Standard Operating Procedure
and Guidelines
For the New Reactor Combined License Application
October 10, 2008
Revision 4.1

Radiological Emergency Preparedness Program
Standard Operating Procedure and Guidelines for
New Reactor Combined License Application
This page intentionally left blank.
Standard Operating Procedure and Guidelines
for New Reactor Combined License Application
This document is written to guide activities for personnel assigned to the
Federal Emergency Management Agency Radiological Emergency
Preparedness Headquarters, and Regions,
Quality reviews included members from the following agencies:
Federal Emergency Management Agency,
U.S. Nuclear Regulatory Commission,
Revisions will be made as conditions warrant.
This page intentionally left blank.
i
CONTENTS
A. FOREWORD................................................................................................................................................1
B. INTRODUCTION.........................................................................................................................................2
C. PURPOSE....................................................................................................................................................4
D. RULES..........................................................................................................................................................4
E. PLANT SITE SITUATIONS.......................................................................................................................5
F. RESPONSIBILITIES..................................................................................................................................6
FEMA HEADQUARTERS..................................................................................................................................6
FEMA REGIONS .............................................................................................................................................6
G. ACCEPTANCE REVIEW...........................................................................................................................7
PROJECT DETAILS AND RESPONSIBILITIES .......................................................................................................8
Deliverable FEMA Region:........................................................................................................................8
Deliverable FEMA Headquarters: ..............................................................................................................9
H. SECTION 1 – SIX PHASE PROCESS...................................................................................................10
PHASE I – INTERIM FINDING REPORT FOR REQUESTS FOR ADDITIONAL INFORMATION .................................11
Project Details and Responsibilities .........................................................................................................11
Deliverables FEMA Region: ...............................................................................................................11
Deliverable FEMA Headquarters: .......................................................................................................11
Composing the Interim Finding Report....................................................................................................12
Interim Finding Conditions with Examples..............................................................................................13
The Interim Finding Report Sections .......................................................................................................14
Letters and Memoranda for Submittal......................................................................................................17
FEMA Region ....................................................................................................................................17
FEMA HQ 1 .......................................................................................................................................17
FEMA HQ 2 .......................................................................................................................................17
RAI Process.............................................................................................................................................19
Tools for the RAI process:...................................................................................................................19
RAI Development...............................................................................................................................21
RAI vs. Requirements for Reasonable Assurance....................................................................................22
RAI Flowchart.........................................................................................................................................23
PHASE II – INTERIM FINDING REPORT FOR OPEN ITEMS ................................................................................24
Deliverables FEMA Region: ....................................................................................................................24
Deliverables FEMA Headquarters: ..........................................................................................................24
Letters and Memoranda for Submittal......................................................................................................26
FEMA Region ....................................................................................................................................26
FEMA HQ 1 .......................................................................................................................................26
FEMA HQ 2 .......................................................................................................................................26
PHASE III – REVIEW OF SAFETY EVALUATION REPORT .................................................................................27
PHASE IV – INTERIM FINDING REPORT FOR REASONABLE ASSURANCE.........................................................28
Deliverable FEMA Region:......................................................................................................................28
Deliverables FEMA Headquarters: ..........................................................................................................28
Letters and Memoranda for Submittal......................................................................................................30
FEMA Region ....................................................................................................................................30
FEMA HQ..........................................................................................................................................30
PHASE V – REVIEW OF SAFETY EVALUATION REPORT ..................................................................................31
PHASE VI – FINAL REVIEW OF SAFETY EVALUATION REPORT ......................................................................31
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I. SECTION 2 – FOUR PHASE PROCESS................................................................................................32
PHASE I: PART A AND PART B .......................................................................................................................33
Part A Interim Finding Report for Requests for Additional Information .................................................33
Deliverables FEMA Region: ...............................................................................................................33
Deliverables FEMA Headquarters:......................................................................................................33
Part B Interim Finding Report for Open Items.........................................................................................35
Deliverables FEMA Region: ...............................................................................................................35
Deliverables FEMA Headquarters:......................................................................................................35
PHASE II – INTERIM FINDING REPORT FOR REASONABLE ASSURANCE ..........................................................37
Deliverable FEMA Region:......................................................................................................................37
Deliverables FEMA Headquarters: ..........................................................................................................37
PHASE III – REVIEW OF SAFETY EVALUATION REPORT .................................................................................39
PHASE IV – FINAL REVIEW OF SAFETY EVALUATION REPORT ......................................................................39
J. POST COMBINED LICENSE...................................................................................................................40
INTERIM FINDING REPORT ON PREPAREDNESS/EXERCISE REPORT ................................................................40
Deliverable FEMA Region:......................................................................................................................40
Deliverable FEMA HQ: ...........................................................................................................................40
Letters and Memoranda for Submittal......................................................................................................40
FEMA Region ....................................................................................................................................40
FEMA HQ..........................................................................................................................................41
K. GLOSSARY...............................................................................................................................................42
L. ACRONYMS ..............................................................................................................................................45
M. APPENDICES...........................................................................................................................................46
APPENDIX 1 SAMPLE MEMO FOR INSUFFICIENT ACCEPTANCE REVIEW......................................................47
APPENDIX 2 SAMPLE MEMO FOR SUFFICIENT ACCEPTANCE REVIEW.........................................................48
APPENDIX 3 SAMPLE LETTER FOR INTERIM FINDING REPORT FOR RAIS....................................................49
APPENDIX 4 RAI SUBMITTAL FORM EXAMPLE ..........................................................................................50
APPENDIX 5 OPERATING SITE RAI TRACKING FORM.................................................................................51
APPENDIX 6 NON-OPERATING REACTOR SITE RAI TRACKING FORM ........................................................52
APPENDIX 7 SAMPLE LETTER FOR INTERIM FINDING REPORT FOR OIS ......................................................53
APPENDIX 8 OPEN ITEMS SUBMITTAL FORM EXAMPLE..............................................................................54
APPENDIX 9 DIRECT DISCUSSION FORM.....................................................................................................55
APPENDIX 10 INTERIM FINDING REPORT EXAMPLE....................................................................................56
APPENDIX 11 POST COL ACTIONS NEEDED TRACKING FORM ...................................................................61
APPENDIX 12 REQUIREMENTS FOR REASONABLE ASSURANCE...................................................................66
APPENDIX 13 POINTS OF CONTACT ..........................................................................................................135
Applicant Points of Contact....................................................................................................................135
FEMA Headquarters Points of Contact ..................................................................................................138
NRC Points of Contact ...........................................................................................................................139
FEMA Regions Points of Contact ..........................................................................................................141
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
1
A. Foreword
On December 7, 1979, the President directed the Federal Emergency Management
Agency (FEMA) to assume the lead responsibility for all offsite nuclear planning and
response. FEMA’s activities are conducted pursuant to 44 Code of Federal
Regulations (CFR) parts 350 through 353. These regulations are a key element in the
Radiological Emergency Preparedness (REP) Program that was established following
the Three Mile Island Nuclear Power Plant (NPP) Station accident in March 1979.
FEMA Rule 44 CFR 350-353 establishes the policies and procedures for FEMA’s
initial and continued approval of State and local governments’ radiological emergency
planning and preparedness for commercial nuclear power plants. This approval is
contingent, in part, on State, Tribal, and local government participation in joint
exercises with licensees.
Suggested changes or questions regarding this document should be directed to the
FEMA New Reactor Team at:
U.S. Department of Homeland Security
Federal Emergency Management Agency
National Preparedness Directorate
Technological Hazards Division
Radiological Emergency Preparedness Program
500 C. Street SW
Washington D.C. 20472
Phone: 202-212-2120
Fax: 703-305-0837
Section Chief
Albert.Coons@dhs.gov
Team Lead
Bonnie.Sheffield@dhs.gov
New Reactor Team
Thomas.Strother@dhs.gov
Nathaniel.Yates@dhs.gov
Lisa.Banks-Robinson@dhs.gov
Rebecca.Fontenot@dhs.gov
Patricia.Gardner@dhs.gov
David.Jeremy@dhsgov
Harry.W.NashJr@dhs.gov
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
2
B. Introduction
FEMA has entered into a Memorandum of Understanding (MOU) with the U.S.
Nuclear Regulatory Commission (NRC) as stated in 44 CFR 353 appendix A.
FEMA agreed to furnish assessments, findings, and determinations as to whether
State, Tribal, and local emergency plans and preparedness are adequate and
continue to be capable of implementation (e.g., adequacy and maintenance of
procedures, training, resources, staffing levels and qualifications, and equipment
adequacy). These findings and determinations are used by the NRC under its own
rules in connection with its licensing and regulatory requirements and FEMA
supports its findings in the NRC licensing process and related court proceedings as
outlined in 44 CFR 350.3(f).
FEMA is involved in approximately seventeen to eighteen months of the Combined
License process using the sixteen planning standards for safety that are reviewed
for new construction nuclear power plants. FEMA only reviews fifteen of the sixteen
planning standards, which are comprised of one hundred nine detailed criteria
(NUREG-0654 FEMA-REP-1, Rev. 1).
FEMA’s responsibilities with respect to offsite radiological emergency preparedness
are specified as:
? Take the lead during the review and assessment of adequate offsite
emergency plans and preparedness.
? Determine whether plans and procedures can be implemented based on
analyzing plans and observing the effectiveness of plans through the
evaluation of exercises conducted by State, Tribal, and local governments in
conjunction with licensee’s and the NRC.
? Respond to requests by the NRC pursuant to the MOU between the NRC and
FEMA (44 CFR 353 Appendix A).
The NRC and FEMA Headquarters (HQ) work together alongside the FEMA Regions,
the NRC Regions, States, Tribal, local governments, and organizations to help facilitate
the process for the new reactor licensing for established sites that have operating
reactors and sites that currently do not have an operating reactor.
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
3
The process for licensing a nuclear power plant has several options (Early Site Permit,
Standard Design Certification, and Combined License).
Relationship between Combined Licenses, Early Site Permits and Standard
Designs Certifications1
*A combined license application can reference an early site permit, a standard design
certification, both or neither. If an application does not reference an early site permit and/or
a standard design certification, the Applicant must provide an equivalent level of information
in the combined license application.
1 Source: U.S. NRC
Optional
Pre-Application
Review
Standard Design
Certification or
Equivalent Design
Information*
Early Site Permit or
Equivalent
Environmental
Information*
Verification of
Inspections, Test,
Analyses, and
Acceptance
Criteria
Reactor
Operation
Combined
License
Review,
Hearing and
Decision*
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
4
C. Purpose
The purpose of this document is to describe FEMA’s responsibility in supporting the
Combined License (COL) application process for new reactors and to provide an
understanding and guidance in the review process from the earliest letter or memo
to the completion of the Interim Finding Report (IFR).
D. Rules
Delays: Any delays during the review that may accrue from an outside factor
should be noted on the tracking form (See Appendix 5 and 6) and a letter should be
sent to FEMA HQ within twenty four (24) hours. HQ will then forward the
information to the NRC. For example, if the Applicant takes more than five (5) days
to respond to your communication, then notify HQ.
Extensions: Extensions to the review process must be requested in writing to
FEMA HQ no later than ten (10) days prior to the Regional suspense date. The
request must detail the reason for the extension and provide a proposed
completion date. The request will be reviewed by FEMA HQ and coordinated with
NRC.
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
5
E. Plant Site Situations
There are three (3) types of situations for new reactors where the FEMA review of
offsite radiological emergency preparedness will be required. This helps FEMA
review the applications more consistently, in order for an interim finding to be given
more quickly.
Situation 1
Interim Finding Report
Situation 2
Interim Finding Report
Situation 3
Interim Finding Report
A request to build a new
reactor at an operating
commercial NPP.
In this case, State, Tribal,
and local REP plans,
equipment, and training
programs already exist.
An IFR will be developed
reflecting the current REP
program for the offsite
jurisdiction(s). It also
reflects any identified
shortfalls of the proposed
REP plans that may exist.
(44 CFR 353 Appendix A)
A request to build a new
reactor at a non operating
site within a State or
Tribal Nation that already
has at least one
operating commercial
NPP.
In this case, State and
Tribal plans already exist,
but there is a need to
refine the State’s plan to
be specific for the
proposed NPP. Plans and
procedures and training
will need to be developed
for jurisdictions that do not
have an operating
commercial nuclear power
plant. An IFR with
Schedule of Requirements
for Reasonable Assurance
delineating milestones for
preparation of the county
plans during the postlicensing
period will be
part of the IFR.
(44 CFR 353 Appendix A)
A request to build a new
reactor in a State or Tribal
Nation with no operating
commercial NPP.
In this case, there are no
existing State and local
plans. Equipment and
training programs would
require significant
development in order to
meet regulating criteria. In
this case, a Schedule of
Requirements for
Reasonable Assurance
delineating milestones for
preparation of the State
and county plans during
the post-licensing period
will be part of the IFR.
(44 CFR 353 Appendix A)
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
6
F. Responsibilities
FEMA Headquarters
FEMA Headquarters personnel have primary responsibility for the overall review of
materials related to the proposed licensing of a new reactor. FEMA Headquarters
New Reactors Team staff will:
? Update and maintain the master schedule for all of the new reactor
applications as information is obtained from the NRC. Distribute to the
Regions, emphasizing all changes that have occurred since last revision.
? Track progress of all Regional review activities. Communicate with Regions
on status of their reviews weekly.
? Review all documents and correspondence submitted by the Regions in
support of new reactor reviews. Clarify any RAIs prior to drafting
management correspondence to the NRC.
? Research and respond to questions from the Regions regarding FEMA
regulations and other concerns that require interpretation from the Office of
Chief Counsel.
FEMA Regions
FEMA Regional personnel have primary responsibility for the detailed review of
materials related to the proposed licensing of a new reactor. The Regions have
planning and preparedness expertise and operational relationships with the State,
Tribal, and local governments making them the subject matter experts in the field.
FEMA Regional staff will:
? FEMA Regions conduct a conference call with FEMA HQ, Applicant and
State to discuss steps that need to be taken by all parties to meet the
Acceptance Review and Phase I deadlines.
? Distribute copies of plans and supporting procedures to the Regional
Assistance Committee (RAC) for their review.
? Establish a timeline for the review and RAC meeting to discuss the plan
review.
? Coordinate with affected State, Tribal, and local governments as appropriate.
? Conduct RAC meeting to reach consensus on the findings and
determinations made in the plan review.
? Submit the appropriate Interim Finding Reports to FEMA HQ.
? Generate sufficient background documentation to enable any FEMA
representative at a future time (such as at a public hearing) to substantiate
review findings.
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
7
G. Acceptance Review
The purpose of the Acceptance Review is to ensure the application is sufficient for
FEMA to start the Phase I review with current State, Tribal, and local plans that
have been submitted along with the appropriate NUREG-0654 FEMA-REP-1,
Rev. 1 cross-reference.
? As soon as the Region is aware that an application is expected, they should
begin collecting implementing procedures and the all-hazards plans for
affected jurisdictions.
? The Acceptance Review process begins when the Applicant submits a COL
application to the NRC. The NRC has sixty (60) days to determine if the COL
application is sufficient for full licensing review.
? As part of the NRCs Acceptance Review process, the NRC forwards an
official acceptance request letter to FEMA HQ (courtesy copied to respective
FEMA Regions). FEMA HQ confirms tasking in writing to affected Regions.
? Upon receipt of the above information, the FEMA Region has thirteen (13)
working days, within the NRC Acceptance Review sixty (60) working days, to
review the State, Tribal, and local government offsite radiological emergency
response plans as well as NUREG-0654 FEMA-REP-1 Rev. 1 crossreferences
for completeness.
o The NRC regulation, 10 CFR 50, requires the Applicant to submit
current State REP plans within the 50-mile Emergency Planning Zone
(EPZ) and county/local plans within the10-mile EPZ. If these items are
included with the application material, the application is considered
acceptable.
? If the application is for a non-operating site (Situation 2 and 3),
the Applicant is required to develop and submit proposed REP
plans for jurisdictions within the 10-mile EPZ and 50-mile EPZ
of the site.
o In order to accurately determine whether the plans can be
implemented, FEMA may also need the all-hazard emergency plans
(if the REP is not a self contained document) and implementing
procedures to conduct its review. These additional documents should
be requested directly from the states and not requested in the
Acceptance Review letter.
? FEMA HQ provides the NRC with a letter informing them whether or not the
offsite information provided by the Applicant is acceptable. If the information
is not acceptable, the Applicant will be informed to supply the FEMA Region
with the requested information.
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
8
? Maximize the use of federal personnel to conduct the required review and
necessary coordination. Federal employees should be supplemented by
contractual assistance only on a case-by-case basis. If contractor support is
needed, FEMA HQ shall develop the work order.
? Upon completion of the NRC sixty (60) day Acceptance Review period, the
NRC will evaluate all input (internal and external) in order to evaluate and
confirm that the application material is complete and correct. This will occur
before the NRCs decision to docket, or formally accept, the application.
? After the FEMA Region reviews the application materials, a letter is
forwarded to the FEMA HQ REP Branch Chief stating if the application is
acceptable.
? Once the application is docketed, a number is assigned to it and the NRC
gives FEMA HQ an official letter and schedule to guide the COL process,
thus becoming a legal document.
? Following a successful Acceptance Review and docketing, Phase I begins.
FEMA HQ will confirm this task in writing to affected FEMA Regions.
? There are two (2) COL process lengths:
o A six (6) phase application process; in which FEMA is involved in
Phases I, II, and IV, but may assist the NRC in other phases.
o A four (4) phase application process; in which FEMA is involved in
Phases I and II, but may assist the NRC in other phases.
NOTE: If the application is a non-operating site (Situation 2 or Situation 3), the
Region should begin the Phase I Review process as soon as possible to
incorporate the allocated one hundred twenty (120) working days for Phase I.
Project Details and Responsibilities
The FEMA Region reviews the submitted material determining whether it is
sufficient for a plan review to begin.
(See Appendix 1 for insufficient review and Appendix 2 for sufficient review sample
letters.)
Deliverable FEMA Region:
Acceptance Review Transmittal Memorandum
MEMORANDUM FOR: REP Branch Chief, FEMA Headquarters
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
9
FROM: Technological Hazards Branch Chief, FEMA Region
SUBJECT: Acceptance Review of Offsite Radiological Emergency Response
Plans for the _____________________ Site, Combined License Application
In the letter, one of the following must be identified2:
? Material is sufficient to allow FEMA to begin its review
? Material is not sufficient and the following information is required
before FEMA can begin its review
o Provide a list of needed material
o FEMA HQ forwards information to the NRC, who informs
the Applicant that the document is considered incomplete
until the missing information is provided.
o The schedule does not start until a complete application is
received.
NOTE: When reviewing plans for non-operating sites, ensure that the county plans
submitted on the Applicant’s disc are reviewed. These plans may incorporate
NUREG-0654 FEMA-REP-1, Rev. 1.
Deliverable FEMA Headquarters:
Acceptance Review Letter
Generate a letter to the NRC for Acceptance Review from the REP Branch Chief to
the NRC Licensing and Inspection Branch Chief. This letter should include a
statement as to whether FEMA agrees with proposed schedule durations.
Letter Routing
Follow HQ correspondence procedures to ensure proper routing, concurrence, and
signatures.
2 44 CFR 353 Appendix A
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
10
H. Section 1 – Six Phase Process
The Six phase process is used for COL applications with a reactor design that has
not been previously certified by the NRC. As of December 2008 the following COL
applications are following the six phase process:
Bellefonte
Calvert Cliffs
Comanche Peak
North Anna
South Texas Project
COL Process FEMA Deliverable Duration
Acceptance Review Review Letter 13 Working Days
90 Working Days
Phase I IFR for Requests for Additional
Information 120 Working Days
Phase II IFR for Open Items 30 Working Days
Phase III Tentative Support 2 Days
Phase IV IFR for Reasonable Assurance 30 Working Days
Phase V Tentative Support 2 Days
Phase VI Tentative Support 31 Working Days
Hearings Testimony as Needed Throughout Project
as Needed
Post COL IFR on Preparedness After Qualifying
Exercise
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
11
Phase I – Interim Finding Report for Requests for Additional
Information
Ninety (90) working days are allocated for this phase for Situation 1 sites. One
hundred twenty (120) working days are allocated for non-operating sites for this
phase. Non-operating sites will need to begin the Phase I review as soon as the
FEMA Acceptance Review is complete. This will allow for the one hundred twenty
(120) working days on Phase I, by combining thirty (30) working days from the post
Acceptance Review and the ninety (90) working days allocated for Phase I.
This phase begins after the NRC dockets the application materials or as
established by the site-specific schedule. Phase I ends with the issuance of the
final IFR for Requests for Additional Information (RAIs).
FEMA Role: Review offsite emergency response plans to determine if all
NUREG-0654 FEMA-REP-1, Rev.1 criterions are addressed
adequately.
An IFR is described in the FEMA/NRC MOU, 44 CFR 353 Appendix A. It is developed
by reviewing the plans and procedures of State, Tribal, and local governments which
are responsible for a NPP offsite response.
The purpose of the IFR for RAIs is to define gaps in planning, equipment, and
training that must be filled before final reasonable assurance can be granted.
Project Details and Responsibilities
Deliverables FEMA Region:
IFR for RAIs
Final RAIs
Deliverable FEMA Headquarters:
IFR for RAIs sent to the Applicant and the NRC
The FEMA Region will submit draft RAIs to FEMA HQ at bi-weekly intervals during
this phase. Then the FEMA Region will submit the IFR for RAIs and a separate final
RAI report to FEMA HQ for review ten (10) working days prior to the end of Phase I.
The separate RAI report is necessary because the Applicant only receives the RAI
document without the Interim Finding Report. FEMA HQ will submit a letter
containing the RAI report to the Applicant prior to the end of Phase I.
NOTE: The FEMA IFR description of offsite preparedness provides a detailed
summary of actions that must be completed before a proposed reactor will be
authorized and operated. This includes the review of Phase I which becomes a part
of the NRC Preliminary Safety Evaluation Report (PSER).
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
12
Composing the Interim Finding Report
The IFR must be clear and concise. Keep these items in mind during your
preparation of the report.
? RAIs and Schedule of Requirements for Reasonable Assurance are used
outside the context of the report and must make sense on their own.
? The review is for offsite response organization emergency plans. FEMA
does not review the Applicant’s onsite emergency response plans, unless
the onsite emergency response plan impacts offsite emergency response.
? Note that the IFR is a summary document and the Regions should produce a
preliminary review document containing sufficient details about the plan
material to support the rating each criterion is given. This document is not a
deliverable, but should be kept on file at the Region in the event that FEMA
is asked to justify its conclusions during the licensing hearing or any other
time.
? There will be two (2) deliverables produced:
o Interim Finding Report
o RAIs
? If more than one State is involved in a review, only one report is produced.
? Identify one of the following conditions for each evaluation criterion and each
planning standard in the report:
o Adequate: Plans are adequate and there is reasonable assurance
that they can be implemented with only limited or no corrections
needed.
o Adequate – corrections must be made: Plans are adequate, but
before a determination can be made as to whether they can be
implemented, corrections must be made to the plans or supporting
measures must be demonstrated (e.g., adequacy and maintenance of
procedures, training, resources, staffing levels and qualifications, and
equipment).
o Inadequate: Plans are inadequate and cannot be implemented until
they are revised to correct deficiencies noted in the Federal review.
o N/A: The planning criterion is not applicable to this Offsite Response
Organization (ORO).
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
13
Interim Finding Conditions with Examples
Adequate -
Corrections Must Be
Made
Plans are adequate, but
before a determination
can be made as to
whether they can be
implemented,
corrections must be
made to the plans or
supporting measures
must be demonstrated
(e.g. adequacy and
maintenance of
procedures, training,
resources, staffing
levels and
qualifications, and
equipment).
NUREG 0654 EXAMPLE:
J.10.a Maps showing evacuation routes,
evacuation areas, preselected radiological
sampling and monitoring points, relocation
centers in host areas, and shelter areas.
Plan has maps, but missing evacuation route.
Inadequate
Plans are inadequate
and cannot be
implemented until they
are revised to correct
deficiencies noted in
the Federal review.
NUREG 0654 EXAMPLE:
J.10.a Maps showing evacuation routes,
evacuation areas, preselected radiological
sampling and monitoring points, relocation
centers in host areas, and shelter areas.
Plan has EPZ map but none of the other
required maps.
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
14
The Interim Finding Report Sections: (See Appendix 10 for an example
report)
Executive Summary – Description of the circumstances of the application and the
proposed site, the plans reviewed, and the condition for each planning standard.
I. Introduction
A. General Characteristics of the Plant – Include information about the site,
its distance from major landmarks and cities, a listing of the States and
jurisdictions within the 10-mile and 50-mile EPZ, and the name of the
Applicant.
B. Emergency Response Organizations
i. Describe relevant authorities from the State and Local plans.
ii. Describe the concept of operations for overall emergency
management and coordination.
iii. Cite the responsible organization for coordinating State, local, private,
and volunteer organizations and coordination with federal response
elements.
iv. List organizations and relationships within the State with
responsibilities related to radiological emergency planning and
response. Ensure accident assessment, radiation monitoring, health
hazards, and protective action guidelines are discussed.
C. Plans – This section encompasses all plans reviewed. It includes how the
State and local plans are organized, the number of volumes and the
overall content of the volumes, including a list with the full name and
publication date of each plan.
D. Basis for Findings – Discuss the critical elements cited above (and any
previously unmentioned items) that form the basis for the determination.
List key elements, and cite specific coordination used to derive the
finding.
E. Evaluation Format – In accordance with the MOU the NRC and FEMA
agreed to furnish assessments, findings and determinations as to
whether State, Tribal, and local emergency plans and preparedness are
adequate and continue to be capable of implementation (e.g., adequacy
and maintenance of procedures, training, resources, staffing levels and
qualifications, and equipment adequacy). These findings and
determinations are used by the NRC under its own rules in connection
with its licensing and regulatory requirements and FEMA supports its
findings in the NRC licensing process and related court proceedings 44
CFR 350.3(f).
II. Review and Evaluation of Emergency Preparedness Plans
A. This section contains specific information on each criterion reviewed,
grouped by planning standard.
i. For each planning standard, open with a clear statement of the overall
condition of the planning standard (Adequate, Adequate – corrections
must be made, or Inadequate) and the number of criteria in each
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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category. Please note that any criteria addressed in the Schedule of
Pending Actions should have a rating of “Adequate – corrections must
be made”. (See Schedule of Pending Actions below)
ii. Briefly describe all of the adequate evaluation criteria for the planning
standard.
iii. For the IFR for OIs and IFR for Reasonable Assurance, describe any
criteria that have changed to adequate and the actions that resolved
the respective RAIs and OIs.
iv. Briefly describe each of the remaining criteria in order, identify the
condition, and summarize the information needed to change that
criterion to an adequate condition.
III. Schedules
A. Pending Actions – This section tracks administrative items that are
scheduled for completion as part of regular periodic activities, but will
occur after FEMA’s review process is completed. These only apply to
existing REP plans, and would represent the final step in resolving an
RAI. Pending actions must have a specific scheduled completion date.
For example, corrections to address an RAI have been made to a Local
plan but the official signature on the revisions is scheduled to occur
during the annual plan update.
B. Requirements for Reasonable Assurance
i. For Situation 2 and 3 sites, the Schedule of Requirements for
Reasonable Assurance contains items that cannot reasonably be
addressed in new plans until the post-licensing period, when support
agreements between response organizations have been finalized and
facilities have been built or identified.
ii. When a new reactor is built at a new site, some or all of the
municipalities within the new site’s EPZ will not have existing
radiological emergency plans. FEMA works with these municipalities,
who must adopt and complete the proposed plans prepared by the
utility, develop detailed procedures, and train responders prior to
conducting the qualifying joint exercise. (See Appendix 11 and 12)
iii. Other than the qualifying exercise, items on this schedule apply
primarily to new REP plans.
IV. Review Composite Rating Summary – This section consists of a table showing
each NUREG-0654 FEMA-REP-1, Rev. 1 criterion reviewed and the
corresponding condition (Adequate, Adequate – corrections must be made, or
Inadequate).
V. Requests for Additional Information or Open Items – This section consists of a
table of all draft and final RAIs or OIs in numerical order. The table describes
the information required to bring the criterion to an adequate condition, as well
as the actual resolution of the item.
VI. Acronym Key
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
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IFR for RAIs Outline:
Executive Summary
I. Introduction
A. General Characteristics
B. Emergency Response Organizations
C. Plans
D. Basis for the findings:
i. 44 CFR part 353
ii. Guidance Memoranda
iii. NUREG-0654 FEMA-REP-1, Rev. 1
E. Evaluation Format
II. Interim Findings of the Review of Evaluation of Emergency Preparedness
Plans
A. NUREG-0654 Planning Standards A – P
B. Identify one of the following conditions for each criterion and each
planning standard in the report:
i. Adequate: Plans are adequate and there is reasonable assurance
that they can be implemented with only limited or no corrections
needed.
ii. Adequate – corrections must be made: Plans are adequate, but
before a determination can be made as to whether they can be
implemented, corrections must be made to the plans or supporting
measures must be demonstrated (e.g., adequacy and maintenance of
procedures, training, resources, staffing levels and qualifications, and
equipment).
iii. Inadequate: Plans are inadequate and cannot be implemented until
they are revised to correct deficiencies noted in the Federal review.
iv. N/A: The planning criterion is not applicable to this ORO.
III. Schedule of Pending Actions/Requirements for Reasonable Assurance
IV. Review Composite Summary
V. Requests for Additional Information - A separate document containing only
the RAIs also must be submitted.
VI. Acronym Key
Criterion Rating Criterion Rating Criterion Rating
A.1.a. Adequate A.2.a. Adequ/Corr C.1.b. Adequate
A.1.b. Adequate A.2.b. Inadequate C.1.c. Adequ/Corr
A.1.c. Adequate A.3. Inadequate C.2.a. Adequ/Corr
A.1.d. Adequ/Corr A.4. Adequ/Corr C.2.b. Adequ/Corr
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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Letters and Memoranda for Submittal
FEMA Region
MEMORANDUM FOR: Chief, Radiological Emergency Preparedness Branch
FROM: Chief, Technological Hazards Branch, FEMA Region
SUBJECT: Interim Finding Report for Request for Additional Information
Content:
Identify the request for Interim Finding from the NRC, stating what
plans/procedures were used in the finding. Also, identify State, Tribal, and local
government’s plans and procedures by publication date.
Include basis for the findings citing:
NUREG 0654 FEMA-REP-1 Rev 1
Guidance Memoranda
44 CFR part 350 - 354
FEMA HQ 1
Create cover letter to the NRC for IFR for RAIs (See Appendix 3 for sample letter)
To: Chief, Licensing and Inspection Branch, NRC
From: Chief, Radiological Emergency Preparedness Branch, FEMA
Identify the request for Interim Finding from the NRC, stating what plans and
procedures were used in the finding. Also, identify State, Tribal, and local
governments and the plans and procedures by publication date.
Include basis for the findings citing:
NUREG 0654/FEMA-REP-1 Rev 1
Guidance Memoranda
44 CFR part 350 – 354
This letter will be courtesy copied to the respective FEMA Region.
FEMA HQ 2
Create cover letter to the Applicant for the Final RAIs
To: Applicant Point of Contact (See Appendix 13)
From: Chief, Radiological Emergency Preparedness Branch, FEMA
Ref: FEMA Final Request for Additional Information of the Offsite Emergency
Response Plans for the Combined License
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
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Explain that in accordance with the current RAI process, the Applicant should
review all of the enclosed RAIs and respond with the information or updates within
forty-five (45) working days of the date of the letter.
This letter will be courtesy copied to the NRC and to the respective FEMA Region.
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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RAI Process
The RAI process was developed during a public meeting with Nuclear Energy
Institute, the NRC, and FEMA. This process was agreed upon and must be
followed.
Tools for the RAI process:
Purpose of these documents is for the Region to keep track of all RAIs until they
are all corrected and to note phone calls related to the COL process. These
documents should be kept on file for the final hearings.
Appendix 4 – RAI Submittal Format
Appendix 5 – Operating Site RAI Tracking Form
Appendix 6 – Non-Operating Site RAI Tracking Form
Appendix 9 – Direct Discussion Form
Acceptance Review
Step 1: The COL Application including offsite planning documents are
submitted to the NRC.
Step 2: The NRC forwards the offsite plans to FEMA HQ and the respective
FEMA Region.
Phase I
Step 3: The FEMA Region reviews the offsite plans to validate them in
accordance with all one hundred and nine (109) criteria in
NUREG-0654 FEMA-REP-1, Rev. 1.
Step 4: The FEMA Region reviewer contacts the Applicant and FEMA HQ
BI-WEEKLY with a list of verbal questions regarding information
shortfalls. The FEMA Regions should maintain logs of all
conversations concerning RAIs, and record them on the Direct
Discussion Form (See Appendix 9). The Applicant will coordinate
answers with State, Tribal, and local agencies as appropriate. The
purpose of this step is to verbally resolve as many information
shortfalls as possible prior to establishing draft RAIs.
NOTE: Send a group e-mail or set up a conference call with the Applicant, the
State, Tribal, and local governments notifying them of an impending letter from the
FEMA Region referencing all RAIs. The RAI letter will request that when the State
responds to the RAIs they will need to send a courtesy copy to the Applicant and
the NRC. The Applicant’s licensing contact will be courtesy copied. Questions will
be directed to the NRC Project Manager. Any information shortfalls that were
corrected immediately by the Applicant will be stated as such with the correction in
the IFR.
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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Step 5: After the reviewer determines that the unresolved verbal questions
will become a draft RAI, it needs to be submitted to FEMA HQ as
soon as possible. The FEMA Region develops draft RAIs. Do not
wait until the RAIs have accumulated because it will overwhelm the
Applicant and FEMA HQ causing a backlog.
Step 6: FEMA HQ receives the draft RAIs and reviews them for consensus.
Step 7: FEMA HQ sends the draft RAIs to the Applicant who forwards the
draft RAIs to State, Tribal, and local government, as appropriate.
FEMA HQ also sends a copy to the NRC for docketing.
Step 8: FEMA HQ and the FEMA Region discuss draft RAIs with the
Applicant, State, Tribal, and local government, and if needed with
the NRC. This should lead to final RAIs which are clear,
understandable, and attainable. (See below for samples of poorly
written vs. clearly written RAIs)
Step 9: The FEMA Region submits the IFR for RAIs to FEMA HQ for
concurrence; FEMA HQ then sends the report to the NRC for
docketing. FEMA HQ also sends the final RAIs to the Applicant who
forwards them to State, Tribal, and local government, as
appropriate.
End of Phase I
Step 10: The Applicant addresses the final RAIs with the State, Tribal, and
local governments and then submits responses to FEMA
HQ/Regions and the NRC within the below allotted timeframes:
? Operating Site - 45 working days
? Non Operating Site - 60 working days
The Applicant will submit RAI responses from State, Tribal, and
local governments’ to the appropriate FEMA Regions, within three
days of receipt.
NOTE: Any RAI that the State refuses to answer or cannot answer will be directed
to the NRC and Applicant for their review.
Phase II
Step 11: FEMA HQ forwards the RAI responses and Phase II tasking to the
affected FEMA Regions.
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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RAI Development
In order for RAIs to be clear, understandable, and attainable, they must contain:
? A specific description of the information required in the NUREG-0654
criterion that is in error, insufficient, or missing entirely from the plan
? The plan section that requires correction
? A statement of the action that must be taken to bring the plan condition to
adequate using the language of the NUREG-0654 criterion
The following are examples of poorly written RAIs and clear, understandable, and
attainable RAIs.
Evaluation Criterion A.3:
Poor: The State of Zstate Radiological Emergency Response Plans (RERP)
lists two Memoranda of Understanding. There are no agreements for
hospitals, transportation providers, radiological monitoring personnel,
etc. Provide these agreements.
Clear: The State of Zstate RERP, Volume III, Basic Plan, Appendix 1,
Supporting Plans, Memoranda of Understanding, Standing Operating
Procedures and Public Affairs Publications, lists two Memoranda of
Understanding. Required written agreements (such as those for
hospitals, transportation providers, radiological monitoring personnel,
etc.) are not included. Provide the written agreements either in an
appendix or described in the plan and verified with signature pages.
Evaluation Criterion C.3:
Poor: The State of Zstate RERP and the Zstate Department of
Health/Division of Radiological Health Emergency Response Plans do
not include information about the general capabilities and expected
availability of the laboratories named.
Clear: A.1 The State of Zstate RERP, Appendix 2, Section I.C, Task
Assignments, Division of Consolidated Laboratory Services, states
that the Consolidated Laboratory Services will provide emergency
laboratory services to State agencies and political subdivisions.
However, the capabilities and expected availability of the laboratory
are not specified. Provide information about the general capabilities
and expected availability of the Division of Consolidated Laboratory
Services to provide analysis services.
A.2 The State of Zstate RERP, Annex H, ESF #8, Tab B, Public
Health and Medical Services, Radiological Laboratories lists
secondary laboratories at the Medical College of Zstate and the
University of Zstate Medical Center. However, the capabilities and
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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expected availability of the secondary laboratories are not specified.
Provide information about the general capabilities and expected
availability of the secondary laboratories to provide analysis services.
A.3 The Zstate Department of Health/Division of Radiological Health
ERP, Appendix 5, Section 2.2.3.3, Accident Assessment, states that
laboratory services will be provided by their own mobile laboratory or
by the Consolidated Laboratory. However, the capabilities and
expected availability of the laboratory are not specified. Provide
information about the general capabilities and expected availability of
the laboratories providing analysis services.
RAI vs. Requirements for Reasonable Assurance
Given that operational NPPs have demonstrated planning and preparedness
competency through initial and ongoing Reasonable Assurance reviews, Situation 1
sites should not have any items on the Schedule of Pending Actions other than the
qualifying exercise for the new reactor. This is because State, Tribal, and local
plans have already been developed for the operating reactor(s) and demonstrated
through exercises. Modification to plan information, and any needed demonstrated
competencies for these sites is handled through the RAI process and will be
resolved before the new reactor license is issued.
For Situation 2 or 3 sites, reviewers must determine whether missing information
should be handled through an RAI or the Schedule of Requirements for
Reasonable Assurance. The deciding factor is whether the information can
reasonably be finalized during the pre-licensing stage. Incomplete plan information
that is dependent on support agreements, facilities, or equipment that do not yet
exist is documented in the Schedule of Requirements for Reasonable Assurance
and completed during the post-licensing period. These decisions must be
discussed with affected jurisdictions and licensees during the plan review cycle
using the RAI process.
The IFR for Situation 2 sites will contain a mixture of RAIs and Requirements for
Reasonable Assurance. The State plans will need to be modified to include
information relevant to the new site. Plan omissions that can be corrected by
amending the existing or proposed plans should be handled through RAIs. Plan
omissions that are dependent on things that do not exist yet should be documented
as Requirements for Reasonable Assurance. The majority of incomplete items in
the proposed local plans will be Requirements for Reasonable Assurance if those
jurisdictions have never had REP plans before.
If the proposed plans for a Situation 3 site are as complete as possible in the prelicensing
period, the IFR might not contain any RAIs at all, but only Requirements
for Reasonable Assurance.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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RAI Flowchart
COLA including
Offsite Planning
Documents
submitted to NRC
NRC sends Offsite
Plan to FEMA HQ
FEMA Region reviews
Offsite Plans to validate
COLA reasonable
assurance
FEMA Region Reviewer contacts applicant
with list of verbal questions – Applicant
coordinates answers with State and local
agencies as appropriate ¹
Draft RAIs are
developed by
FEMA Region
Draft RAIs
approved by FEMA
HQ
Draft RAIs are sent to
Applicant
Draft RAIs are sent to
State and local agencies
as appropriate
Draft RAIs cc’d to
NRC; FEMA
interactions as needed
FEMA discuss RAIs with applicant,
State, and local agencies as
appropriate and if needed NRC –
Results in RAIs that are Clear,
Understood, and Attainable ¹
Final RAIs are sent to
Applicant
Applicant addresses RAIs and
submits to NRC/FEMA
FEMA sends Statement of
Reasonable Assurance for the
COLA
Final RAIs are sent to State and
local agencies as appropriate
Final RAIs are cc’d to NRC –
NRC Dockets
¹ Allows Applicant to provide FEMA with information in the COLA documents
that may have been overlooked by the reviewer.
Draft RAIs are cc’d to
NRC – NRC dockets
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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Phase II – Interim Finding Report for Open Items
Thirty (30) working days are allocated for this phase.
Phase II begins with the receipt of the Applicant’s final Phase I RAI responses.
The Applicant will submit RAI responses from State, Tribal, and local governments’
to the FEMA Region and HQ, within three days of receipt.
FEMA Role: Review Phase I RAIs to determine what remains unresolved. Any
unanswered RAIs are converted into OIs that form the basis for the
Phase II IFR for OIs.
NOTE: FEMA does not review the Applicant’s onsite emergency response plans
unless the onsite emergency response plan impacts offsite emergency response.
This action will have twenty (20) working days to complete this task in addition to
the thirty (30) working days allowed for the phase.
“For modeling purposes, Phase I and Phase II are treated as occurring
sequentially. However, since the Applicant’s RAI responses may be received before
the completion of Phase I, Phase II could actually run concurrently with the later
part of Phase I.”3
Deliverables FEMA Region:
IFR for OIs
OIs
Deliverables FEMA Headquarters:
IFR for OIs sent to the NRC
OIs sent to the Applicant
Complete an updated IFR that identifies remaining OIs based on review of
information provided from the Applicant’s response to Phase I RAIs.
The FEMA Region will submit the IFR for OIs and a separate final OI report to
FEMA HQ for review ten (10) working days prior to the end of Phase II. FEMA HQ
will submit a letter containing the OI report to the Applicant prior to the end of
Phase II.
(See Appendix 8 for OI format)
3 NRC letter dated December 20, 2007, to Dennis Schrader, Deputy Administrator
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot /P. Gardner
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IFR for OIs Outline:
Executive Summary
I. Introduction
A. General Characteristics
B. Emergency Response Organizations
C. Plans
D. Basis for the findings:
i. 44 CFR part 353
ii. Guidance Memoranda
iii. NUREG-0654 FEMA-REP-1, Rev. 1
E. Evaluation Format
II. Interim Finding of the Review of Evaluation of Emergency Preparedness Plans
A. NUREG-0654 Planning Standards A – P
B. Identify one of the following conditions for each criterion and each planning
standard in the report:
i. Adequate: Plans are adequate and there is reasonable assurance that
they can be implemented with only limited or no corrections needed.
ii. Adequate – corrections must be made: Plans are adequate, but before
a determination can be made as to whether they can be implemented,
corrections must be made to the plans or supporting measures must be
demonstrated (e.g., adequacy and maintenance of procedures, training,
resources, staffing levels and qualifications, and equipment).
iii. Inadequate: Plans are inadequate and cannot be implemented until they
are revised to correct deficiencies noted in the Federal review.
III. Schedule of Pending Actions or Requirements for Reasonable Assurance
IV. Review Composite Summary
V. Open Items - A separate document containing only the OIs also must be
submitted. (See Appendix 8)
VI. Acronym Key
Criterion Rating Criterion Rating Criterion Rating
A.1.a. Adequate A.2.a. Adequ/Corr C.1.b. Adequate
A.1.b. Adequate A.2.b. Adequ/Corr C.1.c. Adequ/Corr
A.1.c. Adequate A.3. Adequ/Corr C.2.a. Adequ/Corr
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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Letters and Memoranda for Submittal
FEMA Region
MEMORANDUM FOR: Chief, Radiological Emergency Preparedness Branch
FROM: Chief, Technological Hazards Branch, FEMA Region
SUBJECT: Interim Finding Report for Open Items
Content:
Identify the request for Interim Finding from the NRC, stating what plans or
procedures were used in the finding. Also, identify State, Tribal, and local
government’s plans and procedures by publication date. Identify how many open
items there are and expected date of finalization.
Include basis for the findings citing:
NUREG 0654/FEMA-REP-1 Rev 1
Guidance Memoranda
44 CFR part 350 - 354
FEMA HQ 1
Create cover letter to the NRC for IFR for OIs (See Appendix 7 for sample letter)
To: Chief, Licensing and Inspection Branch, NRC
From: Chief, Radiological Emergency Preparedness Branch, FEMA
Identify the request for Interim Finding from the NRC, stating what plans or
procedures were used in the finding. Also, identify State, Tribal, and local
government’s plans and procedures by publication date. Identify how many open
items there are and expected date of finalization.
Include your basis for the findings citing:
NUREG 0654 FEMA-REP-1 Rev 1
Guidance Memoranda
44 CFR part 350 – 354
This letter will be courtesy copied to the respective FEMA Region.
FEMA HQ 2
Create cover letter to the Applicant for the OIs
To: Applicant Point of Contact (See Appendix 13)
From: Chief, Radiological Emergency Preparedness Branch, FEMA
Ref: FEMA Open Items Concerning Offsite Emergency Response Plans for the
Combined License for (name of site).
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot /P. Gardner
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Explain that in accordance with the current OI process, the Applicant should review
all of the enclosed OIs and respond with the information or updates within thirty (30)
working days of the date of the letter.
This letter will be courtesy copied to the NRC and to the respective FEMA Region.
Phase III – Review of Safety Evaluation Report
FEMA is not directly involved in Phase III but could be called upon by the NRC for
consultation or review of offsite plans.
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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Phase IV – Interim Finding Report for Reasonable Assurance
Thirty (30) working days allocated for this phase.
This phase begins upon receipt of the Applicant’s responses to the Phase II OIs.
FEMA will receive the Applicants responses to OIs from the NRC within three days
of the Applicant’s response being available to the NRC. The duration, for FEMA
purposes, starts on the date of receipt of the Applicant’s OI response from the
NRC. FEMA HQ sends a letter to the FEMA Region (courtesy copied to the NRC)
notifying them to begin Phase IV.
FEMA Role: Review Applicant’s proposed resolutions to any OI pertaining to REP
offsite issues and finalize the IFR.
NOTE: “An Interim Finding based only on the review of currently available offsite
plans will include an assessment as to whether these plans are adequate when
measured against the standards and criteria of NUREG-0654 FEMA-REP-1,
Rev. 1, and, pending a demonstration through an exercise, whether there is
reasonable assurance that the plans can be implemented.”4
All OIs should be resolved at the conclusion of Phase IV.
Deliverable FEMA Region:
IFR for RA
Deliverables FEMA Headquarters:
IFR for RA sent to the Applicant and the NRC
This report constitutes an assessment of offsite planning and characterizes
preparedness related tasks and conditions that must be completed or met in order
to operate the proposed plant. The report is based on plans measured against
standards identified in NUREG-0654 FEMA-REP-1, Rev. 1.
For Situation 1 sites, all OIs should be resolved and the plans addressing all
planning standards and evaluation criteria should be fully Adequate or placed on
the Schedule of Pending Actions. For example, when the Applicant responds within
the required thirty (30) working days addressing the OIs they will not be submitting
any supporting documents because of the phase-in of 2009/2010 plan changes, but
only a letter stating what action they are taking to correct the OIs. For Situation 2
and 3 sites, evaluation criteria with elements addressed in the Schedule of
Requirements for Reasonable Assurance should be described as Adequate –
corrections must be made. All other evaluation criteria should be fully Adequate.
4 44 CFR 353 Appendix A
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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The FEMA Region will submit an IFR for Reasonable Assurance to FEMA HQ ten
(10) working days prior to the end of the Phase IV. FEMA HQ will submit the IFR for
Reasonable Assurance to the NRC prior to the end of Phase IV.
IFR for Reasonable Assurance Outline:
Executive Summary
I. Introduction
A. General Characteristics
B. Emergency Response Organizations
C. Plans
D. Basis for the findings:
i. 44 CFR part 353
ii. Guidance Memoranda
iii. NUREG-0654 FEMA-REP-1, Rev. 1
E. Evaluation Format
II. Interim Finding of the Review of Evaluation of Emergency Preparedness Plans
A. NUREG-0654 Planning Standards A – P
B. Identify one of the following conditions for each criterion and each planning
standard in the report:
i. Adequate: Plans are adequate and there is reasonable assurance that
they can be implemented with only limited or no corrections needed.
ii. Adequate – corrections must be made: Plans are adequate, but before
a determination can be made as to whether they can be implemented,
corrections must be made to the plans or supporting measures must be
demonstrated (e.g., adequacy and maintenance of procedures, training,
resources, staffing levels and qualifications, and equipment).
III. Schedule of Pending Actions or Requirements for Reasonable Assurance
A. 44 CFR 353, Appendix A, part II.2 states that if the plans submitted are not
complete (e.g., Situation 3 Site), then a Requirement for Reasonable
Assurance is required. It will delineate milestones for preparation of the plan
by the offsite authorities as well as FEMA’s actions to assist in timely
development and review of the plans. FEMA has determined that the
Requirements for Reasonable Assurance will be incorporated into the IFR
within Section III.
IV. Review Composite Summary
A. Situation 1 Sites
Criterion Rating Criterion Rating Criterion Rating
A.1.a. Adequate A.2.a. Adequate C.1.b. Adequate
A.1.b. Adequate A.2.b. Adequate C.1.c. Adequate
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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A.1.c. Adequate A.3. Adequate C.2.a. Adequate
A.1.d. Adequate A.4. Adequate C.2.b. Adequate
A.1.e. Adequate C.1.a. Adequate C.3. Adequate
B. Situation 2 and 3 Sites
Criterion Rating Criterion Rating Criterion Rating
A.1.a. Adequate A.2.a. Adequ/Corr C.1.b. Adequate
A.1.b. Adequate A.2.b. Adequ/Corr C.1.c. Adequate
A.1.c. Adequate A.3. Adequ/Corr C.2.a. Adequ/Corr
A.1.d. Adequate A.4. Adequate C.2.b. Adequ/Corr
A.1.e. Adequate C.1.a. Adequate C.3. Adequ/Corr
V. Acronym Key
Letters and Memoranda for Submittal
FEMA Region
MEMORANDUM FOR: Chief, Radiological Emergency Preparedness Branch
FROM: Chief, Technological Hazards Branch, FEMA Region
SUBJECT: Interim Finding Report for Reasonable Assurance
Content:
Identify the request for Interim Finding from the NRC, stating what plans or
procedures were used in the finding. Also, identify State, Tribal, and local
government’s and the plans and procedures by publication date.
Include basis for the findings citing:
NUREG 0654FEMA-REP-1 Rev 1
Guidance Memoranda
44 CFR part 350 - 354
“An Interim Finding based on the review of the currently available offsite plans will
include an assessment as to whether these plans are adequate when measured
against the standards and criteria of NUREG 0654FEMA-REP-1 and pending a
demonstration through an exercise, whether there is reasonable assurance that the
plans can be implemented5.”
FEMA HQ
Create cover letter to the NRC for IFR for Reasonable Assurance
5 MOU between FEMA and the NRC
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot /P. Gardner
2/6/2009 12:25:11 PM
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To: Chief, Licensing and Inspection Branch, NRC
From: Chief, Radiological Emergency Preparedness Branch, FEMA
Identify the request for Interim Finding from the NRC, stating what plans or
procedures were used in the finding. Also, identify State, Tribal, and local
government’s plans and procedures by publication date.
Include basis for the findings citing:
NUREG 0654/FEMA-REP-1 Rev 1
Guidance Memoranda
44 CFR part 350 – 354
The plans are adequate when measured against the standards and criteria of
NUREG 0654 FEMA-REP-1 and pending a demonstration through an exercise,
whether there is reasonable assurance that the plans can be implemented.
This letter will be courtesy copied to the respective FEMA Region.
Phase V – Review of Safety Evaluation Report
Two (2) working days allocated for this phase.
Advisory Committee on Reactor Safety (ACRS) reviews the Safety Evaluation
Report (SER). FEMA is not directly involved in Phase V, but could be called upon
by the NRC for consultation or review of offsite plans.
Phase VI – Final Review of Safety Evaluation Report
Thirty-one (31) working days allocated for this phase.
This phase is primarily internal to the NRC for the final review editing and
management concurrence of the Final SER. FEMA support would be requested for
any changes that will impact FEMA’s final report.
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
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I. Section 2 – Four Phase Process
The four phase process is used for applications containing a previously certified
reactor design by the NRC. As of December 2008, the following COL applications
are following the four phase process:
Bell Bend
Calloway
Fermi 3
Grand Gulf
Lee
Levy County
Nine Mile Point
River Bend
Shearon Harris
Summer
Victoria
Vogtle
COL Process FEMA Deliverable Duration
Acceptance Review Review Letter 13 Working Days
90 Working Days
Phase I – Part A IFR for Requests for Additional
Information 120 Working Days
Phase I – Part B IFR for Open Items 30 Days
Phase II IFR for Reasonable Assurance 30 Working Days
Phase III Tentative Support 2 Days
Phase IV Tentative Support 31 Days
Hearings Testimony as Needed Throughout Project
As Needed
Post COL IFR on Preparedness After Qualifying
Exercise
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot /P. Gardner
2/6/2009 12:25:11 PM
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Phase I: Part A and Part B
Part A
Interim Finding Report for Requests for Additional Information
Ninety (90) working days are allocated for operating sites for this phase. One
hundred twenty (120) working days are allocated for non-operating sites for this
phase. Non-operating sites will use the thirty (30) working days for Acceptance
Review combined with the ninety (90) working days allocated for Phase I.
This phase begins after the NRC dockets the application materials or as
established by the site-specific schedule. Part A ends with the issuance of the final
IFR for RAIs.
FEMA Role: Review offsite emergency response plans to determine if all
NUREG-0654 FEMA-REP-1, Rev.1 criterions are addressed
adequately.
An IFR is described in the FEMA/NRC MOU, 44 CFR 353 Appendix A. It is developed
by reviewing the plans and procedures of State, Tribal, and local governments are
responsible for a NPP offsite response.
The purpose of the IFR for RAIs is to define gaps in planning, equipment, and
training that must be filled before final reasonable assurance can be granted.
Deliverables FEMA Region:
IFR for RAIs
Final RAIs
Deliverables FEMA Headquarters:
IFR for RAIs sent to the Applicant and the NRC
The FEMA Region will contact FEMA HQ with an update of draft RAIs at bi-weekly
intervals during this phase. Then the FEMA Region will submit the IFR for RAIs
report to FEMA HQ for review ten (10) working days prior to the end of Part A.
FEMA HQ will submit a letter containing the RAI report to the Applicant prior to the
end of Part A.
NOTE: The FEMA IFR description of offsite preparedness provides a detailed
summary of actions that must be completed before a proposed reactor will be
authorized and operated. This includes the review of Part A which becomes a part
of the NRC PSER.
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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IFR for RAIs Outline:
Executive Summary
I. Introduction
A. General Characteristics
B. Emergency Response Organizations
C. Plans
D. Basis for the findings:
i. 44 CFR part 353
ii. Guidance Memoranda
iii. NUREG-0654 FEMA-REP-1, Rev. 1
E. Evaluation Format
II. Interim Findings of the Review of Evaluation of Emergency Preparedness
Plans
A. NUREG-0654 Planning Standards A – P
B. Identify one of the following conditions for each criterion and each
planning standard in the report:
i. Adequate: Plans are adequate and there is reasonable assurance
that they can be implemented with only limited or no corrections
needed.
ii. Adequate – corrections must be made: Plans are adequate, but
before a determination can be made as to whether they can be
implemented, corrections must be made to the plans or supporting
measures must be demonstrated (e.g., adequacy and maintenance of
procedures, training, resources, staffing levels and qualifications, and
equipment).
iii. Inadequate: Plans are inadequate and cannot be implemented until
they are revised to correct deficiencies noted in the Federal review.
iv. N/A: The planning criterion is not applicable to this ORO.
III. Schedule of Pending Actions/Requirements for Reasonable Assurance
IV. Review Composite Summary
Criterion Rating Criterion Rating Criterion Rating
A.1.a. Adequate A.2.a. Adequ/Corr C.1.b. Adequate
A.1.b. Adequate A.2.b. Inadequate C.1.c. Adequ/Corr
A.1.c. Adequate A.3. Inadequate C.2.a. Adequ/Corr
A.1.d. Adequ/Corr A.4. Adequ/Corr C.2.b. Adequ/Corr
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot /P. Gardner
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V. Requests for Additional Information - A separate document containing only
the RAIs also must be submitted.(See Appendix 4)
VI. Acronym Key
NOTE: Follow the Letters and Memoranda for Submittal process found in the Six
Phase – Phase I process.
Part B
Interim Finding Report for Open Items
Thirty (30) working days are allocated for this phase.
Part B begins with the receipt of the Applicant’s Part A RAI responses. FEMA will
receive the Applicant’s responses to RAIs from the NRC within three days of the
Applicant’s response being available to the NRC.
FEMA Role: Review Part A RAIs to determine what remains unresolved. Any
unanswered RAIs are converted into OIs that form the basis for the
Part B IFR for OIs.
NOTE: FEMA does not review the Applicant’s onsite emergency response plans
unless the onsite emergency response plan impacts offsite emergency response.
This action will have twenty (20) working days to complete this task in addition to
the thirty (30) working days allowed for the phase.
Deliverables FEMA Region:
IFR for OIs
OIs
Deliverables FEMA Headquarters:
IFR for OIs sent to the NRC
OIs sent to the Applicant
Complete an updated IFR that identifies remaining OIs based on review of
information provided by the Applicant’s response to Part A RAIs.
Then the Region will submit the IFR for OIs to FEMA HQ for review ten (10)
working days prior to the end of Part B. FEMA HQ will submit a letter containing the
OI report to the Applicant prior to the end of Part B.
(See Appendix 8 for OI format)
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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IFR for OIs Outline:
Executive Summary
I. Introduction
A. General Characteristics
B. Emergency Response Organizations
C. Plans
D. Basis for the findings:
i. 44 CFR part 353
ii. Guidance Memoranda
iii. NUREG-0654 FEMA-REP-1, Rev. 1
E. Evaluation Format
II. Interim Finding of the Review of Evaluation of Emergency Preparedness Plans
A. NUREG-0654 Planning Standards A – P
B. Identify one of the following conditions for each criterion and each planning
standard in the report:
i. Adequate: Plans are adequate and there is reasonable assurance that
they can be implemented with only limited or no corrections needed.
ii. Adequate – corrections must be made: Plans are adequate, but before
a determination can be made as to whether they can be implemented,
corrections must be made to the plans or supporting measures must be
demonstrated (e.g., adequacy and maintenance of procedures, training,
resources, staffing levels and qualifications, and equipment).
III. Schedule of Pending Actions or Requirements for Reasonable Assurance
IV. Review Composite Summary
V. Open Items - A separate document containing only the OIs also must be
submitted. (See Appendix 8)
VI. Acronym Key
NOTE: Follow the Letters and Memoranda for Submittal process found in the Six
Phase – Phase II process.
Criterion Rating Criterion Rating Criterion Rating
A.1.a. Adequate A.2.a. Adequ/Corr C.1.b. Adequate
A.1.b. Adequate A.2.b. Adequ/Corr C.1.c. Adequ/Corr
A.1.c. Adequate A.3. Adequ/Corr C.2.a. Adequ/Corr
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot /P. Gardner
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Phase II – Interim Finding Report for Reasonable Assurance
Thirty (30) working days allocated for this phase.
This phase begins upon receipt of the Applicant’s responses to the Phase I OIs.
FEMA will receive the Applicants responses to OIs from the NRC within three days
of the Applicant’s response being available to the NRC. The duration, for FEMA
purposes, starts on the date of receipt of the Applicant’s OI response from the
NRC.
FEMA Role: Review Applicant’s proposed resolutions to any OI pertaining to REP
offsite issues and finalize the IFR for Reasonable Assurance.
NOTE: “An Interim Finding based only on the review of currently available offsite
plans will include an assessment as to whether these plans are adequate when
measured against the standards and criteria of NUREG-0654 FEMA-REP-1,
Rev. 1, and, pending a demonstration through an exercise, whether there is
reasonable assurance that the plans can be implemented.”6
All OIs should be resolved at the conclusion of Phase II.
Deliverable FEMA Region:
IFR for RA
Deliverables FEMA Headquarters:
IFR for RA sent to the Applicant and the NRC
This report constitutes an assessment of offsite planning and characterizes
preparedness related tasks and conditions that must be completed or met in order
to operate the proposed plant. The report is based on plans measured against
standards identified in NUREG-0654 FEMA-REP-1, Rev. 1.
For Situation 1 sites, all OIs should be resolved and the plans addressing all
planning standards and evaluation criteria should be fully Adequate or placed on
the Schedule of Pending Actions. For example, when the Applicant responds within
the required thirty (30) working days addressing the OIs they will not be submitting
any supporting documents because of the phase-in of 2009/2010 plan changes, but
only a letter stating what action they are taking to correct the OIs. For Situation 2
and 3 sites, evaluation criteria with elements addressed in the Schedule of
Requirements for Reasonable Assurance should be described as Adequate –
corrections must be made. All other evaluation criteria should be fully Adequate.
6 44 CFR 353 Appendix A
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
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The FEMA Region will submit an IFR for Reasonable Assurance to FEMA HQ five
(5) working days prior to the end of the Phase II. FEMA HQ will submit the IFR for
Reasonable Assurance to the NRC prior to the end of Phase II.
IFR for Reasonable Assurance Outline:
Executive Summary
I. Introduction
A. General Characteristics
B. Emergency Response Organizations
C. Plans
D. Basis for the findings:
i. 44 CFR part 353
ii. Guidance Memoranda
iii. NUREG-0654 FEMA-REP-1, Rev. 1
E. Evaluation Format
II. Interim Finding of the Review of Evaluation of Emergency Preparedness Plans
A. NUREG-0654 Planning Standards A – P
B. Identify one of the following conditions for each criterion and each planning
standard in the report:
i. Adequate: Plans are adequate and there is reasonable assurance that
they can be implemented with only limited or no corrections needed.
ii. Adequate – corrections must be made: Plans are adequate, but before
a determination can be made as to whether they can be implemented,
corrections must be made to the plans or supporting measures must be
demonstrated (e.g., adequacy and maintenance of procedures, training,
resources, staffing levels and qualifications, and equipment).
III. Schedule of Pending Actions or Requirements for Reasonable Assurance
A. 44 CFR 353, Appendix A, part II.2 states that if the plans submitted are not
complete (e.g., Situation 3 Site), then a Requirement for Reasonable
Assurance is required. It will delineate milestones for preparation of the plan
by the offsite authorities as well as FEMA’s actions to assist in timely
development and review of the plans. FEMA has determined that the
Requirements for Reasonable Assurance will be incorporated into the IFR
within Section III.
IV. Review Composite Summary
A. Situation 1 Sites
Criterion Rating Criterion Rating Criterion Rating
A.1.a. Adequate A.2.a. Adequate C.1.b. Adequate
A.1.b. Adequate A.2.b. Adequate C.1.c. Adequate
A.1.c. Adequate A.3. Adequate C.2.a. Adequate
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot /P. Gardner
2/6/2009 12:25:11 PM
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A.1.d. Adequate A.4. Adequate C.2.b. Adequate
A.1.e. Adequate C.1.a. Adequate C.3. Adequate
B. Situation 2 and 3 Sites
Criterion Rating Criterion Rating Criterion Rating
A.1.a. Adequate A.2.a. Adequ/Corr C.1.b. Adequate
A.1.b. Adequate A.2.b. Adequ/Corr C.1.c. Adequate
A.1.c. Adequate A.3. Adequ/Corr C.2.a. Adequ/Corr
A.1.d. Adequate A.4. Adequate C.2.b. Adequ/Corr
A.1.e. Adequate C.1.a. Adequate C.3. Adequ/Corr
V. Acronym Key
NOTE: Follow the Letters and Memoranda for Submittal process found in the Six
Phase – Phase IV process.
Phase III – Review of Safety Evaluation Report
Two (2) working days allocated for this phase.
ACRS reviews the SER. FEMA is not directly involved in Phase III but could be
called upon by the NRC for consultation or review of offsite plans.
Phase IV – Final Review of Safety Evaluation Report
Thirty-one (31) working days allocated for this phase.
This phase is primarily internal to the NRC for the final review editing and
management concurrence of the Final SER. FEMA support would be requested for
any changes that will impact FEMA’s final report.
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
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J. Post Combined License
Interim Finding Report on Preparedness
Deliverable FEMA Region:
IFR on Preparedness
Deliverable FEMA HQ:
Letter of Reasonable Assurance to the NRC
This report will be issued after a qualifying exercise
An IFR on Preparedness will be based on the review of currently available plans
and joint exercise results and will include an assessment as to:
? Whether offsite emergency plans are adequate as measured against the
standards and criteria of NUREG-0654 FEMA-REP-1, Rev. 1.
? Whether the exercise(s) demonstrated that there is reasonable assurance that
the plans can be implemented.
An IFR on Preparedness will indicate one of the following conditions:
? There is reasonable assurance that the plans are adequate and can be
implemented as demonstrated in an exercise.
? There are deficiencies that must be corrected.
? FEMA is undecided and will provide a schedule of actions leading to a decision.
Letters and Memoranda for Submittal
FEMA Region
Create a Memorandum for FEMA HQ detailing the results of the Preparedness
Exercise.
MEMORANDUM FOR: Chief, Radiological Emergency Preparedness Branch
FROM: Chief, Technological Hazards Branch
SUBJECT: Final Report for the (Plant Name) Qualifying Exercise
The body of the memorandum should include all Deficiencies and Areas Requiring
Corrective Actions (ARCAs). Provide a statement detailing whether or not the plans
and preparedness of the jurisdictions can be implemented are adequate to provide
Reasonable Assurance to protect the health and safety of the public.
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot /P. Gardner
2/6/2009 12:25:11 PM
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FEMA HQ
Create letter to the NRC for IFR on Preparedness
To: Chief, Licensing and Inspection Branch, NRC
From: Chief, Radiological Emergency Preparedness Branch, FEMA
Compose a letter relaying the information supporting the above statements.
This letter will be courtesy copied to the respective FEMA Region.
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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K. Glossary
AGENCYWIDE
DOCUMENTS ACCESS
AND MANAGEMENT
SYSTEM (ADAMS)
The ADAMS is an information system that
provides access to all image and text documents
that the NRC has made public since November 1,
1999, as well as bibliographic records (some with
abstracts and full text) that the NRC made public
before November 1999. The NRC continues to
add several hundred new documents daily.
ADAMS permits full-text searching and enables
users to view document images, download files,
and print locally.
COMBINED LICENSE (COL)
APPLICATIONS AND
SUPPLEMENTAL
INFORMATION
A combined license, when issued, is authorization
from the NRC to construct and, with conditions,
operate a nuclear power plant at a specific site
and in accordance with laws and regulations. Prior
to issuing a COL, the NRC staff will complete
safety and environmental reviews of the combined
license applications in accordance with the Atomic
Energy Act, NRC regulations, and the National
Environmental Policy Act. All stakeholders, most
importantly the public, will be given notice as to
how and when they may participate in the
regulatory process including opportunities to
request a hearing on issuance of the license.
DELIVERABLES The work product from a process that includes
analysis and reporting on the current State of
emergency preparedness in a jurisdiction.
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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EARLY SITE PERMITS
(ESP)
The NRC can issue an ESP for approval of one or
more sites for one or more nuclear power facilities
separate from the filing of an application for a
construction permit or combined license in
accordance with 10 CFR Part 52. An ESP is a
partial construction permit and is, therefore,
subject to all procedural requirements in 10 CFR
Part 2 that are applicable to construction permits.
Applications for ESPs will be reviewed according
to the applicable standards set out in 10 CFR
Parts 50 and 100 as they apply to applications for
construction permits for nuclear power plants.
ESP is good for 10 to 20 years and can be
renewed for an additional 10 to 20 years. ESPs
address site safety issues, environmental
protection issues, and plans for coping with
emergencies, independent of the review of a
specific nuclear plant design.
FEDERAL EMERGENCY
MANAGEMENT AGENCY
(FEMA)
This agency establishes Federal policies for and
coordinates all civil defense and civil emergency
planning, management, mitigation, and assistance
functions of executive agencies. FEMA assists
local and State agencies in their emergency
planning. Its primary role is one of coordinating
Federal, State, local, and volunteer response
actions for offsite areas.
INTERIM FINDING REPORT
(IFR)
Report that is developed by reviewing States, Tribal
and local plans that are responsible for a nuclear
power plant.
NUCLEAR REGULATORY
COMMISSION (NRC)
Congress created the NRC as an independent
agency in 1974 to enable the nation to safely use
radioactive materials for beneficial civilian
purposes while ensuring that people and the
environment are protected. The NRC regulates
commercial nuclear power plants and other uses
of nuclear materials, such as nuclear medicine,
through licensing, inspection and enforcement of
its requirements.
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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REASONABLE
ASSURANCE
Reasonable assurance is the recognition that
“adequate protective measures can and will be
taken in the event of a radiological emergency”.
Reasonable assurance is based on licensees
complying with NRC regulations and guidance, as
well as licensees and offsite response
organizations demonstrating that they can
effectively implement emergency plans and
procedures during periodic evaluated exercises.
OPEN ITEMS Any RAIs that have not been resolved as of Phase
II in accordance with NUREG-0654 FEMA-REP-1,
Rev. 1 criteria. All open items must be resolved
before Phase IV.
SCHEDULE OF
REQUIREMENTS FOR
REASONABLE
ASSURANCE
The Schedule of Requirements for Reasonable
Assurance is used primarily with Situation 2 and 3
site applications. It is included in the Interim
Finding Report (IFR) when plans cannot be
completely developed because equipment,
buildings, and infrastructure do not exist yet
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot /P. Gardner
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L. Acronyms
ACRS ADVISORY COMMITTEE ON REACTOR SAFETY
CFR CODE OF FEDERAL REGULATIONS
COL COMBINED LICENSE
FEMA FEDERAL EMERGENCY MANAGEMENT AGENCY
FR FEDERAL REGISTER
HQ HEADQUARTERS
IFR INTERIM FINDING REPORT
MOU MEMORANDUM OF UNDERSTANDING
NEI NUCLEAR ENERGY INSTITUTE
NPP NUCLEAR POWER PLANT
NRC NUCLEAR REGULATORY COMMISSION
NRO NEW REACTOR OFFICER
NUREG NUCLEAR REGULATIONS
OI OPEN ITEM
ORO OFFSITE RESPONSE ORGANIZATION
POA&M PLAN OF ACTION AND MILESTONES
PM PROJECT MANAGER
PSER PRELIMINARY SAFETY EVALUATION REPORT
RRAC RADIOLOGICAL REGIONAL ASSISTANCE COMMITTEE
RAI REQUEST FOR ADDITIONAL INFORMATION
REP RADIOLOGICAL EMERGENCY PREPAREDNESS
REPP RADIOLOGICAL EMERGENCY PREPAREDNESS PROGRAM
RERP RADIOLOGICAL EMERGENCY RESPONSE PLANS
SER SAFETY EVALUATION REPORT
SOP STANDARD OPERATING PROCEDURES
TBD TO BE DETERMINED
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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M. Appendices
1. Sample Memo for Insufficient Acceptance Review
2. Sample Memo for Sufficient Acceptance Review
3. Sample Letter for Interim Finding Report for RAIs
4. RAI Submittal Form Example
5. Operating Site RAI Tracking Form
6. Non-Operating Reactor Site RAI Tracking Form
7. Sample Letter for Interim Finding Report for OIs
8. Open Items Submittal Form Example
9. Direct Discussion Form
10. Interim Finding Report Example
11. Post COL Actions Needed Tracking Form
12. Requirements for Reasonable Assurance
13. Points of Contact
Applicant
FEMA Headquarters
NRC
FEMA Regions
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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APPENDIX 1
Sample Memo for Insufficient Acceptance Review
(Date)
MEMORANDUM FOR: ___________________
Chief
Radiological Emergency Preparedness Branch
FROM: ___________________
Chief
Technological Hazards Branch
SUBJECT: Acceptance Review of Offsite Radiological Emergency Plans
for the __________________, Combined License Application
The FEMA Region_________ REP staff has reviewed the plans submitted for (Plant Name)
dated (date). FEMA has found the _________ State plans and ________county plans
submitted to be current and complete.
However, there are additional supporting plans/references in the ________________ Plan
which were not included and are necessary for performing a complete review of the
application. The following list identifies the information needed in order to proceed with the
review:
?
?
?
Please contact (Regional staff person) at (phone) if you have any questions.
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
48
APPENDIX 2
Sample Memo for Sufficient Acceptance Review
(Date)
MEMORANDUM FOR: ___________________
Chief
Radiological Emergency Preparedness Branch
FROM: ___________________
Chief
Technological Hazards Branch
SUBJECT: Acceptance Review of Offsite Radiological Emergency
Response Plan for _____________Nuclear Power Plant
(NPP) Combined License (COL)
Describe the Regions, Plant site and relevant authorities from the State/counties plans.
Describe any information that was received for further review that was omitted in the
original submission.
In response to our ___________ memorandum to you, we received additional plans relative
to the subject application directly from the utility on _______________. These resubmitted
plans, provided to address the shortcomings described in our ______
memorandum, were reviewed, and the following comments are provided:
? Our _______ memorandum indicated the plans for the State of __________(Annex
Q) and the ____________ Risk Counties (Alpha, Beta and Charlie Counties) were
dated 2004 and did not contain a NUREG -0654 cross –reference. Updated plans for
the State of ___________ (July 2007) were subsequently submitted. Those plans
contained the requested cross reference, and this issue is considered resolved.
? Our __________ memorandum indicated the plans for the State of ________
(Annex ___) did not contain references (including maps) to the new county highway
that has been completed, and would most surely impact upon various aspects of the
evacuation plan. The revised _______ (date) evacuation annex (___) was received
by this Office, and it addresses in all respects, the earlier paucity of information on
this new highway. All issues related to this earlier oversight to be closed.
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot /P. Gardner
2/6/2009 12:25:11 PM
49
APPENDIX 3
Sample Letter for Interim Finding Report for RAIs
(Date)
Chief, Licensing and Inspection Branch
Division of Preparedness and Response
Office of Nuclear Security and Incident Response
U.S. Nuclear Regulatory Commission
Washington DC 20555-0001
Ref: Interim Finding Report (IFR) for Requests for Addition Information (RAIs) of the
Offsite Emergency Response Plans for the Combined License Application – (Name
of site)
Dear (Addressee):
Please find enclosed the Interim Finding Report of the COL application, (Name of site)
submitted by the Radiological Emergency Preparedness Program staff from our Region ___
Office. The information pertaining to offsite radiological emergency response plans,
provided in the COL application, was utilized in establishing the content of this report.
All Requests for Addition Information (RAIs) have been submitted to your agency for this
phase of the safety review and are all identified in the enclosed report.
Should you and or members of your staff have any questions regarding this matter, please
contact (New Reactor Team member) at (phone) or (New Reactor Team Leader) at (phone).
Sincerely,
(Branch Chief)
Chief
Radiological Emergency Preparedness Branch
Enclosure: As stated
cc: (New Reactor Team Leader), NRC
(Name), FEMA Region ____
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
50
APPENDIX 4
RAI Submittal Form Example
RAIs should be formatted according to the template below and should contain the
following information:
? Each RAI should include the description of the needed additional information
or question posed to the COL Applicant.
? Each RAI should include a reference to the planning standard and, if
applicable, the evaluation criterion identified in NUREG-0654 FEMA-REP-1,
Rev. 1
? All RAIs will contain of a site identifier and be sequentially numbered.
? Organize planning standard in separate paragraphs.
? Standardize wording
? For multiple parts of one RAI use sub-numbers organized in the same order
as the requirements in the criterion
RAI
Number
RAI Description
State/Tribal
County 1/
County 2
(SITE) - 001 Subject: (brief subject)
Basis: NUREG-0654, Evaluation Criterion (X.1.x)
SRP ACCEPTANCE CRITERION : Requirement H
Note: (if applicable, related RAI or revision information)
A. State Plan (name) (specific plan section, if
applicable) (description of question) Provide
(needed information)
B. County Plan 1 (name) (specific plan section, if
applicable) (if multiple items relevant to this
subject and this plan – otherwise put different
subject under a new RAI)
B.1. County Plan 1, (specific plan section, if
applicable) (description of question)
Provide (needed information)
B.2. County Plan 1, (different specific plan
section, if applicable) (description of
question) Provide (needed information)
C. County Plan 2 (name) (specific plan section, if
applicable) (description of question) Provide
(needed information)
S/C1/C2
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
51
APPENDIX 5
Operating Site RAI Tracking Form
RAI
Number
Date
RAI Cited
Planning
Standard
Plant
Site
State, Tribal,
local govt’s RAI Description Resolution
Description
Open
Item
Y/N
JS 001 1/5/2008
Planning
standard
NUREG
Criterion
A.1.a,
A.1.b,
A.1.c
RAI Resolved:
1/30/2008
John
Smith
Idaho Please provide the
following for ABC
County:
1. The current
Emergency
Operation Plan
(EOP) for the ABC
County Idaho.
Corrective Action:
ABC County
Emergency
Operation Plans
were received on
1/28/2008
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
Sheffield/Strother/Fontenot/Gardner
2/6/2009 12:25 PM
52
APPENDIX 6
Non-Operating Reactor Site RAI Tracking Form
RAI
Number
Date
RAI Cited
Planning
Standard
Plant
Site
State,
Tribal, local
govt’s
RAI Description
Resolution
Description with
proposed date
Open
Item
Y/N
JD001 9/15/2008
Planning standard
NUREG Criterion
P.7
RAI Resolved
Date:
Jane
Doe
North
Dakota
Please provide the
following for ABC
County:
1. Provide a list of
the implementing
procedures
associated with
each plan and what
section(s) of the
plan are
implemented by
each procedure
Corrective Action:
The implementing
procedures will be
developed by
2015
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
53
APPENDIX 7
Sample Letter for Interim Finding Report for OIs
(Date)
(Addressee)
Chief, Licensing and Inspection Branch
Division of Preparedness and Response
Nuclear Security and Incident Response
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555-0001
Ref: Interim Findings Report (IFR) for Open Items (OIs) for the (name of site) Combined
License (COL) Application
Dear (Addressee):
Please find enclosed the IFR for OIs for the (name of site) COL application submitted by
the Radiological Emergency Preparedness (REP) Program staff from our Region __ Office.
FEMA has reviewed the applicant’s response to Phase I IFR Request for Additional
Information (RAI), and the unresolved RAIs have been converted to OIs in the development
of this document.
The enclosed IFR for OIs serves as the deliverable for the completion of FEMA’s portion of
Phase II of the (name of site) COL application process.
Should you or members of your staff have any questions regarding this matter, please
contact (New Reactor Team member) at (phone) or (New Reactor Team Leader) at (phone)
Sincerely,
(Branch Chief)
Chief
Radiological Emergency Preparedness Branch
Enclosure: As stated
cc: (New Reactor Team Leader), NRC
(Name), FEMA Region ____
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
54
APPENDIX 8
Open Items Submittal Form Example
Each OI should keep the original RAI site identifier and number
OI Ref.
Open Item Description
State/Tribal
County 1/
County 2
RAI
Number
(SITE) - 001
Subject: (brief subject)
Basis: NUREG-0654, Evaluation Criterion (X.1.x)
SRP ACCEPTANCE CRITERION : Requirement H
Note: (if applicable, related RAI or revision
information)
A. State Plan (name) (specific plan section, if
applicable) (description of question) Provide
(needed information)
B. County Plan 1 (name) (specific plan section,
if applicable) (if multiple items relevant to this
subject and this plan – otherwise put different
subject under a new RAI)
B.1. County Plan 1, (specific plan section, if
applicable) (description of question)
Provide (needed information)
B.2. County Plan 1, (different specific plan
section, if applicable) (description of
question) Provide (needed information)
C. County Plan 2 (name) (specific plan section,
if applicable) (description of question)
Provide (needed information)
S/C1/C2
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
55
APPENDIX 9
Direct Discussion Form
Date: ______________________ Phone: _____________________________
Plant/Site: __________________State/local government: _________________
Point of Contact: _________________________________________
Topic of Discussion: ______________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
________________________
Signature ___________________________________
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
56
APPENDIX 10
Interim Finding Report Example
Interim Finding Report for ______
(RAI/OI/Reasonable Assurance)
On the adequacy of the offsite
Radiological Emergency Response Planning and Preparedness
for the
_____________________Nuclear Power Plant
___________City _____________State
________________Date
Prepared by the
U.S. Department of Homeland Security
Federal Emergency Management Agency
National Preparedness Directorate
Technological Hazards Division
Region_____
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
57
Table of Contents
Page
Executive Summary 1
I. Introduction 1
A. General Characteristics of the ___________ Nuclear Plant
B. Emergency Response Organizations
C. Plans
D. Basis for Findings
E. Evaluation Format
II. Review and Evaluation of Emergency Preparedness Plans for the 2
__________ Nuclear Plant against the Planning Standards of
NUREG-0654 FEMA-REP-1, Rev. 1
A. Assignment of responsibility (Organizational Control)
B. Onsite Emergency Organization
C. Emergency Response Support and Resources
D. Emergency Classification System
E. Notification Methods and Procedures
F. Emergency Communications
G. Public Education and Information
H. Emergency Facilities and Equipment
I. Accident Assessment
J. Protective Response
K. Radiological Exposure Control
L. Medical and Public Health Support
M. Recovery and Reentry Planning and Post-Accident Operations
N. Exercises and Drills
O. Radiological Emergency Response Training
P. Responsibility for the Planning Effort: Distribution,
Periodic Review, and Distribution of Emergency Plans
III. Schedule 2
A. Pending Actions
B. Requirements for Reasonable Assurance
IV. Review Composite Rating Summary 3
V. RAIs/OIs/RA 3
VI. Acronym Key 3
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
58
Executive Summary
I. Introduction
A. General Characteristics of the _______ Nuclear Plant
The ______________ Nuclear Plant sites, consisting of ____ acres, is located in
________ County(ies) in (direction) State, on the E/N/W/S shore of the (body of
water) or describe the general location and cite approximate distance/direction from
the nearest major cities (use two examples).
The 10-mile plume Emergency Planning Zone (EPZ) includes (list the counties and
major cities) within the (States).
The __________Nuclear Power plant is owned and operated by _________.
B. Emergency Response Organizations
Describe the authorities from the State/counties plans. Example “Final authority for
all offsite emergency actions in response to a radiological incident at a fixed nuclear
plant rests with the Governor of the State of _____; or with the Mayor of the City of
________”.
Describe the concept for overall emergency management and coordination. Cite the
responsible organization for coordination of State, local, private and volunteer
organizations with Federal response elements.
Describe the organizations and relationships within the State for entities with
responsibilities related to radiological emergency planning and response. Ensure
accident assessment, radiation monitoring, health hazards, and protective action
guidelines are discussed.
C. Plans
Describe how the State plans are organized. Include number of volumes and overall
content of each volume. List the annexes by volumes that are in the plans.
D. Basis for Findings
Discuss the critical elements citing above (and any not-previously mentioned items)
that form the basis for the determination. List key elements, and cite specific
coordination used to derive finding.
SOP for New Reactor Combined License (COL) Application_____________________________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
59
E. Evaluation Format
In accordance with the Memorandum of Understanding (MOU) (44 CFR 353
appendix A) with the Nuclear Regulatory Commission (NRC) FEMA agreed to
furnish assessments, findings and determinations as to whether State, Tribal and local
emergency plans and preparedness are adequate and continue to be capable of
implementation (e.g., adequacy and maintenance of procedures, training, and
resources, staffing levels and qualification and equipment adequacy). These findings
and determinations are used by the NRC under its own rules in connection with its
licensing and regulatory requirements and FEMA supports its findings in the NRC
licensing process and related court proceedings- 44 CFR 350.3(f).
NUREG/0654/FEMA-REP-1 Rev. 1 Criteria for Preparation and Evaluation of
Radiological Emergency Response Plans and Preparedness in Support of Nuclear
Power Plants November 1980 is the guidance used to review and develop this
Interim Finding Report. Each planning standard will have an overall rating.
II. Review and Evaluation of Emergency Preparedness Plans for the _______ Nuclear Plant
against the Planning Standards of NUREG-0654/FEMA-REP-1, Rev.1
A. Assignment of responsibility (Organizational Control)
B. Onsite Emergency Organization
C. Emergency Response Support and Resources
D. Emergency Classification System
E. Notification Methods and Procedures
F. Emergency Communications
G. Public Education and Information
H. Emergency Facilities and Equipment
I. Accident Assessment
J. Protective Response
K. Radiological Exposure Control
L. Medical and Public Health Support
M. Recovery and Reentry Planning and Post-Accident Operations
N. Exercises and Drills
O. Radiological Emergency Response Training
P. Responsibility for the Planning Effort: Distribution, Periodic Review and
Distribution of Emergency Plans
III. Schedule
A. Pending Action – Describe in a statement items that are pending.
1. The State of _______ is awaiting the Qualifying Exercise of the offsite plans and
procedures that will be conducted on __________.
2. The county is awaiting the county official signature for the final revision to the
plans
B. Requirements for Reasonable Assurance
Technological Hazards Division/Radiological Emergency Preparedness Program___________________________
_______________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
60
IV. Review Composite Rating Summary – A one page table of the 109 criterion ratings
Criterion Rating Criterion Rating Criterion Rating
A.1.a. Adequate A.2.a. Adequate C.1.b. Adequate
A.1.b. Adequate A.2.b. Adequate C.1.c. Adequate
A.1.c. Adequate A.3. Adequate C.2.a. Adequate
A.1.d. Adequate A.4. Adequate C.2.b. Adequate
A.1.e. Adequate C.1.a. Adequate C.3. Adequate
V. Request for Additional Information
VI. Acronym Key
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
61
APPENDIX 11
Requirements for Reasonable Assurance Tracking Form
Time
Frame7 Evaluation Criterion8 Action Needed and Applicable Exercise Evaluation
Methodology9 Resolution Description and Date
A.3 (State/Local) All appropriate Letters of Agreement have been obtained and
incorporated into the State plan.
E-22
C.4 (State/Local) All appropriate Letters of Agreement have been obtained and
incorporated into the State plan.
E.2 (State/Local) Procedures are established for alerting, notifying, and mobilizing
emergency response personnel. (1.a.1)
E.5 (State/Local) Emergency Alert System procedures are developed. (5.a.1,
5.b.1)
E.6 (State/Local) Public Alert and Notification procedures are developed. (5.a.1,
5.a.3)
Install and test outdoor warning systems (sirens)
G.3.a (State/Local) State plans designate the points of contact and physical
locations for use by news media during an emergency. (5.b.1)
E-18
H.7 (State/Local) Plans indicate where offsite monitoring equipment is located.
(1.e.1)
7 E - x = Months prior to qualifying exercise
8 NUREG 0654 FEMA-REP-1 Rev 1
9 Federal Register Vol. 67 No. 80, April 25, 2002
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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2/6/2009 12:25 PM
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Time
Frame7 Evaluation Criterion8 Action Needed and Applicable Exercise Evaluation
Methodology9 Resolution Description and Date
H.10 (State/Local) Plans include an inventory of equipment and instruments, as
well as inspection and calibration procedures. (1.e.1, 4.a.1,
6.d.1)
H.11 (State/Local) Plans include emergency equipment inventory lists in an
appendix.
H.12 (State/Local) Plans establish a central point for the receipt and analysis of all
field monitoring data and coordination of sample media. (4.a.2)
I.8 (State/Local) Plans and procedures describe, where appropriate, the
methods, equipment and expertise to be used to make rapid
assessment of the actual or potential radiological hazards.
(2.b.1, 4.a.1, 4.a.2, 4.b.1)
I.10 (State/Local) Plans and procedures describe, where appropriate, the means
for relating the various measured parameters to dose rates for
key isotopes and gross radioactivity measurements. Provisions,
described in separate procedures, are made for estimating
integrated dose from the projected and actual dose rates and for
comparing these estimates with the protective action guides.
(2.b.1, 2.e.1)
J.10.e (State/Local) Plans describe provisions for the use of radio protective drugs,
such as potassium iodide (KI), especially for emergency workers
and institutionalized persons within the plume exposure EPZ.
State plans and/or procedures, as appropriate, include the
quantities, storage locations, and means of distribution of KI.
(1.e.1, 2.a.1, 2.c.1, 3.b.1)
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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Time
Frame7 Evaluation Criterion8 Action Needed and Applicable Exercise Evaluation
Methodology9 Resolution Description and Date
J.10.h (see J.12)
(State/Local)
Plans describe, as appropriate the locations of Congregate Care
Centers in host areas which are at least 5 miles, and preferably
10 miles, beyond the boundaries of the plume exposure
emergency planning zone. (6.a.1, 6.c.1)
J.10.j (State/Local) Traffic/Access Control procedures are developed. (3.d.1)
J.11 (State/Local) Procedures for detecting contamination, for estimating the dose
commitment consequences from the ingestion pathway and for
imposing protective measures such as impoundment,
decontamination, processing, decay, product diversion and
preservation are developed and included in State plans. Maps
for recording survey and monitoring data, key land use data are
developed. Up-to-date lists of the name and location of all
facilities within the ingestion pathway EPZ which regularly
process milk products and other food or agricultural products
originating in that EPZ are maintained. (1.e.1, 2.d.1, 3.e.1, 3.e.2,
4.b.1, 4.c.1)
J.12 (State/Local) Reception Center/Monitoring and Decontamination procedures
K.3.a (State/Local) Plans and/or procedures are developed, as appropriate, for the
distribution of both self-reading and permanent record devices to
State emergency workers. (1.3.1, 3.a.1)
K.5.b (State/Local) Procedures for radiological decontamination of emergency
personnel wounds, supplies, instruments and equipment, and
for waste disposal are developed, as appropriate. (6.b.1, 6.d.1)
L.4 (State/Local) Emergency medical services providers are identified and the
appropriate LOAs are obtained. (6.d.1)
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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Time
Frame7 Evaluation Criterion8 Action Needed and Applicable Exercise Evaluation
Methodology9 Resolution Description and Date
O.1.b (State/Local) Mutual aid organizations are identified and training opportunities
are offered to those organizations.
O.4.a (State/Local) Training for directors or coordinators of response organizations
is conducted.
O.4.b and O.4.c
(State/Local)
Training for accident assessment and radiological monitoring/
analysis personnel is conducted.
O.4.d (State/Local) Training for police security and fire fighting personnel is
conducted.
O.4.f (State/Local) Training for first aid and rescue personnel is conducted.
O.4.g (State/Local) Training for local support services personnel is conducted.
O.4.h (State/Local) Training for medical support personnel is conducted.
O.4.j (State/Local) Training for personnel responsible for transmission of
emergency information and instructions is conducted.
G.1 (State/Local) Public information materials are developed to include the
required information.
E-12
G.2 (State/Local) A description of the types, locations, means for annual updating,
and means of distribution of public information materials is
included in the State plan, as appropriate.
N.2.a (State/Local) Communication drills are conducted.
N.2.c (State/Local) Medical emergency drills are conducted prior to the qualifying
exercise and a schedule for subsequent drills is established.
E-6
N.2.d (State/Local) Radiological monitoring drills are conducted.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
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65
Time
Frame7 Evaluation Criterion8 Action Needed and Applicable Exercise Evaluation
Methodology9 Resolution Description and Date
N.2.e (State/Local) Health physics drills are conducted.
P.6 (State/Local) The plan is updated to include all supporting plans.
P.7 (State/Local) The plan is updated to include a listing of all implementing
procedures and the plan sections to be implemented by each.
E-2
P.8 (State/Local) The plan table of contents and NUREG-0654 cross-reference
are updated.
E-0 N.1.a (State/Local) A successful qualifying exercise is conducted.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
66
APPENDIX 12
Requirements for Reasonable Assurance
*Refers to Interim REP Program Manual
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard A
A.1.a Each plan shall identify
the State, local, Federal and
private sector organizations
(including utilities), that are
intended to be part of the
overall response organization
for Emergency Planning
Zones. (See appendix 5).
(State/Local)
Existing plans: Review has verified
that plans describe State, Federal,
local, Tribal, and private sector
organizations comprising the overall
ORO. Identify the principal response
organizations as outlined in NUREG-
0654 Appendix 5.
Proposed plans: Review has verified
that plans describe known and
anticipated State, Federal, local,
Tribal, and private sector
organizations comprising the overall
ORO and identify the principal
response organizations as outlined in
NUREG-0654 Appendix 5.
Plans: Review has verified that plans
identify State, Federal, local, Tribal,
and private sector organizations
comprising the overall ORO, along
with the principal response
organizations as outlined in NUREG-
0654 Appendix 5.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
10 Federal Register Vol. 67 No.:80, April 25, 2002
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
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Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
A.1.b Each organization and
sub organization having an
operational role shall specify
its concept of operations and
its relationship to the total
effort.
(State/Local)
Existing plans: Review has verified
that plans describe each
organization’s role and how the
organization will carry out its
responsibilities in an emergency
consistent with NIMS*.
Proposed plans: Review has verified
that plans describe each known
organization’s role and how the
organization will carry out its
responsibilities in an emergency
consistent with NIMS*.
Plans: Review has verified that plans
describe all organizations’ roles and
how the organizations will carry out
their responsibilities in an emergency
consistent with NIMS*.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
A.1.c Each plan shall
illustrate these
interrelationships in a block
diagram.
(State/Local)
Existing plans: Review has verified
that plans include block diagram.
Proposed plans: Review has verified
that plans include block diagram, if
available.
Plans: Review has verified that plans
include block diagram.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
A.1.d Each organization shall
identify a specific individual
by title who shall be in charge
of the emergency response.
(State/Local)
1.c.1 Key personnel with
leadership roles for ORO
provide direction and control
to that part of the overall
response effort for which they
are responsible.
Existing plans: Review has verified
that plans identify specific
individual(s) by title or position in
charge of emergency response.
Proposed plans: Review has verified
that plans identify specific
individual(s) by title or position in
charge of emergency response, if
known.
Plans: Review has verified that plans
identify specific individual(s) by title or
position in charge of emergency
response.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
68
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
A.1.e Each organization shall
provide for 24-hour per day
emergency response,
including 24-hour per day
manning of communications
links.
(State/Local)
Existing plans: Review has verified
that plans describe 24-hour response
and communication capability.
Proposed plans: Review has verified
that plans provide assurance that 24-
hour response and communication
capability will exist.
Plans: Review has verified that plans
describe 24-hour response and
communication capability and this
capability is successfully
demonstrated.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
69
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
A.2.a Each organization shall
specify the functions and
responsibilities for major
elements and key individuals
by title, of emergency
response, including the
following: Command and
Control, Alerting and
Notification, Communications,
Public Information, Accident
Assessment, Public Health
and Sanitation, Social
Services, Fire and Rescue,
Traffic Control, Emergency
Medical Services, Law
Enforcement, Transportation,
Protective Response
(including authority to request
Federal assistance and to
initiate other protective
actions), and Radiological
Exposure Control. The
description of these functions
shall include a clear and
concise summary such as a
table of primary and support
responsibilities using the
agency as one axis, and the
function as the other. (See
Section B for licensee).
(State/Local)
1.c.1 Key personnel with
leadership roles for ORO
provide direction and control
to that part of the overall
response effort for which they
are responsible.
Existing plans: Review has verified
that plans include a matrix of known
primary and support organizations
addressing all functions and
responsibilities consistent with ICS*.
Proposed plans: Review has verified
that plans provide a matrix of known
primary and support organizations
addressing all functions and
responsibilities consistent with ICS*.
Plans: Review has verified that plans
provide a finalized matrix of all
primary and support organizations
addressing all functions and
responsibilities consistent with ICS*.
Implementation: Provide a finalized
matrix of all primary and support
organizations
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
70
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
A.2.b Each plan shall contain
(by reference to specific acts,
codes or statutes) the legal
basis for such authorities.
(State/Local)
1.c.1 Key personnel with
leadership roles for ORO
provide direction and control
to that part of the overall
response effort for which they
are responsible.
Existing plans: Review has verified
that plans provide (by reference to
specific acts, codes or statutes) the
legal basis for such authorities.
Proposed plans: Review has verified
that plans provide (by reference to
specific acts, codes or statutes) the
legal basis for such authorities, if
established.
Plans: Review has verified that plans
provide (by reference to specific acts,
codes or statutes) the legal basis for
such authorities.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
71
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
A.3 Each plan shall include
written agreements referring
to the concept of operations
developed between Federal,
State, and local agencies and
other support organizations
having an emergency
response role within the
Emergency Planning Zones.
The agreements shall identify
the emergency measures to
be provided and the mutually
acceptable criteria for their
implementation, and specify
the arrangements for
exchange of information.
These agreements may be
provided in an appendix to
the plan or the plan itself may
contain descriptions of these
matters and a signature page
in the plan may serve to verify
the agreements. The
signature page format is
appropriate for organizations
where response functions are
covered by laws, regulations
or executive orders where
separate written agreements
are not necessary.
(State/Local)
All appropriate Letters of
Agreement have been
obtained and incorporated
into the plan.
Existing plans: Review has verified
that plans contain all appropriate
letters of agreement.
Proposed plans: Review has verified
that plans include a commitment to
obtain all appropriate letters of
agreement.
Plans: Review has verified that all
appropriate Letters of Agreement
have been obtained and incorporated
into the plan.
Implementation: Letters of Agreement
have been obtained and incorporated
into the plan.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
72
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
A.4 Each principal
organization shall be capable
of continuous (24-hour)
operations for a protracted
period. The individual in the
principal organization who will
be responsible for assuring
continuity of resources
(technical, administrative, and
material) shall be specified by
title.
(State/Local)
1.a.1 OROs use effective
procedures to alert, notify,
and mobilize emergency
personnel and activate
facilities in a timely manner.
Existing plans: Review has verified
that plans describe capability for
continuous (24-hour) operations for a
protracted period.
Proposed plans: Review has verified
that plans provide assurance that
capability for continuous (24-hour)
operations for a protracted period will
be established.
Plans: Review has verified that plans
describe capability for continuous (24-
hour) operations for a protracted
period and specify by title the
individual in the principal organization
who will be responsible for assuring
continuity of resources (technical,
administrative, and material).
Implementation: This capability is
successfully demonstrated.
Planning Standard C
C.1.a Each State and
licensee shall make
provisions for incorporating
the Federal response
capability into its operation
plan, including… specific
persons by title authorized to
request Federal assistance;
see A.1.d., and A.2.a.
(Licensee/State)
Existing plans: Review has verified
that plans describe the process of
requesting Federal assistance.
Proposed plans: Review has verified
that plans describe the process of
requesting Federal assistance.
Plans: Review has verified that plans
describe the process of requesting
Federal assistance.
Implementation: The process is
successfully demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
73
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
C.1.b Each State and
licensee shall make
provisions for incorporating
the Federal response
capability into its operation
plan, including… specific
Federal resources expected,
including expected times of
arrival at specific nuclear
facility sites.
(Licensee/State)
Existing plans: Review has verified
that plans describe the process of
incorporating Federal response
capability into the operation plan,
including expected times of arrival.
Proposed plans: Review has verified
that plans describe the process of
incorporating Federal response
capability into the operation plan.
Plans: Review has verified that plans
describe the process of incorporating
Federal response capability into the
operation plan, including expected
times of arrival.
Implementation: Provide a copy of the
plan section incorporating Federal
response capability, including
expected times of arrival.
C.1.c Each State and
licensee shall make
provisions for incorporating
the Federal response
capability into its operation
plan, including… specific
licensee, State and local
resources available to
support the Federal
response, e.g., airfields,
command posts, telephone
lines, radio frequencies and
telecommunications centers.
(Licensee/State)
Existing plans: Review has verified
that plans describe the process of
incorporating Federal response
capability into the plan, including
specific resources available to
support the Federal response.
Proposed plans: Plans describe the
process of incorporating Federal
response capability into the plan,
including any specific known
resources available to support the
Federal response.
Plans: Review has verified that plans
describe the process of incorporating
Federal response capability into the
plan, including specific resources
available to support the Federal
response.
Provide the plan section incorporating
Federal response capability, including
specific resources available to
support the Federal response.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
74
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
C.2.a Each principal offsite
organization may dispatch
representatives to the
licensee’s near site
Emergency Operations
Facility. (State technical
analysis representatives at
the near site EOF are
preferred.)
(State/Local)
Existing plans: Plans describe
expectations of entities responding to
the EOF.
Proposed plans: Plans describe
expectations of entities responding to
the EOF, if known.
Plans: Review has verified that plans
describe expectations of entities
responding to the EOF.
Implementation: If applicable,
capability to dispatch technical
liaisons to the EOF is demonstrated.
C.3 Each organization shall
identify radiological
laboratories and their general
capabilities and expected
availability to provide
radiological monitoring and
analyses services which can
be used in an emergency.
(State)
Existing plans: Review has verified
that plans include a listing of
radiological laboratories and their
general capabilities.
Proposed plans: Review has verified
that plans provide assurance that a
listing of radiological laboratories and
their general capabilities will be
included.
Plans: Review has verified that plans
identify radiological laboratories, their
general capabilities and expected
availability sufficient to provide
radiological monitoring and analyses
services which can be used in an
emergency.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
C.4 Each organization shall
identify nuclear and other
facilities, organizations or
individuals which can be
relied upon in an emergency
to provide assistance. Such
assistance shall be identified
and supported by appropriate
letters of agreement.
(State/Local)
All appropriate Letters of
Agreement have been
obtained and incorporated
into the plan.
Existing plans: Plans include all
appropriate letters of agreement.
Proposed plans: Plans provide a
commitment to obtain all appropriate
letters of agreement.
Plans: Review has verified that plans
all appropriate Letters of Agreement
have been obtained and incorporated
into the plan.
Implementation: Letters of Agreement
have been obtained and incorporated
into the plan.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
75
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard D
D.3 Each State and local
organization shall establish
an emergency classification
and emergency action level
scheme consistent with that
established by the facility
licensee.
(State/Local)
1.a.1 OROs use effective
procedures to alert, notify,
and mobilize emergency
personnel and activate
facilities in a timely manner.
Existing plans: Review has verified
that plans include an emergency
classification and emergency action
level scheme that is consistent with
the one established by the facility
licensee.
Proposed plans: Review has verified
that plans provide a commitment that
an emergency classification and
emergency action level scheme will
be established consistent with the one
established by the facility licensee.
Plans: Review has verified that plans
include an emergency classification
and emergency action level scheme
that is consistent with the one
established by the facility licensee.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
D.4 Each State and local
organization should have
procedures in place that
provide for emergency
actions to be taken which are
consistent with the
emergency actions
recommended by the nuclear
facility licensee, taking into
account local offsite
conditions that exist at the
time of the emergency.
(State/Local)
1.a.1 OROs use effective
procedures to alert, notify,
and mobilize emergency
personnel and activate
facilities in a timely manner.
Existing plans: Review has verified
that plans include procedures for
emergency actions to be taken to
protect the public at each ECL, given
the local conditions at the time of the
emergency.
Proposed plans: Review has verified
that plans provide a commitment to
develop procedures for emergency
actions to be taken to protect the
public at each ECL, given the local
conditions at the time of the
emergency.
Plans: Review has verified that plans
include the emergency actions to be
taken to protect the public at each
ECL, given the local conditions at the
time of the emergency.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
Planning Standard E
E.1 Each organization shall
establish procedures which
describe mutually agreeable
1.a.1 OROs use effective
procedures to alert, notify,
and mobilize emergency
Existing plans: Review has verified
that plans establish procedures which
describe mutually agreeable bases for
Plans: Review has verified that plans
establish procedures which describe
mutually agreeable bases for
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
76
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
bases for notification of
response organizations
consistent with the
emergency classification and
action level scheme set forth
in Appendix 1. These
procedures shall include
means for verification of
messages. The specific
details of verification need not
be included in the plan.
(State/Local)
personnel and activate
facilities in a timely manner.
notification of response organizations
consistent with the emergency
classification and action level
scheme, including verification of
messages.
Proposed plans: Review has verified
that plans provide a commitment to
establish procedures which describe
mutually agreeable bases for
notification of response organizations
consistent with the emergency
classification and action level
scheme, including verification of
messages.
notification of response organizations
consistent with the emergency
classification and action level
scheme, including verification of
messages.
Implementation: Demonstrate plans
and or procedures for notification of
response organizations consistent
with the emergency classification and
action level scheme, including
verification of messages.
E.2 Each organization shall
establish procedures for
alerting, notifying, and
mobilizing emergency
response personnel.
(State/Local)
1.a.1 OROs use effective
procedures to alert, notify,
and mobilize emergency
personnel and activate
facilities in a timely manner.
Existing plans: Review has verified
that plans establish procedures for
alerting, notifying, and mobilizing
emergency response personnel.
Proposed plans: Review has verified
that plans provide a commitment to
establish procedures for alerting,
notifying, and mobilizing emergency
response personnel.
Plans: Review has verified that
procedures are established
Implementation: Procedures are
successfully tested for alerting,
notifying, and mobilizing emergency
response personnel.
E.5 State and local
government organizations
shall establish a system for
disseminating to the public
appropriate information
contained in initial and followup
messages received from
the licensee including the
appropriate notification to
appropriate broadcast media,
e.g., the Emergency Alert
5.a.1 Activities associated
with primary alerting and
notification of the public are
completed in a timely manner
following the initial decision
by authorizer offsite
emergency officials to notify
the public of an emergency
situation. The initial
instructional message to the
public must include as a
Existing plans:
Review has verified that plans include
a system for disseminating
appropriate information to the public
through initial and follow-up
messages.
Proposed plans: Review has verified
that plans provide a commitment to
establish a system for disseminating
appropriate information to the public
Plans: Review has verified that
Emergency Alert System procedures
for initial and follow-up messages are
developed.
Implementation: Emergency Alert
System procedures are successfully
demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
77
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
System.
(State/Local)
minimum the elements
required by current FEMA
REP guidance.
5.b.1 OROs provide accurate
emergency information and
instructions to the public and
the news media in a timely
manner.
through initial and follow-up
messages.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
78
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
E.6 Each organization shall
establish administrative and
physical means, and the time
required for notifying and
providing prompt instructions
to the public within the plume
exposure pathway
Emergency Planning Zone.
(See Appendix 3.) It shall be
the licensee’s responsibility to
demonstrate that such means
exist, regardless of who
implements this requirement.
It shall be the responsibility of
the State and local
governments to activate such
a system.
(State/Local)
5.a.1 Activities associated
with primary alerting and
notification of the public are
completed in a timely manner
following the initial decision
by authorizer offsite
emergency officials to notify
the public of an emergency
situation. The initial
instructional message to the
public must include as a
minimum the elements
required by current FEMA
REP guidance.
5.a.3 Activities associated
with FEMA approved
exception areas (where
applicable) are completed
within 45 minutes following
the initial decision by
authorized offsite emergency
officials to notify the public of
an emergency situation.
Backup alert and notification
of the public is completed
within 45 minutes following
the detection by the ORO of a
failure of the primary alert and
notification system.
Existing plans: Review has verified
that plans establish a public alert and
notification system in accordance with
current FEMA ANS guidance.
Proposed plans: Review has verified
that plans provide a commitment to
establish a public alert and notification
system in accordance with current
FEMA ANS guidance.
Plans: Review has verified that plans
establish a public alert and notification
system in accordance with current
FEMA ANS guidance.
Implementation: The Public Alert and
Notification system has been
designed, developed, installed, and
tested successfully.
E.7 Each organization shall
provide written messages
intended for the public,
consistent with the licensee’s
classification scheme. In
particular, draft messages to
5.a.1 Activities associated
with primary alerting and
notification of the public are
completed in a timely manner
following the initial decision
by authorizer offsite
Existing plans: Review has verified
that plans contain pre-scripted
messages intended for the public,
consistent with the licensee’s
classification scheme, including draft
messages to the public giving
Plans: Review has verified that plans
contain pre-scripted messages
intended for the public, consistent
with the licensee’s classification
scheme. In particular, draft messages
to the public giving instructions with
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
79
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
the public giving instructions
with regard to specific
protective actions to be taken
by occupants of affected
areas shall be prepared and
included as part of the State
and local plans. Such
messages should include the
appropriate aspects of
sheltering, ad hoc respiratory
protection, e.g., handkerchief
over mouth, thyroid blocking
or evacuation. The role of the
licensee is to provide
supporting information for the
messages. For ad hoc
respiratory protection see
“Respiratory Protective
Devices Manual” American
Industrial Hygiene
Association, 1963, pp. 123–
126.
(State/Local)
emergency officials to notify
the public of an emergency
situation. The initial
instructional message to the
public must include as a
minimum the elements
required by current FEMA
REP guidance.
5.b.1 OROs provide accurate
emergency information and
instructions to the public and
the news media in a timely
manner.
instructions with regard to specific
protective actions to be taken by
occupants of affected areas.
Proposed plans: Review has verified
that plans provide a commitment to
develop pre-scripted messages
intended for the public, consistent
with the licensee’s classification
scheme, including draft messages to
the public giving instructions with
regard to specific protective actions to
be taken by occupants of affected
areas.
regard to specific protective actions to
be taken by occupants of affected
areas shall be prepared and included
as part of the State and local plans.
Implementation: Use of these
messages is successfully
demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
80
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard F
F.1.a Each plan shall
include… provision for 24-
hour per day notification to
and activation of the
State/local emergency
response network; and at a
minimum, a telephone link
and alternate, including 24-
hour per day manning of
communications links that
initiate emergency response
actions.
(State/Local)
1.d.1 At least two
communication systems are
available, at least one
operates properly, and
communication links are
established and maintained
with appropriate locations.
Communications capabilities
are managed in support of
emergency operations.
Existing plans: Review has verified
that plans include provision for a 24-
hour activation of response, including
primary and backup communication
links.
Proposed plans: Review has verified
that plans provide a commitment to
include a 24-hour activation of
response, including primary and
backup communication links.
Plans: Review has verified that plans
describe the equipment, personnel,
and systems used for notification and
activation of response on a 24-hour
basis.
Implementation: This activation is
successfully demonstrated.
F.1.b Each plan shall
include… provision for
communications with
contiguous State/local
governments within the
Emergency Planning Zones.
(State/Local)
1.d.1 At least two
communication systems are
available, at least one
operates properly, and
communication links are
established and maintained
with appropriate locations.
Communications capabilities
are managed in support of
emergency operations.
Existing plans: Review has verified
that plans include provisions for
communications with contiguous
State/local governments within the
Emergency Planning Zones.
Proposed plans: Review has verified
that plans provide a commitment to
include provisions for communications
with contiguous State/local
governments within the Emergency
Planning Zones.
Plans: Review has verified that plans
include provisions for communications
with contiguous State/local
governments within the Emergency
Planning Zones.
Implementation: This communication
is successfully demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
81
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
F.1.c Each plan shall
include… provision for
communications as needed
with Federal emergency
response organizations.
(State/Local)
1.d.1 At least two
communication systems are
available, at least one
operates properly, and
communication links are
established and maintained
with appropriate locations.
Communications capabilities
are managed in support of
emergency operations.
Existing plans: Review has verified
that plans include provisions for
communications as needed with
Federal emergency response
organizations.
Proposed plans: Review has verified
that plans provide a commitment to
include provisions for communications
as needed with Federal emergency
response organizations.
Plans: Review has verified that plans
describe provisions for
communications as needed with
Federal emergency response
organizations.
Implementation: These provisions are
successfully demonstrated.
F.1.d Each plan shall
include… provision for
communications between the
nuclear facility and the
licensee’s near-site
Emergency Operations
Facility, State and local
emergency operations
centers, and radiological
monitoring teams.
(State/Local)
1.d.1 At least two
communication systems are
available, at least one
operates properly, and
communication links are
established and maintained
with appropriate locations.
Communications capabilities
are managed in support of
emergency operations.
Existing plans: Review has verified
that plans include provisions for
communications between the nuclear
facility and the licensee’s near-site
Emergency Operations Facility, State
and local emergency operations
centers, and radiological monitoring
teams.
Proposed plans: Review has verified
that plans provide a commitment to
include communications between the
nuclear facility and the licensee’s
near-site Emergency Operations
Facility, State and local emergency
operations centers, and radiological
monitoring teams.
Plans: Review has verified that plans
include provisions for communications
between the nuclear facility and the
licensee’s near-site Emergency
Operations Facility, State and local
emergency operations centers, and
radiological monitoring teams.
Implementation: This communication
is successfully demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
82
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
F.1.e Each plan shall
include… provision for
alerting or activating
emergency personnel in each
response organization.
(State/Local)
1.d.1 At least two
communication systems are
available, at least one
operates properly, and
communication links are
established and maintained
with appropriate locations.
Communications capabilities
are managed in support of
emergency operations.
Existing plans: Review has verified
that plans include provisions for
alerting or activating emergency
personnel in each response
organization.
Proposed plans: Review has verified
that plans provide a commitment to
include provisions for alerting or
activating emergency personnel in
each response organization.
Plans: Review has verified that plans
include provisions for alerting or
activating emergency personnel in
each response organization.
Implementation: This alerting or
activating is successfully
demonstrated.
F.2 Each organization shall
ensure that a coordinated
communication link for fixed
and mobile medical support
facilities exists.
(State/Local)
1.d.1 At least two
communication systems are
available, at least one
operates properly, and
communication links are
established and maintained
with appropriate locations.
Communications capabilities
are managed in support of
emergency operations.
6.d.1 The facility/ORO has
the appropriate space,
adequate resources, and
trained personnel to provide
transport, monitoring,
decontamination, and medical
services to contaminated
injured individuals.
Existing plans: Review has verified
that plans contain provisions to
ensure that a coordinated
communication link for fixed and
mobile medical support facilities
exists.
Proposed plans: Review has verified
that plans provide a commitment to
ensure that a coordinated
communication link for fixed and
mobile medical support facilities
exists.
Plans: Review has verified that plans
contain provisions to ensure that a
coordinated communication link for
fixed and mobile medical support
facilities exists.
Implementation: These
communication links are successfully
demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
83
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
F.3 Each organization shall
conduct periodic testing of the
entire emergency
communications system (see
evaluation criteria N.2.a,
N.2.d and Appendix 311).
(State/Local)
Existing plans: Review has verified
that plans include provisions for
periodic testing of the entire
emergency communications system.
Proposed plans: Review has verified
that plans provide a commitment to
conduct periodic testing of the entire
emergency communications system.
Plans: Review has verified that plans
include provisions for periodic testing
of the entire emergency
communications system.
Implementation: The entire
emergency communications system is
successfully demonstrated.
11 Revised by FEMA GM PR-1.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
84
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard G
G.1 Each organization shall
provide a coordinated
periodic (at least annually)
dissemination of information
to the public regarding how
they will be notified and what
their actions should be in an
emergency. This information
shall include, but not
necessarily be limited to:
a. educational information
on radiation;
b. contact for additional
information;
c. protective measures, e.g.,
evacuation routes and
relocation centers,
sheltering, respiratory
protection, radio
protective drugs; and
d. protective measures
related to the ingestion
pathway12; and
e. special needs of the
handicapped.
Means for accomplishing the
required dissemination prior
to an emergency may
include, but are not
necessarily limited to:
information in the telephone
book; periodic information in
utility bills; posting in public
Public information materials
are developed to include the
required information.
Existing plans: Review has verified
that plans include provisions for a
coordinated periodic (at least
annually) dissemination of information
to the public regarding how they will
be notified and what their actions
should be in an emergency.
Proposed plans: Review has verified
that plans provide a commitment to
develop a coordinated periodic (at
least annually) dissemination of
information to the public regarding
how they will be notified and what
their actions should be in an
emergency.
Plans: Review has verified that plans
describe all periodic information to be
disseminated to the public.
Implementation: These materials are
presented for review.
12 Revised by FEMA GM IN-1
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
85
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
areas; and publications
distributed on an annual
basis.
(State/Local)
G.2 The public information
program shall provide the
permanent and transient adult
population within the plume
exposure EPZ an adequate
opportunity to become aware
of the information annually.
The programs should include
provision for written material
that is likely to be available in
a residence during an
emergency. Updated
information shall be
disseminated at least
annually. Signs or other
measures (e.g., decals,
posted notices or other
means. placed in hotels,
motels, gasoline stations and
phone booths) shall also be
used to disseminate to any
transient population within the
plume exposure pathway
EPZ appropriate information
that would be helpful if an
emergency or accident
occurs. Such notices should
refer the transient to the
A description of the types,
locations, means for annual
updating, and means of
distribution of public
information materials is
included in the plan, as
appropriate.
Existing plans: Review has verified
that plans describe the types,
locations, means of annual update,
and means of distribution of public
information materials.
Proposed plans: Review has verified
that plans provide a commitment to
describe the types, locations, means
of annual update, and means of
distribution of public information
materials included in the plan.
Plans: Review has verified that plans
describe the types, locations, means
of annual update, and means of
distribution of public information
materials.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
86
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
telephone directory or other
source of local emergency
information and guide the
visitor to appropriate radio
and television frequencies.
(State/Local)
G.3.a Each principal
organization shall designate
the points of contact and
physical locations for use by
news media during an
emergency.
(State/Local)
5.b.1 OROs provide accurate
emergency information and
instructions to the public and
the news media in a timely
manner.
Existing plans: Review has verified
that plans designate the points of
contact and physical locations for use
by news media during an emergency.
Proposed plans: Review has verified
that plans provide a commitment to
designate the points of contact and
physical locations for use by news
media during an emergency.
Plans: Review has verified that plans
designate the points of contact and
physical locations for use by news
media during an emergency.
Implementation: The adequacy of
such facilities is demonstrated.
G.4.a Each principal
organization shall designate a
spokesperson who should
have access to all necessary
information.
(State/Local)
Existing plans: Review has verified
that plans designate a
spokesperson(s) who shall have
access to all necessary information.
Proposed plans: Review has verified
that plans provide a commitment to
designate a spokesperson(s) who
shall have access to all necessary
information.
Plans: Review has verified that plans
identifying the designated
spokesperson(s).
Implementation: Access to all
necessary information is successfully
demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
87
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
G.4.b Each organization shall
establish arrangements for
timely exchange of
information among
designated spokespersons.
(State/Local)
Existing plans: Review has verified
that plans establish arrangements for
timely exchange of information among
designated spokespersons.
Proposed plans: Review has verified
that plans provide a commitment to
establish arrangements for timely
exchange of information among
designated spokespersons.
Plans: Review has verified that plans
establish arrangements for timely
exchange of information among
designated spokespersons.
Implementation: These arrangements
are successfully demonstrated.
G.4.c Each organization shall
establish coordinated
arrangements for dealing with
rumors.
(State/Local)
5.b.1 OROs provide accurate
emergency information and
instructions to the public and
the news media in a timely
manner.
Existing plans: Review has verified
that plans establish coordinated
arrangements for dealing with rumors.
Proposed plans: Review has verified
that plans provide a commitment to
establish coordinated arrangements
for dealing with rumors.
Plans: Review has verified that plans
describe coordinated arrangements
for dealing with rumors.
Implementation: These arrangements
are successfully demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
88
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
G.5 Each organization shall
conduct coordinated
programs at least annually to
acquaint news media with the
emergency plans, information
concerning radiation, and
points of contact for release
of public information.13
(State/Local)
Existing plans: Review has verified
that plans describe provisions to
conduct coordinated programs at
least annually to acquaint news media
with the emergency plans, information
concerning radiation, and points of
contact for release of public
information.
Proposed plans: Review has verified
that plans provide a commitment to
conduct coordinated programs at
least annually to acquaint news media
with the emergency plans, information
concerning radiation, and points of
contact for release of public
information.
Plans: Review has verified that plans
describe provisions to coordinated
programs at least annually to acquaint
news media with the emergency
plans, information concerning
radiation, and points of contact for
release of public information.
Implementation: It is successfully
demonstrated that the program is
being carried out.
Planning Standard H
H.3 Each organization shall
establish an emergency
operations center for use in
directing and controlling
response functions.
(State/Local)
1.b.1 Facilities are sufficient
to support the emergency
response
Existing facilities: Review has verified
that plans describe the emergency
operations center for use in directing
and controlling response functions.
Proposed facility: Review has verified
that plans provide a commitment to
establish and describe an emergency
operations center capable of directing
and controlling response functions.
Plans: Review has verified that plans
describe an emergency operations
center capable of directing and
controlling response functions.
Implementation: Its use is
successfully demonstrated.
13 Revised by FEMA GM PR-1.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
89
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
H.4 Each organization shall
provide for timely activation
and staffing of the facilities
and centers described in the
plan.
(State/Local)
1.a.1 OROs use effective
procedures to alert, notify,
and mobilize emergency
personnel and activate
facilities in a timely manner.
Existing plans: Review has verified
that plans provide for timely activation
and staffing of the facilities and
centers described in the plan.
Proposed plans: Review has verified
that plans include a commitment to
provide for timely activation and
staffing of the facilities and centers
described in the plan.
Plans: Review has verified that plans
provide for timely activation and
staffing of the facilities and centers
described in the plan.
Implementation: This timely activation
and staffing is successfully
demonstrated.
H.7 Each organization, where
appropriate, shall provide for
offsite radiological monitoring
equipment in the vicinity of
the nuclear facility.
(State/Local)
1.e.1 Equipment, maps,
displays, dosimetry,
potassium iodide (KI), and
other supplies are sufficient to
support emergency
operations.
Existing plans: Review has verified
that plans provide for offsite
radiological monitoring equipment in
the vicinity of the nuclear facility.
Proposed plans: Review has verified
that plans include a commitment to
provide for offsite radiological
monitoring equipment in the vicinity of
the nuclear facility.
Plans: Review has verified that plans
provide for offsite radiological
monitoring equipment in the vicinity of
the nuclear facility.
Implementation: The equipment
described is verified as sufficient and
functional.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
90
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
H.10 Each organization shall
make provisions to inspect,
inventory and operationally
check emergency
equipment/instruments at
least once each calendar
quarter and after each use.
There shall be sufficient
reserves of
instruments/equipment to
replace those which are
removed from emergency kits
for calibration or repair.
Calibration of equipment shall
be at intervals recommended
by the supplier of the
equipment.
(State/Local)
1.e.1 Equipment, maps,
displays, dosimetry,
potassium iodide (KI), and
other supplies are sufficient to
support emergency
operations.
4.a.1 The field teams are
equipped to perform field
measurements of direct
radiation exposure (cloud and
ground shine) and to sample
airborne radioiodine and
particulates.
6.d.1 The facility/ORO has
the appropriate space,
adequate resources, and
trained personnel to provide
transport, monitoring,
decontamination, and medical
services to contaminated
injured individuals.
Existing plans: Review has verified
that plans include provisions to
inspect, inventory and operationally
check emergency equipment/
instruments at least once each
calendar quarter and after each use,
and describe instrument reserves.
Calibration of equipment shall be at
intervals recommended by the
supplier of the equipment.
Proposed plans: Review has verified
that plans provide a commitment to
inspect, inventory and operationally
check emergency equipment/
instruments at least once each
calendar quarter and after each use,
and provide for instrument reserves.
Calibration of equipment shall be at
intervals recommended by the
supplier of the equipment.
Plans: Review has verified that plans
include provisions to inspect,
inventory and operationally check
emergency equipment/ instruments at
least once each calendar quarter and
after each use, and describe
instrument reserves.
Implementation: Adherence to
procedures and equipment reserves
are verified. Calibration of equipment
shall be at intervals recommended by
the supplier of the equipment.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
91
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
H.11 Each plan shall, in an
appendix, include
identification of emergency
kits by general category
(protective equipment,
communications equipment,
radiological monitoring
equipment and emergency
supplies).
(State/Local)
Plans include emergency
equipment inventory lists in
an appendix.
Existing plans: Review has verified
that plans describe inventories of
general categories of emergency
equipment, including protective
equipment, communications
equipment, radiological monitoring
equipment and emergency supplies.
Proposed plans: Review has verified
that plans provide a commitment to
describe inventories of general
categories of emergency equipment,
including protective equipment,
communications equipment,
radiological monitoring equipment and
emergency supplies.
Plans: Plans describe inventories of
general categories of emergency
equipment, including protective
equipment, communications
equipment, radiological monitoring
equipment and emergency supplies.
Implementation: Equipment described
is verified as sufficient.
H.12 Each organization shall
establish a central point
(preferably associated with
the licensee’s near-Site
Emergency Operations
Facility), for the receipt and
analysis of all field monitoring
data and coordination of
sample media.
(State/Local)
4.a.2 Field teams are
managed to obtain sufficient
information to help
characterize the release and
to control radiation exposure.
Existing plans: Review has verified
that plans describe the central point
identified for the receipt and analysis
of all field monitoring data and
coordination of sample media.
Proposed plans: Review has verified
that plans provide a commitment to
establish a central point for the receipt
and analysis of all field monitoring
data and coordination of sample
media.
Plans: Review has verified that plans
describe the central point identified for
the receipt and analysis of all field
monitoring data and coordination of
sample media.
Implementation: This is successfully
demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
92
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard I
I.7 Each organization shall
describe the capability and
resources for field monitoring
within the plume exposure
Emergency Planning Zone
which are an intrinsic part of
the concept of operations for
the facility.
(State/Local)
1.e.1 Equipment, maps,
displays, dosimetry,
potassium iodide (KI), and
other supplies are sufficient to
support emergency
operations.
4.a.1 The field teams are
equipped to perform field
measurements of direct
radiation exposure (cloud and
ground shine) and to sample
airborne radioiodine and
particulates.
6.d.1 The facility/ORO has
the appropriate space,
adequate resources, and
trained personnel to provide
transport, monitoring,
decontamination, and medical
services to contaminated
injured individuals.
Existing plans: Review has verified
that plans describe the capability and
resources for field monitoring within
the plume exposure Emergency
Planning Zone which are an intrinsic
part of the concept of operations.
Proposed plans: Review has verified
that plans provide a commitment to
describe the capability and resources
for field monitoring within the plume
exposure Emergency Planning Zone
which are an intrinsic part of the
concept of operations.
Plans: Review has verified that plans
describe the capability and resources
for field monitoring within the plume
exposure Emergency Planning Zone
which are an intrinsic part of the
concept of operations.
Implementation: The capability and
resources are successfully
demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
93
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
I.8 Each organization, where
appropriate, shall provide
methods, equipment and
expertise to make rapid
assessment of the actual or
potential magnitude and
locations of radiological
hazards through liquid or
gaseous release pathways.
This shall include activation,
notification means, field team
composition, and
transportation,
communication, monitoring
equipment and estimated
deployment times.
(State/Local)
2.b.1 Appropriate protective
action recommendation are
based on available
information on plant
conditions, field monitoring
data, and licensee and ORO
does projections, as well as
knowledge of onsite and
offsite environmental
conditions.
4.a.1 The field teams are
equipped to perform field
measurements of direct
radiation exposure (cloud and
ground shine) and to sample
airborne radioiodine and
particulates.
4.a.2 Field teams are
managed to obtain sufficient
information to help
characterize the release and
to control radiation exposure.
4.b.1 The field teams
demonstrate the capability to
make appropriate
measurements and to collect
appropriate samples (for
example, food crops, milk,
water, vegetation, and soil) to
support adequate
assessments and protective
action decision-making.
Existing plans: Review has verified
that plans and procedures describe,
where appropriate, the methods,
equipment and expertise to be used
to make rapid assessment of the
actual or potential radiological
hazards. This shall include activation,
notification means, field team
composition, and transportation,
communication, monitoring equipment
and estimated deployment times.
Proposed plans: Review has verified
that plans provide a commitment to
develop plans and procedures that
describe, where appropriate, the
methods, equipment and expertise to
be used to make rapid assessment of
the actual or potential radiological
hazards. This shall include activation,
notification means, field team
composition, and transportation,
communication, monitoring equipment
and estimated deployment times.
Plans: Review has verified that plans
and procedures describe, where
appropriate, the methods, equipment
and expertise to be used to make
rapid assessment of the actual or
potential radiological hazards.
Implementation: These procedures
are successfully demonstrated. This
shall include activation, notification
means, field team composition, and
transportation, communication,
monitoring equipment and
deployment times.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
94
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
I.9 Each organization shall
have a capability to detect
and measure radioiodine
concentrations in air in the
plume exposure EPZ as low
as 10-7 uCi/cc (micro curies
per cubic centimeter) under
field conditions. Interference
from the presence of noble
gas and background radiation
shall not decrease the stated
minimum detectable activity.
(State/Local)
4.a.3 Ambient radiation
measurements are made and
recorded at appropriate
locations, and radioiodine and
particulate samples are
collected. Teams will move
to an appropriate low
background location to
determine whether and
significant (as specified in the
plan and/or procedures)
amount of radioactivity has
been collected on the
sampling media.
Existing plans: Review has verified
that plans describe the capability to
detect and measure radioiodine
concentrations in air in the plume
exposure EPZ as low as 10-7 uCi/cc
(micro curies per cubic centimeter)
under field conditions without
interference from the presence of
noble gas and background radiation.
Proposed plans: Review has verified
that plans provide a commitment to
establish the capability to detect and
measure radioiodine concentrations in
air in the plume exposure EPZ as low
as 10-7 uCi/cc (micro curies per cubic
centimeter) under field conditions
without interference from the
presence of noble gas and
background radiation.
Plans: Review has verified that plans
describe the capability to detect and
measure radioiodine concentrations in
air in the plume exposure EPZ as low
as 10-7 uCi/cc (micro curies per cubic
centimeter)* under field conditions.
Implementation: This capability is
successfully demonstrated without
interference from the presence of
noble gas and background radiation.
*Or limits specified in current
guidance.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
95
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
I.10 Each organization shall
establish means for relating
the various measured
parameters (e.g.,
contamination levels, water
and air activity levels) to dose
rates for key isotopes (i.e.,
those given in Table 3, page
18) and gross radioactivity
measurements. Provisions
shall be made for estimating
integrated dose from the
projected and actual dose
rates and for comparing these
estimates with the protective
action guides. The detailed
provisions shall be described
in separate procedures.
(State/Local)
2.b.1 Appropriate protective
action recommendation are
based on available
information on plant
conditions, field monitoring
data, and licensee and ORO
does projections, as well as
knowledge of onsite and
offsite environmental
conditions.
2.e.1 Timely relocation,
reentry, and return decisions
are made and coordinated as
appropriate based on
assessments of the
radiological conditions and
criteria in the OROs plan
and/or procedures.
Existing plans: Review has verified
that procedures describe, where
appropriate, the means for relating
the various measured parameters to
dose rates for key isotopes and gross
radioactivity measurements.
Provisions, described in separate
procedures, are made for estimating
integrated dose from the projected
and actual dose rates and for
comparing these estimates with the
protective action guides.
Proposed plans: Review has verified
that plans provide a commitment to
develop procedures that describe,
where appropriate, the means for
relating the various measured
parameters to dose rates for key
isotopes and gross radioactivity
measurements. Provisions, described
in separate procedures, are made for
estimating integrated dose from the
projected and actual dose rates and
for comparing these estimates with
the protective action guides.
Plans: Review has verified that
procedures describe, where
appropriate, the means for relating
the various measured parameters to
dose rates for key isotopes and gross
radioactivity measurements.
Provisions, described in separate
procedures, are made for estimating
integrated dose from the projected
and actual dose rates and for
comparing these estimates with the
protective action guides.
Implementation: These procedures
are successfully demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
96
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
I.11 Arrangements to locate
and track the airborne
radioactive plume shall be
made, using either or both
Federal and State resources.
(State/Local)
2.b.1 Appropriate protective
action recommendation are
based on available
information on plant
conditions, field monitoring
data, and licensee and ORO
does projections, as well as
knowledge of onsite and
offsite environmental
conditions.
4.a.1 The field teams are
equipped to perform field
measurements of direct
radiation exposure (cloud and
ground shine) and to sample
airborne radioiodine and
particulates.
4.a.2 Field teams are
managed to obtain sufficient
information to help
characterize the release and
to control radiation exposure.
4.b.1 The field teams
demonstrate the capability to
make appropriate
measurements and to collect
appropriate samples (for
example, food crops, milk,
water, vegetation, and soil) to
support adequate
assessments and protective
action decision-making.
Existing plans: Review has verified
that plans describe arrangements to
locate and track the airborne
radioactive plume, using either or
both Federal and State resources.
Proposed plans: Review has verified
that plans include a commitment to
provide for arrangements to locate
and track the airborne radioactive
plume, using either or both Federal
and State resources.
Plans: Review has verified that plans
describe arrangements to locate and
track the airborne radioactive plume,
using either or both Federal and State
resources.
Implementation: These arrangements
are demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
97
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard J
J.2 Each licensee shall make
provisions for evacuation
routes and transportation for
onsite individuals to some
suitable offsite location,
including alternatives for
inclement weather, high traffic
density and specific
radiological conditions.
(State/Local)
Existing plans: Review has verified
that plans describe assistance
provided (or state that none is
required) for evacuation routes and
transportation for onsite individuals to
some suitable offsite location,
including alternatives for inclement
weather, high traffic density and
specific radiological conditions.
Proposed plans: Review has verified
that plans provide a commitment to
describe assistance provided (or state
that none is required) for evacuation
routes and transportation for onsite
individuals to some suitable offsite
location, including alternatives for
inclement weather, high traffic density
and specific radiological conditions.
Plans: Review has verified that plans
describe assistance provided (or state
that none is required) for evacuation
routes and transportation for onsite
individuals to some suitable offsite
location, including alternatives for
inclement weather, high traffic density
and specific radiological conditions.
Implementation: These provisions are
successfully demonstrated.
J.9 Each State and local
organization shall establish a
capability for implementing
protective measures based
on protective actions guides
and other criteria. This shall
be consistent with the
recommendations for EPA
regarding exposure resulting
from the passage of
radioactive plumes, (EPA-
400-R-92-001, May 1992)
and with those of FDA/DHHS
2.b.2 A decision-making
process involving
consideration of appropriate
factors and necessary
coordination is used to make
protective action decisions
(PAD) for the general public
(including the
recommendation for the use
of KI, if ORO policy).
2.c.1 Protective action
decisions are made, as
Existing plans: Review has verified
that plans describe the capability for
implementing plume and ingestion
protective measures based on
protective actions guides and other
criteria consistent with current
EPA/FDA guidance.
Proposed plans: Review has verified
that plans provide a commitment to
establish a capability for implementing
plume and ingestion protective
measures based on protective actions
Plans: Review has verified that plans
describe the capability for
implementing plume and ingestion
protective measures based on
protective actions guides and other
criteria consistent with current
EPA/FDA guidance.
Implementation: The implementation
of these measures is successfully
demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
98
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
regarding radioactive
contamination of human food
and animal feeds as
published in the Federal
Register of August 13,1998
(63 FR 43402).
(State/Local)
appropriate for special
population groups.
2.d.1 Radiological
consequences for the
ingestion pathway are
assessed and appropriated
protective action decisions
are made based on the
OROs planning criteria.
2.e.1 Timely relocation,
reentry, and return decisions
are made and coordinated as
appropriate based on
assessments of the
radiological conditions and
criteria in the OROs plan
and/or procedures.
3.e.1 The ORO demonstrates
the availability and the
appropriate use of adequate
information regarding water,
food supplies, milk, and
agricultural production within
the ingestion exposure
pathway emergency planning
zone for implementation of
protective actions.
3.e.2 Appropriate measures,
strategies, and pre-printed
instructional material are
developed for implementing
protective action decisions for
contaminated water, food
guides and other criteria consistent
with current EPA/FDA guidance.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
99
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
products, milk, and
agricultural production.
J.10.a The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include maps showing
evacuation routes, evacuation
areas, preselected
radiological sampling and
monitoring points, relocation
centers in host areas, and
shelter areas; (identification
of radiological sampling and
monitoring points shall
include the designator in
Table J-1 or an equivalent
uniform system described in
the plan).
(State/Local)
1.e.1 Equipment, maps,
displays, dosimetry,
potassium iodide (KI), and
other supplies are sufficient to
support emergency
operations.
4.a.2 Field teams are
managed to obtain sufficient
information to help
characterize the release and
to control radiation exposure
Existing plans: Review has verified
that plans include maps showing
evacuation routes, evacuation areas,
preselected radiological sampling and
monitoring points, relocation centers
in host areas, and shelter areas.
Proposed plans: Review has verified
that plans provide a commitment to
develop maps showing evacuation
routes, evacuation areas, preselected
radiological sampling and monitoring
points, relocation centers in host
areas, and shelter areas.
Plans: Review has verified that plans
include maps showing evacuation
routes, evacuation areas, preselected
radiological sampling and monitoring
points, relocation centers in host
areas, and shelter areas.
Implementation: These maps are
verified through inspection.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
100
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
J.10.b The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include… maps showing
population distribution around
the nuclear facility. This shall
be by evacuation areas
(licensees shall also present
the information in a sector
format).
(State/Local)
1.e.1 Equipment, maps,
displays, dosimetry,
potassium iodide (KI), and
other supplies are sufficient to
support emergency
operations.
2.a.1 OROs use a decisionmaking
process considering
relevant factors and
appropriate coordination to
ensure that an exposure
control system, including the
use of KI, is in place for
emergency workers including
provisions to authorize
radiation exposure in excess
of administrative limits or
protective action guides.
Existing plans: Review has verified
that plans include maps showing
population distribution around the
nuclear facility by evacuation areas.
Proposed plans: The ETE has been
conducted and review has verified
that plans provide a commitment to
incorporate maps showing population
distribution around the nuclear facility
by evacuation areas.
Plans: Review has verified that plans
include maps showing population
distribution around the nuclear facility
by evacuation areas.
Implementation: These maps are
verified through inspection.
J.10.c The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include… means for notifying
all segments of the transient
and resident population.
(State/Local)
3.c.1 Protective action
decisions are implemented
for special populations other
than schools within areas
subject to protective actions.
3.c.2 OROs/School officials
implement protective actions
for schools.
Existing plans: Review has verified
that plans describe the means for
notifying all segments of the transient
and resident population.
Proposed plans: Review has verified
that plans provide a commitment to
develop the means for notifying all
segments of the transient and
resident population.
Plans: Review has verified that plans
describe the means for notifying all
segments of the transient and
resident population.
Implementation: These means are
successfully verified and
demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
101
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
J.10.d The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include… means for
protecting those persons
whose mobility may be
impaired due to such factors
as institutional or other
confinement.
(State/Local)
2.c.1 Protective action
decisions are made, as
appropriate for special
population groups.
3.c.1 Protective action
decisions are implemented
for special populations other
than schools within areas
subject to protective actions.
3.c.2 OROs/School officials
implement protective actions
for schools.
Existing plans: Review has verified
that plans describe the means for
protecting those persons whose
mobility may be impaired due to such
factors as institutional or other
confinement.
Proposed plans: Review has verified
that plans provide a commitment to
develop the means for protecting
those persons whose mobility may be
impaired due to such factors as
institutional or other confinement.
Plans: Review has verified that plans
describe the means for protecting
those persons whose mobility may be
impaired due to such factors as
institutional or other confinement
Implementation: These means are
successfully demonstrated.
J.10.e The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include… provisions for the
use of radio protective drugs,
particularly for emergency
workers and institutionalized
persons within the plume
exposure EPZ whose
immediate evacuation may be
infeasible or very difficult,
including quantities, storage,
and means of distribution.
(State/Local)
1.e.1 Equipment, maps,
displays, dosimetry,
potassium iodide (KI), and
other supplies are sufficient to
support emergency
operations.
2.a.1 OROs use a decisionmaking
process considering
relevant factors and
appropriate coordination to
ensure that an exposure
control system, including the
use of KI, is in place for
emergency workers including
provisions to authorize
radiation exposure in excess
of administrative limits or
protective action guides.
Existing plans: Review has verified
that plans describe provisions for the
use of radio protective drugs, such as
potassium iodide (KI), especially for
emergency workers and
institutionalized persons within the
plume exposure EPZ, including the
quantities, storage locations, and
means of distribution of KI.
Proposed plans: Review has verified
that plans provide a commitment to
develop provisions for the use of radio
protective drugs, such as potassium
iodide (KI), especially for emergency
workers and institutionalized persons
within the plume exposure EPZ,
including the quantities, storage
locations, and means of distribution of
Plans: Review has verified that plans
describe provisions for the use of
radio protective drugs, such as
potassium iodide (KI), especially for
emergency workers and
institutionalized persons within the
plume exposure EPZ, including the
quantities, storage locations, and
means of distribution of KI.
Implementation: These provisions are
successfully demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
102
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
2.c.1 Protective action
decisions are made, as
appropriate for special
population groups.
3.b.1 KI and appropriate
instructions are available
should a decision to
recommend use of KI be
made. Appropriate record
keeping of the administration
of KI for emergency workers
and institutionalized
individuals is maintained.
KI.
J.10.f State and local
organizations’ plans should
include the method by which
decisions by the State Health
Department for administering
radioprotective drugs to the
general population are made
during an emergency and the
pre-determined conditions
under which such drugs may
be used by offsite emergency
workers.
(State/Local)
1.e.1 Equipment, maps,
displays, dosimetry,
potassium iodide (KI), and
other supplies are sufficient to
support emergency
operations.
2.a.1 OROs use a decisionmaking
process considering
relevant factors and
appropriate coordination to
ensure that an exposure
control system, including the
use of KI, is in place for
emergency workers including
provisions to authorize
radiation exposure in excess
of administrative limits or
protective action guides.
Existing plans: Review has verified
that plans describe how decisions are
made by the State Health
Department* for administering
radioprotective drugs to the general
population (if applicable) during an
emergency and the pre-determined
conditions under which such drugs
may be used by offsite emergency
workers.
Proposed plans: Review has verified
that plans provide a commitment to
develop and describe how decisions
are made by the State Health
Department* for administering
radioprotective drugs to the general
population (if applicable) during an
emergency and the pre-determined
conditions under which such drugs
Plans: Review has verified that plans
describe how decisions are made by
the State Health Department* for
administering radioprotective drugs to
the general population (if applicable)
during an emergency and the predetermined
conditions under which
such drugs may be used by offsite
emergency workers.
Implementation: These methods are
successfully demonstrated.
*Or authorized agency
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
103
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
2.c.1 Protective action
decisions are made, as
appropriate for special
population groups.
3.b.1 KI and appropriate
instructions are available
should a decision to
recommend use of KI be
made. Appropriate record
keeping of the administration
of KI for emergency workers
and institutionalized
individuals is maintained.
may be used by offsite emergency
workers.
J.10.g The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include… means of
relocation.
(State/Local)
3.c.1 Protective action
decisions are implemented
for special populations other
than schools within areas
subject to protective actions.
3.c.2 OROs/School officials
implement protective actions
for schools.
3.d.1 Appropriate traffic and
access control is established.
Accurate instructions are
provided to traffic and access
control personnel.
Existing plans: Review has verified
that plans describe the means of
relocation (evacuation) to protect the
public during the plume phase.
Proposed plans: The ETE has been
completed and review has verified
that plans provide a commitment to
develop the means of relocation
(evacuation) to protect the public
during the plume phase.
Plans: Review has verified that plans
describe the means of relocation
(evacuation) to protect the public
during the plume phase.
Implementation: These means are
successfully demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
104
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
J.10.h The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include… relocation centers
in host areas which are at
least 5 miles, and preferably
10 miles, beyond the
boundaries of the plume
exposure emergency
planning zone; (see J.12).
(State/Local)
6.a.1 The reception
center/emergency worker
facility has appropriate space,
adequate resources, and
trained personnel to provide
monitoring, decontamination,
and registration of evacuees
and/or emergency workers.
6.c.1 Managers of congregate
care facilities demonstrate
that the centers have
resources to provide services
and accommodations
consistent with American Red
Cross planning guidelines.
Managers demonstrate the
procedures to assure that
evacuees have been
monitored for contamination
and have been
decontaminated as
appropriate before entering
congregate care facilities.
Existing plans: Review has verified
that plans identify relocation
(reception and/or congregate care)
centers in host areas which are at
least 5 miles, and preferably 10 miles,
beyond the boundaries of the plume
exposure emergency planning zone.
Proposed plans: Review has verified
that plans provide a commitment to
identify relocation (reception and/or
congregate care) centers in host
areas which are at least 5 miles, and
preferably 10 miles, beyond the
boundaries of the plume exposure
emergency planning zone.
Plans: Review has verified that plans
identify relocation (reception and/or
congregate care) centers in host
areas which are at least 5 miles, and
preferably 10 miles, beyond the
boundaries of the plume exposure
emergency planning zone.
Implementation: This is verified
through inspection.
J.10.i The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include… projected traffic
capacities of evacuation
routes under emergency
conditions.
(State/Local)
Plans and procedures are
developed to implement
protective measures for the
plume exposure pathway
shall include… projected
traffic capacities of
evacuation routes under
emergency conditions.
Existing plans: Review has verified
that plans describe projected traffic
capacities of evacuation routes under
emergency conditions.
Proposed plans: The ETE is
completed and review has verified
that plans provide a commitment to
incorporate projected traffic capacities
of evacuation routes under
emergency conditions.
Plans: Review has verified that plans
describe projected traffic capacities of
evacuation routes under emergency
conditions.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Plan Review, as appropriate.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
105
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
J.10.j The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include control of access to
evacuated areas and
organization responsibilities
for such control.
(State/Local)
3.d.1 Appropriate traffic and
access control is established.
Accurate instructions are
provided to traffic and access
control personnel.
Existing plans: Review has verified
that plans describe control of access
into and out of evacuated areas and
organization responsibilities for such
control.
Proposed plans: Review has verified
that plans provide a commitment to
develop measures for control of
access into and out of evacuated
areas and organization
responsibilities for such control.
Plans: Review has verified that plans
describe control of access into and
out of evacuated areas and
organization responsibilities for such
control
Implementation: Control and
organization are successfully
demonstrated.
J.10.k The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include… identification of and
means for dealing with
potential impediments (e.g.,
seasonal impassability of
roads) to use of evacuation
routes, and contingency
measures.
(State/Local)
3.d.2 Impediments to
evacuation are identified and
resolved.
Existing plans: Review has verified
that plans include identification of and
means for dealing with potential
impediments (e.g., seasonal
impassability of roads) to use of
evacuation routes, and contingency
measures.
Proposed plans: Review has verified
that plans provide a commitment
include identification of and means for
dealing with potential impediments
(e.g., seasonal impassability of roads)
to use of evacuation routes, and
contingency measures.
Plans: Review has verified that plans
include identification of and means for
dealing with potential impediments
(e.g., seasonal impassability of roads)
to use of evacuation routes, and
contingency measures.
Implementation: These means are
successfully demonstrated.
J.10.l The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include… time estimates for
evacuation of various sectors
4.a.1 The field teams are
equipped to perform field
measurements of direct
radiation exposure (cloud and
ground shine) and to sample
airborne radioiodine and
Existing plans: Review has verified
that plans reference the Evacuation
Time Estimate report or incorporate
appropriate data.
Proposed plans: Review has verified
Plans: Review has verified that plans
reference the Evacuation Time
Estimate report or incorporate
appropriate data.
Implementation: Evidence of this
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
106
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
and distances based on a
dynamic analysis (timemotion
study under various
conditions) for the plume
exposure pathway
emergency planning zone
(See Appendix 4)
(State/Local)
particulates.
that plans provide a commitment to
reference the Evacuation Time
Estimate report or incorporate
appropriate data.
training has been provided to the
FEMA Region or included in the
Annual Plan Review, as appropriate.
J.10.m The organization’s
plans to implement protective
measures for the plume
exposure pathway shall
include… the bases for the
choice of recommended
protective actions from the
plume exposure pathway
during emergency conditions.
This shall include expected
local protection afforded14 in
residential units or other
shelter for direct and
inhalation exposure, as well
as evacuation time estimates.
(State)
2.b.2 A decision-making
process involving
consideration of appropriate
factors and necessary
coordination is used to make
protective action decisions
(PAD) for the general public
(including the
recommendation for the use
of KI, if ORO policy).
Existing plans: Review has verified
that plans describe the bases for the
choice of recommended protective
actions from the plume exposure
pathway during emergency
conditions.
Proposed plans: Review has verified
that plans provide a commitment to
develop and describe the bases for
the choice of recommended
protective actions from the plume
exposure pathway during emergency
conditions.
Plans: Review has verified that plans
describe the bases for the choice of
recommended protective actions from
the plume exposure pathway during
emergency conditions.
Implementation: Use of the bases for
the choice of recommended
protective actions from the plume
exposure pathway during emergency
conditions is successfully
demonstrated.
J.11 Each State shall specify
the protective measures to be
used for the ingestion
pathway, including the
methods for protecting the
public health [from
1.e.1 Equipment, maps,
displays, dosimetry,
potassium iodide (KI), and
other supplies are sufficient to
support emergency
operations.
Existing Plans: Review has verified
that plans include procedures for
detecting contamination, for
estimating the dose commitment
consequences from the ingestion
pathway and for imposing protective
Plans: Review has verified that plans
include procedures for detecting
contamination, for estimating the dose
commitment consequences from the
ingestion pathway and for imposing
protective measures such as
14 Manual of Protective Action Guides and Protective Actions for Nuclear Incidents”, EPA 400-R-92-001 (May 1992). (NUREG 0654 addenda #18).
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
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Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
consumption of contaminated
foodstuffs] in the event of
food contamination. This shall
include criteria for deciding
whether dairy animals should
be put on stored feed. The
plan shall identify & describe
procedures for detecting
contamination, for estimating
the dose commitment
consequences from the
ingestion pathway and for
imposing protective measures
such as impoundment,
decontamination, processing,
decay, product diversion and
preservation. Maps for
recording survey and
monitoring data, key land use
data (e.g., farming, dairies,
food processing plants,
watersheds, water supply
intake and treatment plants
and reservoirs) shall be
provided. Provisions for maps
showing general crop
information may be met by
including all of the 50-mile
ingestion pathway EPZ. Upto-
date lists of the name and
location of all facilities within
the ingestion pathway EPZ
which regularly process milk
products and other food or
2.d.1 Radiological
consequences for the
ingestion pathway are
assessed and appropriated
protective action decisions
are made based on the
OROs planning criteria.
3.e.1 The ORO demonstrates
the availability and the
appropriate use of adequate
information regarding water,
food supplies, milk, and
agricultural production within
the ingestion exposure
pathway emergency planning
zone for implementation of
protective actions.
3.e.2 Appropriate measures,
strategies, and pre-printed
instructional material are
developed for implementing
protective action decisions for
contaminated water, food
products, milk, and
agricultural production.
4.b.1 The field teams
demonstrate the capability to
make appropriate
measurements and to collect
appropriate samples (for
measures such as impoundment,
decontamination, processing, decay,
product diversion and preservation.
Maps for recording survey and
monitoring data, key land use data
are developed. Up-to-date lists of the
name and location of all facilities
within the ingestion pathway EPZ
which regularly process milk products
and other food or agricultural products
originating in that EPZ are
maintained.
Proposed plans: Review has verified
that plans provide a commitment to
develop procedures for detecting
contamination, for estimating the dose
commitment consequences from the
ingestion pathway and for imposing
protective measures such as
impoundment, decontamination,
processing, decay, product diversion
and preservation. Maps for recording
survey and monitoring data, key land
use data are developed. Up-to-date
lists of the name and location of all
facilities within the ingestion pathway
EPZ which regularly process milk
products and other food or agricultural
products originating in that EPZ are
maintained.
impoundment, decontamination,
processing, decay, product diversion
and preservation. Maps for recording
survey and monitoring data, key land
use data are developed. Up-to-date
lists of the name and location of all
facilities within the ingestion pathway
EPZ which regularly process milk
products and other food or agricultural
products originating in that EPZ are
maintained.
Implementation: These procedures
are successfully demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
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Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
agricultural products
originating in that EPZ shall
be maintained.
(State)
example, food crops, milk,
water, vegetation, and soil) to
support adequate
assessments and protective
action decision-making.
4.c.1 The laboratory is
capable of performing
required radiological analysis
to support protective action
decisions.
J.12 Each organization shall
describe the means for
registering and monitoring of
evacuees at relocation
centers in host areas. The
personnel and equipment
available should be capable
of monitoring within about a
12 hour period all residents
and transients in the plume
exposure EPZ arriving at
relocation centers.
(State/Local)
6.a.1 The reception
center/emergency worker
facility has appropriate space,
adequate resources, and
trained personnel to provide
monitoring, decontamination,
and registration of evacuees
and/or emergency workers.
6.c.1 Managers of congregate
care facilities demonstrate
that the centers have
resources to provide services
and accommodations
consistent with American Red
Cross planning guidelines.
Managers demonstrate the
procedures to assure that
evacuees have been
monitored for contamination
and have been
decontaminated as
appropriate before entering
congregate care facilities.
Existing plans: Review has verified
that plans describe the means for
registering and monitoring of
evacuees at relocation (reception
and/or congregate care) centers in
host areas. The personnel and
equipment available should be
capable of monitoring within about a
12 hour period a minimum of 20% of
all residents and transients in the
plume exposure EPZ.
Proposed plans: Review has verified
that plans provide a commitment to
develop the means for registering and
monitoring of evacuees at relocation
(reception and/or congregate care)
centers in host areas. The personnel
and equipment available should be
capable of monitoring within about a
12 hour period a minimum of 20% of
all residents and transients in the
plume exposure EPZ.
Plans: Review has verified that plans
describe the means for registering
and monitoring of evacuees at
relocation (reception and/or
congregate care) centers in host
areas. The personnel and equipment
available should be capable of
monitoring within about a 12 hour
period a minimum of 20% of all
residents and transients in the plume
exposure EPZ.
Implementation: These means are
successfully demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
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Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard K
K.3.a Each organization shall
make provision for 24-hourper-
day capability to
determine the doses received
by emergency personnel
involved in any nuclear
accident, including
volunteers. Each organization
shall make provisions for
distribution of dosimeters,
both self-reading and
permanent record devices.
(State/Local)
1.e.1 Equipment, maps,
displays, dosimetry,
potassium iodide (KI), and
other supplies are sufficient to
support emergency
operations.
3.a.1 The OROs issue
appropriate dosimetry and
procedures, and mange
radiological exposure to
emergency workers in
accordance with the plans
and procedures. Emergency
workers periodically and at
the end of each mission read
their dosimeters and record
the readings on the
appropriate exposure record
or chart.
Existing plans: Review has verified
that plans describe provisions for 24-
hour-per-day capability to determine
the doses received by emergency
personnel involved in any nuclear
accident, including volunteers. Each
organization shall make provisions for
distribution of dosimeters, both selfreading
and permanent record
devices in accordance with current
guidance.
Proposed plans: Review has verified
that plans provide a commitment to
provide for 24-hour-per-day capability
to determine the doses received by
emergency personnel involved in any
nuclear accident, including
volunteers. Each organization shall
make provisions for distribution of
dosimeters, both self-reading and
permanent record devices in
accordance with current guidance.
Plans: Review has verified that plans
describe provisions for 24-hour-perday
capability to determine the doses
received by emergency personnel
involved in any nuclear accident,
including volunteers. Each
organization shall make provisions for
distribution of dosimeters, both selfreading
and permanent record
devices in accordance with current
guidance.
Implementation: These provisions are
successfully demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
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Interim Finding of Reasonable
Assurance for Preparedness
K.3.b Each organization shall
ensure that dosimeters are
read at appropriate
frequencies and provide for
maintaining dose records for
emergency workers involved
in any nuclear accident.
(State/Local)
3.a.1 The OROs issue
appropriate dosimetry and
procedures, and mange
radiological exposure to
emergency workers in
accordance with the plans
and procedures. Emergency
workers periodically and at
the end of each mission read
their dosimeters and record
the readings on the
appropriate exposure record
or chart.
Existing plans: Review has verified
that plans include procedures to
ensure that dosimeters are read at
appropriate frequencies and provide
for maintaining dose records for
emergency workers involved in any
nuclear accident.
Proposed plans: Review has verified
that plans provide a commitment to
ensure that dosimeters are read at
appropriate frequencies and provide
for maintaining dose records for
emergency workers involved in any
nuclear accident.
Plans: Review has verified that plans
describe procedures to ensure that
dosimeters are read at appropriate
frequencies and provide for
maintaining dose records for
emergency workers involved in any
nuclear accident.
Implementation: These procedures
are successfully demonstrated.
K.4 Each State and local
organization shall establish
the decision chain for
authorizing emergency
workers to incur exposures in
excess of the EPA General
Public Protective Action
Guides (i.e., EPA PAGs for
emergency workers and
lifesaving activities).
(State/Local)
2.a.1 OROs use a decisionmaking
process considering
relevant factors and
appropriate coordination to
ensure that an exposure
control system, including the
use of KI, is in place for
emergency workers including
provisions to authorize
radiation exposure in excess
of administrative limits or
protective action guides.
Existing plans: Review has verified
that plans describe the decision chain
for authorizing emergency workers to
incur exposures in excess of the EPA
General Public Protective Action
Guides (i.e., EPA PAGs for
emergency workers and lifesaving
activities).
Proposed plans: Review has verified
that plans provide a commitment to
establish the decision chain for
authorizing emergency workers to
incur exposures in excess of the EPA
General Public Protective Action
Guides (i.e., EPA PAGs for
emergency workers and lifesaving
activities).
Plans: Review has verified that plans
describe the decision chain for
authorizing emergency workers to
incur exposures in excess of the EPA
General Public Protective Action
Guides (i.e., EPA PAGs for
emergency workers and lifesaving
activities).
Implementation: These procedures
are successfully demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
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Interim Finding of Reasonable
Assurance for Preparedness
K.5.a Each organization as
appropriate, shall specify
action levels for determining
the need for decontamination.
(State/Local)
6.d.1 The facility/ORO has
the appropriate space,
adequate resources, and
trained personnel to provide
transport, monitoring,
decontamination, and medical
services to contaminated
injured individuals.
Existing plans: Review has verified
that plans specify action levels for
determining the need for
decontamination.
Proposed plans: Review has verified
that plans provide a commitment to
specify action levels for determining
the need for decontamination.
Plans: Review has verified that plans
specify action levels for determining
the need for decontamination.
Implementation: Use of these levels is
successfully demonstrated.
K.5.b Each organization, as
appropriate, shall establish
the means for radiological
decontamination of
emergency personnel
wounds, supplies,
instruments and equipment,
and for waste disposal.
(State/Local)
6.b.1 The facility/ORO has
adequate procedures and
resources for the
accomplishment of monitoring
and decontamination of
emergency worker
equipment, including
vehicles.
6.d.1 The facility/ORO has
the appropriate space,
adequate resources, and
trained personnel to provide
transport, monitoring,
decontamination, and medical
services to contaminated
injured individuals.
Existing plans: Review has verified
that plans describe the means for
radiological decontamination of
emergency personnel wounds,
supplies, instruments and equipment,
and for waste disposal.
Proposed plans: Review has verified
that plans provide a commitment to
develop the means for radiological
decontamination of emergency
personnel wounds, supplies,
instruments and equipment, and for
waste disposal.
Plans: Review has verified that plans
describe the means for radiological
decontamination of emergency
personnel wounds, supplies,
instruments and equipment, and for
waste disposal.
Implementation: These means are
successfully demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
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Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard L
L.1 Each organization shall
arrange for local and backup
hospital and medical services
having the capability for
evaluation of radiation
exposure and uptake,
including assurance that
persons providing these
services are adequately
prepared to handle
contaminated individuals.
(State/Local)
6.d.1 The facility/ORO has
the appropriate space,
adequate resources, and
trained personnel to provide
transport, monitoring,
decontamination, and medical
services to contaminated
injured individuals.
Existing plans: Review has verified
that plans describe arrangements for
a primary and backup hospital and
medical services having the capability
for evaluation of radiation exposure
and uptake, including assurance that
persons providing these services are
adequately prepared to handle
contaminated individuals.
Proposed plans: Review has verified
that plans provide a commitment to
arrange for a primary and backup
hospital and medical services having
the capability for evaluation of
radiation exposure and uptake,
including assurance that persons
providing these services are
adequately prepared to handle
contaminated individuals.
Plans: Review has verified that plans
describe arrangements for a primary
and backup hospital and medical
services having the capability for
evaluation of radiation exposure and
uptake, including assurance that
persons providing these services are
adequately prepared to handle
contaminated individuals.
Implementation: These arrangements
are successfully demonstrated.
L.3 Each State shall develop
lists indicating the locations of
public, private and military
hospitals and other
emergency medical service
facilities within the State or
contiguous States considered
capable of providing medical
support for any contaminated
injured individual. The listing
shall include the name,
location, type of facility and
capacity, and any special
radiological capabilities.
These emergency medical
Existing plans: Review has verified
that plans contain lists indicating the
locations of public, private and military
hospitals and other emergency
medical service facilities within the
State or contiguous States considered
capable of providing medical support
for any contaminated injured
individual. The listing shall include the
name, location, type of facility and
capacity, and any special radiological
capabilities. These emergency
medical services should be able to
radiologically monitor contaminated
persons, and have facilities and
Plans: Review has verified that plans
contain lists indicating the locations of
public, private and military hospitals
and other emergency medical service
facilities within the State or
contiguous States considered capable
of providing medical support for any
contaminated injured individual. The
listing shall include the name,
location, type of facility and capacity,
and any special radiological
capabilities. These emergency
medical services should be able to
radiologically monitor contaminated
persons, and have facilities and
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
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Interim Finding of Reasonable
Assurance for Preparedness
services should be able to
radiologically monitor
contaminated personnel, and
have facilities and trained
personnel able to care for
contaminated injured
persons.
(State/Local)
trained personnel able to care for
contaminated injured persons.
Proposed plans: Review has verified
that plans provide a commitment to
develop lists indicating the locations
of public, private and military hospitals
and other emergency medical service
facilities within the State or
contiguous States considered capable
of providing medical support for any
contaminated injured individual. The
listing shall include the name,
location, type of facility and capacity,
and any special radiological
capabilities. These emergency
medical services should be able to
radiologically monitor contaminated
persons, and have facilities and
trained personnel able to care for
contaminated injured persons.
trained personnel able to care for
contaminated injured persons.
L.4 Each organization shall
arrange for transporting
victims of radiological
accidents to medical support
facilities.
(State/Local)
6.d.1 The facility/ORO has
the appropriate space,
adequate resources, and
trained personnel to provide
transport, monitoring,
decontamination, and medical
services to contaminated
injured individuals.
Existing plans: Review has verified
that plans describe arrangements and
procedures for transporting victims of
radiological accidents to medical
support facilities in accordance with
current guidance.
Proposed plans: Review has verified
that plans provide a commitment to
develop arrangements and
procedures for transporting victims of
radiological accidents to medical
Plans: Review has verified that plans
describe arrangements and
procedures for transporting victims of
radiological accidents to medical
support facilities in accordance with
current guidance.
Implementation: These procedures
are successfully demonstrated.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
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Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
support facilities in accordance with
current guidance.
Planning Standard M
M.1 Each organization, as
appropriate, shall develop
general plans and procedures
for reentry and recovery and
describe the means by which
decisions to relax protective
measures (e.g., allow reentry
into an evacuated area) are
reached. This process should
consider both existing and
potential conditions.
(State/Local)
2.e.1 Timely relocation,
reentry, and return decisions
are made and coordinated as
appropriate based on
assessments of the
radiological conditions and
criteria in the OROs plan
and/or procedures.
3.f.1 Decisions regarding
controlled re-entry of
emergency workers and
relocation and return of the
public are coordinated with
appropriate organizations and
implemented.
Existing plans: General plans and
procedures for reentry and recovery
describe the means by which
decisions to relax protective
measures (e.g., allow reentry into an
evacuated area) are reached. This
process should consider both existing
and potential conditions.
Proposed plans: Review has verified
that plans provide a commitment to
develop general plans and
procedures for reentry and recovery
and describe the means by which
decisions to relax protective
measures (e.g., allow reentry into an
evacuated area) are reached. This
process should consider both existing
and potential conditions.
Plans: General plans and procedures
for reentry and recovery describe the
means by which decisions to relax
protective measures (e.g., allow
reentry into an evacuated area) are
reached. This process should
consider both existing and potential
conditions.
Implementation: These plans and
procedures are successfully
demonstrated.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
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Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
M.3 Each licensee and State
plan shall specify means for
informing members of the
response organizations that a
recovery operation is to be
initiated, and of any changes
in the organizational structure
that may occur.
(State)
3.f.1 Decisions regarding
controlled re-entry of
emergency workers and
relocation and return of the
public are coordinated with
appropriate organizations and
implemented.
Existing plans: Review has verified
that plans describe procedures for
informing members of the response
organizations of the means for
keeping all involved OROs informed
of recovery phase/ plans/ procedures
being developed, and of any changes
in the organizational structure that
may occur, as applicable.
Proposed plans: Review has verified
that plans provide a commitment to
develop procedures for informing
members of the response
organizations of the means for
keeping all involved OROs informed
of recovery phase/ plans/ procedures
being developed, and of any changes
in the organizational structure that
may occur, as applicable.
Plans: Review has verified that plans
describe procedures for informing
members of the response
organizations of the means for
keeping all involved OROs informed
of recovery phase/ plans/ procedures
being developed, and of any changes
in the organizational structure that
may occur, as applicable.
Implementation: These procedures
are successfully demonstrated.
M.4 Each plan shall establish
a method for periodically
estimating total population
exposure.
(State)
Existing plans: Review has verified
that plans describe the method for
periodically estimating total population
exposure.
Proposed plans: Review has verified
that plans provide a commitment to
develop a method for periodically
estimating total population exposure.
Plans: Review has verified that plans
describe the method for periodically
estimating total population exposure.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
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Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard N
N.1.a An exercise is an event
that tests the integrated
capability and a major portion
of the basic elements existing
within emergency
preparedness plans and
organizations. The
emergency preparedness
exercise shall simulate an
emergency that results in
offsite radiological releases
which would require response
by offsite authorities.
Exercises shall be conducted
as set forth in NRC and
FEMA rules.
(State/Local)
A successful qualifying
exercise is conducted.
Existing plans: Review has verified
that plans include provisions for
exercises that test the integrated
capability and a major portion of the
basic elements existing within
emergency preparedness plans and
organizations. The emergency
preparedness exercise shall simulate
an emergency that results in offsite
radiological releases which would
require response by offsite
authorities. Exercises shall be
conducted as set forth in current NRC
and FEMA rules and guidance.
Proposed plans: Review has verified
that plans include provisions for
exercises that test the integrated
capability and a major portion of the
basic elements existing within
emergency preparedness plans and
organizations. The emergency
preparedness exercise shall simulate
an emergency that results in offsite
radiological releases which would
require response by offsite
authorities. Exercises shall be
conducted as set forth in current NRC
and FEMA rules and guidance.
Plans: Review has verified that plans
include provisions for exercises that
test the integrated capability and a
major portion of the basic elements
existing within emergency
preparedness plans and
organizations. The emergency
preparedness exercise shall simulate
an emergency that results in offsite
radiological releases which would
require response by offsite
authorities.
Implementation: Exercises shall be
conducted as set forth in current NRC
and FEMA rules and guidance.
N.1.b An exercise shall
include mobilization of State
and local personnel and
resources adequate to verify
A successful qualifying
exercise is conducted.
Existing plans: Review has verified
that plans provide for exercises in
accordance with current NRC and
FEMA guidance.
Plans: Review has verified that plans
provide for exercises in accordance
with current NRC and FEMA
guidance.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
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Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
the capability to respond to
an accident scenario
requiring response. The
organization shall provide for
a critique of the biennial
exercise by Federal and State
observers/evaluators.15 The
scenario should be varied
from exercise to exercise
such that the major elements
of the plans and
preparedness organizations
are tested within a six-year
period. Each organization
should make provisions to
start an exercise between 6:
00 p. m. and 4: 00 a. m.
within a six-year period for
exercising under various
weather conditions. At least
one exercise over a period of
six years should be
unannounced.
(State/Local)
Proposed plans: Review has verified
that plans provide for exercises in
accordance with current NRC and
FEMA guidance.
Implementation: Appropriate
exercises are conducted.
N.2.a Communication Drills:
Communications with State
and local governments within
the plume exposure pathway
Emergency Planning Zone
shall be tested monthly.
Communication drills are
conducted.
Existing plans: Review has verified
that plans provide for communication
drills as follows: Communications with
State and local governments within
the plume exposure pathway
Emergency Planning Zone shall be
Plans: Review has verified that plans
provide for communication drills as
follows: Communications with State
and local governments within the
plume exposure pathway Emergency
Planning Zone shall be tested
15 Changes have been made to this criterion as specified by GM PR-1.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
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NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Communications with Federal
emergency response
organizations and States
within the ingestion pathway
shall be tested quarterly.
Communications between the
nuclear facility, State and
local government emergency
operations centers and field
assessment teams shall be
tested at least once every
year. Communication drills
shall also include the aspect
of understanding the content
of messages.
(State/Local)
tested monthly. Communications with
Federal emergency response
organizations and States within the
ingestion pathway shall be tested
quarterly. Communications between
the nuclear facility, State and local
government emergency operations
centers and field assessment teams
shall be tested at least once every
year. Communication drills shall also
include the aspect of understanding
the content of messages.
Proposed plans: Review has verified
that plans provide for communication
drills as follows: Communications with
State and local governments within
the plume exposure pathway
Emergency Planning Zone shall be
tested monthly. Communications with
Federal emergency response
organizations and States within the
ingestion pathway shall be tested
quarterly. Communications between
the nuclear facility, State and local
government emergency operations
centers and field assessment teams
shall be tested at least once every
year. Communication drills shall also
include the aspect of understanding
the content of messages.
monthly. Communications with
Federal emergency response
organizations and States within the
ingestion pathway shall be tested
quarterly. Communications between
the nuclear facility, State and local
government emergency operations
centers and field assessment teams
shall be tested at least once every
year. Communication drills shall also
include the aspect of understanding
the content of messages.
Implementation: These drills are
successfully conducted.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
119
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
N.2.c Medical Emergency
Drills: A medical emergency
drill involving a simulated
contaminated individual which
contains provisions for
participation by local support
services agencies (i.e.,
ambulance and offsite
medical treatment facility)
shall be conducted annually.
The offsite portions of the
medical drill may be
performed as part of the
required biennial16 exercise.
(State/Local)
Medical emergency drills are
conducted prior to the
qualifying exercise and a
schedule for subsequent drills
is established.
Existing plans: Review has verified
that plans provide for medical
emergency drills in accordance with
current FEMA guidance involving a
simulated contaminated individual
which contains provisions for
participation by local support services
agencies (i.e., ambulance and offsite
medical treatment facility) to be
conducted annually. The offsite
portions of the medical drill may be
performed as part of the required
biennial exercise.
Proposed plans: Review has verified
that plans provide for medical
emergency drills in accordance with
current FEMA guidance involving a
simulated contaminated individual
which contains provisions for
participation by local support services
agencies (i.e., ambulance and offsite
medical treatment facility) to be
conducted annually. The offsite
portions of the medical drill may be
performed as part of the required
biennial exercise.
Plans: Review has verified that plans
provide for medical emergency drills
in accordance with current FEMA
guidance involving a simulated
contaminated individual which
contains provisions for participation
by local support services agencies
(i.e., ambulance and offsite medical
treatment facility) to be conducted
annually. The offsite portions of the
medical drill may be performed as
part of the required biennial exercise.
Implementation: These drills are
successfully conducted.
16 Revised by FEMA GM PR-1
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
120
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
N.2.d Radiological Monitoring
Drills: Plant environs and
radiological monitoring drills
(onsite and offsite) shall be
conducted annually. These
drills shall include collection
and analysis of all sample
media (e.g., water,
vegetation, soil and air), and
provisions for
communications and record
keeping. The State drills need
not be at each site. Where
appropriate, local
organizations shall
participate.
(State/Local)
Radiological monitoring drills
are conducted.
Existing plans: Review has verified
that plans provide for annual
radiological monitoring drills that
include collection and analysis of all
sample media (e.g., water,
vegetation, soil and air), and
provisions for communications and
record keeping. The State drills need
not be at each site. Where
appropriate, local organizations shall
participate.
Proposed plans:
Review has verified that plans provide
for annual radiological monitoring
drills that include collection and
analysis of all sample media (e.g.,
water, vegetation, soil and air), and
provisions for communications and
record keeping. The State drills need
not be at each site. Where
appropriate, local organizations shall
participate.
Plans: Review has verified that plans
provide for annual radiological
monitoring drills that include collection
and analysis of all sample media
(e.g., water, vegetation, soil and air),
and provisions for communications
and record keeping. The State drills
need not be at each site. Where
appropriate, local organizations shall
participate.
Implementation: These drills are
successfully conducted.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
121
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
N.2.e Health Physics Drills:
Health Physics drills shall be
conducted annually by State
governments with licensees
to test response to and
analysis of simulated
elevated airborne and liquid
samples and direct radiation
measurements in the
environment. The State drills
can be conducted at any
site.17
(State/Local)
Health physics drills are
conducted.
Existing plans: Review has verified
that plans provide for annual Health
Physics drills with State governments
and licensees to test response to and
analysis of simulated elevated
airborne and liquid samples and direct
radiation measurements in the
environment.
Proposed plans: Review has verified
that plans provide for annual Health
Physics drills with State governments
and licensees to test response to and
analysis of simulated elevated
airborne and liquid samples and direct
radiation measurements in the
environment.
Plans: Review has verified that plans
provide for annual Health Physics
drills with State governments and
licensees to test response to and
analysis of simulated elevated
airborne and liquid samples and direct
radiation measurements in the
environment.
Implementation: These drills are
successfully conducted. The State
drills can be conducted at any site.
N.3.a …The scenarios for use
in exercises and drills shall
include, but not be limited to,
the following: The basic
objective(s) of each drill and
exercise and appropriate
evaluation criteria.
(State/Local)
A successful scenario is
developed
Existing plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
the basic objective(s) of each drill and
exercise and appropriate evaluation
criteria based on current NRC and
FEMA guidance.
Proposed plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
the basic objective(s) of each drill and
exercise and appropriate evaluation
criteria based on current NRC and
Plans: Review has verified that plans
provide for exercise scenarios that
include, at a minimum, the basic
objective(s) of each drill and exercise
and appropriate evaluation criteria
based on current NRC and FEMA
guidance.
Implementation: Inclusion of these
provisions is verified during the
scenario review.
17 Revised by FEMA GM PR-1
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
122
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
FEMA guidance.
N.3.b …The scenarios for use
in exercises and drills shall
include, but not be limited to,
the following: The date(s),
time period, place(s) and
participating organizations.
(State/Local)
A successful scenario is
developed
Existing plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
the date(s), time period, place(s) and
participating organizations.
Proposed plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
the date(s), time period, place(s) and
participating organizations.
Plans: Review has verified that plans
provide for exercise scenarios that
include, at a minimum, the date(s),
time period, place(s) and participating
organizations.
Implementation: Inclusion of these
provisions is verified during the
scenario review.
N.3.c …The scenarios for use
in exercises and drills shall
include, but not be limited to,
the following: The simulated
events.
(State/Local)
A successful scenario is
developed
Existing plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
identification of events that will be
simulated.
Proposed plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
identification of events that will be
simulated.
Plans: Review has verified that plans
provide for exercise scenarios that
include, at a minimum, identification
of events that will be simulated.
Implementation: Inclusion of these
provisions is verified during the
scenario review.
N.3.d …The scenarios for use
in exercises and drills shall
include, but not be limited to,
the following: A time schedule
of real and simulated initiating
events.
(State/Local)
A successful scenario is
developed
Existing plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
a time schedule of real and simulated
initiating events.
Proposed plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
a time schedule of real and simulated
initiating events.
Plans: Review has verified that plans
provide for exercise scenarios that
include, at a minimum, a time
schedule of real and simulated
initiating events.
Implementation: Inclusion of these
provisions is verified during the
scenario review.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
123
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
N.3.e. …The scenarios for
use in exercises and drills
shall include, but not be
limited to, the following: A
narrative summary describing
the conduct of the exercises
or drills to include such things
as simulated casualties,
offsite fire department
assistance, rescue of
personnel, use of protective
clothing, deployment of
radiological monitoring teams,
and public information
activities.
(State/Local)
A successful scenario is
developed
Existing plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
a narrative summary describing the
conduct of the exercises or drills to
include such things as simulated
casualties, offsite fire department
assistance, rescue of personnel, use
of protective clothing, deployment of
radiological monitoring teams, and
public information activities.
Proposed plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
a narrative summary describing the
conduct of the exercises or drills to
include such things as simulated
casualties, offsite fire department
assistance, rescue of personnel, use
of protective clothing, deployment of
radiological monitoring teams, and
public information activities.
Plans: Review has verified that plans
provide for exercise scenarios that
include, at a minimum, a narrative
summary describing the conduct of
the exercises or drills to include such
things as simulated casualties, offsite
fire department assistance, rescue of
personnel, use of protective clothing,
deployment of radiological monitoring
teams, and public information
activities.
Implementation: Inclusion of these
provisions is verified during the
scenario review.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
124
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
N.3.f …The scenarios for use
in exercises and drills shall
include, but not be limited to,
the following: A description of
the arrangements for and
advance materials to be
provided to official observers.
(State/Local)
A successful scenario is
developed
Existing plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
a description of the arrangements for
and advance materials to be provided
to official observers.
Proposed plans: Review has verified
that plans provide for exercise
scenarios that include, at a minimum,
a description of the arrangements for
and advance materials to be provided
to official observers.
Plans: Review has verified that plans
provide for exercise scenarios that
include, at a minimum, a description
of the arrangements for and advance
materials to be provided to official
observers.
Implementation: Inclusion of these
provisions is verified during the
scenario review.
N.4 Official observers from
Federal, State or local
governments will observe,
evaluate, and critique the
required exercises. A critique
shall be scheduled at the
conclusion of the exercise to
evaluate the ability of
organizations to respond as
called for in the plan. The
critique shall be conducted as
soon as practicable after the
exercise, and a formal
evaluation should result from
the critique.
(State/Local)
A successful qualifying
exercise is conducted.
Existing plans: Review has verified
that plans include provisions for
Federal, State or local governments
to observe, evaluate, and critique the
required exercises. A critique shall be
scheduled at the conclusion of the
exercise to evaluate the ability of
organizations to respond as called for
in the plan.
Proposed plans: Review has verified
that plans include provisions for
Federal, State or local governments
to observe, evaluate, and critique the
required exercises. A critique shall be
scheduled at the conclusion of the
exercise to evaluate the ability of
organizations to respond as called for
in the plan.
Plans: Review has verified that plans
include provisions for Federal, State
or local governments to observe,
evaluate, and critique the required
exercises.
Implementation: A critique shall be
scheduled at the conclusion of the
exercise to evaluate the ability of
organizations to respond as called for
in the plan.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
125
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
N.5 Each organization shall
establish means for
evaluating observer and
participant comments on
areas needing improvement,
including emergency plan
procedural changes, and for
assigning responsibility for
implementing corrective
actions. Each organization
shall establish management
control used to ensure that
corrective actions are
implemented.
(State/Local)
A successful qualifying
exercise is conducted.
Existing plans: Review has verified
that plans describe the means for
evaluating observer and participant
comments on areas needing
improvement, including emergency
plan procedural changes, and for
assigning responsibility for
implementing corrective actions. Each
organization shall establish
management control used to ensure
that corrective actions are
implemented.
Proposed plans: Review has verified
that plans provide a commitment to
develop the means for evaluating
observer and participant comments
on areas needing improvement,
including emergency plan procedural
changes, and for assigning
responsibility for implementing
corrective actions. Each organization
shall establish management control
used to ensure that corrective actions
are implemented.
Plans: Review has verified that plans
describe the means for evaluating
observer and participant comments
on areas needing improvement,
including emergency plan procedural
changes, and for assigning
responsibility for implementing
corrective actions. Each organization
shall establish management control
used to ensure that corrective actions
are implemented.
Implementation: Evidence of this will
be done in the annual plan review.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
126
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard O
O.1 Each organization shall
assure the training of
appropriate individuals.
(State/Local)
Training for appropriate
individuals is conducted.
Existing plans: Review has verified
that plans assure the training of
appropriate individuals.
Proposed plans: Review has verified
that plans provide a commitment to
assure the training of appropriate
individuals.
Plans: Review has verified that plans
assure the training of appropriate
individuals.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
O.1.b Each offsite response
organization shall participate
in and receive training. Where
mutual aid agreements exist
between local agencies such
as fire, police and ambulance/
rescue, the training shall also
be offered to the other
departments who are
members of the mutual aid
district.
(State/Local)
Mutual aid organizations are
identified and training
opportunities are offered to
those organizations.
Existing plans: Review has verified
that plans assure the training of local
agencies such as fire, police and
ambulance/ rescue, the training shall
also be offered to the other
departments who are members of the
mutual aid district.
Proposed plans: Review has verified
that plans provide a commitment to
assure the training of local agencies
such as fire, police and ambulance/
rescue, the training shall also be
offered to the other departments who
are members of the mutual aid
district.
Plans: Review has verified that plans
assure the training of local agencies
such as fire, police and ambulance/
rescue, the training shall also be
offered to the other departments who
are members of the mutual aid
district.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
O.4.a Each organization shall
establish training program
for…directors or coordinators
of the response
organizations.
(State/Local)
Training for directors or
coordinators of response
organizations is conducted.
Existing plans: Review has verified
that plans describe a training program
for directors or coordinators of the
response organizations.
Proposed plans: Review has verified
that plans provide a commitment to
develop a training program for
directors or coordinators of the
response organizations.
Plans: Review has verified that plans
describe a training program for
directors or coordinators of the
response organizations.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
127
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
O.4.b Each organization shall
establish a training program
for…accident assessment
personnel.
(State)
Training for accident
assessment and radiological
monitoring/analysis personnel
is conducted.
Existing plans: Review has verified
that plans describe a training program
for accident assessment personnel.
Proposed plans: Review has verified
that plans provide a commitment to
develop a training program for
accident assessment personnel.
Plans: Review has verified that plans
assure the training of accident
assessment personnel.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
O.4.c Each organization shall
establish a training program
for… radiological
monitoring/analysis
personnel.
(State)
Training for accident
assessment and radiological
monitoring/analysis personnel
is conducted.
Existing plans: Review has verified
that plans describe a training program
for radiological monitoring/analysis
personnel.
Proposed plans: Review has verified
that plans provide a commitment to
develop a training program for
radiological monitoring/analysis
personnel.
Plans: Review has verified that plans
assure the training of radiological
monitoring/analysis personnel.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
O.4.d Each organization shall
establish a training program
for…police security and fire
fighting personnel.
(Local)
Training for police security
and fire fighting personnel is
conducted.
Existing plans: Review has verified
that plans describe a training program
for police security and fire fighting
personnel.
Proposed plans: Review has verified
that plans provide a commitment to
develop a training program for police
security and fire fighting personnel.
Plans: Review has verified that plans
assure the training of for police
security and fire fighting personnel.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
128
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
O.4.f Each organization shall
establish a training program
for…first aid and rescue
personnel.
(Local)
Training for first aid and
rescue personnel is
conducted.
Existing plans: Review has verified
that plans describe a training program
for first aid and rescue personnel.
Proposed plans: Review has verified
that plans provide a commitment to
develop a training program for first aid
and rescue personnel.
Plans: Review has verified that plans
assure the training of first aid and
rescue personnel.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
O.4.g Each organization shall
establish a training program
for…local support services
personnel including Civil
Defense/Emergency Service
personnel.
(Local)
Training for local support
services personnel is
conducted.
Existing plans: Review has verified
that plans describe a training program
for local support services personnel
including Civil Defense/Emergency
Service personnel.
Proposed plans: Review has verified
that plans provide a commitment to
develop a training program for local
support services personnel including
Civil Defense/Emergency Service
personnel.
Plans: Review has verified that plans
assure the training of local support
services personnel including Civil
Defense/Emergency Service
personnel.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
O.4.h Each organization shall
establish a training program
for…medical support
personnel.
(State/Local)
Training for medical support
personnel is conducted.
Existing plans: Review has verified
that plans describe a training program
for medical support personnel.
Proposed plans: Review has verified
that plans provide a commitment to
develop a training program for
medical support personnel.
Plans: Review has verified that plans
assure the training of medical support
personnel
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
____________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
129
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
O.4.j Each organization shall
establish a training program
for…personnel responsible
for transmission of
emergency information and
instructions.
(State/Local)
Training for personnel
responsible for transmission
of emergency information and
instructions is conducted.
Existing plans: Review has verified
that plans describe a training program
for personnel responsible for
transmission of emergency
information and instructions.
Proposed plans: Review has verified
that plans provide a commitment to
develop a training program for
personnel responsible for
transmission of emergency
information and instructions.
Plans: Review has verified that plans
assure the training of personnel
responsible for transmission of
emergency information and
instructions.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
O.5 Each organization shall
provide for the initial and
annual retraining of personnel
with emergency response
responsibilities.
(State/Local)
Re-training for personnel is
developed.
Existing plans: Review has verified
that plans describe a training program
for initial and annual retraining of
personnel with emergency response
responsibilities.
Proposed plans: Review has verified
that plans provide a commitment to
develop a training program for the
initial and annual retraining of
personnel with emergency response
responsibilities.
Plans: Review has verified that plans
assure the training of the initial and
annual retraining of personnel with
emergency response responsibilities.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
DHS/FEMA/NPD/THD-REP
B. Sheffield/T. Strother/R. Fontenot/P. Gardner
2/6/2009 12:25 PM
130
Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
Planning Standard P
P.1 Each organization shall
provide for the training of
individuals responsible for the
planning effort.
(State/Local)
Training for personnel
responsible for the planning
effort.
Existing plans: Review has verified
that plans describe a training program
for the training of individuals
responsible for the planning effort.
Proposed plans: Review has verified
that plans provide a commitment to
develop a training program for the
training of individuals responsible for
the planning effort.
Plans: Review has verified that plans
ensure that there will be initial and
annual retraining of personnel with
emergency response responsibilities.
Implementation: Evidence of this
training has been provided to the
FEMA Region or included in the
Annual Letter of Certification, as
appropriate.
P.2 Each organization shall
identify by title the individual
with the overall authority and
responsibility for radiological
emergency response
planning.
(State/Local)
Training for personnel
responsible for radiological
emergency response
planning.
Existing plans: Review has verified
that plans identify specific
individual(s) by title or position with
the overall authority and responsibility
for radiological emergency response
planning
Proposed plans: Review has verified
that plans identify specific
individual(s) by title or position with
the overall authority and responsibility
for radiological emergency response
planning.
Plans: Review has verified that plans
identify specific individual(s) by title or
position with the overall authority and
responsibility for radiological
emergency response planning.
Implementation: Evidence of this will
be in the staffing of radiological
emergency response personnel.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
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Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
P.3 Each organization shall
designate an Emergency
Planning Coordinator with
responsibility for the
development and updating of
emergency plans and
coordination of these plans
with other response
organizations.
(State/Local)
The emergency plans are
updated.
Existing plans: Review has verified
that plans identify an Emergency
Planning Coordinator with
responsibility for the development and
updating of emergency plans and
coordination of these plans with other
response organizations.
Proposed plans:
Review has verified that plans identify
an Emergency Planning Coordinator
with responsibility for the
development and updating of
emergency plans and coordination of
these plans with other response
organizations.
Plans: Review has verified that plans
identify an Emergency Planning
Coordinator with responsibility for the
development and updating of
emergency plans and coordination of
these plans with other response
organizations.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
P.4 Each organization shall
update its plan and
agreements as needed,
review and certify it to be
current on an annual basis.
The update shall take into
account changes identified by
drills and exercises.
(State/Local)
The plan and agreements are
updated as needed.
Existing plans: Each organization
shall update its plan and agreements
as needed, review and certify it to be
current on an annual basis. The
update shall take into account
changes identified by drills and
exercises.
Proposed plans: The plan shall
comment to updating its plan and
agreements as needed, review and
certify it to be current on an annual
basis. The update shall take into
account changes identified by drills
and exercises.
Plans: Review has verified that each
organization shall update its plan and
agreements as needed, review and
certify it to be current on an annual
basis. The update shall take into
account changes identified by drills
and exercises.
Implementation: Evidence of this plan
update has been provided to the
FEMA Region or included in the
Annual Plan Review as appropriate.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
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Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
P.5 The emergency response
plans and approved changes
to the plans shall be
forwarded to all organizations
and appropriate individuals
with responsibility for
implementation of the plans.
Revised pages shall be dated
and marked to show where
changes have been made.
(State/Local)
The plan is updated
forwarded to include all
organizations and appropriate
individuals.
Existing plans: Review has verified
that plans provide for the emergency
response plans and approved
changes to the plans shall be
forwarded to all organizations and
appropriate individuals with
responsibility for implementation of
the plans. Revised pages shall be
dated and marked to show where
changes have been made.
Proposed plans: Review has verified
that plans provide a commitment the
emergency response plans and
approved changes to the plans shall
be forwarded to all organizations and
appropriate individuals with
responsibility for implementation of
the plans. Revised pages shall be
dated and marked to show where
changes have been made.
Plans: Review has verified that plans
provide for the emergency response
plans and approved changes to the
plans shall be forwarded to all
organizations and appropriate
individuals with responsibility for
implementation of the plans. Revised
pages shall be dated and marked to
show where changes have been
made.
Implementation: Evidence of these
updates has been provided to the
FEMA Region or included in the
Annual Plan Review, as appropriate
P.6 Each plan shall contain a
detailed listing of supporting
plans and their source.
(State/Local)
The plan is updated to
include all supporting plans.
Existing plans: Review has verified
that plans provide for a detailed listing
of supporting plans and their source.
Proposed plans: Review has verified
that plans provide a commitment to
include a detailed listing of supporting
plans and their source.
Plans Review has verified that plans
provide for a detailed listing of
supporting plans and their source.
Implementation: Evidence of these
updates has been provided to the
FEMA Region or included in the
Annual Plan Review, as appropriate.
SOP for New Reactor Combined License (COL) Application___________________________________________________________________________________________
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Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
P.7 Each plan shall contain
as an appendix listing, by
title, procedures required to
implement the plan. The
listing shall include the
section(s) of the plan to be
implemented by each
procedure.
(State/Local)
The plan is updated to
include a listing of all
implementing procedures and
the plan sections to be
implemented by each.
Existing plans: Review has verified
that plans provide for an appendix
listing, by title, procedures required to
implement the plan. The listing shall
include the section(s) of the plan to be
implemented by each procedure.
Proposed plans: Review has verified
that plans provide for an appendix
listing, by title, procedures required to
implement the plan. The listing shall
include the section(s) of the plan to be
implemented by each procedure.
Plans: Review has verified that plans
contain an appendix listing, by title,
procedures required to implement the
plan. The listing shall include the
section(s) of the plan to be
implemented by each procedure.
Implementation: Evidence of these
updates has been provided to the
FEMA Region or included in the
Annual Plan Review, as appropriate.
P.8 Each plan shall contain a
specific table of contents.
Plans submitted for review
should be cross-referenced to
these criteria.
(State/Local)
The plan table of contents
and NUREG-0654 crossreference
are updated.
Existing plans: Review has verified
that plans contain a table of contents
and NUREG-0654 cross-reference.
Proposed plans: Review has verified
that plans contain a table of contents
and NUREG-0654 cross-reference.
Plans and implementation: Review
has verified that plans contain an
accurate table of contents and
NUREG-0654 cross-reference.
Technological Hazards Division/Radiological Emergency Preparedness Program________________________________________________________________________
___________________________________________________________________________________________________________________________________________
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Evaluation Criterion
NUREG 0654 FEMA-REP-1
Rev 1
Action Needed and
Applicable Exercise
Evaluation Methodology
Criteria10
Interim Finding of Reasonable
Assurance for Planning
Interim Finding of Reasonable
Assurance for Preparedness
P.10 Each organization shall
provide for updating
telephone numbers, calldown
lists and maps18 in
emergency procedures at
least quarterly.
(State/Local)
The plan is updated to
include a listing updating
telephone numbers, calldown
lists and maps19
Existing plans: Review has verified
that plans provide for updating
telephone numbers, call-down lists
and maps in emergency procedures
at least quarterly.
Proposed plans: Review has verified
that that plans provide for updating
telephone numbers, call-down lists
and maps in emergency procedures
at least quarterly.
Plans: Review has verified that that
plans provide for updating telephone
numbers, call-down lists and maps in
emergency procedures at least
quarterly.
Implementation: Evidence of these
updates has been provided to the
FEMA Region or included in the
Annual Plan Review, as appropriate.
18 Revised by FEMA GM PR-1.
19 Revised by FEMA GM PR-1.
SOP for New Reactor Combined License (COL) Application___________________________________________________
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APPENDIX 13
Points of Contact
Applicant Points of Contact
Site Name
and Units Licensing Contact Alternates
Vogtle
(Units 3 & 4)
Mr. J. A. “Buzz” Miller, Senior Vice President -
Nuclear Development
Southern Nuclear Operating Company, Inc.,
40 Inverness Center Parkway,
P.O. Box 1295,
Birmingham, AL 35201
Wes Sparkman and
Amy Aughtman,
Southern Nuclear Operating
Company, Inc.,
40 Inverness Center Parkway,
P.O. Box 1295,
Birmingham, AL 35201
North Anna
(Unit 3)
Mr. Eugene S. Grecheck
Vice President, Nuclear Development Dominion
Innsbrook Technical Center,
5000 Dominion Boulevard,
Glen Allen, VA 23060-6711
Dominion.Naps3Colarai@dom.com
Regina.Borsh@dom.com
John.Hayden@dom.com
Wanda.K.Marshall@dom.com
South Texas
Project
(Units 3 & 4)
Gregory Gibson
Manager of Regulatory Affairs for
STP Units 3 and 4
4000 Avenue F, Suite A
Bay City, Texas 77414
361-972-4626
GTGibson@STPEGS.com
Bellefonte
(Units 3 & 4)
Mr. Phillip Ray
Sr. Project Manager
Tennessee Valley Authority
1101 Market Street
Chattanooga, TN 37402-2801
PMRay@tva.gov
423-751-7030
Mr. Richard Grumbir
Sr. Project Manager
Tennessee Valley Authority
1101 Market Street
Chattanooga, TN 37402-2801
RGrumbir@tva.gov
256-308-1770
Shearon Harris
(Units 2 & 3)
Mr. James Scarola
Senior Vice President and Chief Nuclear Officer
Progress Energy, Inc.
P.O. Box 1551
Raleigh, NC 27602
919-546-4222
James.Scarola@pgnmail.com
Mr. Gary Miller and
Mr. Robert Kitchen
Progress Energy, Inc
P.O. Box 1551
Raleigh, NC 27602
919-546-6107
Gary.Miller@pgnmail.com
919-546-6992
Robert.Kitchen@pgnmail.com
Lee
Chris Nolan
Duke Energy
526 South Church Street
Charlotte, NC 28201-1009
704-382-7426
MCNolan@duke-energy.com
Technological Hazards Division/Radiological Emergency Preparedness Program_________________________________
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Site Name
and Units Licensing Contact Alternates
Summer
Amy Moore
Mail Code P-40
So. Carolina Electric and Gas
PO Box 88
Jenkinsville, SC 29065
803-345-4106
AMonroe@scana.com
Calvert Cliffs
John Price
UniStar
750 E. Pratt Street
Baltimore, MD 21202
410-470-5531
John.Price2@unistarnuclear.com
Grand Gulf
Mr. Thomas Williamson
Manager, GGNS COLA Project
Entergy Nuclear
1340 Echelon Parkway
Jackson, MS 39213
601-368-5786
TWilli2@entergy.com
Levy
Bob Kitchen
Progress Energy
PO Box 1981
TPP-15
Raleigh, NC 27602-1981
919-546-6992
Robert.Kitchen@pgnmail.com
Callaway
David Shafer
Assistant Manager, Engineering
AmerenUE
Callaway Plant
PO Box 620
Fulton, MO 65251
573-676-4722
DShafer@ameren.com
Roger Wink
Supervising Engineer
AmerenUE
Callaway Plant
PO Box 620
Fulton, MO 65251
573-676-8498
RWink@ameren.com
River Bend
Jerry Burford
Manager, RBS COLA Project
Entergy Nuclear
1340 Echelon Parkway
Jackson, MS 39212
601-955-8050
fburfor@entergy.com
Nine Mile Point
George Wrobel
Director, Unistar Nuclear Energy
1503 Lake Road
Ontario, New York 14519
585-771-3535 (o)
SOP for New Reactor Combined License (COL) Application___________________________________________________
_____________________________________________________________________________________________________
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Site Name
and Units Licensing Contact Alternates
585-315-0552 (c)
George.Wrobel@unistarnuclear.com
Bell Bend
Rocco R. Sgarro
Manager - Nuclear Regulatory Affairs
PPL Bell Bend, LLC
570-802-8102 (Bell Bend)
610-774-7552 (Allentown)
610-657-4667 (c)
RRSgarro@pplweb.com
Comanche Peak
Don Woodlan
Manager, Nuclear Regulatory Affairs
P.O. Box 1002
Glen Rose, Texas 76043
Donald.Woodlan@luminant.com
254-897-6887
Fermi
Mr. Peter Smith
6400 N. Dixie Highway
Newport, MI 48166
313-235-3341
Peter.Smith@dteenergy.com
Victoria
Mr. Joseph Bauer
Lead Licensing Engineer
Exelon Generation Co.
4300 Winfield Road
Warrenville, IL. 60555
630-657-3106
Joseph.Bauer@exeloncorp.com
Turkey Point
Mr. Martin Gettler
Vice President – New Nuclear Projects,
Florida Power and Light Company,
Juno Beach Office,
700 Universe Blvd,
Juno Beach, FL 33408
Mr. William Maher
Senior Director – Licensing, New
Nuclear Projects,
Florida Power and Light Company,
Juno Beach Office,
700 Universe Blvd,
Juno Beach, FL 33408
Amarillo
Bruneau
Contact information was provided by NRC and updates will be provided as they are
recieved.
Technological Hazards Division/Radiological Emergency Preparedness Program_________________________________
_____________________________________________________________________________________________________
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FEMA Headquarters Points of Contact
Section Chief
Site Contact
Albert Coons
Albert.Coons@dhs.gov
202-212-2318
Team Lead
Bonnie Sheffield
Bonnie.Sheffield@dhs.gov
202-212-2120
Callaway
Summer
Lisa Banks-Robinson
Lisa.Banks-Robinson@dhs.gov
202-212-2123
Bellefonte
River Bend
Victoria
Rebecca Fontenot
Rebecca.Fontenot@dhs.gov
202-212-2315
Calvert Cliffs
Comanche Peak
Fermi 3
Patricia Gardner
Patricia.Gardner@dhs.gov
202-212-2314
Bell Bend
Grand Gulf
Harry Nash
Harry.W.NashJr@dhs.gov
202-212-2317
Shearon Harris
Turkey point
Vogtle
David Jeremy
David.Jeremy@dhs.gov
202-212-2316
Bruneau
Lee
South Texas Project
Thomas Strother
Thomas.Strother@dhs.gov
202-212-2121
Levy
Nine Mile Point
North Anna
Nathaniel Yates
Nathaniel.Yates@dhs.gov
202-212-2125
SOP for New Reactor Combined License (COL) Application___________________________________________________
_____________________________________________________________________________________________________
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NRC Points of Contact
Branch Chief Site Lead Reviewer
Contact
Kevin Williams
Licensing & Inspection Branch
301-415-3264
Kevin.Williams@nrc.gov
Daniel M. Barss
Team Lead
Emergency Preparedness (EP)
New Reactor Licensing Team
301-415-2922
Dan.Barss@nrc.gov
River Bend
Rollie Berry
General Engineer
301-415-6119
Rollie.Berry@nrc.gov
Levy
Anthony Bowers
EP Specialist
301-415-5313
Anthony.Bower@nrc.gov
Callaway
Don Johnson
Sr. EP Specialist
301-415-4040
Don.Johnson@nrc.gov
Summer
Walter Lange
EP Specialist
301-415-8028
Walter.Lange@nrc.gov
Nine Mile Point
Steve LaVie
Sr. EP Specialist
301-415-1081
Steve.Lavie@nrc.gov
Bellefonte
South Texas Project
Bob Moody
Sr. EP Specialist
301-415-1737
Robert.Moody@nrc.gov
North Anna
Vogtle
Bruce Musico
Sr. EP Specialist
301-415-2310
Bruce.Musico@nrc.gov
Comanche Peak
Edward Robinson
EP Specialist
301-415-1022
Technological Hazards Division/Radiological Emergency Preparedness Program_________________________________
_____________________________________________________________________________________________________
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Branch Chief Site Lead Reviewer
Contact
Shearon Harris
Edward.Robinson@nrc.gov
Grand Gulf
Ronald V. Schmitt
EP Specialist
301-415-4082
Ronald.Schmitt@nrc.gov
Bell Bend
Victoria
Jeff Temple
EP Specialist
301-415-0156
Jeffrey.Temple@nrc.gov
Calvert Cliffs
Fermi 3
Eric Weiss
Sr. EP Specialist
301-415-1104
Eric.Weiss@nrc.gov
Lee
Ned Wright
EP Specialist
301-415-5563
Ned.Wright@nrc.gov
Amarillo
Turkey Point
Bruneau
SOP for New Reactor Combined License (COL) Application___________________________________________________
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FEMA Regions Points of Contact
FEMA Regional Office Regional Assistance Committee
Chairperson Alternates
Region I
99 High Street
6th Floor
Boston, MA 02110
Dean Savramis
617-956-7564
Dean.Savramis@dhs.gov
Fax: 617-832-4773
Vacant
Region II
26 Federal Plaza
Room 1307
New York, NY 10278-0001
Rebecca S. Thomson
212-680-8509
Rebecca.Thomson@dhs.gov
Fax: 212-680-3608
William R. Cullen
212-680-8505
William.R.Cullen@dhs.gov
Region III
One Independence Mall
6th Floor
615 Chestnut St.
Philadelphia, PA 19106-4404
Darrell W. Hammons
215-931-5546
Darrell.Hammons@dhs.gov
Fax: 215-931-5539
John F. Price
215-931-5570
John.Price@dhs.gov
Region IV
3003 Chamblee Tucker Rd.
Atlanta, GA 30341
Conrad S. Burnside
770-220-5486
Conrad.Burnside@dhs.gov
Fax: 770-220-5233
Lawrence A. Robertson
770-220-5378
Larry.Robertson@dhs.gov
Region V
536 S. Clark St.
6th Floor
Chicago, IL 60605
William King
312-408-5575
William.King2@dhs.gov
Fax: 312-408-5222
Gary Naskrent
312-408-5214
Gary.Naskrent@dhs.gov
Region VI
FRC 800 North Loop 288
Denton, TX 76209-3698
Lisa R. Hammond
940-898-5199
Lisa.Hammond@dhs.gov
Fax: 940-898-5263
Nan Calhoun
940-898-5398
Nan.Calhoun@dhs.gov
Region VII
9221 Ward Parkway, Suite 300
Kansas City, MO 64114
Ronald L. McCabe
816-283-7007
Ronald.McCabe@dhs.gov
Fax: 816-283-7098
Norman E. Valentine Jr.
816-283-7017
Norm.Valentine@dhs.gov
Region VIII
Denver Federal Center, Bldg 710
P.O. Box 25267
Denver, CO 80225-0267
Dan Feighert
303-235-4737
Dan.Feighert@dhs.gov
Vacant
Region IX
1111 Broadway, Suite 1200
Oakland, CA
94607-4052
Harry Sherwood
510-627-7240
Harry.Sherwood@dhs.gov Fax:
510-627-7214
Richard Echavarria
510-627-7217
Richard.Echavarria@dhs.gov
Region X
Federal Regional Center
130 228th Street SW
Bothell, WA 98021
Michael L. Hammond
425-487-3715
Michael.Hammond@dhs.gov Fax:
425-627-3775
Janet Hlavaty-LaPosa
425-487-3745
Janet.Hlavaty-Laposa@dhs.gov
Technological Hazards Division/Radiological Emergency Preparedness Program_________________________________
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