NEI 13-01 [Revision 0]

Reportable Action Levels

for Loss of Emergency 

Preparedness 

Capabilities 

July 2014 
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Nuclear Energy Institute, 1201 F Street N. W., Suite 1100, Washington D.C. (202.739.8000) 

NEI 13-01 [Revision 0]

Nuclear Energy Institute 

Reportable Action Levels

for Loss of Emergency 

Preparedness 

Capabilities 

July 2014
ACKNOWLEDGMENTS 

This document was prepared by the Nuclear Energy Institute (NEI) Reportable Action Level 

(RAL) Task Force. 

NEI Chairperson: David Young 

Industry Representatives 

Chris Boone – Southern Nuclear/Corporate 

Don Mothena – NextEra Energy/Corporate 

John Stephenson – Duke Energy/Corporate 

Brian Thomas – PSEG Nuclear/Salem and Hope Creek 

The RAL Task Force Team wishes to express their appreciation for the technical assistance and 

independent reviews provided by the following individuals. 

Doug Walker – Exelon Nuclear/Corporate 

Tony Zimmerman – Duke Energy/Corporate 

NOTICE

Neither NEI, nor any of its employees, members, supporting organizations, contractors, or 

consultants make any warranty, expressed or implied, or assume any legal responsibility for the 

accuracy or completeness of, or assume any liability for damages resulting from any use of, any 

information apparatus, methods, or process disclosed in this report or that such may not 

infringe privately owned rights. 
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EXECUTIVE SUMMARY 

Title 10 of the Code of Federal Regulations (CFR) 50.72, “Immediate Notification Requirements 

for Operating Nuclear Power Reactors,” requires a licensee to report the occurrence of certain 

events to the US Nuclear Regulatory Commission (NRC). In particular, 10 CFR 

50.72(b)(3)(xiii) requires that a licensee report any event that results in a major loss of 

emergency assessment capability, offsite response capability, or offsite communications 

capability as soon as practical and in all cases within eight hours of the occurrence, unless 

already reported under 10 CFR 50.72(a), (b)(1) or (b)(2). The regulatory guidance concerning 

this requirement is contained in NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 

50.73. NUREG-1022 refers to the above three event types collectively as a “Loss of Emergency 

Preparedness Capabilities.” 

The purpose of this technical report is to provide a recommended and uniform approach that will 

promote consistent application of the event reporting guidance associated with a loss of 

emergency preparedness capabilities. To that end, this document provides a set of generic event 

reporting criteria referred to as Reportable Action Levels or RALs. An event described by one 

of these RALs constitutes a major loss of emergency assessment capability, offsite response 

capability, or offsite communications capability, and thus should be reported to the NRC in 

accordance with 10 CFR 50.72(b)(3)(xiii). 

A licensee may use the information from this document to create site-specific RALs for 

assessing an event that potentially involves a reportable loss of emergency preparedness 

capabilities. When doing so, the licensee is encouraged to maintain as much fidelity as possible 

to the generic material contained herein. This approach will help ensure that the resulting RALs 

are consistent with the guidance in NUREG-1022 and minimize the potential for regulatory 

compliance issues associated with subsequent event reporting decisions. 

The guidance presented in this document should only be used to identify a loss of emergency 

preparedness capabilities. It should not be utilized for other reporting purposes or to address 

unrelated regulatory requirements. 

Finally, NEI 13-01 does not address the requirements of 10 CFR 50.73, “Licensee Event Report 

System,” because these requirements are not applicable to the loss of an emergency preparedness 

capability. 
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TABLE OF CONTENTS 

EXECUTIVE SUMMARY ....................................................................................................... i 

1. DEFINITIONS USED IN NEI 13-01 .............................................................................. 1

2. DEVELOPMENT OF SITE-SPECIFIC MATERIAL .......................................................... 4

2.1 INTEGRATION OF MATERIAL INTO EXISTING PROGRAMS/PROCEDURES ....................4

2.2 DEVELOPER USE OF GENERIC MATERIAL ....................................................................4

3. REPORTABLE ACTION LEVELS .................................................................................. 6

3.1 REPORTABLE EVENT: A MAJOR LOSS OF EMERGENCY ASSESSMENT CAPABILITY ...6

3.2 REPORTABLE EVENT: A MAJOR LOSS OF OFFSITE RESPONSE CAPABILITY .............18

3.3 REPORTABLE EVENT: A MAJOR LOSS OF OFFSITE COMMUNICATIONS 

 CAPABILITY ..................................................................................................................23
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REPORTABLE ACTION LEVELS FOR LOSS OF EMERGENCY 

PREPAREDNESS CAPABILITIES 

1. DEFINITIONS USED IN NEI 13-01 

To promote clarity and understanding of the event reporting criteria for a loss of emergency 

preparedness capabilities, the Reportable Action Level (RAL) methodology employs several 

defined terms, i.e., words that have specific meanings as used in this document. The 

development of these term definitions considered related material already in use in 

regulations, and NRC and NEI guidance documents. Defined terms appear in all capital 

letters (i.e., ALL CAPS) and, along with their definitions, are listed below. 

These definitions have been developed specifically for use in the RAL methodology 

described in this document and should not be used for other purposes without 

evaluation/validation of suitability. 

Where warranted, information intended to aid in the understanding of a defined term was 

added in italicized text and bracketed (i.e., [example text]). 

ALERT AND NOTIFICATION SYSTEM (ANS): The system that demonstrates 

compliance with the public alerting and notification planning standard described in 10 CFR 

50.47(b)(5) and the associated requirements of section IV.D of 10 CFR 50, Appendix E. 

ALTERNATE FACILITY: A temporary location that may serve as a Technical Support 

Center (TSC) or Emergency Operations Facility (EOF) in support of a planned work 

activity. [An acceptable ALTERNATE FACILITY must have sufficient capability to support 

effective direction and control of an emergency response; however, it need not meet the 

same design or operating requirements applied to a normally used ERF (e.g., it may not 

possess a protected ventilation system.)] 

BACKUP EMERGENCY RESPONSE FACILITY (ERF): A facility that may serve as the 

TSC or EOF in the event that the primary facility is unavailable, as described in the site 

emergency plan or a procedure described in the emergency plan. [An acceptable BACKUP 

ERF must meet the requirements of 10 CFR 50, Appendix E, sections IV.E.8.a and 8.c, and 

be functionally equivalent to the primary facility.] 

COMPENSATORY MEASURE: A temporary means, established as part of a planned 

activity, to perform a given emergency response function during a period when the normally 

used METHODS are unavailable such that, when implemented, there is a reasonable 

expectation that the function would be accomplished during an actual emergency, albeit in a 

possibly degraded manner. [A COMPENSATORY MEASURE need not meet the same 

design or operating requirements as the normally used METHODS but must be sufficient to 

support effective implementation of the site emergency plan. Also refer to the related term 

“VIABLE.”] 

EMERGENCY ACTION LEVEL (EAL): A pre-determined, site-specific, observable 

threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in 
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2 

a given emergency classification level, as described in the site emergency plan or an 

implementing procedure described in the emergency plan. 

EMERGENCY ASSESSMENT: The evaluation of plant information such as operational 

and radiological indications and data, and reports from onsite and offsite sources, to 

determine the consequences of an accident or other emergency-related event, and the 

appropriate measures for mitigation and protection of the public. [RADIOLOGICAL 

ASSESSMENT is a sub-function of EMERGENCY ASSESSMENT.] 

EMERGENCY NOTIFICATION SYSTEM (ENS): A telephonic communications system 

designed to allow a licensee to provide timely notifications to the NRC Operations Center of 

off-normal incidents affecting a facility, and information concerning the operation and status 

of the plant. 

EMERGENCY RESPONSE DATA SYSTEM (ERDS): The direct near real-time electronic 

data link between a licensee's onsite computer system and the NRC Operations Center that 

provides for the automated transmission of a limited data set of selected parameters as 

required by section VI of 10 CFR 50, Appendix E. 

EMERGENCY RESPONSE FACILITY (ERF): A licensee facility that demonstrates 

compliance with planning standard 10 CFR 50.47(b)(8) and is staffed by members of the 

licensee’s EMERGENCY RESPONSE ORGANIZATION during an emergency. 

EMERGENCY RESPONSE ORGANIZATION (ERO): The organization of qualified 

licensee personnel that demonstrates compliance with planning standard 10 CFR 

50.47(b)(2). 

FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA): The federal government 

agency with responsibility for reviewing and assessing offsite emergency plans and 

preparedness for adequacy, and making findings and determinations as to whether offsite 

emergency plans are adequate and can be implemented. 

HEALTH PHYSICS NETWORK (HPN): A telephonic communications system designed 

to allow a licensee to provide health physics (radiological) and environmental monitoring 

information to the NRC Operations Center during an emergency. 

INITIATING CONDITION (IC): An event or condition that aligns with the definition of 

one of the four emergency classification levels by virtue of the potential or actual effects or 

consequences, as described in the site emergency plan or an implementing procedure 

described in the emergency plan. [An IC provides one or more EALs which, when met, will 

require an emergency declaration.] 

METHOD: A means that could be employed to perform an emergency response function as 

described in the site emergency plan or an implementing procedure described in the 

emergency plan. [Site emergency plans and implementing procedures typically describe 

primary and one or more alternate METHODS for performing a given function. Provided 

that at least one METHOD is available, then the ability to perform the associated function 

has not been lost.] 
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OFFSITE RESPONSE ORGANIZATION (ORO): Those state, local and tribal agencies 

with primary responsibility for coordinating and implementing offsite emergency measures. 

RADIOLOGICAL ASSESSMENT: An evaluation of plant parameters and radiological 

data performed to determine potential or actual offsite doses during an emergency. [This 

function is sometimes referred to as “dose assessment” and supports the performance of 

EMERGENCY ASSESSMENT.] 

REACTOR COOLANT SYSTEM (RCS): The system used to remove energy from the 

reactor core. 

REPORTABLE ACTION LEVEL (RAL): A predetermined, site-specific, observable 

threshold that, when met or exceeded, requires notification of the associated event to the 

NRC in accordance with 10 CFR 50.72(b)(3)(xiii). 

RESTORATION TIME: The time available for restoring a lost structure or piece of 

equipment to service. [Where allowed, RESTORATION TIMES are specified in the RALs.] 

VIABLE: A COMPENSATORY MEASURE that (1) can restore a required function in a 

reasonably comparable manner and (2) is proceduralized prior to an event. [Proceduralized 

means that the necessary instructions to perform a function exist in a document (e.g., a 

procedure, a user aid, a night or standing order, etc.) that will be followed by response 

personnel should an emergency occur. Further, individuals expected to implement the 

COMPENSATORY MEASURE must be aware of the measure, in advance of its potential or 

actual implementation. A VIABLE COMPENSATORY MEASURE does not include reliance 

upon “skill-of-the-craft” or individual judgment.] 
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2. DEVELOPMENT OF SITE-SPECIFIC MATERIAL 

2.1 INTEGRATION OF MATERIAL INTO EXISTING PROGRAMS/PROCEDURES

The site-specific event reporting guidance developed in accordance with this document 

should be incorporated into existing programs and procedures in the manner deemed 

most appropriate by the licensee. The selected approach should maintain alignment with 

current practices, and minimize organizational impacts and necessary document changes. 

It is not intended that a separate (stand-alone) program or procedure be created to address 

new or revised reporting guidance. 

In order to ensure that the site-specific RALs are properly aligned with the guidance 

contained in NUREG-1022, developers are urged to closely adhere to the material 

presented in the Developer Notes included in Section 3. These notes provide information 

for adjusting the generic RAL thresholds to properly reflect site-specific considerations 

and emergency plan requirements. It is recognized that some differences from the 

generic guidance may be necessary to address unique site characteristics; in these cases, it 

is recommended that a rationale for the difference be developed and incorporated within 

the RAL basis. 

It is important that the event evaluation criteria contained in this document be 

implemented as an integrated package. Using selected portions of the guidance is 

strongly discouraged as it could lead to potentially inaccurate or inadequate event 

reporting. 

A failure to adhere to the above development guidance may result in RALs that are not 

consistent with the guidance in NUREG-1022 and increases the potential for regulatory 

compliance issues associated with subsequent event reporting decisions. 

2.2 DEVELOPER USE OF GENERIC MATERIAL

The RAL scheme developer will use the generic guidance in NEI 13-01 to prepare a set 

of site-specific RALs. A review of all applicable NRC requirements and guidance should 

be performed prior to beginning this work. Consistent with the structure and format of 

the existing fleet or site reporting guidance document(s), incorporation of RAL-related 

information should include the following elements: 

 Reportable Event: The summary description of the 3 events involving a loss of 

Emergency Preparedness (EP) capabilities - emergency assessment capability, offsite 

response capability, or offsite communications capability. 

 RALs: The predetermined, site-specific, observable thresholds that, when met or 

exceeded, will require notification of the associated event to the NRC in accordance 

with 10 CFR 50.72(b)(3)(xiii). The RAL alpha-numeric designations and Table 

identifiers may be changed as necessary to align with the format of the existing fleet 

or site reporting guidance document(s). 
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 Basis: Background information that supports proper decision-making for event 

reporting. 

 Definitions: The definitions from Section 1 should be included somewhere within the 

fleet or site reporting guidance document(s) to ensure consistent and proper 

application of the RALs. Where warranted, information intended to aid in the 

understanding of a defined term was added in italicized text and bracketed (i.e., 

[example text]); this text should be kept with the definitions when incorporated into 

the licensee’s document. 

In cases where fleet-wide/corporate-level RAL guidance will be developed, the RAL 

scheme developer should ensure that the resulting RALs are consistent which each site’s 

EP licensing basis (e.g., reflects site-specific commitments, capabilities and equipment 

for each facility). 

Finally, the reporting guidance document(s) should contain clear instructions to the user 

that a report to the NRC is required if an RAL is met. 

Questions or comments concerning the material in this document may be directed to the 

NEI Emergency Preparedness staff, NEI RAL task force members or submitted to the 

Emergency Preparedness Frequently Asked Questions (EPFAQ) process.
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3. REPORTABLE ACTION LEVELS 

3.1 REPORTABLE EVENT: A MAJOR LOSS OF EMERGENCY ASSESSMENT CAPABILITY

Example Reportable Action Levels:

Note: Review both the RALs and the Basis section information before making a report. 

1) Loss of EMERGENCY ASSESSMENT capability meeting the Unplanned or 

Planned Event criteria in Tables A, B1, B2 or C. 

Table A – Loss of Emergency Classification Capability 

Unplanned Event 

a. Loss of a structure or equipment, including indications, display systems and 

annunciators, that prevents the evaluation of ALL EALs for an emergency 

INITIATING CONDITION. 

Planned Event 

a. Loss of a structure or equipment, including indications, display systems and 

annunciators, that prevents the evaluation of ALL EALs for an emergency 

INITIATING CONDITION for greater than 24 hours. 

AND 

b. ANY of the following: 

1. No VIABLE COMPENSATORY MEASURE is in place. 

 OR 

2. Lost structures or equipment necessary to evaluate at least one EAL are 

not expected to be restored within 72 hours from the start of the outage. 

 OR 

3. Lost structures or equipment necessary to evaluate at least one EAL are 

not restored within 72 hours from the start of the outage. 
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Table B1 – UNPLANNED Loss of Emergency Response Facilities and Equipment 

a. Loss of a structure or equipment that would prevent the performance of 

EMERGENCY ASSESSMENT in ANY of the following ERFs if an emergency 

were to occur. 

 Control Room 

 Primary Technical Support Center 

 Primary Emergency Operations Facility 

 AND 

b. The capability to perform EMERGENCY ASSESSMENT was not restored 

within the RESTORATION TIME specified in Table B1-1. 

Table B1-1 

ERF RESTORATION TIME 

Control Room None 

Primary Technical Support 

Center 

(site-specific time #1) from the time of 

the unplanned loss, if known, OR 

absent that knowledge, the time-ofdiscovery. 

Primary Emergency Operations 

Facility 

(site-specific time #2) from the time of 

the unplanned loss, if known, OR 

absent that knowledge, the time-ofdiscovery. 

 

 AND

c. The lost EMERGENCY ASSESSMENT capability cannot be performed at a 

BACKUP EMERGENCY RESPONSE FACILITY. 
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Table B2 – PLANNED Loss of Emergency Response Facilities and Equipment 

a. Loss of a structure or equipment, for greater than 24 hours, which would prevent 

the performance of EMERGENCY ASSESSMENT in ANY of the following 

ERFs if an emergency were to occur. 

 Control Room 

 Primary Technical Support Center 

 Primary Emergency Operations Facility 

 AND 

b. ANY of the following: 

 1. (a) The capability to perform EMERGENCY ASSESSMENT 

cannot be restored within the RESTORATION TIME specified 

in Table B2-1. 

Table B2-1 

ERF RESTORATION TIME 

Control Room None 

Primary Technical 

Support Center 

(site-specific time #1) following an emergency 

declaration, should one occur. 

Primary Emergency 

Operations Facility 

(site-specific time #2) following an emergency 

declaration, should one occur. 

 AND 

 (b) No VIABLE COMPENSATORY MEASURE is in place. 

 AND 

 (c) The lost EMERGENCY ASSESSMENT capability cannot be 

performed at an ALTERNATE FACILITY. 

 OR 

2. The lost structure or equipment is not expected to be restored within 72 

hours from the start of the outage. 

 OR 

3. The lost structure or equipment is not restored within 72 hours from the 

start of the outage. 
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 AND

c. The lost EMERGENCY ASSESSMENT capability cannot be performed at a 

BACKUP EMERGENCY RESPONSE FACILITY. 
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Table C – Loss of Radiological Assessment Capability 

Unplanned Event 

a. Loss of a structure or equipment that would prevent the performance of 

RADIOLOGICAL ASSESSMENT for ANY of the following assessment 

options/types. 

(site-specific list #1) 

Planned Event 

a. Loss of a structure or equipment that would prevent the performance of 

RADIOLOGICAL ASSESSMENT for ANY of the following assessment 

options/types for greater than 24 hours. 

(site-specific list #1) 

AND 

b. ANY of the following: 

1. No VIABLE COMPENSATORY MEASURE is in place. 

 OR 

2. The lost structure or equipment is not expected to be restored within 72 

hours from the start of the outage. 

 OR 

3. The lost structure or equipment is not restored within 72 hours from the 

start of the outage. 

Basis: 

This Reportable Event addresses a major loss of EMERGENCY ASSESSMENT capability such 

that a response function necessary for determining accident or event consequences, and 

appropriate measures for mitigation and protection of the public, would be significantly impaired 

if an emergency were to occur. A report would be required for an ongoing condition that meets 

the criteria in one of the RAL Tables above, as well as such a condition that occurred within 3 

years of the date of discovery.
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A degraded capability will exist when a METHOD(S) used to perform an EMERGENCY 

ASSESSMENT function is unavailable but the reporting criteria contained in the applicable RAL 

Table above are not met. A degraded EMERGENCY ASSESSMENT capability should not be 

reported. Examples of a degraded condition are provided below. 

EMERGENCY ASSESSMENT capability subsumes the functions to classify an emergency and 

perform RADIOLOGICAL ASSESSMENTS; however, separate RALs were included to better 

address the unique aspects of these functions and related industry operating experience. Refer to 

Tables A and C, respectively. This approach to the presentation of information notwithstanding, 

users should evaluate a structure or equipment loss against the criteria in all Tables. 

The criteria in the RAL Tables distinguish between losses which are planned and unplanned. A 

planned loss is one that results from a scheduled work activity such as component maintenance, 

testing, modification or replacement. An unplanned loss would typically involve the failure of a 

structure or piece of equipment. 

A VIABLE COMPENSATORY MEASURE is implemented as part of a planned activity. It 

need not meet the same design or operating requirements as the normally used METHODS; 

however, its effectiveness should be sufficient to ensure that the supported emergency response 

function would be accomplished during an actual emergency, albeit in a possibly degraded 

manner. A VIABLE COMPENSATORY MEASURE must be proceduralized, i.e., the necessary 

instructions to perform a function must exist in a document that will be followed by response 

personnel should an emergency occur. A VIABLE COMPENSATORY MEASURE cannot rely 

upon “skill-of-the-craft” or individual judgment. 

It is recognized that the performance of a VIABLE COMPENSATORY MEASURE may require 

more time to complete than a normally used METHOD(S) (e.g., performance of a sample 

analysis vs. a radiation monitor reading). The fact that a VIABLE COMPENSATORY 

MEASURE requires more time to implement than a normally used METHOD(S) does not 

automatically mean that the associated EMERGENCY ASSESSMENT capability has been lost. 

The time necessary to implement a VIABLE COMPENSATORY MEASURE should not be 

unreasonably long and minimized to the degree practical. 

Discussion of Table A – Loss of Emergency Classification Capability 

Table A addresses a loss of the capability to obtain parameter values or information necessary 

for the evaluation of EAL thresholds for a given IC, such that an emergency could not be 

declared per that IC. In cases where multiple EALs are provided for the IC, the loss of the 

capability to evaluate one or more of them constitutes a degraded capability so long as one or 

more of them can still be evaluated, and an emergency could be declared per that IC. In 

addition, given that the readings from certain radiation monitors may be used to perform a 

RADIOLOGICAL ASSESSMENT, the loss of a radiation monitor should also be assessed using 

the criteria in Table C. 
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Each IC in the Fission Product Barrier Table has multiple fission product barrier thresholds1

. 

Each of these threshold should be treated as an EAL for reporting evaluation purposes. 

Events that should be assessed using the Table A criteria include those involving a loss of data 

acquisition, computation and display systems at the Technical Support Center (TSC) or 

Emergency Operations Facility (EOF) where such systems support emergency classification. 

Such events should also be assessed against the appropriate Table B1 (unplanned) or B2 

(planned) criteria, and related Basis information. 

It is recognized that the assessment of some EALs may require more time than others to 

complete (e.g., performance of a sample analysis vs. a radiation monitor reading). The time 

necessary to perform an EAL assessment is not a factor in determining whether a loss is 

reportable. 

Two examples are provided for clarification. 

1. An IC with multiple EALs that assess the same condition: A site has an IC for high RCS 

radioactivity with two EALs – one based on a letdown monitor reading and one based on 

a sample analysis. The monitor is removed from service for maintenance. This event 

represents a degraded condition because the IC can still be evaluated using the sample 

analysis data; it is not reportable. If a concurrent failure were to occur that prevented the 

collection or analysis of an RCS sample, then both EALs could not be evaluated and, 

thus, the IC could not be evaluated. This event would be reportable. 

2. An IC with multiple EALs that assess different conditions: A site has an IC for natural or 

manmade hazards with 4 EALs – one for high wind speed, one for a seismic event, one 

for an explosion and one for flooding (i.e., only one EAL for assessing each condition). 

The seismic monitoring system suffers a failure such that the one seismic-related EAL 

cannot be evaluated. This event would be reportable because the remaining EALs under 

the IC assess conditions that are unrelated to a seismic event. 

The criterion(ia) for initiating a METHOD to assess an EAL using indications available from 

sources outside the Control Room should be proceduralized; initiation of the METHOD should 

not be dependent upon “skill-of-the-craft” or individual judgment. For example, consider a site 

with two EALs related to the plant vent – one using a radiation monitor reading and the other 

using the results of an effluent sample analysis. The criteria for requiring initiation of the plant 

vent sampling process should be defined in a procedure. 

                                                            

1

 [Developer note: For users of NUMARC-007, and NEI 99-01 revisions 4 and 5, these ICs are FU1, FA1, FS1 and 

FG1. For NEI 99-01 revision 6 users, the ICs are FA1, FS1 and FG1.] 
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Discussion of Tables B1 and B2 for Loss of Emergency Response Facilities and Equipment 

Table B1 and B2 address an unplanned or planned loss of a structure or equipment that results in 

the inability to perform EMERGENCY ASSESSMENT at an ERF. These RALs should be 

evaluated following a reported or planned degradation of any of the following items to determine 

if a loss of EMERGENCY ASSESSMENT capability has occurred: 

 Structural integrity 

 Lighting 

 Power sources 

 Data acquisition, computation and display systems; including those used for 

RADIOLOGICAL ASSESSMENT (dose projection) purposes 

 Heating, Ventilation and Air Conditioning (HVAC) systems and components 

 Habitability systems and components (e.g., HEPA or charcoal filters) 

 Unique design features necessary for facility operation (e.g., flooding protection) 

 Any other item that could render an EMERGENCY ASSESSMENT function unavailable. 

As used in these Tables, an inability to perform EMERGENCY ASSESSMENT should not be 

assumed to have occurred simply because a structure or equipment design parameter is exceeded 

or feature nonfunctional. Rather, the decision should be based on whether or not ERO personnel 

could effectively perform EMERGENCY ASSESSMENT functions within the facility, using the 

equipment and data available. This decision should consider both the ability to activate the 

facility as well as the capability for protracted operation under emergency conditions. 

The following two examples are provided for clarification. 

1. An ERF has two METHODS for supplying electrical power - an offsite power source and 

a backup generator capable of powering all loads needed for the performance of 

EMERGENCY ASSESSMENT functions. An unplanned event involving a loss of 

power to the ERF would be reportable only if both the offsite power source and the 

backup power generator are simultaneously unavailable, and the other criteria in Table 

B1 are met. The unavailability of the offsite power source alone, or the backup power 

generator alone, represents a degraded condition and would not require a report. 

2. Procedures describe one METHOD for providing plant data to ERFs as the Safety 

Parameter Display System (SPDS)2

 and another METHOD that relies upon manual 

                                                            

2

 For purposes of this example, the name of the site-specific computer system that provides accident-related 

information to the ERFs may be substituted. Some common names include the Main Plant Computer System, Plant 

Process Computer or the Emergency Response Facility Information System. 
NEI 13-01 (Revision 0) 

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actions (e.g., use of a communicator). An unplanned event involving a loss of the SPDS 

would be reportable only if the ability to perform the manual METHOD was 

simultaneously unavailable, and the other criteria in Table B1 are met. The unavailability 

of the SPDS alone, or the manual METHOD alone, represents a degraded condition and 

would not require a report. 

If a licensee has an ALTERNATE FACILITY or a BACKUP ERF that is capable of performing 

the functions of the primary facility, consistent with the Table B1 and B2 criteria, then 

EMERGENCY ASSESSMENT is not significantly impaired during the period that the primary 

facility is not available. As a result, NRC action or awareness is not likely warranted in such 

scenarios, and therefore a report would not be needed. 

A report is not required if the lost capability affects only an ALTERNATE FACILITY or a 

BACKUP ERF, and the primary ERF remains available. 

Since the Control Room is always activated, a RESTORATION TIME does not apply to this 

facility. 

Discussion of Table C – Loss of Radiological Assessment Capability 

Table C addresses the loss of a structure or equipment that provides the parameter values or 

information necessary for performing a RADIOLOGICAL ASSESSMENT for a given 

assessment option/type during an emergency3. In cases where multiple METHODS for 

obtaining data or information are provided for given assessment option/type, the loss of one or 

more METHODS constitutes a degraded capability so long as one or more of them can still be 

performed. In addition, given that certain radiation monitor readings are specified in EALs, the 

loss of a radiation monitor should also be assessed using the criteria in Table A. 

It is recognized that some backup/alternate METHODS used to provide data and information for 

a RADIOLOGICAL ASSESSMENT may require more time than others to complete (e.g., 

performance of a sample analysis vs. a radiation monitor reading). The time necessary to 

implement a backup/alternate METHOD is not a factor in determining whether a loss is 

reportable. 

The inability to perform RADIOLOGICAL ASSESSMENT at an ERF is evaluated in 

accordance with Tables B1 and B2, since it is a sub-function of EMERGENCY ASSESSMENT. 

Table C primarily addresses the loss of structures and equipment that provide inputs to a 

RADIOLOGICAL ASSESSMENT (e.g., those used to ascertain radiation levels, radiological 

release rates or meteorological parameters). 

                                                            

3

 These assessment options/types are sometimes referred to as the “release pathways”. 
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The following examples are provided for clarification. 

A site has an offsite dose assessment process that employs three options/types – plant 

vent, main steam line and containment source term. Each option/type has two 

performance METHODS described in the site emergency plan and/or an implementing 

procedure described in the emergency plan. Likewise, the site possesses two METHODS 

for obtaining the meteorological data necessary to perform a RADIOLOGICAL 

ASSESSMENT for any release option/type. The plant vent monitor has two detectors 

and associated channels, a low-range and a high-range; the low-range can provide data 

supporting emergency classifications up to Alert level, and the high-range from the Site 

Area Emergency through the General Emergency level. 

Case 1: The high-range channel fails (becomes nonfunctional) while the low-range 

channel remains in service. The low-range channel is NOT an acceptable 

METHOD to compensate for the loss of the high-range channel because it 

cannot provide data throughout the range necessary to evaluate all emergency 

classification levels. The site’s backup METHOD, which uses a 

“grab”/manual effluent sample process, is available to provide the data 

normally provided by the high-range channel. This event represents a 

degraded capability and would not be reportable because the plant vent 

assessment option/type can still be evaluated for all emergency classification 

levels.4

Case 2: Continued from Case 1 – The plant vent low-range channel also fails 

(becomes nonfunctional); however, the “grab”/manual effluent sample process 

is available to provide this data as well. This event represents a degraded 

capability and would not be reportable because the plant vent assessment 

option/type can still be evaluated for all emergency classification levels. 

Case 3: Continued from Case 2 – The backup METHOD that relies upon a 

“grab”/manual effluent sample process becomes unavailable due to the failure 

of the required analysis equipment; both described METHODS for obtaining 

radiological data necessary for performing a RADIOLOGICAL 

ASSESSMENT using the plant vent assessment option/type are now 

unavailable. This condition represents a loss of EMERGENCY 

ASSESSMENT capability and would be reportable. 

Case 4: The plant vent assessment option/type relies upon 3 meteorological data 

inputs – upper wind speed, upper wind direction and upper ΔT. The upper 

wind speed instrument on the primary meteorological tower (the primary 

METHOD) becomes nonfunctional while the corresponding instrument on the 

backup tower (the backup METHOD) remains in service. This event 

represents a degraded capability and would not be reportable. 

                                                            

4

 Absent the availability of a backup METHOD, the event as described to this point would be reportable. 
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Case 5: Continued from Case 4 – The upper wind speed instrument on the backup 

meteorological tower becomes nonfunctional; the backup METHOD for 

obtaining this data is now also lost. All described METHODS for obtaining 

upper wind speed, which is meteorological data necessary for performing a 

RADIOLOGICAL ASSESSMENT using the plant vent assessment 

option/type, are now unavailable. This condition represents a loss of 

EMERGENCY ASSESSMENT capability and would be reportable. 

In cases where a radiation monitor has multiple detectors and related channels that provide input 

data for performing a RADIOLOGICAL ASSESSMENT, and an unplanned failure occurs that 

removes a detector or channel from service, a loss of RADIOLOGICAL ASSESSMENT 

capability is considered to have occurred only if the data range of the remaining available 

detectors and channels is not sufficient to support the evaluation of all EALs associated with that 

release assessment option/type (e.g., a low-range channel that cannot read a General Emergencyrelated release rate or concentration from the plant vent), and there is no other data collection 

METHOD available. 

The criterion(ia) for initiating a RADIOLOGICAL ASSESSMENT METHOD using indications 

available from sources outside the Control Room should be proceduralized; initiation of the 

METHOD should not be dependent upon “skill-of-the-craft” or individual judgment. For 

example, consider a site with two METHODS to obtain a plant vent effluent release 

concentration – one using a radiation monitor reading and the other using the results of an 

effluent sample analysis. The criteria for requiring initiation of the plant vent sampling process 

should be defined in a procedure. 

Other Information 

A time limit of 24-hours has been applied to planned events. If this threshold and the other 

related RAL criteria are met, the subsequent report will allow the NRC to be aware of the 

situation and determine if additional actions are necessary. 

72 hours was included to the RAL Tables to reflect guidance from NUREG-0696, Functional 

Criteria for Emergency Response Facilities. This guidance suggests an equipment unavailability 

factor of no more than approximately 1% per year, or about 87 hours per year. This was rounded 

down to 72 hours to align with other NRC reporting criteria. 

Developer Notes: 

Tables B1 and B2 specify the ERFs staffed by augmented ERO personnel typically responsible 

for performance of EMERGENCY ASSESSMENT functions (consistent with the guidance 

provided in NUREG-0696). Other ERFs should not be included in this RAL unless they perform 

an EMERGENCY ASSESSMENT function similar to that done in the TSC or EOF. For 

example, the OSC and Joint Information Center would typically not be included because 

personnel in these facilities do not perform EMERGENCY ASSESSMENT functions. 

(site-specific time #1) – Enter the maximum elapsed time allowed for activation of the TSC as 

described in the site emergency plan or an implementing procedure described in the emergency 

plan. 
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(site-specific time #2) – Enter the maximum elapsed time allowed for activation of the EOF as 

described in the site emergency plan or an implementing procedure described in the emergency 

plan. 

(site-specific list #1) – list the RADIOLOGICAL ASSESSMENT options /types that could be 

evaluated during an emergency as described in the site emergency plan or an implementing 

procedure described in the emergency plan5

. For example, a site-specific list of 

RADIOLOGICAL ASSESSMENT options /types for a hypothetical 2-loop pressurized water 

reactor might include: 

 Plant Vent 

 Fuel Storage Building Vent 

 Main Steam Line A 

 Main Steam Line B 

 Containment 

 Unmonitored 

If desired, developers may include lists of site-specific systems, structures and components 

within the RALs or in referenced tables. 

Developers should incorporate site-specific terminology where appropriate. 

                                                            

5

 These assessment options/types are sometimes referred to as the “release pathways”. 
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3.2 REPORTABLE EVENT: A MAJOR LOSS OF OFFSITE RESPONSE CAPABILITY

Example Reportable Action Levels: (1 or 2)

Note: Review both the RALs and the Basis section information before making a report. 

1) a. The occurrence of a significant natural hazard (e.g., earthquake, hurricane, 

tornado, flood, major winter storms, etc.) or other event of similar scope and 

impact. 

AND 

b. The hazard or event results in ANY of the following: 

1. An ORO agency has provided information indicating that they are 

unable to implement protective measures for the public as described in 

their emergency plan if an actual emergency were to occur (e.g., key 

evacuation routes are impassable, loss of response infrastructure, etc.). 

OR 

2. ERO personnel coming from offsite locations could not report to their 

onsite response locations within (site-specific time #1) if an actual 

emergency were to occur. 

OR 

3. ANY of the ERFs listed in Table A could not be activated within the 

specified Timeframes if an actual emergency were to occur. 

Table A 

ERFs Timeframe 

Primary Technical Support Center (site-specific time #2) 

Primary Operational Support Center (site-specific time #2) 

Primary Emergency Operations Facility (site-specific time #2) 

OR 
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4. ANY of the local offsite support agencies listed in Table B would be 

unable to access the site if their assistance were to be requested. 

Table B 

Local Offsite Support Agency 

(site-specific list #1) 

[Developer Note – for sites with a FEMA-approved backup alerting METHOD(S) that 

does not meet the primary ANS design objective stated in 10 CFR Part 50, Appendix E, 

IV.D.3, use the RAL wording below.] 

2) a. Unplanned or planned loss of ANY of the following primary ANS equipment 

for greater than one hour: 

(site-specific list #2) 

AND 

b. ANY of the following: 

1. The FEMA-approved backup alerting METHOD(S) cannot be 

implemented for the area affected by the lost primary ANS equipment. 

OR 

2. The primary ANS equipment is not expected to be returned to service 

within 24 hours. 

OR 

3. The primary ANS equipment was not returned to service within 24 

hours. 

[Developer Note – for sites with a FEMA-approved backup alerting METHOD(S) that 

does meet the primary ANS design objective stated in 10 CFR Part 50, Appendix E, 

IV.D.3, use the RAL wording below.] 

2) a. Unplanned or planned loss of ANY of the following primary ANS equipment 

for greater than one hour: 

(site-specific list #2) 

AND 
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b. The FEMA-approved backup alerting METHOD(S) cannot be implemented 

for the area affected by the lost primary ANS equipment. 

Basis: 

This Reportable Event addresses a major loss of offsite response capability that could prevent the 

on-shift staff from obtaining needed response assistance or offsite officials from implementing 

key functions needed for protection of the public if an emergency were to occur. The loss of an 

individual structure or piece of equipment that supports performance of the offsite response 

capability is reportable only to the extent that it meets an RAL threshold; a degraded capability 

caused by a failure or planned activity should not be reported. A report would be required for an 

ongoing condition that meets one the RALs above, as well as such a condition that occurred 

within 3 years of the date of discovery. 

RAL #1 is met when the licensee has confirmed that an event has caused conditions which meet 

any of the RAL criteria. Because a significant natural hazard is an unplanned event, no allowed 

outage duration or RESTORATION TIMES are specified. 

As used in RAL #1, an ORO agency should be one with primary responsibility for coordinating 

and implementing offsite emergency measures. 

Impediments to evacuation such as fog, snow, and ice, should generally not be reported if they 

are within the respective capabilities of the licensee, state, or local officials to resolve or 

mitigate. Rather, the reporting requirement is intended to apply to more significant events such 

as the conditions around the Turkey Point Nuclear Plant after Hurricane Andrew struck in 1992 

or the conditions around the Cooper Nuclear Station during the Midwest floods of 1993. During 

this type of event, a licensee should periodically gather and assess information available from 

OROs and other sources to determine if a loss offsite response capability has occurred. 

For RAL #2 – an unplanned ANS outage - An unplanned outage would typically be initiated by 

the failure of a structure or piece of equipment. The specified durations begin when the failure 

occurred, if firm evidence of the failure time exists. This includes instances where a failure time 

is logged by an automated diagnostics and reporting technology for subsequent and periodic 

review by personnel (e.g., a data logger that captures routine siren feedback results). Absent 

firm evidence of a failure time, the specified durations begin with the time-of-discovery. 

For RAL #2 – a planned ANS outage - A planned outage is one that results from a scheduled 

work activity such as component maintenance, testing, modification or replacement. The 

specified durations begin when the ANS component(s) are removed from service. 

[Developer Note – for sites with a FEMA-approved backup alerting METHOD(S) that does not 

meet the primary ANS design objective stated in 10 CFR Part 50, Appendix E, IV.D.3, insert the 

RAL basis wording below.] 

For RAL #2, the unplanned and planned loss cases have been combined. The one-hour condition 

duration reflects guidance provided in NUREG-1022. Because the FEMA-approved backup 

alerting METHOD(S) does not meet the performance criteria of 10 CFR 50, Appendix E, Section 

IV.D.3, a time limit of 24-hours has been applied. If this threshold is met, the subsequent report 
NEI 13-01 (Revision 0) 

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will allow the NRC to discuss the situation with FEMA and determine if additional actions are 

necessary. 

[Developer Note – for sites with a FEMA-approved backup alerting METHOD(S) that does 

meet the primary ANS design objective stated in 10 CFR Part 50, Appendix E, IV.D.3, insert the 

RAL basis wording below.] 

For RAL #2, the unplanned and planned loss cases have been combined. The loss of the primary 

system is not reportable since the available FEMA-approved backup alerting METHOD(S) 

meets the same design objective as the primary alerting METHOD(S). 

Developer Notes:

(site-specific time #1) - Enter the maximum elapsed time allowed for the arrival of augmenting 

ERO personnel to the site as described in the site emergency plan or an implementing procedure 

described in the emergency plan. If different time values are specified, use the lowest value. 

(site-specific time #2) – Enter the maximum elapsed time allowed for activation of the TSC, 

OSC and EOF as described in the site emergency plan or an implementing procedure described 

in the emergency plan.

(site-specific list #1) – List the local offsite support agencies that may be requested to respond to 

the site, as described in the site emergency plan. These should include the “first responder” 

agencies that support the on-shift ERO with the initial response to an event and may include a 

fire department, an ambulance service or local law enforcement. It is not the intent to include 

organizations that support the augmented ERO (e.g., a reactor vendor specialist who reports to 

the TSC) or that otherwise are not expected to report to the site during the initial response to an 

event. 

(site-specific list #2) – The primary ANS system for a site may employ one or more technologies 

for public alerting – examples include sirens, tone alert radios, “reverse 911” notification 

systems, etc. The list for this RAL should specify the primary ANS equipment, or combinations 

of equipment, that, in the event of their failure, would result in the loss of the capability to alert a 

large segment of the population in the EPZ. For purposes of developing this list, “a large 

segment of the population in the EPZ” should be taken to mean approximately 25% of the total 

EPZ population. 

Variations in population density/distribution should be considered when identifying potential 

combinations of lost equipment (e.g., sirens) that could cause the “25% of the total EPZ 

population” threshold to be exceeded. For example, depending upon the site-specific ANS 

design and EPZ characteristics (e.g., topography, population density/distribution, etc.), the 

criterion “approximately 25% of the total EPZ population” may or may not correlate to 25% of 

the sirens6

. Developers should also consider the need to list siren or other alerting system 

                                                            

6

 To further illustrate this point, consider that a loss of 10% of the sirens in high population density area could be 

more significant than a loss of 25% of the sirens in a low population density area. Simply averaging the number of 

EPZ sirens over the EPZ total population will generally be unacceptable. 
NEI 13-01 (Revision 0) 

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activation and control equipment that may be used during an emergency as described in a 

FEMA-approved offsite emergency plan7 or a FEMA-approved ANS design report. 

The process used to develop the equipment list for this RAL should be documented and be 

available for subsequent review; it need not be incorporated into a reporting procedure. 

Developers should incorporate site-specific terminology where appropriate. 

                                                            

7

 Approved in accordance with 44 CFR 350 and related guidance. 
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3.3 REPORTABLE EVENT: A MAJOR LOSS OF OFFSITE COMMUNICATIONS CAPABILITY

Example Reportable Action Level:

Note: Review both the RAL Tables and the Basis section information before making a 

report. 

1) Loss of an offsite communications capability meeting the Unplanned or Planned 

Event criteria in Tables A, B, C, D, E or F. 

Table A – Loss of the Emergency Notification System (ENS) 

ENS METHOD Control Room Primary TSC Primary EOF 

ENS Line   

(other site-specific 

ENS METHODS) 

(enter  where 

appropriate) 

(enter  where 

appropriate) 

(enter  where 

appropriate) 

RESTORATION 

TIME None (site-specific 

time #1) 

(site-specific 

time #1) 

Unplanned Event 

a. ALL the ENS METHODS checked above for a given facility are lost. 

Planned Event 

a. ALL the ENS METHODS checked above for a given facility are lost. 

AND 

b. ANY of the following: 

1. (a) At least one METHOD could not be restored to service within 

the specified RESTORATION TIME following an emergency 

declaration, should one occur. 

 AND 

(b) No VIABLE COMPENSATORY MEASURE is in place. 
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OR 

2. At least one METHOD is not expected to be restored within 72 hours 

from the start of the outage. 

 OR 

3. At least one METHOD is not restored within 72 hours from the start of 

the outage. 
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Table B – Loss of the Health Physics Network (HPN) 

HPN METHOD Primary TSC Primary EOF 

HPN Line  

(other site-specific HPN METHODS) (enter  where 

appropriate) 

(enter  where 

appropriate) 

RESTORATION TIME (site-specific 

time #1) 

(site-specific 

time #1) 

Unplanned Event 

a. ALL the HPN METHODS checked above for a given facility are lost. 

Planned Event 

a. ALL the HPN METHODS checked above for a given facility are lost. 

AND 

b. ANY of the following: 

1. (a) At least one METHOD could not be restored to service within the 

specified RESTORATION TIME following an emergency 

declaration, should one occur. 

AND 

(b) No VIABLE COMPENSATORY MEASURE is in place. 

OR 

2. At least one METHOD is not expected to be restored within 72 hours 

from the start of the outage. 

OR 

3. At least one METHOD is not restored within 72 hours from the start 

of the outage. 
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Table C – Loss of ORO Communications 

Communications 

METHOD Control Room Primary TSC Primary EOF 

(site-specific ORO 

Communications 

METHODS) 

(enter  where 

appropriate)

(enter  where 

appropriate)

(enter  where 

appropriate)

Unplanned Event 

a. ALL the ORO communications METHODS checked above for a given facility 

are lost. 

Planned Event 

a. ALL the ORO communications METHODS checked above for a given facility 

are lost. 

AND 

b. ANY of the following: 

1. (a) At least one METHOD could not be restored to service within 15 

minutes of an emergency declaration, should one occur. 

AND 

(b) No VIABLE COMPENSATORY MEASURE is in place. 

OR 

2. At least one METHOD is not expected to be restored within 72 hours 

from the start of the outage. 

OR 

3. At least one METHOD is not restored within 72 hours from the start of 

the outage. 
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Table D – Loss of ERO Notifications 

ERO Notification METHODS 

(site-specific ERO Notification METHODS)

Unplanned Event 

a. ALL the ERO notification METHODS listed above are lost. 

Planned Event 

a. ALL the ERO notification METHODS listed above are lost. 

AND 

b. ANY of the following: 

1. (a) At least one METHOD could not be restored to service within 15 

minutes of an emergency declaration, should one occur. 

AND 

(b) No VIABLE COMPENSATORY MEASURE is in place. 

OR 

2. At least one METHOD is not expected to be restored within 72 hours 

from the start of the outage. 

OR 

3. At least one METHOD is not restored within 72 hours from the start of 

the outage. 
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Table E – Loss of ERF Communications 

Communications 

METHOD Control Room Primary TSC Primary EOF 

(site-specific ERF 

Communications 

METHODS) 

(enter  where 

appropriate) 

(enter  where 

appropriate) 

(enter  where 

appropriate) 

RESTORATION 

TIME None (site-specific 

time #1) 

(site-specific 

time #1) 

Unplanned Event 

a. ALL the ERF communications METHODS checked above for a given facility 

are lost. 

Planned Event 

a. ALL the ERF communications METHODS checked above for a given facility 

are lost. 

AND 

b. ANY of the following: 

1. (a) At least one METHOD could not be restored to service within the 

specified RESTORATION TIME following an emergency 

declaration, should one occur. 

AND 

(b) No VIABLE COMPENSATORY MEASURE is in place. 

OR 

2. At least one METHOD is not expected to be restored within 72 hours 

from the start of the outage. 

OR

3. At least one METHOD is not restored within 72 hours from the start of 

the outage. 
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Table F – Loss of ERO Offsite Monitoring Team Communications 

ERO Offsite Monitoring Team (OMT) Communications METHODS 

(site-specific ERO OMT Communications METHODS) 

Unplanned Event 

a. ALL the offsite monitoring team communications METHODS listed above are 

lost. 

Planned Event 

a. ALL the offsite monitoring team communications METHODS listed above are 

lost. 

AND 

b. ANY of the following: 

1. (a) At least one METHOD could not be restored to service within (sitespecific time #2) of an emergency declaration, should one occur. 

AND 

(b) No VIABLE COMPENSATORY MEASURE is in place. 

OR 

2. At least one METHOD is not expected to be restored within 72 hours 

from the start of the outage. 

OR

3. At least one METHOD is not restored within 72 hours from the start of 

the outage. 
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Basis: 

This Reportable Event addresses a major loss of offsite communications capability that could 

prevent a licensee from performing required communications with federal, state, and local 

officials; or between the site and ERO personnel at offsite locations. A report would be required 

for an ongoing condition that meets the criteria in one of the RAL Tables above, as well as such 

a condition that occurred within 3 years of the date of discovery. 

A degraded capability will exist when a METHOD(S) used to perform a communications 

function is unavailable but the reporting criteria contained in the applicable RAL Table above are 

not met. A degraded offsite communications capability should not be reported. For example, if 

an ERF has two METHODS for maintaining communications with an ORO, an unplanned event 

involving a simultaneous loss of both methods would be reportable. The loss of either 

METHOD alone represents a degraded condition, and thus would not require a report. 

The criteria in the RAL Tables distinguish between losses which are planned and unplanned. A 

planned loss is one that results from a scheduled work activity such as component maintenance, 

testing, modification or replacement. An unplanned loss would typically involve the failure of a 

structure or piece of equipment. 

A VIABLE COMPENSATORY MEASURE is implemented as part of a planned activity. It 

need not meet the same design or operating requirements as the normally used METHODS; 

however, its effectiveness should be sufficient to ensure that the supported emergency response 

function would be accomplished during an actual emergency, albeit in a possibly degraded 

manner. A VIABLE COMPENSATORY MEASURE must be proceduralized, i.e., the necessary 

instructions to perform a function must exist in a document that will be followed by response 

personnel should an emergency occur. A VIABLE COMPENSATORY MEASURE cannot rely 

upon “skill-of-the-craft” or individual judgment. 

It is recognized that the performance of a VIABLE COMPENSATORY MEASURE may require 

more time to complete than a normally used METHOD(S). The fact that a VIABLE 

COMPENSATORY MEASURE requires more time to implement that a normally used 

METHOD(S) does not automatically mean that the associated offsite communications capability 

has been lost. The time necessary to implement a VIABLE COMPENSATORY MEASURE 

should not be unreasonably long and minimized to the degree practical. 

Since the Control Room is always activated, a RESTORATION TIME does not apply to this 

facility. 

The 72-hour value reflects guidance from NUREG-0696, Functional Criteria for Emergency 

Response Facilities. This guidance suggests an equipment unavailability factor of no more than 

approximately 1% per year, or about 87 hours per year. This was rounded down to 72 hours to 

align with other NRC reporting criteria. 

ERDS was implemented as a supplement to the ENS in accordance with Appendix E of 10 CFR 

50. The ERDS provides the NRC with the information necessary for performance of its 

oversight function. The loss of ERDS cannot impair a licensee’s emergency response or 
NEI 13-01 (Revision 0) 

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communications capabilities during an emergency; therefore, a failure of the ERDS does not 

constitute a major loss of offsite communication capability and should not be reported. 

Although a notification may not be required under 10 CFR 50.72(b)(3)(xiii) in the event of a loss 

of the ENS, HPN, or ERDS, the NRC Operations Center should be informed of any failure of 

NRC-supplied communications equipment so that the NRC may arrange for repair. The 

commercial telephone number 301-816-5100 may be used to inform the NRC Operations Center 

of a failed piece of equipment. At the time the failure is reported, the licensee should be 

prepared to supply the following information to expedite repair: (1) name of contact at location 

of failure, (2) commercial phone number of contact, (3) location of contact (i.e., street address, 

building number, room number, etc., and (4) any other information that would expedite repair. 

If the NRC Operations Center provides the initial notification that an ENS line is out-of-service, 

then there is no need to make a report provided that another communications METHOD listed in 

Table A is available. 

Developer Notes:

(site-specific time #1) – Enter the maximum elapsed time allowed for activation of the primary 

TSC and EOF as described in the site emergency plan, or an implementing procedure described 

in the emergency plan. 

(site-specific time #2) – Enter the maximum elapsed time allowed for activation of the ERF that 

controls ERO offsite monitoring team personnel as described in the site emergency plan, or an 

implementing procedure described in the emergency plan. If more than on ERF could perform 

this function and different time values are specified for each, use the lowest value. 

(other site-specific ENS METHODS) – Enter the METHOD(S) that may be used by each facility 

to maintain ENS communications in the event that the ENS line is not available, as described in 

the site emergency plan or an implementing procedure described in the emergency plan. Add as 

many table rows as necessary to include all METHODS and place checkmarks where 

appropriate. 

(other site-specific HPN METHODS) – Enter the METHOD(S) that may be used by each facility 

to maintain HPN communications in the event that the HPN line is not available, as described in 

the site emergency plan or an implementing procedure described in the emergency plan. Add as 

many table rows as necessary to include all METHODS and place checkmarks where 

appropriate. 

(site-specific ORO Communications METHODS) – Enter the METHOD(S) that may be used by 

each facility to communicate with the ORO agency(ies) that receives notification of an 

emergency, as described in the site emergency plan or an implementing procedure described in 

the emergency plan. Add as many table rows as necessary to include all METHODS and place 

checkmarks where appropriate. 

(site-specific ERO Notification METHODS) – Enter the METHOD(S) that may be used to notify 

the ERO of an emergency during off-hours, as described in the site emergency plan or an 
NEI 13-01 (Revision 0) 

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implementing procedure described in the emergency plan. Add as many table rows as necessary 

to include all METHODS. 

(site-specific ERF Communications METHODS) – Enter the METHOD(S) that a given ERF 

may use to communicate with other ERFs, as described in the site emergency plan or an 

implementing procedure described in the emergency plan. Add as many table rows as necessary 

to include all METHODS and place checkmarks where appropriate. 

(site-specific ERO OMT Communications METHODS) – Enter the METHOD(S) that may be 

used by ERO offsite monitoring team personnel to communicate with their controlling ERF, as 

described in the site emergency plan or an implementing procedure described in the emergency 

plan. Add as many table rows as necessary to include all METHODS. 

Concerning the ERDS reporting rationale provided in the Basis, it is noted that if a licensee did 

rely upon the ERDS for data transmittal between ERO ERFs, then the loss of the ERDS would 

be appropriately assessed as a potential loss of EMERGENCY ASSESSMENT capability in 

accordance with RAL 3.1. 

Developers should incorporate site-specific terminology where appropriate.