____________ 

POLICY ISSUE 

(Information) 

October 28, 2016 SECY-16-0125 

FOR: The Commissioners 

FROM: Victor M. McCree 

Executive Director for Operations 

SUBJECT: ANNUAL UPDATE ON THE STATUS OF EMERGENCY PREPAREDNESS 

AND INCIDENT RESPONSE PROGRAM ACTIVITIES 

PURPOSE: 

The purpose of this paper is to update the Commission on the U.S. Nuclear Regulatory 

Commission’s (NRC’s) emergency preparedness (EP) and incident response (IR) program 

activities for fiscal year (FY) 2016, and provide an assessment of the NRC’s EP and IR 

programs with a focus on current and projected activities. This paper does not address any 

new commitments or resource implications. 

Included in this update, in Enclosure 1, is a final disposition of the eight medium and low 

priority EP rulemaking issues that the staff had previously committed (W200900090) to 

resolving in SECY-09-0152, “Annual Update on the Status of Emergency Preparedness 

Activities” (Agencywide Document Access and Management System (ADAMS) Accession No. 

ML091900372). 

SUMMARY: 

The NRC’s EP and IR programs continue to align with the agency’s strategic security and safety 

goals. During FY 2016, the staff completed multiple complex EP licensing, rulemaking and 

research actions, and IR activities. Some of these actions and activities included: developing 

safety evaluation input for independent spent fuel storage installation (ISFSI)-only emergency 

plan changes for Zion, Kewaunee, and Crystal River decommissioning sites; providing 

EP-specific support for the mandatory hearings for the South Texas Project and Levy combined 

operating license (COL) applications; successful completion of all the new regulatory 

CONTACT: Jeannette Arce, NSIR/DPR 

 (301) 287-9053 
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requirements for hostile action-based (HAB) exercises; conducting research on offsite 

response organizations (OROs) to ensure NRC assumptions about OROs’ intermediate-phase 

protective action decisions and associated capabilities are modeled as accurately as 

possible; and successful implementation of the Eagle Horizon 2016 evaluated exercise. 

BACKGROUND: 

In the staff requirements memorandum (SRM) to SECY-07-0182, “Semi-Annual Update on the 

Status of Emergency Preparedness Activities,” dated December 21, 2007 (ADAMS Accession

No. ML073550647), the Commission provided the following direction: 

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

perhaps summarizing accomplishments and providing a status on improvement 

initiatives within our EP programs. Such an assessment should be coordinated with and 

not overlap the Reactor Oversight Process self-assessment of the EP cornerstone, and 

should be designed to aid the staff in effecting continuous and coordinated 

improvements to the overall EP program, as well as to inform the Commission and the 

public of progress. 

DISCUSSION: 

Accomplishments 

This paper provides an update on the major FY 2016 activities within the NRC’s EP and IR 

programs, including regulatory oversight of licensee programs and internal preparedness to 

respond to events. The discussion that follows is organized by product lines in the NRC’s 2016 

budget structure, which includes licensing, oversight, rulemaking, event response, research, 

and international activities. Notable EP and IR accomplishments, program status, and 

improvements relevant to these product lines are described. 

Key improvement initiatives and management goals for the EP and IR programs for FY 2016 

included: maintaining readiness of the NRC IR organization and operations centers; completing 

EP licensing activities associated with decommissioning reactors; developing the EP-specific 

portions of the decommissioning rulemaking; and ensuring clear expectations and compatibility 

with stakeholders on broader all-hazards approaches. The accomplishments described below 

demonstrate a clear nexus to these goals. 

Licensing — Emergency Preparedness Casework 

The Office of Nuclear Security and Incident Response (NSIR) serves as a centralized agency 

resource for EP licensing support and technical reviews for operating reactors, 

decommissioning reactors, new reactors, research and test reactors, fuel facilities, and spent 

fuel facilities. 

The staff completed the technical reviews and developed safety evaluation input for several EPrelated license amendment requests associated with emergency action level (EAL) scheme 

changes adopting the latest NRC-endorsed guidance Revision 6 to the Nuclear Energy Institute 

(NEI) 99-01, “Methodology for Development of Emergency Action Levels.” The staff also 
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evaluated license amendment requests on EAL scheme changes for Vogtle Units 3 and 4, and 

V.C. Summer Units 2 and 3, to address deviations and differences from the guidance provided 

in NEI 07-01, “Methodology for Development of Emergency Action Levels Advanced Passive 

Light Water Reactors.” 

A significant licensing activity included the review of a “fleet-wide” emergency plan for the 

Southern Nuclear Operating Company, Inc. (SNC). This action accomplished several things: 

re-baselined the common SNC emergency plan and respective annexes to remove extraneous 

detail from the plans, which facilitates licensee changes under Title 10 of the Code of Federal 

Regulations (10 CFR) 50.54(q) and integrated emergency plans for Vogtle Units 3 and 4, 

currently under construction, with operating Units 1 and 2. 

The staff continues to evaluate a license amendment request from Duke Energy to incorporate 

the off-site emergency operations facility (EOF) for the recently acquired former Progress 

Energy sites (H.B. Robinson, Hatch, and Brunswick) into the existing Duke Energy Corporate 

EOF. The existing Duke Energy Corporate EOF serves as a common EOF for the Catawba, 

McGuire, and Oconee sites. Since the Duke Energy Corporate EOF is located greater than 25 

miles from these sites, prior Commission approval is required under Appendix E to 

10 CFR Part 50. If the staff finds the submittal acceptable, the staff will submit a SECY paper 

requesting Commission approval of the license amendment request. 

The staff completed technical evaluations and development of safety evaluation input for license 

amendment requests for four decommissioning sites (Crystal River, Kewaunee, Vermont 

Yankee, and San Onofre) previously exempted from certain emergency planning standards of 

10 CFR 50.47 and requirements of Appendix E to 10 CFR Part 50. Among these license 

amendment requests was the addition of an ISFSI to the permanently defueled emergency plan 

and EAL scheme for the Crystal River site. The staff also completed the technical evaluation 

and development of safety evaluation input for license amendment requests for ISFSI-only 

emergency plans for Zion, Kewaunee, and Crystal River decommissioning sites to address 

further reductions in on-shift and Emergency Response Organization (ERO) staffing and 

augmentation, as well as EALs, based on the removal and transfer of spent fuel from the spent 

fuel pool to dry cask storage. 

The staff is also preparing for the technical reviews of potential decommissioning EP exemption 

requests for the Fort Calhoun, Clinton, Quad Cities, Oyster Creek, and Pilgrim sites. The staff 

will perform these reviews using the recently developed guidance in NSIR/DPR-ISG-02, “Interim 

Staff Guidance (ISG) on Emergency Planning Exemption Requests for Decommissioning 

Nuclear Power Plants,” issued May 11, 2015 (ADAMS Accession No. ML13304B442). 

In FY 2016, the staff continued to conduct EP reviews on new reactor applications. Specifically, 

the staff completed reviews for three COLs, and two new reactor design certifications. EP staff 

from NSIR also served as members on the new reactor oversight working group; the Regulatory 

Guide 1.206, “Combined License Applications for Nuclear Power Plants,” update working group; 

the standardized inspections, tests, analyses, and acceptance criteria working group; and the 

radioisotope production facilities construction inspection procedure working group. In addition, 

the staff provided input to Chapter 1.5.5 (Receipt, Possession, Use, and Transportation of 

Source, Byproduct, and Special Nuclear Material Authorized by 10 CFR 52 Combined 

Licenses), Chapter 13.3 (Emergency Planning), Chapter 14.3 (Certified Design Material), and 
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Chapter 20.4 (Emergency Preparedness) for the final safety evaluation reports for the Levy, 

Lee, Turkey Point, and North Anna COLs, and Chapter 12.4.7 (Emergency Planning) for the 

final safety evaluation report for the SHINE Medical Technologies construction permit 

application. The staff also supported the mandatory hearings for the South Texas Project and 

Levy COLs, Public Service Enterprise Group early site permit, and the SHINE Medical 

Technologies construction permit applications. The staff continues to support EP reviews of the 

construction permit application for the Northwest Medical Isotopes Radioisotope production 

facility, certification of the Advanced Power Reactor 1400 design, recertification of the Advanced 

Boiling Water Reactor design certification, and pre-application activities for the NuScale small 

modular reactor design certification. 

The staff completed technical evaluations and development of safety evaluation input on the 

research reactor license renewals for the University of Missouri, the University of 

Massachusetts, and the University of Florida. These reviews evaluated the emergency plans 

for these three facilities using the guidance provided in ANSI/ANS-15.16-2015, “Emergency 

Planning for Research Reactors.” Additionally, the staff completed a technical evaluation and 

development of safety evaluation input for a change to the technical specifications for the 

University of Missouri Research Reactor. 

The staff completed technical evaluations and development of safety evaluation input for five 

fuel cycle facility emergency plan changes, evaluating the changes made by the respective 

licensees against the regulations in 10 CFR 70.32(i). Additionally, the staff completed technical 

evaluations and development of safety evaluation input for license renewals for the General 

Electric Hitachi Nuclear Energy Vallecitos Nuclear Center and the Westinghouse Columbia Fuel 

Fabrication Facility. These reviews evaluated the emergency plans for these two facilities using 

the guidance provided in NUREG-1520, “Standard Review Plan for Fuel Cycle Facilities License 

Applications.” 

The staff is also supporting the EP acceptance review for a license application from Waste 

Control Specialists (WCS) to build and operate a Consolidated Interim Storage Facility for spent 

nuclear fuel and greater-than-class-C waste. A pre-application audit was held March 14, 2016, 

to discuss the application process and NRC expectations with WCS. WCS formally submitted 

their license application by letter dated April 28, 2016. To date, the staff has written several 

Requests for Supplemental Information (RSI) and are reviewing the responses. NSIR staff 

continues to support meetings with WCS to discuss RSI responses as part of the acceptance 

review. 

Licensing — Regulatory Issue Summary on Emergency Response Organization Staffing 

To promote better industry consistency in licensee ERO staffing and improved the quality of 

submittals, the staff published RIS 2016-10, “License Amendment Requests for Changes to 

Emergency Response Organization Staffing and Augmentation” (ADAMS Accession No. 

ML16124A002), following public meetings with industry and lessons-learned from recent 

submittals. The regulatory issue summary (RIS) was developed in response to a number of 

license amendment requests that did not sufficiently justify requested changes to ERO staffing. 

The RIS will help ensure that future license amendment requests provide appropriate 

justification, and that staff can complete their review in a timely and predictable manner. 
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Licensing — Near-Term Task Force Emergency Preparedness Activities 

On April 30, 2015, the staff provided the Commission with a proposed consolidated rulemaking 

package in SECY-15-0065, “Mitigation of Design-Basis Events” (ADAMS Accession No. 

ML15049A213). In the associated SRM, dated August 27, 2015, the Commission approved the 

publication of the proposed rule in the Federal Register (FR) for public comment, subject to 

changes directed by the Commission. The staff published this proposed rule for comment in 

November 2015. The comment period for the rule closed in February 2016 and the staff 

received a total of 20 comment submissions. The staff is in the process of responding to these 

comments and making revisions to the rule and supporting documents. The current timeline is 

to provide the final rule package to the Commission in December 2016. 

In SECY-15-0137, “Proposed Plans for Resolving Open Fukushima Tier 2 and 3 

Recommendations,” dated October 29, 2015 (ADAMS Accession No. ML15254A006), the staff 

proposed closure plans for the following open Tier 2 and Tier 3 EP recommendations: 10.3, 

Emergency Response Data System Enhancements, 11.2, Evaluate Recovery and Reentry 

Insights from Fukushima, and 11.4, Training in the Local Community on Radiation, Radiation 

Safety, and the use of Potassium Iodide. The staff also included the proposed plan for closure 

of the Tier 3 Item “Basis of Emergency Planning Zone Size and Pre-staging Potassium Iodide 

Beyond 10-miles.” The staff also proposed that Recommendation 11.3, “Study the efficacy of 

real-time radiation monitoring onsite and within the EPZs (including consideration of ac 

independence and real-time availability on the internet)” remain open for further evaluation and 

interaction with stakeholders. 

 

On February 8, 2016, the Commission approved the staff’s proposed closure plans for the open 

Tier 2 and 3 recommendations. Recommendation 11.3 remains open to facilitate further 

assessment and documentation and stakeholder engagement. The staff intends to provide the 

Commission with the resolution plan for Recommendation 11.3 before the end of calendar year 

(CY) 2016. 

Licensing — Revision of NUREG-0654/FEMA-REP-1 

NUREG-0654/FEMA-REP-1, “Criteria for Preparation and Evaluation of Radiological 

Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,” is a joint 

NRC and the Federal Emergency Management Agency (FEMA) guidance document originally 

issued in November 1980. Both agencies use the document to evaluate the adequacy of 

radiological emergency plans and preparedness: the NRC evaluates applicants and licensees, 

and FEMA evaluates State, local, and Tribal governments within the emergency planning zones 

(EPZs) surrounding nuclear power plants (NPP). 

In 2012, the NRC and FEMA began a major effort to update NUREG-0654/FEMA-REP-1 to 

reflect current regulations (including the 2011 NRC EP final rule) and to integrate nearly 

35 years of lessons learned in the EP program. One important aspect of the revision of 

NUREG-0654/FEMA-REP-1 is that it will enable better alignment between the radiological EP 

programs and the Comprehensive Emergency Management Programs or “all-hazards” 

programs, which are set forth in the National Preparedness Doctrine and supported by the 

National Preparedness System. This enhancement will help ensure that the NRC and licensee 
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programs remain reflective of broader emergency-management concepts that would be 

employed if there were an NPP incident with off-site radiological consequences. 

In 2015, the NRC and FEMA achieved a major project milestone by jointly issuing draft Revision 

2 of NUREG-0654/FEMA-REP-1 for a 135-day public comment period. The staff received 42 

comment submissions from external stakeholders. Following the closure of the comment 

period, the NRC, in coordination with FEMA, considered the comments and revised the 

document, as appropriate. The NUREG is currently in concurrence at both agencies. The staff 

expects to issue the final version of Revision 2 of NUREG-0654/FEMA-REP-1 by the end of 

February 2017. 

Licensing — the Federal Emergency Management Agency Interface 

On December 7, 2015, an updated “Memorandum of Understanding [MOU] between the 

Department of Homeland Security/Federal Emergency Management Agency and Nuclear 

Regulatory Commission Regarding Radiological Response, Planning and Preparedness” 

(ADAMS Accession No. ML15344A371), was approved by NRC’s Executive Director of 

Operations and the FEMA Administrator. The MOU updates and consolidates three earlier 

MOUs that guide how NRC and FEMA cooperate on all aspects of radiological emergency 

response, planning, and preparedness. In addition, the updated MOU retains the Steering 

Committee for Emergency Planning. The revised MOU does not alter any existing agency 

roles, responsibilities, or commitments of resources. 

Staff continues to use the Steering Committee for Emergency Planning to work with FEMA’s 

Technological Hazards Division to discuss, and as necessary, obtain resolution on joint issues 

regarding radiological EP. Notably, NRC is working with FEMA to better understand initiatives 

to change radiological EPs and potential implications on NRC-licensed facilities. 

 

Rulemaking — Hostile Action-Based Exercises 

The December 23, 2011, Emergency Preparedness rule (76 FR 72560) amended 

Appendix E to Part 50 to require that nuclear power reactor licensees consider hostile 

action and conduct hostile action based (HAB) exercises. In December 2015, Wolf Creek 

completed the HAB exercise scenario demonstration as required in 10 CFR 50 Appendix 

E.IV.F.2.j. This marked full implementation (across the industry) of the regulatory 

requirements in the 2011 EP rule. 

Following completion of the Wolf Creek HAB exercise, the staff developed a HAB-exercise 

lessons-learned report that was completed on July 25, 2016 (ADAMS Accession No. 

ML16207A435). The report will enhance the planning, logistics, and demonstrations of 

future HAB exercises. Concurrently, the FEMA/NRC EP Steering Committee formed a 

joint FEMA/NRC Working Group to collect observations from all involved stakeholders, and 

to independently develop reports detailing significant observations captured during the first 

cycle of HAB exercises. The staff will next assess the independently developed report 

observations, make recommendations for those observations determined to need further 

action, and create an action plan to implement them. 
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Rulemaking — Decommissioning Rulemaking and Technical Basis 

In SECY-15-0014, “Anticipated Schedule and Estimated Resources for a Power Reactor 

Decommissioning Rulemaking,” dated January 30, 2015 (ADAMS Accession No. 

ML15082A089), the NRC staff committed to proceed with a rulemaking on decommissioning 

and provided an anticipated schedule and estimate of the resources required for the 

completion of this rulemaking. 

The Power Reactor Decommissioning Rulemaking Working Group developed an Advance 

Notice of Proposed Rulemaking (ANPR), which was issued on November 19, 2015. A public 

meeting was held on December 9, 2015, explaining the content of the ANPR to assist 

stakeholders in submitting informed comments. Public comments were accepted until March 

18, 2016. The staff is proceeding with the development of a draft regulatory basis, which is 

scheduled to be issued for public comment in mid-December 2016. The proposed rulemaking 

package is scheduled to be provided to the Commission in CY 2018. The final rulemaking 

package is scheduled to be provided to the Commission in CY 2019. 

 

Rulemaking — Emergency Preparedness for Small Modular Reactors and other New 

Technologies 

In response to the SRM for SECY-15-0077, “Options for Emergency Preparedness for Small 

Modular Reactors and Other New Technologies,” dated August 4, 2015, (ADAMS Accession 

No. ML15216A492), an interagency working group developed SECY-16-0069, “Rulemaking 

Plan on Emergency Preparedness for Small Modular Reactors and Other New Technologies” 

(ADAMS Accession No. ML16020A388). The staff proposed a plan for rulemaking to address 

the growing need to define emergency planning for new reactor designs for light-water and nonlight-water moderated advanced reactors, and for medical isotope production and utilization 

facilities. 

Substantial public interest is expected on this rulemaking because of the potential to 

significantly change the traditional offsite EP requirements for SMRs and other new 

technologies. Staff has had extensive interactions with other Federal agencies, in different 

forums, to broaden the awareness of and seek the cooperation of NRC’s Federal partners. The 

staff will continue interactions with the Federal Radiological Preparedness Coordinating 

Committee (FRPCC) to discuss issues of mutual interest to the NRC, FEMA, and other 

government organizations. On August 22, 2016, the staff held a Category 3 public meeting to 

discuss and receive feedback about the merits of and challenges with a performance-based 

approach to this rulemaking. The staff anticipates issuing a draft regulatory basis for comment 

in March 2017. 

Rulemaking — Appendix E Administrative Rule Change/Enforcement Guidance Memorandum 

and Regulatory Issue Summary 

In 2013 licensees submitted to the NRC over 750 administrative changes to Emergency Plan 

Implementing Procedures (EPIPs), in accordance with Section V of Appendix E to 10 CFR Part 

50. Staff determined that the submittal of emergency plan and EPIP changes, based solely on 

the Section V requirement, has no impact on the NRC’s regulatory oversight of licensees, and 

that the Section V submittals impose a significant and unnecessary administrative burden on the 
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licensees and NRC staff. In coordination with the Office of Enforcement, staff developed and 

issued an enforcement guide memorandum (EGM) to grant enforcement discretion to licensees 

for not submitting updates in accordance with Section V, and to provide temporary relief from 

the administrative burden. EGM 15-003 "Enforcement Discretion Not to Cite Certain Violations 

of Section V of Appendix E to 10 CFR Part 50 for Non-Submittal of Emergency Plan and 

Emergency Plan Implementing Procedure Changes by Operating Reactor Licensees, While 

Rulemaking Changes are Being Developed" (ADAMS Accession No. ML15223A098) was 

issued on October 23, 2015. Additionally, staff developed and issued an associated RIS to 

inform licensees and stakeholders of the issuance of EGM 15-003. RIS 2015-14 “Issuance of 

Enforcement Guidance Memorandum — Emergency Plan and Emergency Plan Implementing 

Procedure Updates” was issued on October 30, 2015 (ADAMS Accession No. ML15233A223). 

EGM 15-003 was developed as an immediate measure to provide temporary relief from the 

reporting requirement in Section V of Appendix E to 10 CFR Part 50. The EGM was issued 

contingent upon the development and implementation of a final resolution that amends Section 

V to eliminate the reporting requirement from the regulations. Staff determined that the most 

expedient and efficient means to eliminate the requirement was to incorporate the change into 

the Miscellaneous Corrections Rulemaking that was being developed by the Office of 

Administration. The final rule was published on December 1, 2015, (80 FR 74974) and went 

into effect on December 31, 2015. As of the effective date, Section V of Appendix E no longer 

requires the reporting of EPIP changes, and the long-term resolution identified in EGM 15-003 

has been implemented. 

Event Response – U.S. Nuclear Regulatory Commission Incident Response Program and 

Exercises 

The staff planned and participated in the Fitzpatrick/Nine Mile Point, Beaver Valley, and 

Arkansas Nuclear One evaluated reactor-licensee emergency exercises during FY 2016 from 

the Headquarters Operations Center (HOC); the regional offices also participated in 17 reactor 

licensee exercises. The evaluated exercise involving two separate NPPs, Fitzpatrick and Nine 

Mile Point, offered a unique opportunity to test and evaluate the response organization’s ability 

to manage simultaneously occurring events at separated facilities. 

In addition, the staff planned and participated in two exercises with fuel cycle facilities during FY 

2016. On October 14, 2015, the NRC and URENCO USA participated in a limited scope 

exercise to examine both organizations’ ability to establish and maintain communications, and 

for URENCO to train their staff on communications with the NRC’s HOC during an event. On 

September 14, 2016, the NRC and Babcock & Wilcox Nuclear Operations Group, Inc. (BWXT 

NOG) participated in a full scope exercise. 

Event Response – Southern Exposure 2015 Exercise Agency Recovery Plan 

During the preparations for and execution of the Southern Exposure 2015 (SE15) exercise, staff 

identified needed improvements in the agency’s readiness to support responsibilities under the 

Price-Anderson Act (PAA), and Federal doctrine/guidance for recovery from nuclear/radiological 

incidents. As a result, staff prepared and exercised capabilities in this area during the SE15 

exercise and collected lessons learned that would inform continued development of the plan. 
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The PAA contains detailed requirements for the NRC to fulfill in the event of an incident at an 

operating reactor that results in offsite consequences. The staff is developing an agency 

recovery plan that will facilitate addressing the full scope of the NRC’s recovery-related 

requirements. 

Internal and external after action reports for the SE15 exercise were completed in spring 2016. 

Event Response — Protective Action Guides Update Efforts 

The NRC staff is participating in an effort by the FRPCC to update the U.S. Environmental 

Protection Agency (EPA) Protective Action Guides (PAG) manual, which was published in 1992. 

The updated PAG manual provides recommended numerical PAGs for the principal protective 

actions available to responsible officials during a radiological incident. A PAG is a specific 

protective action guideline designed to help reduce or avoid the projected dose to an individual 

from a release of radioactive material. A draft document for interim use was published in 2013 

and included updated dosimetry, changes to the intermediate and late phase PAGs (i.e., 

removed the intermediate phase relocation PAG of 5 rem over 50 years and maintained the 

relocation PAG of 2 rem the first year and not to exceed 500 millirem in any subsequent year), 

and guidance on optimization for recovery. Although the EPA did not include drinking water 

PAGs in this draft for interim use, they requested input on the appropriateness of such PAGs. 

As a result of the comments received, the EPA developed a plan for drinking water PAGs that 

are consistent with the Food and Drug Administration food PAGs (500 millirem/yr). The draft 

drinking water PAGs were used in the SE15 exercise. The EPA published the draft drinking 

water PAGs for a 45-day public comment period in the Federal Register on June 10, 2016. The 

final PAG guidance, including the drinking water PAGs, is expected to be published in 2016. 

Event Response — Nuclear Radiological Incident Annex Update Efforts 

Staff participated in a FRPCC-led interagency effort to revise the nuclear radiological incident 

annex (NRIA). This annex to the Response and Recovery Federal Interagency Operational 

Plans, under the National Response Framework (NRF) and National Disaster Recovery 

Framework (NDRF), reflects existing authorities’ roles and responsibilities for nuclear and 

radiological incidents (including, but not limited to, NRC-regulated activities). In addition, the 

revision reflects new response and recovery concepts from the revised NRF and NDRF and 

incorporates lessons learned from Fukushima, other events, and exercises. In 2016 the draft 

NRIA was used and validated during several exercises including Gradient Aspect, Eagle 

Horizon, and Vibrant Response. 

The revision of the NRIA supports building more robust national communication with the “whole 

community” of responders. In addition, the NRC’s participation helped to maintain cooperative 

intergovernmental relationships to ensure the NRC roles and responsibilities are considered and 

reflected in national resiliency capabilities. The NRC anticipates that the final NRIA will be 

issued in the near-term. 
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Event Response — Continuity of Operations Program 

The staff continues to enhance the operational aspects of the Continuity of Operations Program 

(COOP) program. In FY 2016, the staff completed the annual update to the NRC COOP plan 

and procedures based on lessons learned during the Eagle Horizon 2015 exercise; in addition, 

the staff developed new planning tools. In coordination with Federal partners, the NRC 

planned, coordinated, and conducted the biennial, externally-evaluated, full-scale exercise 

Eagle Horizon 2016. The NRC received high marks for its participation from external 

evaluators. An after action report has been developed, and the lessons learned include 

enhancing employee accountability; clarifying the relationship between IR and COOP response 

activities; and enhancing communications with internal and external stakeholders. These and 

other lessons learned will be incorporated into the next annual update to the NRC COOP plan 

and procedures. 

Event Response — Incident Response Standardization Project 

In April 2015 staff initiated the Incident Response Standardization Project (IRSP) to identify 

opportunities for improving effectiveness and efficiency through the standardization of 

information technology (IT) and communication assets for the agency’s IR program. The staff 

identified several areas for improvement, including the bolstering of the governance framework 

for procuring, servicing, and change control of IT and communication equipment for the HOC 

and the regional IR centers. The staff is further exploring additional opportunities and will 

complete its implementation of the IRSP by CY 2017.

Research — Offsite Response Organization Capabilities and Practices for Protective Actions 

in the Intermediate Phase of an Emergency Response Study 

The NRC is sponsoring a study of probable Offsite Response Organization (ORO) decisionmaking in the intermediate phase of a radiological emergency, with offsite consequences, in 

order to more accurately model the potential dose and risk to the public from a range of 

scenarios and associated policy and operational responses. In its models, the NRC makes 

assumptions about the protective action decisions (PAD) and capabilities of OROs. The NRC is 

conducting this study to ensure NRC assumptions about OROs’ intermediate-phase PADs and 

associated capabilities are modeled as accurately as possible. A key part of the study is 

voluntary interviews with ORO decision-makers and their staffs in various states. The study 

results are expected to advance NRC’s understanding of ORO practices and capabilities, 

improve modeling assumptions (primarily addressing ORO actions), and identify best practices 

that can be shared. The study results are expected to be published in a NUREG/CR in CY 

2017. 

Research — Evacuation Time Estimate Study 

The NRC enhanced the regulatory requirements for evacuation time estimate (ETEs) in 2011, 

requiring, in part, that licensees update ETEs after every decennial census and in between 

decennial censuses as necessary. Guidance for the development of ETEs is provided in 

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

Accession No. ML113010515). To further the technical basis for this guidance and enhance 

the staff’s understanding of evacuation science, the staff is conducting a study of ETEs. This 
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study will provide an analysis of parameters important to ETEs and will examine, through 

modeling and simulation, the impact of evacuations outside declared evacuation zones 

(shadow evacuation) and the effect of manual traffic control. The staff presented the technical 

approach to this study as well as a validation of current ETEs at the National Evacuation 

Conference on March 1, 2016 (ADAMS Accession No. ML16054A042). The staff has a 

communication plan (ADAMS Accession No. ML16033A188) to explain the purpose of this 

study and FEMA has expressed support for this effort. The results of this study will be 

published in a NUREG/CR document in late CY 2018. 

International — Emergency Preparedness and Incident Response Activities 

 

In FY 2016, the staff maintained its relationships with international partners on both bilateral and 

multilateral bases. Relationships were enhanced through: conducting multiple meetings to 

discuss EP and IR issues and activities, hosting a foreign assignee in the EP area, conducting 

tours of the NRC HOC, and arranging for two foreign regulators to observe a U.S. nuclear 

power plant emergency exercise. Highlights of staff’s FY 2016 international accomplishments 

include: 

• In FY 2016, the Director, Division of Preparedness and Response, NSIR, served as the 

National Competent Authority at the eighth meeting for the Convention on Early 

Notification of a Nuclear Accident (Notification Convention), where NRC worked with 

other Member States to review and, where needed, strengthen commitments to early 

notification and assistance in the event of a nuclear or radiological emergency. The staff 

also participated in the technical meeting of the Notification Convention. At the technical 

meeting, the staff worked with other regulators to continue the development of standards 

and methods for information exchange during nuclear or radiological incidents and 

emergencies.

• In 2015 the International Atomic Energy Agency (IAEA) established the Emergency 

Preparedness and Response Standards Committee (EPReSC) as the fifth IAEA Safety 

Standards Committee under the Commission on Safety Standards. The EPReSC 

makes recommendations on the IAEA’s program for the development, review, and 

revision of EP and response safety standards, and on activities to support the use and 

application of these standards. The EPReSC provides feedback and recommendations 

to the IAEA on its EP safety programs and on areas for improvement, with a view to 

achieving greater transparency, consensus, quality, coherence, and consistency in the 

development of IAEA safety standards. The Deputy Director, Division of Preparedness 

and Response, NSIR, is the U.S. representative to this committee. 

• In FY 2016, an EP staff member continued to participate in IAEA’s Small Modular 

Reactor (SMR) Regulators’ Forum, providing technical input related to EP reviews of 

SMR designs. In addition, a staff member continues to be the Group Chair of the EPZ 

Working Group (WG), under the Regulators’ Forum. In September 2016, the EPZ WG 

provided a draft document to the Regulators’ Forum that proposed a generic 

methodology to inform Member States’ determinations of the EPZ size around any 

proposed SMR plant. The Regulators’ Forum will review this draft report and make a 

recommendation to publish this report in spring 2017. 
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• In coordination with the Office of International Programs, staff worked with 

representatives from the regulatory bodies of Japan and China to assist them in 

arranging for observations of U.S. NPP EP/IR exercises. Representatives from China 

observed a plume exposure exercise in Pennsylvania, while representatives from Japan 

observed a HAB exercise in Illinois. 

Self–Assessment 

The NRC’s EP and IR programs and activities continue to align with the agency’s strategic 

security and safety goals. In the interests of continuous improvement, the NRC’s FY 2016 EP 

and IR programs’ performance was assessed using the following three performance measures: 

(1) Ensure the NRC emergency response capabilities for safety or security events at 

licensed facilities by maintaining the readiness of the HOC and response 

organizations. 

(2) Ensure safety and security considerations are appropriately integrated and reflected 

in EP regulatory activities related to decommissioning. 

(3) Maintain a stable and predictable EP regulatory program for licensing, oversight, and 

regulatory infrastructure. 

Performance measure (1) is associated with the event response and training product lines. 

Successful demonstration of performance measure (1) is reflected in the staff maintaining 

response team qualifications and HOC response availability; annual participation in EP/IR 

exercises that involve a wide array of Federal, State, and local authorities; and overall 

maintenance of cooperative intergovernmental relationships to ensure NRC roles and 

responsibilities are considered in national resilience programs. Activities that demonstrate 

successful implementation of performance measure (1) include: maintaining a 

99-percent rate of NRC qualified responders for the various IR teams; participation in three 

evaluated reactor licensee emergency exercises and two fuel facility licensee exercises; 

interagency coordination on the development of the NRIA and updates to the EPA’s PAG 

manual, including the draft water PAGs; and participating in the Eagle Horizon 2016 COOP 

exercise. 

Performance measures (2) and (3) are associated with the licensing, oversight, rulemaking, and 

research product lines. Successful demonstration of both performance measures are reflected 

in the staff’s ability to complete, with greater than 85-percent timeliness and quality, technical 

evaluations of EP submittals for fuel cycle facilities, operating reactors, and new reactors; and 

technical reviews of licensee EP exemption requests and license amendment requests 

associated with existing emergency plans and EAL scheme changes for permanently defueled 

decommissioning sites. Successful performance is also reflected in recent rulemaking activities 

such as responding to EP-specific public comments received on the ANPR for decommissioning 

facilities and developing the draft regulatory basis for SMRs and other new technologies. 

Additionally, the staff is conducting research on OROs to ensure NRC assumptions about 

OROs’ intermediate-phase protective action decisions and associated capabilities are modeled 

as accurately as possible. The staff maintains engagement with stakeholders by keeping an 
The Commissioners -13- 

open dialogue and integrating stakeholder concepts and language into guidance documents 

such as NUREG-0654/FEMA-REP-1, RIS 2016-10 “License Amendment Requests for Changes 

to Emergency Response Organization Staffing and Augmentation,” and RIS 2015-14 “Issuance 

of Enforcement Guidance Memorandum – Emergency Plan and Emergency Plan Implementing 

Procedure Updates.” 

In addition to successful implementation of the performance measures, staff achieved Project 

AIM efficiencies in the event response, licensing, and rulemaking product lines. Specifically, 

staff saved approximately $650K by shedding low priority work. In addition to the $650K 

contract savings, staff is working on identifying ways to streamline the NRC IR program, 

including making better use of Region IV’s Operations Officer capabilities. This would allow for 

increased agency flexibility in responding to and participating in IR activities. 

CONCLUSION: 

The accomplishments of the NRC’s EP and IR programs during FY 2016 supported the NRC’s 

mission and strategic plan. The programs and activities performed by the staff have improved 

by incorporating lessons learned through operating experience, EP exercises, interagency IR 

activities, and stakeholder engagement. The staff continues to demonstrate an ability to 

develop and implement a stable and predictable EP regulatory program for licensing, oversight, 

and regulatory infrastructure. Further, the staff continues to participate in IR activities that help 

to maintain cooperative intergovernmental relationships to ensure that NRC roles and 

responsibilities are considered and reflected in national resiliency programs. 

COORDINATION: 

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

 /RA Michael R. Johnson Acting For/ 

 Victor M. McCree 

 Executive Director 

 for Operations 

Enclosure: 

Status of Medium and Low Priority EP 

 Topics Identified in SECY-06-0200 
The Commissioners -13- 

open dialogue and integrating stakeholder concepts and language into guidance documents 

such as NUREG-0654/FEMA-REP-1, RIS 2016-10 “License Amendment Requests for Changes 

to Emergency Response Organization Staffing and Augmentation,” and RIS 2015-14 “Issuance 

of Enforcement Guidance Memorandum – Emergency Plan and Emergency Plan Implementing 

Procedure Updates.” 

In addition to successful implementation of the performance measures, staff achieved Project 

AIM efficiencies in the event response, licensing, and rulemaking product lines. Specifically, 

staff saved approximately $650K by shedding low priority work. In addition to the $650K 

contract savings, staff is working on identifying ways to streamline the NRC IR program, 

including making better use of Region IV’s Operations Officer capabilities. This would allow for 

increased agency flexibility in responding to and participating in IR activities. 

CONCLUSION: 

The accomplishments of the NRC’s EP and IR programs during FY 2016 supported the NRC’s 

mission and strategic plan. The programs and activities performed by the staff have improved 

by incorporating lessons learned through operating experience, EP exercises, interagency IR 

activities, and stakeholder engagement. The staff continues to demonstrate an ability to 

develop and implement a stable and predictable EP regulatory program for licensing, oversight, 

and regulatory infrastructure. Further, the staff continues to participate in IR activities that help 

to maintain cooperative intergovernmental relationships to ensure that NRC roles and 

responsibilities are considered and reflected in national resiliency programs. 

COORDINATION: 

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

 /RA Michael R. Johnson Acting for/ 

 Victor M. McCree 

 Executive Director 

 for Operations 

Enclosure: 

Status of Medium and Low Priority EP 

 Topics Identified in SECY-06-0200 

Distribution: 

The Commissioners RidsSECYMailCenterResource RidsOCFOMailCenterResource 

Tara Inverso/EDO RidsNSIRMailCenterResource RidsOGCMailCenterResource 

 WITS200500137 and W200900090 

ADAMS ACCESSION No.: ML16236A307 *concurrence via email 

OFFICE: NSIR/DPR NSIR/DPR NSIR/DPR: D OE NRR RES OCFO 

NAME: J. Arce J. Anderson M. Bailey *P. Holahan *M. King for 

W Dean

M. Weber *S.Ha for 

M Wylie DATE: 9/16/16 9/21/16 9/21/16 10/17/16 10/6/16 9/30/16 9/26/16 

OFFICE: NMSS NRO RI RII RIII RIV Tech Editor 

NAME: *S. Moore for 

M. Dapas 

*J. Uhle *P. Krohn for 

D. Dorman 

*C. Haney *C. Pederson *K. Kennedy C. Raynor 

DATE: 10/5/16 10/12/16 10/12/16 10/7/16 10/13/16 9/30/16 10/17/16

OFFICE: OGC NSIR EDO

NAME: J. Maltese B. Holian V. McCree

DATE: 10/24/16 10/24/16 10/28/16 

 OFFICIAL RECORD COPY 
 Enclosure 

Status of Medium and Low Priority Emergency Preparedness Topics 

Identified in SECY-06-0200 

In September 2006 the staff submitted SECY-06-0200, “Results of the Review of Emergency 

Preparedness [EP] Regulations and Guidance,” (Agencywide Document Access and 

Management System (ADMAS) Accession No. ML061910707), which identified several high, 

medium, and low priority areas for enhancing EP regulations and guidance. In SECY-06-0200, 

the staff recommended that rulemaking be initiated for 12 high priority topics and committed to 

revisit those issues that were determined to be less than a high priority at a later time. 

In October 2009 the staff submitted SECY-09-0152, “Annual Update on the Status of 

Emergency Preparedness Activities,” (ADAMS Accession No. ML091900372), which provided 

recommendations for resolving the remaining eight medium and low priority EP rulemaking 

issues identified in SECY-06-0200. The resolutions to the eight remaining items are outlined 

below. Staff considers these medium and low priority EP issues identified in SECY-06-0200 to 

be adequately addressed as discussed and therefore no further action is needed. 

SECY-06-0200 Medium Priority Emergency Preparedness Issues 

1. Emergency Response Organization Report-In and Call-In Drills 

This issue pertains to a recommendation to expand the U.S. Nuclear Regulatory 

Commission (NRC) regulations and guidance to address the type and frequency of 

the Emergency Response Organization (ERO) augmentation drills in order to 

demonstrate EROs’ ability to meet additional demands during drills/exercises. NRC 

staff determined that additional guidance specifying the type and frequency of drills 

would be sufficient to ensure that licensees are conducting an adequate number of 

effective Report-In and Call-in Drills to ensure successful ERO augmentation in the 

event of an emergency. Evaluation criteria N.4.g and N.4.h have been incorporated 

in Section II of NUREG-0654/FEMA-REP-1, Revision 2, to capture this additional 

guidance. 

2. Emergency Preparedness Corrective Action Program 

This issue stemmed from an observation during the EP review in SECY-06-0200 that 

EP program-related issues and changes were not being adequately evaluated. The 

staff determined that additional guidance will sufficiently address the issue. Staff is 

developing additional guidance to include formal critiques of drills and exercises, and 

to include EP program-related issues and changes into the site-wide corrective 

actions program. Resolution of corrective actions identified in drills and exercises is 

addressed in Title 10 of the Code of Federal Regulations (10 CFR), 

Section 50.47(b)(14), and Appendix E to 10 CFR Part 50. Evaluation criteria N.1.b 

and P.11 for use of the licensee’s corrective action program to track and address EP 

drill, exercise, and program issues have been incorporated in Section II of NUREG0654/FEMA-REP-1, Revision 2. 
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3. Emergency Preparedness Staff Training 

This issue was identified as a result of inspection findings, where the staff noted that 

many of the root causes were related to inadequate training of licensees’ EP staff. 

Additional guidance on initial training and periodic retraining of EP staff, in order to 

provide an adequate level of knowledge of NRC EP requirements so that an effective 

EP program is developed and maintained, has been incorporated in evaluation 

criterion P.1 in Section II of NUREG-0654/FEMA-REP-1, Revision 2. 

4. Use of Systematic Approach to Training for Emergency Response Organizations 

This issue was identified by internal and external stakeholders and is related to 

concerns that training programs for the ERO staff are not as robust and effective as 

training programs used for reactor operators. Additional guidance for enhancements 

to training programs will be incorporated in evaluation criterion O.2 in Section II of 

NUREG-0654/FEMA-REP-1, Revision 2, which encompasses designing and 

conducting ERO training using a systematic analysis of jobs and tasks from which 

learning objectives are derived. 

5. Notification of Alert System Major Loss 

This issue is related to a need for greater clarity regarding the definition of a major 

loss of alert and notification system capability in order to minimize potential for nonreporting of such events to the NRC. Recent guidance, clarifying what constitutes a 

major loss of a licensee's alert and notification system and reporting guidelines, have 

been provided in NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 

and 50.73," Revision 3, Supplement 1, dated September 2014. This guidance 

endorses Nuclear Energy Institute (NEI) 13-01, "Reportable Action Levels for Loss of 

Emergency Preparedness Capabilities," dated July 2014 and provides specific 

guidance for reporting a failure of the primary alerting system under 10 CFR 

50.72(b)(3)(xiii) which, as a result, reduces the need for engineering judgment. 

6. Clarification of Consideration of Potassium Iodide Use and Other Protective 

Action Recommendations 

During the EP review in SECY-06-0200, this issue arose from the concern that the 

rule language in 10 CFR 50.47(b)(10) was not clear on the need for licensees to 

include sheltering as a protective action recommendations (PAR) option in their 

emergency plans and to provide a range of protective actions for individuals onsite 

and in the owner controlled area. The staff subsequently recommended rulemaking 

to clarify the wording and intent of 10 CFR 50.47(b)(10). In the EP final rule that was 

published in the Federal Register (FR) on November 23, 2011, (76 FR 72560) and 

became effective on December 23, 2011, licensees are required to provide a range 

of protective actions for onsite personnel. The EP final rule also requires the use of 

evacuation time estimates (ETEs) in the development of protective action strategies. 

In November 2011 the NRC published NUREG/CR-7002, “Criteria for Development 

of Evacuation Time Estimate Studies,” (ADAMS Accession No. ML113010515), and 
-3- 

 

Supplement 3, “Guidance for Protective Action Strategies,” (ADAMS Accession No. 

ML113010596), to NUREG-0654/FEMA-REP-1, Revision 1, to provide guidance on 

how to develop and use ETEs in the formulation of these strategies. The guidance 

also addresses the use of sheltering, potassium iodide, and other protective action 

strategies. NUREG-0654/FEMA-REP-1, Revision 2, reflects changes in NRC EP 

regulations and guidance regarding the use of ETEs and PAR development. 

SECY-06-0200 Low Priority Emergency Preparedness Issues 

7. Joint Information Center Enhancements 

This issue pertains to a recommendation to expand NRC regulations and guidance 

to demonstrate the effectiveness of numerous competencies necessary for 

emergency response, including the Joint Information Center (JIC). Two NUREG/CR 

documents were developed to address JIC enhancements to account for changes in 

media practices, advances in communications technology, and changes in public 

access to information. The documents are NUREG/CR-7032, “Developing an 

Emergency Risk Communication (ERC)/Joint Information Center (JIC) Plan for a 

Radiological Emergency,” (ADAMS Accession No. ML110490119), and 

NUREG/CR-7033, “Guidance on Developing Effective Radiological Risk 

Communication Messages: Effective Message Mapping and Risk Communication 

with the Public in Nuclear Plant Emergency Planning Zones,” (ADAMS Accession 

No. ML110490120), both published in February 2011. NUREG-0654/FEMA-REP-1, 

Revision 2, reflects changes in NRC guidance regarding the development of risk 

communications plans and messages for nuclear power plants. 

8. License Transfer 

This issue is related to a concern that there is no requirement for an acquiring entity 

to submit EP information at the time of a license transfer application. The staff 

determined that no additional requirement would be needed, as existing EP 

requirements are adequate. Specifically, any changes to a site’s emergency plan 

would be evaluated per NRC requirements in 10 CFR 50.54(q), and any reduction in 

effectiveness submitted for prior NRC approval in accordance with 10 CFR 50.90, 

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