increase in the amount of time necessary to put changes into effect to needed 

emergency plan and supporting procedures identified as corrective actions for 

identified plan deficiencies and ERO weaknesses; 

(c) changes in the scope or frequency of training and performance enhancement 

opportunities for emergency preparedness management and staff; and 

(d) delegation of responsibility for the performance of various aspects of emergency 

plan maintenance to contractors or other external groups without adequate 

supervisory oversight to ensure that program elements continue to be met 

(e.g., a change delegating the testing and maintenance of the ANS to an external 

group that is not subject to typical nuclear facility work process and 

configuration controls). 

d. A proposed change that consolidates some site emergency preparedness program maintenance 

and review activities with those of sister facilities within a corporation would generally not 

require prior NRC approval provided that site-specific commitments continue to be met. 

5. Review Process 

 This section supplies an acceptable approach for reviewing changes as required by 

10 CFR 50.54(q)(3), submitting proposed changes for NRC review under 10 CFR 50.54(q)(4), and 

documenting the changes and their analyses under 10 CFR 50.54(q)(5) and (6). The licensee 

should use this section in conjunction with Regulatory Positions 1, 3, and 4. Appendix A to this 

guide offers an illustration of the major steps of this review approach.

 

5.1 Screening Changes 

a. The licensee should screen all proposed changes to the emergency plan to determine whether a 

10 CFR 50.54(q) evaluation is necessary and to determine whether another formal change process 

is applicable. The purpose of this screening is not to decide which proposed changes could reduce 

effectiveness but instead whether a 10 CFR 50.54(q) change evaluation is necessary. The licensee 

should screen each proposed change separately and reserve the treatment of changes collectively 

for (1) repetitive identical changes, (2) editorial or typographical changes such as formatting, 

paragraph numbering, spelling, or punctuation that do not change intent, (3) conforming changes, 

or (4) two or more elements that are interdependent (e.g., a change to one element compensates 

for a change to another element). The licensee should document this screening if it concludes that 

a 10 CFR 50.54(q) evaluation is not necessary. 

b. Does another change process control the proposed change? If so, put the other change process 

into place. If the proposed change is subject to one or more change processes in addition to 

10 CFR 50.54(q), compliance with all of the applicable change processes is required. For 

example, a change to the radiation monitoring system described in the FSAR that is subject to a 

technical specification and that affects an EAL threshold could be subject to 10 CFR 50.59, 

10 CFR 50.90. Continue with Regulatory Position 5.1.c. 

(1) Does the proposed change affect information supplied in the FSAR? If so, the change 

must be screened for its applicability to 10 CFR 50.59? 
RG-1.219, Rev. 1, Page 37 

(2) Does the proposed change require a revision to a technical specification? If so, a license 

amendment under 10 CFR 50.90 is required before the licensee can carry out the change? 

(3) Carry out the following change processes as applicable: (1) apply 10 CFR 50.54(a) for 

quality assurance programs and (2) apply 10 CFR 50.54(p) for a safeguards plan. 

(4) The regulation at 44 CFR 350.14 describes the applicable change process for proposed 

changes that affect the design, operation, testing, or maintenance of the ANS. The 

appropriate State official(s) must request prior approval from FEMA for implementation 

of the proposed changes. 

c. Does the proposed action meet the definition of “change” to the “emergency plan” in 

10 CFR 50.54(q)(1)(i) and (ii), respectively, as expanded on in Regulatory Positions 3.6 and 3.5? 

If not, the change process in 10 CFR 50.54(q)(3) and (4) is not applicable. Otherwise, continue 

with Regulatory Position 5.1.d. 

d Would the emergency plan, modified as proposed, continue to comply with planning standards in 

10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50? If not, the change must 

be processed as an exemption request under 10 CFR 50.12, “Specific Exemptions,” rather than 

under 10 CFR 50.54(q). Otherwise, continue with Regulatory Position 5.1.e. 

e. Does the proposed change involve program elements associated with one or more emergency 

planning functions as defined in 10 CFR 50.54(q)(1)(iii) and as expanded on in Regulatory 

Position 4 of this guide? If not, the proposed change may be carried out without prior NRC 

approval. Otherwise, continue with Regulatory Position 5.2 

 

5.2 Evaluation Process 

a. The licensee must evaluate proposed changes to the emergency plan, which the above screening 

process did not disposition, under 10 CFR 50.54(q)(3) to determine whether the change reduces 

the effectiveness of the emergency plan. The licensee should submit changes determined to 

reduce the effectiveness of the emergency plan, prior to implementation, to the NRC for approval 

as described in Regulatory Position 5.3. 

b. When considering the effect of a change on one or more program elements, note that a change to 

a single program element may not always reduce the effectiveness of the associated emergency 

planning function. This would need to be considered on a case-by-case basis. In addition, a 

change to a program element under one planning standard may reduce the effectiveness of a 

different planning standard. For example, a change to a training module for emergency 

classification could reduce the effectiveness of the emergency classification process if its content 

is inconsistent with the plan. 

c. The evaluation process should address the items listed below: 

(1) Identify the individual proposed changes to be evaluated. Each proposed change should 

be evaluated separately. The treatment of changes collectively should be reserved for 

(1) repetitive identical changes, (2) editorial or typographical changes such as formatting, 

paragraph numbering, spelling, or punctuation that does not change intent, 

(3) conforming changes, or (4) two or more elements that are interdependent (e.g., a 

change to one element compensates for a change to another element). 
RG-1.219, Rev. 1, Page 38 

(2) For each proposed change, determine the licensing basis for each existing program 

element that is being changed using the guidance in Regulatory Position 1.6. The effect 

of a proposed change cannot be adequately assessed without knowledge of the rationale 

for the original structure of the affected program element. 

(3) Identify the emergency planning functions affected by each proposed change. Use the 

information in Regulatory Position 4 and the evaluation criteria in NUREG-0654 to 

inform this evaluation. Recognize that a proposed change can affect more than one 

emergency planning function. 

(4) Evaluate whether each proposed change would reduce the capability to perform 

emergency planning functions (i.e., reduce the effectiveness of the emergency plan). 

Refer to Regulatory Positions 1 - 4 in making these determinations. 

(5) Compare the NRC-approved emergency plan with the changes being considered to 

evaluate the reduction in effectiveness. In other words, compare the licensee’s 

commitment in the current NRC-approved emergency plan with what would be the 

commitment after the plan is modified. Plant reconfigurations enabled by other change 

processes (e.g., 10 CFR 50.59, 10 CFR 50.48(f), 10 CFR 50.82, 10 CFR 52.110, etc.) do 

not factor into this comparison. This is a yes-no decision: the change would reduce the 

effectiveness of the emergency plan or it would not. There are no degrees of reduction 

(e.g., “minor” reduction). It is inappropriate for a licensee to conclude that certain 

commitments made in the NRC-approved plan are no longer required and to then 

compare the emergency plan as modified to this conclusion, rather than the 

NRC-approved plan. 

(6) Maintain the level of rigor and thoroughness in licensees’ 10 CFR 50.54(q) evaluations 

consistent with the scope of the proposed changes with particular emphasis placed on the 

risk-significant planning standards (10 CFR 50.47(b)(4), (5), (9), and (10)). The NRC 

would consider enforcement action for any 10 CFR 50.54(q) evaluations that are of 

inadequate scope and extent to reasonably assess the effect of the proposed change on the 

effectiveness of the emergency plan. 

(7) Arrange a preapplication call with NRC headquarters staff to discuss the proposed change 

when the licensee is unsure whether the proposed changes constitute a reduction in 

effectiveness. Ask the staff to clarify the regulatory positions in this guide. Note that this 

preapplication conference call does not relieve the licensee of its authority and 

responsibility under 10 CFR 50.54(q)(3) to determine whether the change constitutes a 

reduction in effectiveness. 

(8) In a departure from previous EP guidance, the NRC is no longer separately treating 

alternative methods for complying with EP regulations. The agency expects the licensee 

to evaluate all such alternative approaches under 10 CFR 50.54(q)(3), as it would any 

proposed change, to determine whether the proposed approach reduces the effectiveness 

of the emergency plan. The licensee must submit proposed changes that it determines to 

cause a reduction in effectiveness for prior NRC approval under 10 CFR 50.54(q)(4) and 

Regulatory Position 5.3. 
RG-1.219, Rev. 1, Page 39 

5.3 Approval for Changes That Reduce Effectiveness 

a. The regulation at 10 CFR 50.54(q)(4) requires the licensee to submit a license amendment 

application in accordance with 10 CFR 50.90 for prior NRC approval of a change that it 

believes will reduce the effectiveness of its emergency plan. In addition to the filing 

requirements in 10 CFR 50.90, the application must include all emergency plan pages 

affected by the change and a forwarding letter identifying the change(s), the reason for the 

change(s), and the licensee’s basis for concluding that its emergency plan, as modified, 

continues to meet the planning standards in 10 CFR 50.47(b) and the requirements in 

Appendix E to 10 CFR Part 50. The NRC may approve, deny, or return, as appropriate, the 

license amendment application in accordance with 10 CFR 50.91, “Notice for Public 

Comment; State Consultation,” and 10 CFR 50.92, “Issuance of Amendment.” 

b. If the change is such that any planning standard in 10 CFR 50.47(b) or any requirement in 

Appendix E to 10 CFR Part 50 is not met, the licensee will need to request an exemption 

from the affected requirements in accordance with 10 CFR 50.12. If the NRC grants the 

exemption, there is no need to pursue a license amendment request for the associated 

reduction in effectiveness. 

5.4 Documentation of Changes 

a. The regulation at 10 CFR 50.54(q)(5) requires the licensee to retain a record of each change to the 

emergency plan made without prior NRC approval for a period of 3 years from the date of the 

change. This record should explicitly identify each change made and the basis for the licensee’s 

determination that the change would not require prior NRC approval. All conclusions made under 

10 CFR 50.54(q) should be supported by defensible rationale statements (e.g., “The proposed 

change does not affect planning standard (b)(5) because....”). The amount of rationale will 

necessarily vary with the scope and nature of the change; a simple checkoff is generally not 

acceptable because it cannot represent what the reviewer considered or explain the reviewer’s 

basis for the conclusion. 

b. The regulation at 10 CFR 50.4, “Written Communications,” requires the licensee to submit a 

report of each such change, including a summary of its analysis, within 30 days after the change 

is put into effect. 

c. The regulation at 10 CFR 50.54(q)(6) requires the licensee to retain the emergency plan and each 

change for which it obtained prior NRC approval under 10 CFR 50.54(q)(4) as a record until the 

Commission terminates the license for the nuclear power reactor. Although the licensee is not 

required to maintain records of changes made without prior NRC approval beyond 3 years, a lack 

of change documentation does not absolve the licensee from having to justify any change that is 

subsequently questioned about how it affects the licensee’s emergency plan. As such, a licensee 

may find it prudent to save all emergency plan change documentation to facilitate the resolution 

of such issues. 
RG-1.219, Rev. 1, Page 40 

D. IMPLEMENTATION 

The purpose of this section is to provide information on how applicants and licensees6

 may use 

this guide and information regarding the NRC’s plans for using this RG. In addition, it describes how the 

NRC staff complies with 10 CFR 50.109, “Backfitting” and any applicable finality provisions in 10 CFR 

Part 52, “Licenses, Certifications, and Approvals for Nuclear Power Plants.” 

Use by Applicants and Licensees 

Applicants and licensees may voluntarily7

 use the guidance in this document to demonstrate 

compliance with the underlying NRC regulations. Methods or solutions that differ from those described in 

this RG may be deemed acceptable if they provide sufficient basis and information for the NRC staff to 

verify that the proposed alternative demonstrates compliance with the appropriate NRC regulations. 

Current licensees may continue to use guidance the NRC found acceptable for complying with the 

identified regulations as long as their current licensing basis remains unchanged. 

Licensees may use the information in this RG for actions that do not require NRC review and 

approval such as changes to a facility design under 10 CFR 50.59, “Changes, Tests, and Experiments.” 

Licensees may use the information in this RG or applicable parts to resolve regulatory or inspection 

issues. 

Use by NRC Staff 

The NRC staff does not intend or approve any imposition or backfitting of the guidance in this 

RG. The NRC staff does not expect any existing licensee to use or commit to using the guidance in this 

RG, unless the licensee makes a change to its licensing basis. The NRC staff does not expect or plan to 

request licensees to voluntarily adopt this RG to resolve a generic regulatory issue. The NRC staff does 

not expect or plan to initiate NRC regulatory action which would require the use of this RG. Examples of 

such unplanned NRC regulatory actions include issuance of an order requiring the use of the RG, requests 

for information under 10 CFR 50.54(f) as to whether a licensee intends to commit to use of this RG, or 

generic communication, or promulgation of a rule requiring the use of this RG without further backfit 

consideration. 

During regulatory discussions on plant specific operational issues, the staff may discuss with 

licensees various actions consistent with staff positions in this RG, as one acceptable means of meeting 

the underlying NRC regulatory requirement. Such discussions would not ordinarily be considered 

backfitting even if prior versions of this RG are part of the licensing basis of the facility. However, unless 

this RG is part of the licensing basis for a facility, the staff may not represent to the licensee that the 

licensee’s failure to comply with the positions in this RG constitutes a violation. 

If an existing licensee voluntarily seeks a license amendment or change and (1) the NRC staff’s 

consideration of the request involves a regulatory issue directly relevant to this new or revised RG and (2) 

the specific subject matter of this RG is an essential consideration in the staff’s determination of the 

acceptability of the licensee’s request, then the staff may request that the licensee either follow the 

 

6 In this section, “licensees” refers to licensees of nuclear power plants under 10 CFR Parts 50 and 52; and “applicants,” 

refers to applicants for licenses and permits for (or relating to) nuclear power plants under 10 CFR Parts 50 and 52, and 

applicants for standard design approvals and standard design certifications under 10 CFR Part 52. 

7 In this section, “voluntary” and “voluntarily” mean that the licensee is seeking the action of its own accord, without the 

force of a legally binding requirement or an NRC representation of further licensing or enforcement action. 
RG-1.219, Rev. 1, Page 41 

guidance in this RG or provide an equivalent alternative process that demonstrates compliance with the 

underlying NRC regulatory requirements. This is not considered backfitting as defined in 10 CFR 

50.109(a)(1) or a violation of any of the issue finality provisions in 10 CFR Part 52. 

Additionally, an existing applicant may be required to comply with new rules, orders, or guidance 

if 10 CFR 50.109(a)(3) applies. 

If a licensee believes that the NRC is either using this RG or requesting or requiring the licensee 

to implement the methods or processes in this RG in a manner inconsistent with the discussion in this 

Implementation section, then the licensee may file a backfit appeal with the NRC in accordance with the 

guidance in NRC Management Directive 8.4, “Management of Facility-Specific Backfitting and 

Information Collection” (Ref. 18), and in NUREG-1409, “Backfitting Guidelines,” (Ref. 19). 
RG-1.219, Rev. 1, Page 42 

REFERENCES8

1. U.S. Code of Federal Regulations (CFR), “Domestic Licensing of Production and Utilization 

Facilities,” Part 50, Chapter 1, Title 10, “Energy.” 

2. CFR, “Licenses, Certifications, and Approvals for Nuclear Power Plants,” Part 52, Chapter 1, 

Title 10, “Energy.” 

3. CFR, “Amendments to State Plans,” Part 350.14, Chapter 1, Title 44, “Emergency Management 

and Assistance.” (44 CFR 350.14) 

4. U.S. Nuclear Regulatory Commission (NRC), “Emergency Planning,” Federal Register, Vol. 45, 

August 19, 1980, pp. 55409 (45 FR 55409). 

5. NRC, “Enhancements to Emergency Preparedness Regulations,” Federal Register, Vol. 76, 

No. 226, November 23, 2011, pp. 72560 (76 FR 72560). 

6. 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. 

7. International Atomic Energy Agency (IAEA), “Preparedness and Response for a Nuclear or 

Radiological Emergency,” Safety Standard Series GS-R-2, Vienna, Austria, 2002 (Available at 

http://www-pub.iaea.org/MTCD/Publications/PDF/Pub1133_scr.pdf ) 9

 

8. IAEA “Review and Assessment of Nuclear Facilities by the Regulatory Body” Safety Standard 

Series GS-G-1.2, Vienna, Austria, 2002 (Available at http://wwwpub.iaea.org/books/IAEABooks/6416/Review-and-Assessment-of-Nuclear-Facilities-by-theRegulatory-Body-Safety-Guide ) 

9. NRC Inspection Manual Chapter 2561, “Decommissioning Power Reactor Inspection Program.” 

10. NRC, “Safety Goals for the Operations of Nuclear Power Plants,” Federal Register, Vol. 51, 

August 4, 1986, pp. 30028 (51 FR 30028). 

11. Environmental Protection Agency (EPA), “Manual of Protective Action Guides and Protective 

Actions for Nuclear Incidents,” 400-R-92-001, May 1992. (Available at 

http://www.epa.gov/radiation/docs/er/400-r-92-001.pdf.) 

12. NRC Generic Letter 80-90, “Post-TMI Requirements,” October 31, 1980. 

 

8 Publicly available NRC published documents are available electronically through the NRC Library on the NRC’s 

public Web site at http://www.nrc.gov/reading-rm/doc-collections/ and through the NRC’s 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 NRC’s 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 email pdr.resource@nrc.gov.

9 Copies of International Atomic Energy Agency (IAEA) documents may be obtained through their Web 

site: WWW.IAEA.Org/ or by writing the International Atomic Energy Agency, P.O. Box 100 Wagramer 

Strasse 5, A-1400 Vienna, Austria. 
RG-1.219, Rev. 1, Page 43 

13. NRC, RG 1.101, “Emergency Response Planning and Preparedness for Nuclear Power Reactors.” 

14. NRC, “Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power 

Plants: LWR Edition,” NUREG-0800, Chapter 13, “Conduct of Operations,” Section 13.3, 

“Emergency Planning.” 

15. NRC, “Significance Determination Process,” Inspection Manual Chapter 0609, Appendix B, 

“Emergency Preparedness Significance Determination Process.” 

16. FEMA-REP-10, “Guide for the Evaluation of Alert and Notification Systems for Nuclear Power 

Plants,” November 1985. (ADAMS Accession No. ML102510343) 

17. NRC, “Functional Criteria for Emergency Response Facilities,” NUREG-0696, February 1981. 

18. NRC, “Management of Facility-Specific Backfitting and Information Collection,” Management 

Directive 8.4, October 2013. 

19. NRC, “Backfitting Guidelines,” NUREG-1409, July 1990. 
Appendix A to RG-1.219, Page A-1