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NEI White Paper
Revision 1
Pandemic Licensing Plan
December 2007
NEI White Paper Pandemic Licensing Plan
i Revision 1
December 2007
ACKNOWLEDGEMENTS
NEI acknowledges the assistance of the LATF Pandemic Team in the development of this white paper: Randy Bunt, Southern Nuclear Co. Anne Cottingham, NEI Ellen Ginsberg, NEI Al Haeger, Exelon Bill Horin, Winston & Strawn LLP Lou Larragoite, Constellation Doug McKinney, Southern Nuclear Co. Michael Richardson, Diablo Canyon/STARS Mike Schoppman, NEI Ned Tyler, Constellation
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ABSTRACT The Pandemic Threat A pandemic is an outbreak of infectious disease, such as influenza, that spreads globally across large geographical regions. Pandemics occur when new viruses evolve and begin to transmit rapidly between humans. Given the potentially serious health, social, and economic impacts of a pandemic, the United States (U.S.) government, the private sector, and the international community are developing response strategies. An important national goal of the pandemic response strategy is assuring the continued reliability of generating facilities in support of the electric grid. Electricity production and delivery, two of the most important elements of the North American economic and social infrastructure, must remain dependable during a pandemic because many parts of the infrastructure (e.g., food supply, water, telecommunications, transportation, public health) cannot function without a stable, reliable supply of electric power. Continued safe operation of the 104 operating nuclear plants during a pandemic, and assuring the health and safety of the public, is the fundamental guiding principle for the NRC and licensees. As a critical component of the electrical infrastructure, nuclear power would help maintain grid stability and support reserve power sources in the event of major losses of sources of power generation. The principal threat to the safe operation of any generating facility during a pandemic is the absence of essential personnel from the workplace for extended periods. The federal government projects absentee rates during the first wave of an influenza pandemic of up to 40 percent for six to eight weeks, followed by one or more subsequent waves over a period of 12 to 18 months. Accordingly, this licensing plan addresses the management of that threat in order to assure the safe operation of nuclear power.
National Planning
The Department of Homeland Security (DHS) coordinates the response to national emergencies. DHS has prepared a National Response Plan
1 (the Plan) to integrate incident management disciplines
(homeland security, emergency management, law enforcement, firefighting, public works, public health, responder and recovery worker health and safety, emergency medical services, and the private sector) into a unified structure. The Plan forms the basis for coordinating federal departments and agencies with state, local, and tribal governments and the private sector. It includes response protocols for terrorist attacks and other natural and manmade hazards, including influenza pandemics.
DHS has formed a Critical Infrastructure Partnership Advisory Council (CIPAC) to coordinate critical business sectors. The nuclear sector is represented on CIPAC by the Nuclear Sector Coordinating
1 U.S. Department of Homeland Security, Pandemic Response Plan, “National Strategy for Pandemic Influenza”
(November 2005) followed by the "National Strategy for Pandemic Influenza – Implementation Plan" in May 2006 (available at http://www.whitehouse.gov/infocus/pandemicflu.html). These goals were further reiterated in the broad "National Strategy for Homeland Security," issued in October 2007 (http://www.whitehouse.gov/infocus/pandemicflu/homeland.html).
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Council (NSCC). In coordination with NEI, the NSCC has published NEI 06-032 to describe the
pandemic threat and assist nuclear plant owners and operators in developing response plans. The NRC Interim Pandemic Response Plan
3 identifies the agency’s “pandemic priority functions” as
incident response, threat assessment and dissemination, external communications, critical licensing activities, enforcement, and administrative support. The NRC’s Plan notes that some routine licensing, exercises and inspections may be deferred, delayed or cancelled depending on the availability of staff, but only if operational safety and security can be maintained. The purpose of this NEI white paper is to supplement NEI 06-03 and the NRC Interim Pandemic Response Plan. It recognizes the potential for an influenza pandemic to reduce nuclear plant staffing below the levels necessary to maintain full compliance with all NRC regulatory requirements. It then describes the regulatory actions necessary to assure continued safe operation with reduced staffing levels for until pandemic conditions subside and staffing returns to normal levels. Regulatory relief to permit rescheduling of selected activities and deferral of administrative and programmatic requirements can assure that controlled mechanisms are in place to minimize the risk from continued operation. At the same time such actions would permit the focus of resources on safety-significant activities. An additional result from establishing such mechanisms would be the reduction of the health and safety risks from blackouts and grid instability. This white paper recommends NRC enforcement discretion as the most efficient and effective licensing approach to a pandemic. Significantly, the necessary criteria for evaluating and granting such discretion can be developed in advance. A pre-established NRC policy for granting enforcement discretion would create the flexibility to manage a range of pandemic-related situations while continuing to assure the safe operation of the plant. Other regulatory options (license amendments, exemptions, orders) could be used as needed to supplement enforcement discretion.
2 Nuclear Energy Institute, NEI 06-03, “Nuclear Sector Coordination Council, Influenza Pandemic Threat Summary
and Planning, Preparation, and Response Reference Guide” (March 2006). 3 U.S. NRC, Press Release 06-147, “Interim Pandemic Response Plan” (December 1, 2006).
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TABLE OF CONTENTS
Section Title Page 1.0 INTRODUCTION 1
1.1 Social and Economic Impact 1 1.2 Planning Assumptions 2 1.3 Pandemic Licensing Plan 2 1.4 Summary of NEI Recommendations 3
2.0 STAFFING REQUIREMENTS 5 2.1 Explicit and Implicit Staffing Requirements 5 2.2 Relief Categories 5 2.3 Bases for Regulatory Relief 6
2.3.1 Risk Basis for Extending LCO Completion Times 7 2.3.2 Risk Basis for Increasing Surveillance Test Intervals 7 2.3.3 Regulatory Relief Alternatives 8
3.0 REGULATORY OPTIONS 9 3.1 Current Regulations 9
3.1.1 Program Changes/Deviations 9 3.1.2 Emergency Operations 9
3.2 Enforcement Discretion 10 3.2.1 Pre-established Discretion 11 3.2.2 Plant-specific Discretion at Time of Need 12 3.2.3 Plant-specific Feedback into Pre-established Discretion 12 3.2.4 Entry Criteria 12 3.2.5 Exit Criteria 13
3.3 License Amendments 13 3.3.1 Generic Pandemic Response Program 13 3.3.2 Plant-Specific Emergency/Exigent License Amendments 13
3.4 Exemptions 14 3.5 Orders 15
4.0 PANDEMIC RESPONSE 16 4.1 Pandemic Response Trigger 16 4.2 Evaluation of Staffing Requirements 16 4.3 Risk-informed Evaluation of LCOs and STIs 17
Table 1 Evaluation of Staffing Requirements T1-1 Table 2 Major Department Staffing Guidelines T2-1 Table 3 Evaluation of TS Surveillance Test Intervals T3-1
Appendix A Excerpts from 10 CFR and Technical Specifications A-1 Appendix B Draft Interim Enforcement Policy B-1
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1.0 INTRODUCTION An influenza pandemic is defined as a global outbreak in which influenza rates exceed baseline levels and cause high rates of serious illness and mortality worldwide. Health care professionals predict that an influenza pandemic that severely disrupts affected populations will occur within the next 10 years. This white paper addresses the nuclear licensing aspects of an influenza pandemic in four main Sections:
• Section 1 introduces the planning assumptions for the nuclear industry’s pandemic licensing plan.
• Section 2 lists the NRC regulatory requirements that could become compliance
challenges if plant staffing is reduced significantly due to absenteeism during an influenza pandemic.
• Section 3 lists the regulatory options available to the NRC staff for granting
regulatory relief, and evaluates their suitability for use during a pandemic. • Section 4 proposes a licensing framework for addressing power reactor licensing
issues during a pandemic. 1.1 Social and Economic Impact The H5N1 influenza virus currently affects a large part of the bird population in Asia. A pandemic could result if the virus mutates to become transmissible to and between humans. A virulent pandemic would disrupt all sectors of business and society. The U.S. economy has the following critical business sectors, which are all dependent on electricity to some extent:
• Chemical • Dams • Emergency Services • Energy • Food and Agriculture • Information Technology • Postal and Shipping • Public Health • Telecommunications • Transportation • Water
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1.2 Planning Assumptions For planning purposes, the general phases of a pandemic are:
(1) Pandemic Alert – Responsible government authorities notify public and private sectors that a pandemic is possible. Response plans are prepared or updated.
(2) Pre-Pandemic – Localized outbreaks occur with human-to-human transmission. The public and private sectors begin to assign resources, prepare staff, distribute planning information, and implement pandemic response plans.
(3) Pandemic Outbreak – General outbreaks occur across borders and continents, and pandemic response plans are activated.
(4) Maximum Disruption – High absentee rates (up to 40 percent) occur and impact the workforce for several months.
(5) Prolonged Recovery – Recovery is slow and the underlying economy is weak. Altered business conditions prevail for three to six months.
The World Health Organization pandemic phases and the corresponding U.S. federal response stages are described in detail at http://www.pandemicflu.gov/plan/federal/fedresponsestages.html. Business continuity planning assumptions include the following:
• A pandemic occurs within 10 years. • Once human-to-human virus transmission begins, the disease spreads worldwide
within three to eight weeks. • Infection rates exceed 25 % of the affected population. • Infected employees experience serious illness for up to two weeks (or longer if there
are complications). • The time period away from work varies depending on family situation and recovery
time. • Absentee rates for employees approach 40 percent over a period of six to eight
weeks. • Mortality rates among infected persons approach two percent. • Personnel and business processes focus on maintaining essential business functions
and minimizing the spread of the disease. • There is no vaccine until the actual virus appears and a limited quantity of vaccine is
manufactured (several months). • When a vaccine becomes available, it is distributed by government allotment first to
the very ill and to workers in critical sectors. • There are two or three waves of pandemic, each lasting six to eight weeks.
1.3 Pandemic Licensing Plan The licensing framework described in this paper is intended for use by operating commercial nuclear plant licensees in the U.S. to obtain temporary relief from a defined subset of NRC regulatory requirements during an influenza pandemic. Such relief would be necessary to permit existing nuclear plants to continue operating safely without the staff normally available to comply with all
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regulatory requirements during a pandemic. Continued safe operation of nuclear plants is an important factor in maintaining a functioning electric grid that can support critical sectors of the US infrastructure during times of regional and national emergency. Nevertheless, operation under emergency conditions would not be permitted if nuclear safety and security were jeopardized. The impact on public health and safety of a local or regional pandemic will depend on the resilience of infrastructure (medical, communication, heating, transportation, food supply). The NEI plan assumes (conservatively) that industry and NRC staffing levels will be reduced in the region affected by the pandemic. Therefore, the plan attempts to identify reasonable boundary conditions for the temporary relaxation of a limited set of non-safety administrative and staffing-related requirements to help preclude the loss of the electric grid. The NEI plan also assumes that regional demand for electric power will drop by 50%. The plan assumes that fuel supplies to other generation types will be disrupted, making nuclear generation a necessary contributor to meeting this demand. From that perspective, an adequate, stable power supply is essential to protect public health and safety. The NEI plan identifies requirements that can be relaxed temporarily to reduce the likelihood of a “compliance shutdown” without affecting the risk profile of the plant increasing the likelihood of a radiological accident. The plan also notes the importance of criteria for plant-specific entry into and exit from enforcement discretion, the importance of licensees communicating to NRC during periods of enforcement discretion, and the necessity for plant shutdown if staffing falls to a level that can no longer ensure an acceptable level of safety and security. Safe plant operation and attendant protection of public health and safety are the primary considerations when evaluating and applying any of the licensing options discussed herein. Nuclear plant licensees seeking regulatory relief due to the impact of reduced staffing during a pandemic must assure continued safe plant operation by performing assessments of specific relief either in advance of the pandemic or at the time of need. Relief will become available on a licensee-by-licensee basis when the pandemic has reduced personnel availability for specific activities below pre-established thresholds. In all cases, the relief will be temporary. Relief will be withdrawn when stable staffing levels have risen above pandemic thresholds. If at any point the licensee cannot assure safe operation, the plant will be shut down. 1.4 Summary of NEI Recommendations The body of this paper contains the following recommendations:
(1) NRC should accept NEI 06-09, “Risk-Managed Technical Specifications (RMTS) Guidelines” (November 2006), as a method for determining which limiting conditions for operation (LCOs) can be extended during a pandemic.
(2) NRC should accept NEI 04-10, “Risk-Informed Method for Control of Surveillance
Frequencies” (July 2006), as a method for determining if surveillance test intervals that fall in pandemic categories A and B (the categories are defined in Section 2.2) can be delayed during a pandemic.
(3) NRC should develop regulatory guidance to expand the operational flexibility
available to NRC staff and licensees during temporary pandemic situations.
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(4) NRC should develop an interim enforcement policy regarding enforcement discretion for nuclear plants during a pandemic and publish the proposed policy in the Federal Register to give stakeholders an opportunity to participate in the policy development process.
(5) NRC should authorize enforcement discretion in advance for requirements that do
not have a material impact on the functionality of safety-related SSCs (pre-established discretion for Category C requirements is defined in Section 2.2 and Table 1).
(6) NRC should post on the NRC website the correspondence and evaluations associated
with approved plant-specific enforcement discretion actions. (7) NRC should use the consolidated line item improvement process (CLIIP) to review
generic technical specification changes that are pandemic related. (8) NRC should consider the use of pre-defined templates for managing proposed
emergency and exigent technical specification changes that are pandemic related. (9) NRC and NEI should develop templates for enforcement discretion requests and
exemption requests to facilitate the regulatory review process during a pandemic.
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2.0 STAFFING REQUIREMENTS This section of the white paper discusses NRC regulatory requirements that have staffing implications, the potential for noncompliance with staffing requirements during an influenza pandemic, and the licensing options for obtaining relief from selected staffing requirements to permit continued safe nuclear plant operation during a pandemic. The NEI plan focuses on staffing-related requirements (i.e., requirements that specify a limiting number of trained personnel for a particular task) and requirements that cannot be met if staffing falls below a certain level. It is consistent with NRC’s Interim Pandemic Response Plan in that it addresses staffing and workload requirements in non-critical operations. However, it also looks for similar flexibility in critical operations. Reduced plant-specific staffing levels must be sufficient to maintain safe operation. At the same time, as described in the NEI plan, there are many requirements that can be relaxed temporarily, with NRC oversight, to facilitate continued safe reactor operation, thereby also supporting electric grid reliability and stability, which will in turn help government agencies manage a pandemic. The NEI planning assumptions incorporate threshold, timing, reporting, and documentation criteria. 2.1 Explicit and Implicit Staffing Requirements Appendix A provides excerpts from the NRC regulations and Standard Technical Specifications
4 that
contain explicit and implicit staffing requirements for nuclear reactors. The explicit requirements cite a minimum number of staff for certain job categories (licensed operators, non-licensed operators, shift advisor, fire brigade, and security supervisor). The implicit requirements do not cite staffing numbers, but establish various administrative and programmatic requirements that require staff to implement. Staffing-related requirements will become a compliance challenge if nuclear plant staffing is reduced significantly below normal levels. Table 1 of this white paper lists the source of each staffing-related requirement (Column 1), provides a brief statement of the requirement (Column 2), provides a keyword for use in grouping related requirements (Column 3), places the requirement into one of three compliance or relief categories (Column 4), provides the basis for the chosen relief category (Column 5), and recommends the appropriate vehicle for granting regulatory relief (Column 6). The relief categories are listed on the first page of Table 1. 2.2 Relief Categories A key assumption underlying the proposed relief categories is the benefit to and assurance of protecting the public health and safety of continued nuclear plant operation during an influenza pandemic (i.e., helping to ensure continued operation of the electric grid), which offsets a temporary inability to comply. In many cases, compliance can be deferred, or compensatory measures can be implemented, to mitigate the consequences of noncompliance. Whatever the case, each noncompliance must be documented and dispositioned during or after the pandemic. Significantly, the NEI plan does not seek relief from all NRC regulatory requirements, but primarily from programmatic and administrative requirements. 4 NRC Standard Technical Specifications, NUREG series 1430-1434, Revision 3.1 (December 1, 2005).
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In this context, the proposed categories of regulatory relief include:
A. No Relief or Minimal Relief
Safety-related structures, systems, and components (SSCs) are designed to remain functional at all times to assure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, and the capability to prevent or mitigate the consequences of accidents that could result in an unacceptable release of radioactivity to offsite areas. The regulatory requirements associated with the functionality of safety-related SSCs cannot be compromised. Thus, no (or minimal) regulatory relief for this type of requirement may be sought during a pandemic. Licensees requesting minimal relief from Category A requirements would be required to use the appropriate administrative process defined in existing NRC regulations (typically a license amendment or an exemption) to obtain such relief.
B. Partial Relief
The intent of many technical requirements can be met through a combination of alternative actions and compensatory measures, many of which could be reviewed and approved in advance of a pandemic. In addition, risk-informed logic and analysis could be used to demonstrate that the risk impact of deferred compliance is acceptable, as discussed in Section 2.3.1 for Technical Specification (TS) Limiting Conditions for Operation (LCOs) and Section 2.3.2 for TS Surveillance Test Intervals (STIs). Thus, partial relief from this category of regulations (Category B) could be sought during a pandemic. Licensees would be obliged to communicate with NRC staff to propose and justify any proposed alternatives or compensatory actions. A formal licensing action may be necessary to define and authorize partial relief from a Category B requirement.
C. Substantial Relief
Many administrative and programmatic requirements, and some technical requirements, may be deferred without material impact on the functionality of safety-related SSCs. Thus, substantial relief from this type of requirement (Category C) could be sought during a pandemic, consistent with public health and safety. The scope of relief could be established in advance of a pandemic by a generic policy statement or other NRC-issued guidance, or it could be established plant by plant at time of need based on satisfying pre-established threshold criteria, as described below in Sections 3 and 4.
2.3 Bases for Regulatory Relief The bases for regulatory relief can be qualitative, quantitative, or a mix of the two. Regulatory relief is highly plant-specific for compliance category A (no relief, or minimal relief). It is a combination of qualitative and quantitative for compliance category B (partial relief). It is almost entirely qualitative for compliance category C (substantial relief).The proposed framework for deriving quantitative conclusions in support of extending TS LCO completion times during a pandemic is described in Section 2.3.1. A similar framework for increasing TS surveillance test intervals is described in Section 2.3.2. Alternative licensing actions for obtaining regulatory relief are described in Section 2.3.3.
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2.3.1 Risk Basis for Extending LCO Completion Times All LCOs are in pandemic compliance category A. NEI 06-09
5 describes a risk-informed
methodology for extending LCO completion times that is based on the methodology used to comply with paragraph (a)(4) of the maintenance rule (10 CFR 50.65), consistent with NRC Regulatory Guide 1.174.
6 Probabilistic risk assessment (PRA) tools are used to evaluate the risk impact of longer completion times by taking the configuration-specific risk into account. Deterministic backstop values are used to limit the LCO extension regardless of low risk impact. Recommendation 1 – NEI recommends that NRC accept NEI 06-09 as a method for determining which LCOs can be extended during a pandemic. Each licensee would use its current plant-specific PRA as the basis for the risk evaluation.
2.3.2 Risk Basis for Increasing Surveillance Test Intervals Table 3 shows that surveillance test intervals (STIs) fall into all three pandemic compliance categories. NEI 04-10
7 describes a methodology for evaluating the risk associated with
extending a STI. The methodology was developed as part of Risk Informed Technical Specifications (RITS) Initiative 5b. The Technical Specification Task Force (TSTF), under the auspices of the BWR and PWR Owners Groups, is developing a “surveillance frequency control program” based on NEI 04-10. Under Initiative 5b, surveillance requirements remain in TS, but individual STIs can be relocated to a licensee-controlled document. Recommendation 2 – NEI recommends that NRC accept NEI 04-10 as a method for determining whether surveillance test intervals that fall in pandemic categories A and B can be delayed during a pandemic. Each licensee would use its current plant-specific PRA as the basis for the risk evaluation. 2.3.3 Regulatory Relief Alternatives Alternative approaches for seeking regulatory relief are listed below. In each case, the basis for relief is either:
• Delayed compliance will not adversely affect operation or safety during the limited pandemic time period, and compliance will be restored after the pandemic, or
• A short-term alternative is acceptable for use during the limited pandemic
time period, and normal compliance will be restored after the pandemic.
5 Nuclear Energy Institute, NEI 06-09, “Risk-Managed Technical Specifications (RMTS) Guidelines” (November
2006). 6 U.S. NRC, Regulatory Guide 1.174, “An Approach for Using Probabilistic Risk Assessment in Risk-Informed
Decisions on Plant-Specific Changes to the Licensing Basis,” Revision 1 (November 2002). 7 Nuclear Energy Institute, NEI 04-10, “Risk-Informed Method for Control of Surveillance Frequencies” (July 2006).
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The licensing actions necessary to implement the following regulatory-relief alternatives are discussed in greater detail in Section 3.
(1) Current change-control regulations. (a) 10 CFR 50.54(a)(3) – quality assurance program changes. (b) 10 CFR 50.54(p)(1) – security program changes. (c) 10 CFR 50.54(q) – emergency plan changes. (d) 10 CFR 50.54(x) and (y) – departure from a license condition or
technical specification in an emergency. (e) 10 CFR 50.54(dd) – departure from a license condition or technical
specification in a national security emergency, but only if there is an immediate need for such action to meet national security objectives as designated by the national command authority through the Commission.
(2) Enforcement discretion.
(a) General policy statement for pandemic situations (to be published in the Federal Register).
(b) Plant-specific enforcement discretion. (3) License amendments.
(a) Use of the consolidated line item improvement process8 (CLIIP) to
add a “pandemic response program” to the Administrative Controls section of the Standard Technical Specifications.
(b) Plant-specific emergency or exigent Technical Specification changes. (4) Exemptions.
(a) Specific exemptions (10 CFR 50.12). (b) Alternative to, or relief from, codes and standards requirements (10
CFR 50.55a). (5) Orders.
8 U.S. NRC, Regulatory Issue Summary 2000-06, “Consolidated Line Item Improvement Process For Adopting
Standard Technical Specifications Changes for Power Reactors” (March 20, 2000).
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3.0 REGULATORY OPTIONS A range of regulatory options is available to the NRC to address the staffing impacts anticipated in a pandemic. These are discussed below. Some options (e.g., enforcement discretion, license amendment, exemption, and order) require prior NRC approval. Other options are available to licensees without prior NRC approval (e.g., plant changes that satisfy 10 CFR 50.59 criteria, program changes permitted by 10 CFR 50.54, and departures from technical specifications in emergencies permitted by 10 CFR 50.54(x)). Because the extent of the impact from a pandemic on the NRC or individual licensee cannot be determined in advance, we believe that the NRC should identify (1) the set of requirements for which temporary generic relief can be “pre-established” and (2) the corresponding set of requirements for which plant-specific relief must be granted on a case-by-case basis at the time of need. As described below, NRC enforcement discretion appears to be the most efficient, effective, and flexible means to provide operational flexibility while ensuring continued safe operation during a pandemic. As discussed herein, that option would be available through an enforcement discretion revision to the NRC Enforcement Policy. Otherwise, other regulatory options could be used to address plant-specific situations, as needed. 3.1 Current Change-Control Regulations 10 CFR 50.54 contains a number of provisions that permit licensees to make changes to selected programs without prior NRC approval.
3.1.1 Program Changes/Deviations Certain regulations, including 10 CFR 50.54(a) for quality assurance, 10 CFR 50.54(p) for safeguards and security, and 10 CFR 50.54(q) for emergency preparedness, provide standards for licensees to modify, without prior NRC approval, the associated plant programs and processes so long as the modifications do not decrease program effectiveness or reduce licensee commitments. Recommendation 3 – NEI recommends that NRC develop regulatory guidance (for example Temporary Instructions in the NRC Inspection Manual) to provide flexibility to NRC staff and licensees in implementing these provisions during temporary pandemic situations. 3.1.2 Emergency Operation 10 CFR 50.54(x) and (y) allow licensees to take reasonable action that departs from a license condition, technical specification, or regulation in an emergency when such action is needed to protect the public health and safety. These regulations would be available for licensee implementation during a pandemic.
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The NRC considers the following factors whenever licensees implement 10 CFR 50.54(x) and (y):
9
(1) Did the licensee have to act immediately to avert possible adverse
consequences to public health and safety? (2) Was adequate or equivalent protective action that is consistent with the
license immediately apparent? (3) Was the licensee’s action reasonable, and based on information available at
the time, did it serve to protect the public health and safety? (4) Did the licensee deviate from its license only to the extent necessary to meet
the emergency? (5) Did the NRC staff have time to approve a license amendment?
10 CFR 50.54(x) is available in limited circumstances involving immediate radiological consequences. For example, an NRC memorandum
10 to a Task Interface Agreement states
that it is incumbent on a licensee to follow 10 CFR 50.59 and the provisions of the 10 CFR 50.54(x) final rule. 10 CFR 50.54(dd) allows a licensee to take reasonable action that departs from a license condition or a technical specification in a national security emergency. NEI believes that federal agencies are unlikely to classify an influenza pandemic as a national security emergency subject to the provisions of 10 CFR 50.54(dd). Accordingly, licensees are advised to consider other planning options.
3.2 Enforcement Discretion Under normal circumstances, each nuclear plant licensee must comply with the requirements and conditions of its operating license. However, the NRC has the authority to exercise enforcement discretion. The authority derives from the broad discretionary power of administrative agencies to decline to enforce requirements in circumstances where the agency’s regulatory purposes would not be served. Enforcement discretion is a defined process, which may be subject to stakeholder comment prior to its implementation, that NRC could use to manage the operational and safety impact of an influenza pandemic. Enforcement discretion is an efficient, effective option for dispositioning the safety and licensing impacts of temporary noncompliance. For example, in August 1999, the NRC established an interim policy for exercising enforcement discretion for noncompliance with license conditions and technical specifications related to the “Year 2000” (Y2K) software transition.
11
9 Final Rule, “Applicability of License; Conditions and Technical Specifications in an Emergency,” 48 Fed. Reg. 13966
(April 1, 1983). 10 U.S. NRC, NRC memorandum, “Final Response to Task Interface Agreement (TIA) 2004-04,” ADAMS Accession
No. ML060590273 (September 12, 2006). 11 Policy Statement, “Policy and Procedures for NRC Enforcement Action, Interim Enforcement Policy Regarding
Enforcement Discretion for Nuclear Power Plants during the Year 2000 Transition,” 64 Fed. Reg. 41474 (July 30, 1999).
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The Y2K interim policy established a precedent that reasonably could be followed for pandemic situations. Therefore, NEI has drafted a proposed interim enforcement policy for use during a human pandemic event (Appendix B). The proposed draft policy contains recommended language that provides for enforcement discretion to permit temporary noncompliance with license conditions, technical specifications, and other applicable NRC requirements due to staffing reductions caused by a pandemic. Although the proposed interim enforcement policy is broader than the current NOED (notice of enforcement discretion) policy, it is consistent with NRC’s discretion authority. The proposed interim policy in Appendix B addresses two aspects of pandemic enforcement discretion. First, it provides pre-established discretion applicable to all licensees for a range of pandemic-related programmatic and administrative requirements. Second, it provides a process for granting licensee-specific discretion for pandemic-related situations outside the scope of pre-established discretion. This white paper proposes, and it is reflected in the proposed interim discretion policy, that NRC licensees not be permitted to request enforcement discretion for a noncompliance that occurs during a pandemic unless the noncompliance can be attributed to staffing reductions caused by the pandemic. By granting the requested discretion, the NRC would be acknowledging that affected licensees will be in noncompliance with one or more regulatory requirements as written. The white paper also contemplates, and this is also reflected in the interim discretionary policy, that NRC would not take enforcement action against a noncompliance that is within the scope of a pandemic-related enforcement discretion unless the licensee provided materially incomplete or incorrect information in support of its request for discretion, or if the licensee’s actions clearly were unreasonable considering all relevant circumstances. Recommendation 4 – NEI recommends that NRC develop an interim enforcement policy regarding enforcement discretion for nuclear plants during a pandemic, and publish the proposed policy in the Federal Register to give stakeholders an opportunity to participate in the policy development process.
3.2.1 Pre-established Enforcement Discretion Pre-established enforcement discretion would provide temporary relief from those LCOs, STIs, and administrative requirements that can be extended or deferred during a pandemic. A licensee would not be required to conduct a safety assessment to exercise pre-established discretion because such assessment would be inherent in the interim policy. NEI believes that the items that are described in this paper as eligible for discretion (found in Table 1, Category “C”) are acceptable for the following reasons:
(1) Pre-established enforcement discretion from Category C provisions, whether individually or collectively employed, would not adversely impact plant safety. Many of the requirements for which pre-established discretion is sought are administrative (e.g., reports) that do not have a direct impact on plant safety.
(2) The NRC will review the list of items for which pre-established enforcement discretion is sought before it issues the policy. The main strength of a pre-established pandemic policy is the knowledge gained from considering possible scenarios, individually and collectively, before they occur.
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(3) Relief is not automatic, but is based on need. The pre-established enforcement discretion policy cannot be used unless specific entry conditions are met on a case-by-case basis. Relief is limited to the department, group, or shift that has the staffing shortfall. The discretion period ends when staffing is restored and stabilized for the particular matter subject to discretion.
(4) Licensees are responsible for tracking discretionary items and communicating status to NRC.
Requirements eligible for pre-established discretion are listed in Table 1 as Category C items. The licensee would notify the NRC whenever the licensee exercised a provision of the pre-established discretion. Recommendation 5 – NEI recommends that NRC authorize discretion in advance for requirements that do not have a material impact on the functionality of safety-related SSCs (“pre-established discretion for Category C requirements is defined in Section 2.2 and Table 1). 3.2.2 Plant-specific Discretion at Time of Need Appendix B also permits plant-specific discretion if a pandemic-related situation falls outside the scope of pre-established enforcement discretion. The plant-specific enforcement discretion process described in Appendix B is more streamlined than the current Notice of Enforcement Discretion (NOED) process,
12 although licensees would be expected to follow
the existing NOED guidance to the extent practicable.
The NEI plan envisions that a licensee would be required to submit a safety assessment in support of its request for a plant-specific pandemic-related discretion, and that the NRC would consider granting discretion if the impact on safety of continued plant operation is acceptable. 3.2.3 Plant-specific Feedback into Pre-established Generic Discretion The proposed interim policy provides for increasing the scope of pre-established generic discretion based on precedent that emerges as licensee-specific enforcement discretion is granted during the pandemic. Recommendation 6 – NEI recommends that NRC post on the NRC website the correspondence and evaluations associated with approved plant-specific enforcement discretion actions. Other licensees seeking specific discretion could use the website to search for applicable precedent.
This data could also serve to establish a record and basis for determining that additional pre-
established generic discretion items may be adopted.
12 U.S. NRC, Inspection Manual, Part 9900: Technical Guidance, “Operations – Notices of Enforcement Discretion”
(February 7, 2006).
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December 2007
3.2.4 Entry Criteria We propose the following criteria for entry (or re-entry) into the enforcement discretion policy:
(1) The federal, state, or local government confirms, using pre-defined governmental protocols established to deal with a pandemic threat, that a strain of influenza virus capable of causing a pandemic poses a threat to some portion of the U.S.
(2) Affected NRC reactor licensees determine that absenteeism caused by the
virus has reduced staffing levels within plant departments, groups, or shifts that support licensed activities.
(3) Affected licensees determine that it is not practical to use traditional NRC
regulatory relief mechanisms (NOED, license amendment, exemption). (4) Affected licensees notify NRC when the conditions for entry into the
enforcement discretion policy have been met at a particular location and request NRC concurrence.
(5) Affected licensees monitor staffing levels to confirm that discretionary
conditions continue to exist, and report status to NRC at least bi-monthly. 3.2.5 Exit Criteria We propose the following criteria for exit from the enforcement discretion policy:
(1) Affected licensees determine that the staffing level in an affected department, group, or shift either has returned to normal or no longer affects the capability of the licensee to comply with regulatory requirements.
(2) Affected licensees promptly notify the NRC on a case-by-case basis as
discretionary items are returned to a normal compliance status. 3.3 License Amendments The license amendment request (LAR) process is well established.
13 However, license amendments
would require more time and resources to process than pre-established enforcement discretion. Potential approaches for utilizing the license amendment process are described below.
3.3.1 Generic Pandemic Response Program A process, such as the consolidated line item improvement process (CLIIP), could be used to add a “pandemic response program” to the Administrative Controls section of the Standard Technical Specifications. A CLIIP is initiated by an industry proposal, in this case to
13 See Nuclear Energy Institute, NEI 06-02, “License Amendment Request Guidelines,” December 2006, for guidance
on the LAR process.
NEI White Paper Pandemic Licensing Plan
14 Revision 1
December 2007
implement a pandemic program based on Table 1 in this white paper. Once the programmatic details were determined to NRC’s satisfaction, NRC could publish a “model safety evaluation” for comment in the Federal Register. Following satisfactory resolution of public comments, NRC could make the model SE available for reference by licensees in plant-specific license amendment requests. The subsequent LARs would reference the model SE and confirm that the plant satisfied its criteria. Recommendation 7 – NEI recommends that NRC use the consolidated line item improvement process (CLIIP) to review generic technical specification changes that are pandemic related. 3.3.2 Plant-specific Emergency/Exigent License Amendments
Pandemic situations that cannot be dispositioned by the generic pandemic enforcement discretion appendix to the enforcement policy or by a generic pandemic program in the TS could be addressed by plant-specific emergency or exigent license amendment requests under 10 CFR 50.91. Although plant-specific relief typically is more burdensome administratively than generic relief, the generic options may not accommodate all situations. The NRC could define in advance the criteria for initiating a pandemic-related emergency or exigent LAR. In response to a plant-specific pandemic LAR, the NRC would prepare a safety evaluation and make it available on an expedited basis for public notice and comment in accordance with 10 CFR 50.90(a)(5) or (a)(6). LAR and SE templates could be prepared in advance to facilitate the plant-specific amendment process during a pandemic. Recommendation 8 – NEI recommends that NRC consider the use of pre-defined templates for managing proposed emergency and exigent technical specification changes that are pandemic related.
3.4 Exemptions The NRC’s regulatory process anticipates situations that warrant exemptions from regulatory requirements without changing the regulation itself or modifying a plant-specific license. To the extent that the need for specific exemptions can be identified in advance, they would be effective alternatives to enforcement discretion or license amendments during a pandemic. The exemption process is defined in 10 CFR 50.12. Section 50.12(a) provides that the NRC may, upon application by any interested person or upon its own initiative, grant exemptions from 10 CFR 50 requirements that are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The NRC will not grant an exemption unless “special circumstances” are shown to be present. The special circumstances on which basis the Commission may issue an exemption include those circumstances for which the exemption would provide only temporary relief and the licensee has made a good faith effort to comply. Such circumstances arguably would be satisfied in a pandemic context, based upon an appropriate factual showing.
NEI White Paper Pandemic Licensing Plan
15 Revision 1
December 2007
In addition to the 10 CFR 50.12 exemption process, 10 CFR 50.55a(a)(3) provides a separate exemption-like process for alternatives to, or relief from, ASME requirements
14 and IEEE requirements
15 that are impractical or impossible to perform.
Although NEI supports expedited exemptions as an option for addressing pandemic-related staffing reductions, we are concerned that this approach would not be workable in many circumstances. The time and resources necessary to prepare, file, and defend an application for exemption is significant.
16 Another potential obstacle to industry-wide reliance on exemption requests for obtaining relief from certain regulatory obligations during a pandemic is the significant burden that could be placed on the NRC staff to review large numbers of concurrent requests. Accordingly, while a streamlined exemption process may be useful in certain circumstances, we view the enforcement discretion mechanism as more efficient and consistent with the industry and NRC staffing constraints expected during a pandemic. Recommendation 9 – NEI recommends that NRC and NEI develop templates for enforcement discretion requests and exemption requests to facilitate the regulatory review process during a pandemic. 3.5 Orders The NRC may issue orders to impose plant-specific requirements. The Atomic Energy Act of 1954 and 10 CFR 2.202 provide that NRC may issue an order that is effective immediately when necessary or desirable to promote the common defense and security, or to protect health and safety, or to minimize danger to life or property. While such orders are atypical, NRC is not prohibited from using orders to direct licensees to take specific actions to provide operational flexibility in the event of a pandemic. For example, NRC orders would be an efficient way to specify the conditions under which certain staffing requirements (e.g., licensed operators, fire brigade, and security) could be reduced temporarily to permit operation for a limited period of time during a pandemic with less than licensing-basis staffing levels.
14 American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Section III, Section XI, and
OM Code). 15 Institute of Electrical and Electronic Engineers (IEEE), Standards for Protection and Safety Systems (IEEE-279 and
IEEE-603). 16 The preparation of an exemption is indeed process intensive. It generally requires, at a minimum, personnel in
licensing, engineering, operations, the plant safety review committee, and administrative support, with accompanying often time-consuming review and approval tracks.
NEI White Paper Pandemic Licensing Plan
16 Revision 1
December 2007
4.0 PANDEMIC RESPONSE General guidance for pandemic planning and preparation is contained in NEI 06-03. By contrast, this white paper goes into greater detail to describe the triggering criteria and the licensing processes that could be used by U.S. commercial nuclear plants and the NRC to request and grant regulatory relief during a pandemic. A pandemic event may be declared by federal, state, or local authorities, or by a licensee. When a pandemic event is declared, affected licensees may take action authorized by means of generic, pre-established guidance (a pandemic appendix to the Enforcement Policy, a Technical Specification pandemic program, a generic exemption, or a generic order) or any plant-specific pandemic licensing action granted at time of need. 4.1 Pandemic Response Triggers In the event that appropriate authorities determine that pandemic conditions exist in the vicinity of a U.S. nuclear plant, and a power reactor licensee determines that plant-specific staffing impacts are occurring at its nuclear station due to pandemic illness which would preclude performance of specific activities in accordance with the license, Technical Specifications, or other NRC requirements, the licensee may declare the onset of a pandemic event. Upon licensee notification to the NRC that the above conditions are present,
17 the NRC will confirm that the licensee may apply this Interim Policy
for the facility and for the activities specifically impacted, including associated support functions performed at other locations (e.g., licensee headquarters) or by contractor personnel. The licensee shall also reaffirm the applicability of pandemic impacts every 14 days with the NRC. When the pandemic ceases to cause plant-specific staffing impacts for a particular activity at its nuclear station, and the staffing levels with respect to that activity remain stable for a reasonable period of time, the licensee will determine that the pandemic event for the activity has ended and so notify the NRC. 4.2 Evaluation of Staffing Requirements Following the declaration of a pandemic event, the minimum staffing levels for certain job categories and functions (operators, fire brigade, major departments, programs, and administration) may be reduced utilizing plant-specific requests for relief in accordance with the mechanisms described in is paper. Table 1 (Evaluation of Staffing Requirements) provides suggested mechanisms that may be appropriate for obtaining relief from enumerated NRC requirements. The Table lists (1) the source of the requirement, (2) a brief statement of the requirement, (3) key word, (4) a relief category in accordance with Section 2.2, (5) the basis for the relief category, and (6) the compensatory action(s) or the form of regulatory relief that can be taken to support continued plant operation.
(1) Operations – The licensee may initiate “N-1” staffing for the positions listed in 10 CFR 50.54(m) and plant-specific TS. “N” for a given job category is the more restrictive number specified by either the regulation or the TS.
17 NEI proposes that, for ease of administration and recordkeeping, standard templates be employed in connection
with the application of this policy, including templates for licensee notification of pandemic conditions (which will also include confirmation that the licensee has notified state and local officials), requests for discretion, and NRC confirmation of discretion approval.
NEI White Paper Pandemic Licensing Plan
17 Revision 1
December 2007
(2) Fire Brigade – The licensee may initiate “N-1” staffing for the fire brigade. Typically,
“N” for the fire brigade is five, as specified in 10 CFR 50 Appendix R.
(3) Major Departments – The minimum pandemic staffing for maintenance, radiation protection, chemistry, engineering, and security is addressed in Table 2.
(4) Staffing to Satisfy Programmatic or Administrative Requirements – Table 1 includes is a list of programmatic or administrative requirements that represent implicit staffing requirements.
If staffing continues to fall and the minimum levels cannot be sustained, the licensee must initiate additional communication with the NRC (and possibly other government agencies) to ensure the safest operating condition based on a comparative evaluation of local plant conditions and, secondarily, regional grid conditions. The plant would be shut down if staffing falls to a level that can no longer ensure an acceptable level of safety and security. 4.3 Risk-Informed Evaluation of LCO and STIs Table 3 is a list of recurring, short-term surveillance intervals (i.e., the surveillance frequency is less than six months) associated with LCOs that could lead to a plant shutdown or a significant power reduction if not met. Some of these surveillances are not essential for near-term operations or safety, and therefore can be relaxed, deferred, or rescheduled, subject to NRC concurrence if they come due during a pandemic. Table 3 assigns a compliance category to each of these surveillance requirements and recommends how they may be dispositioned during a pandemic event. The options are full compliance, extension of the LCO interval, or deferral of the surveillance based on the risk-informed guidance in NEI 04-10 and NEI 06-09.
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
Rev
isio
n 1
Dec
embe
r 20
07
Tabl
e 1
is a
list
of
expl
icit
and
impl
icit
requ
irem
ents
in 1
0 CF
R a
nd t
echn
ical
spe
cific
atio
ns t
hat
have
sta
ffin
g im
plic
atio
ns.
Expl
icit
staf
fing
requ
irem
ents
con
tain
num
eric
al c
riter
ia f
or s
peci
fied
job
cate
gorie
s (e
.g.,
licen
sed
oper
ator
s, n
on-li
cens
ed o
pera
tors
, shi
ft a
dvis
ors,
sec
urity
or
gani
zatio
n, a
nd f
ire b
rigad
e).
Impl
icit
staf
fing
requ
irem
ents
are
tho
se t
hat
coul
d be
com
e co
mpl
ianc
e ch
alle
nges
if p
lant
sta
ffin
g is
re
duce
d si
gnifi
cant
ly d
ue t
o w
orke
r ill
ness
dur
ing
an in
fluen
za p
ande
mic
. Ea
ch li
cens
ee is
res
pons
ible
for
impl
emen
ting
the
NEI
whi
te
pape
r in
a m
anne
r co
nsis
tent
with
its
plan
t-sp
ecifi
c Te
chni
cal S
peci
ficat
ion.
Th
e Ta
ble
cont
ains
six
col
umns
:
Col
um
n
Con
ten
ts
1
Sour
ce o
f re
quire
men
t 2
Exce
rpt
from
the
tex
t of
the
req
uire
men
t 3
Keyw
ord18
4
Rel
ief
cate
gory
19
5 Ty
pe o
f Rel
ief20
6
Basi
s fo
r Rel
ief21
18 K
eyw
ords
: Ad
min
, Ope
ratio
n, O
vers
ight
, Pro
cedu
re, P
roce
ss, P
rogr
am, R
ecor
ds, R
epor
ting,
Sta
ffin
g, T
rain
ing
19 R
elie
f ca
tego
ries:
A
= n
o re
lief
or m
inim
al r
elie
f ba
sed
on p
lant
-spe
cific
req
uest
at
time
of n
eed
B =
par
tial r
elie
f ba
sed
on p
lant
-spe
cific
alte
rnat
ives
req
uest
ed in
adv
ance
or
at t
ime
of n
eed
C =
pr
e-es
tabl
ishe
d en
forc
emen
t di
scre
tion
that
wou
ld p
rovi
de t
empo
rary
rel
ief
for
LCO
s, S
TIs,
and
adm
inis
trat
ive
requ
irem
ents
tha
t ca
n be
ext
ende
d or
de
ferr
ed d
urin
g a
pand
emic
20
Typ
es o
f re
lief:
Pos
tpon
e, A
ltern
ativ
e, D
rop
21 B
ases
for
rel
ief:
N
ote
1 –
Del
ayed
com
plia
nce
will
not
adv
erse
ly a
ffec
t op
erat
ion
or s
afet
y du
ring
the
limite
d pa
ndem
ic t
ime
perio
d.
Com
plia
nce
will
be
rest
ored
aft
er t
he
pand
emic
. N
ote
2 –
Dev
elop
a s
hort
-ter
m a
ltern
ativ
e fo
r us
e du
ring
the
limite
d pa
ndem
ic t
ime
perio
d.
Res
tore
nor
mal
com
plia
nce
afte
r th
e pa
ndem
ic.
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
Rev
isio
n 1
Dec
embe
r 20
07
P
art
2 –
Ru
les
of P
ract
ice
Subp
art
A –
Ru
les
of P
ract
ice
for
Dom
esti
c Li
cen
sin
g P
roce
edin
gs a
nd
Issu
ance
of
Ord
ers
10 C
FR 2
.100
– 2
.111
Req
uire
men
ts f
or f
iling
lice
nse
amen
dmen
ts
Proc
ess
A Co
mpl
y, b
ut r
esch
edul
e no
n-es
sent
ial l
icen
se a
men
dmen
ts
Subp
art
B –
Pro
cedu
res
for
Impo
sin
g R
equ
irem
ents
by
Ord
er
10 C
FR 2
.200
– 2
.206
Li
cens
ee a
nd p
ublic
par
ticip
atio
n in
for
mal
pro
cess
es (
Ord
ers,
N
OVs
, civ
il pe
nalti
es, p
etiti
ons)
Pr
oces
s A
Com
ply,
but
res
ched
ule
non-
esse
ntia
l pro
ceed
ings
Subp
arts
C-G
an
d I-
O –
ru
les
and
proc
edu
res
for
diff
eren
t ty
pes
of h
eari
ngs
10 C
FR 2
.700
– 2
.713
Fo
rmal
and
info
rmal
hea
rings
Pr
oces
s A
Com
ply,
but
res
ched
ule
non-
esse
ntia
l hea
rings
Subp
art
H –
Ru
lem
akin
g
10 C
FR 2
.800
– 2
.810
Li
cens
ee a
nd p
ublic
par
ticip
atio
n in
rul
emak
ing
proc
eedi
ngs
Proc
ess
A Co
mpl
y, b
ut r
esch
edul
e no
n-es
sent
ial p
roce
edin
gs
Par
t 1
9 –
Not
ices
, In
stru
ctio
ns
and
Rep
orts
to
Wor
kers
1
9.1
1 –
Pos
tin
g of
not
ices
to
wor
kers
10 C
FR 1
9.11
(c)
Post
ing
of n
ew e
ditio
ns o
f N
RC
Form
3, N
otic
e to
Em
ploy
ees,
w
ithin
30
days
of
rece
ipt
Adm
in
C Po
stpo
ne
Not
e 1
10 C
FR 1
9.11
(e)
Post
not
ices
of
viol
atio
ns, c
ivil
pena
lties
, or
orde
rs w
ithin
2
wor
king
day
s; r
emai
n po
sted
for
at
leas
t 5
wor
king
day
s
Adm
in
C Po
stpo
ne
Not
e 1
19
.12
– I
nst
ruct
ion
to
wor
kers
10 C
FR 1
9.12
(a)
Inst
ruct
ion
to w
orke
rs –
exp
ecte
d to
rec
eive
> 1
00 m
rem
oc
cupa
tiona
l dos
e Pr
oces
s A
Com
ply,
but
res
ched
ule
non-
esse
ntia
l wor
k
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-2
Rev
isio
n 1
Dec
embe
r 20
07
19
.13
– N
otif
icat
ion
s an
d re
port
s to
indi
vidu
als
10 C
FR 1
9.13
(a)
Not
ifica
tions
and
rep
orts
to
indi
vidu
als
– oc
cupa
tiona
l dos
e >
10
0 m
rem
Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 1
9.13
(b)
Advi
se e
ach
wor
ker
annu
ally
of
wor
ker’s
dos
e Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 1
9.13
(c)
Furn
ish
expo
sure
rep
orts
with
in
30 d
ays
of r
eque
st f
rom
wor
ker
Rep
ortin
g C
Post
pone
, unl
ess
nece
ssar
y to
ac
com
mod
ate
wor
ker
re-
assi
gnm
ent
to a
noth
er p
lant
N
ote
1
10 C
FR 1
9.13
(d)
Prov
ide
indi
vidu
als
with
cop
ies
of
expo
sure
rep
orts
tha
t ar
e su
bmitt
ed t
o N
RC
purs
uant
to
appl
icab
le s
ectio
ns o
f Pa
rt 2
0
Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 1
9.13
(e)
Prov
ide
an e
xpos
ure
repo
rt t
o ea
ch w
orke
r at
ter
min
atio
n of
em
ploy
men
t
Rep
ortin
g C
Post
pone
N
ote
1
19
.18
– S
equ
estr
atio
n of
wit
nes
ses
and
excl
usi
on o
f co
un
sel i
n in
terv
iew
s co
ndu
cted
un
der
subp
oen
a
10 C
FR 1
9.18
Li
cens
ee p
artic
ipat
ion
in N
RC
inqu
iries
Pr
oces
s A
Com
ply,
but
res
ched
ule
non-
esse
ntia
l inq
uirie
s
19
.31
– A
pplic
atio
n f
or e
xem
ptio
ns
10 C
FR 1
9.31
Ap
plic
atio
n fo
r ex
empt
ion
from
Pa
rt 1
9 Pr
oces
s A
Com
ply
Par
t 2
0 –
Sta
nda
rds
for
Pro
tect
ion
Aga
inst
Rad
iati
on
Subp
art
B –
Rad
iati
on P
rote
ctio
n P
rogr
ams
10 C
FR 2
0.11
01(a
) D
evel
op, d
ocum
ent,
and
im
plem
ent
a pr
ogra
m
Prog
ram
A
Com
ply
10 C
FR 2
0.11
01(c
) An
nual
pro
gram
rev
iew
Ad
min
C
Post
pone
N
ote
1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-3
Rev
isio
n 1
Dec
embe
r 20
07
Subp
art
C –
Occ
upa
tion
al D
ose
Lim
its
10 C
FR 2
0.12
01
thro
ugh
20.1
208
• lim
its f
or a
dults
•
sum
ext
erna
l + in
tern
al d
ose
• ai
rbor
ne
• in
tern
al e
xpos
ure
• sp
ecia
l pla
nned
exp
osur
e •
min
ors
• em
bryo
/fet
us
Prog
ram
A
Com
ply
Subp
art
D –
Rad
iati
on D
ose
Lim
its
for
Indi
vidu
al M
embe
rs o
f th
e P
ubl
ic
10 C
FR 2
0.13
01 a
nd
20.1
302
• do
se li
mits
•
com
plia
nce
Prog
ram
A
Com
ply
Subp
art
F –
Su
rvey
s an
d M
onit
orin
g
10 C
FR 2
0.15
01 a
nd
20.1
502
• ge
nera
l crit
eria
for
sur
veys
•
cond
ition
s fo
r in
divi
dual
m
onito
ring
Prog
ram
A
Com
ply
Subp
art
G –
Con
trol
of
Expo
sure
fro
m E
xter
nal
Sou
rces
in R
estr
icte
d A
reas
10
CFR
20.
1601
and
20
.160
2 •
high
rad
iatio
n ar
eas
• ve
ry h
igh
radi
atio
n ar
eas
Prog
ram
A
Com
ply
Subp
art
H –
Res
pira
tory
Pro
tect
ion
an
d C
ontr
ols
to R
estr
ict
Inte
rnal
Exp
osu
re in
Res
tric
ted
Are
as
10 C
FR 2
0.17
01
thro
ugh
20.1
705
• ac
cess
•
expo
sure
tim
e •
resp
irato
ry p
rote
ctio
n •
prot
ectio
n fa
ctor
s
Prog
ram
A
Com
ply
Subp
art
I –
Stor
age
and
Con
trol
of
Lice
nse
d M
ater
ial
10 C
FR 2
0.18
01 a
nd
20.1
802
• in
sto
rage
•
not
in s
tora
ge
Prog
ram
A
Com
ply
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-4
Rev
isio
n 1
Dec
embe
r 20
07
Subp
art
J –
Pre
cau
tion
ary
Pro
cedu
res
10 C
FR 2
0.19
01
thro
ugh
20.1
906
• si
gns
• po
stin
gs
• la
bels
•
pack
ages
Prog
ram
A
Com
ply
Subp
art
K –
Was
te D
ispo
sal
10 C
FR 2
0.20
01
thro
ugh
20.2
007
• N
RC
appr
oval
•
sew
erag
e •
inci
nera
tion
• tr
ansf
er
• ot
her
regu
latio
ns
Prog
ram
A
Com
ply
Subp
art
L –
Rec
ords
10 C
FR 2
0.21
02
Rec
ords
of
radi
atio
n pr
otec
tion
prog
ram
s Rec
ords
C
Post
pone
N
ote
1
10 C
FR 2
0.21
03
Rec
ords
of
surv
eys
Rec
ords
C
Post
pone
N
ote
1 10
CFR
20.
2104
(a)(
1)
Prio
r oc
cupa
tiona
l dos
e Rec
ords
A
Com
ply
10
CFR
20.
2104
(b)
Prio
r oc
cupa
tiona
l dos
e Rec
ords
A
Com
ply
10
CFR
20.
2104
(e)
Prio
r oc
cupa
tiona
l dos
e Rec
ords
A
Com
ply
10 C
FR 2
0.21
05
Rec
ords
of
plan
ned
spec
ial
expo
sure
s Rec
ords
C
Post
pone
N
ote
1
10 C
FR 2
0.21
06
Rec
ords
of
indi
vidu
al m
onito
ring
resu
lts
Rec
ords
C
Post
pone
N
ote
1
10 C
FR 2
0.21
07
Rec
ords
of
dose
to
indi
vidu
al
mem
bers
of
the
publ
ic
Rec
ords
C
Post
pone
N
ote
1
10 C
FR 2
0.21
08
Rec
ords
of
was
te d
ispo
sal
Rec
ords
C
Post
pone
N
ote
1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-5
Rev
isio
n 1
Dec
embe
r 20
07
Subp
art
M –
Rep
orts
10 C
FR 2
0.22
01(a
) Te
leph
one
repo
rts
of t
heft
or
loss
of
lice
nsed
mat
eria
l Rep
ortin
g A
Com
ply
10 C
FR 2
0.22
01(b
) W
ritte
n re
port
s of
the
ft o
r lo
ss o
f lic
ense
d m
ater
ial
Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 2
0.22
02
Not
ifica
tion
of in
cide
nts
Rep
ortin
g C
Post
pone
N
ote
1 10
CFR
20.
2203
Rep
orts
of
expo
sure
s, r
adia
tion
leve
ls, a
nd c
once
ntra
tions
of
radi
oact
ive
mat
eria
l exc
eedi
ng
the
cons
trai
nts
or li
mits
Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 2
0.22
04
Rep
orts
of
plan
ned
spec
ial
expo
sure
s Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 2
0.22
05
Rep
orts
to
indi
vidu
als
exce
edin
g do
se li
mits
Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 2
0.22
06
Rep
orts
of
indi
vidu
al m
onito
ring
Rep
ortin
g C
Post
pone
N
ote
1 10
CFR
20.
2207
Rep
orts
of
tran
sact
ions
invo
lvin
g na
tiona
lly t
rack
ed s
ourc
es
Rep
ortin
g C
Post
pone
N
ote
1
Subp
art
N –
Exe
mpt
ion
s an
d A
ddit
ion
al R
equ
irem
ents
10 C
FR 2
0.23
01 a
nd
20.2
302
• ap
plic
atio
n fo
r ex
empt
ion
from
Pa
rt 2
0 •
NRC
may
impo
se a
dditi
onal
re
quire
men
ts
Proc
ess
A Co
mpl
y
Subp
art
O –
En
forc
emen
t 10
CFR
20.
2401
and
20
.240
2 •
viol
atio
ns
• pe
nalti
es
Ove
rsig
ht
A Co
mpl
y
Par
t 2
1 –
Rep
orti
ng
of D
efec
ts a
nd N
onco
mpl
ian
ce
21
.7 –
Exe
mpt
ion
s
10 C
FR 2
1.7
Appl
icat
ion
for
exem
ptio
n fr
om
Part
21
Adm
in
A Co
mpl
y
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-6
Rev
isio
n 1
Dec
embe
r 20
07
21
.21
- N
otif
icat
ion
of
failu
re t
o co
mpl
y or
exi
sten
ce o
f a
defe
ct a
nd
its
eval
uat
ion
10 C
FR 2
1.21
(a)
Not
ifica
tion
of f
ailu
re t
o co
mpl
y or
exi
sten
ce o
f a
defe
ct a
nd it
s ev
alua
tion
Rep
ortin
g B
Alte
rnat
ive
– Te
leph
one
notif
icat
ion
with
writ
ten
follo
w-
up a
fter
pan
dem
ic
Not
e 2
21
.51
– M
ain
ten
ance
an
d in
spec
tion
of
reco
rds
10 C
FR 2
1.51
(a)
Mai
nten
ance
and
insp
ectio
n of
re
cord
s Rec
ords
C
Post
pone
N
ote
1
Par
t 2
5 –
Acc
ess
Au
thor
izat
ion
for
Lic
ense
e P
erso
nn
el
25
.11
– S
peci
fic
exem
ptio
ns
10 C
FR 2
5.11
Sp
ecifi
c ex
empt
ions
– fr
om t
he
requ
irem
ents
of
Part
25
Adm
in
A Co
mpl
y
25
.13
– M
ain
ten
ance
of
reco
rds
10 C
FR 2
5.13
(a)
M
aint
enan
ce o
f re
cord
s Rec
ords
C
Post
pone
N
ote
1 2
5.2
1 –
Det
erm
inat
ion
of
init
ial a
nd c
onti
nu
ed e
ligib
ility
for
acc
ess
auth
oriz
atio
n
10 C
FR 2
5.21
(b)
Det
erm
inat
ion
of in
itial
and
co
ntin
ued
elig
ibili
ty f
or a
cces
s au
thor
izat
ion
Prog
ram
B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
cess
N
ote
2
25
.23
– N
otif
icat
ion
of
gran
t of
acc
ess
auth
oriz
atio
n
10 C
FR 2
5.23
N
otifi
catio
n of
gra
nt o
f ac
cess
au
thor
izat
ion
– no
ndis
clos
ure
agre
emen
t
Adm
in
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
roce
ss
Not
e 2
25
.25
– C
ance
llati
on o
f re
ques
ts f
or a
cces
s au
thor
izat
ion
10 C
FR 2
5.25
Ca
ncel
latio
n of
req
uest
s fo
r ac
cess
aut
horiz
atio
n
Adm
in
C Po
stpo
ne
Not
e 1
25
.31
– E
xten
sion
s an
d tr
ansf
ers
of a
cces
s au
thor
izat
ion
s
10 C
FR 2
5.31
(c)
Exte
nsio
ns a
nd t
rans
fers
of
acce
ss a
utho
rizat
ions
Ad
min
C
Post
pone
N
ote
1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-7
Rev
isio
n 1
Dec
embe
r 20
07
25
.33
– T
erm
inat
ion
of
acce
ss a
uth
oriz
atio
ns
10 C
FR 2
5.33
(b)
Term
inat
ion
of a
cces
s au
thor
izat
ions
– n
otify
CSA
Ad
min
C
Post
pone
N
ote
1
10 C
FR 2
5.33
(c)
Term
inat
ion
of a
cces
s au
thor
izat
ions
– s
ecur
ity
term
inat
ion
brie
fing
Adm
in
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
roce
ss
Not
e 2
Par
t 2
6 –
Fit
nes
s fo
r D
uty
Pro
gram
s 2
6.6
- E
xem
ptio
ns
10 C
FR 2
6.6
Appl
icat
ion
for
exem
ptio
n fr
om
Part
26
Adm
in
A Co
mpl
y
26
.20
– W
ritt
en p
olic
y an
d pr
oced
ure
s
10 C
FR 2
6.20
Es
tabl
ish
and
impl
emen
t w
ritte
n FF
D p
olic
ies
and
proc
edur
es
Prog
ram
B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
cess
N
ote
2
26
.21
– P
olic
y co
mm
un
icat
ion
s an
d aw
aren
ess
trai
nin
g
10 C
FR 2
6.21
(a)
Po
licy
com
mun
icat
ions
and
aw
aren
ess
trai
ning
Tr
aini
ng
C Po
stpo
ne
Not
e 1
10 C
FR 2
6.21
(b)
Polic
y co
mm
unic
atio
ns a
nd
awar
enes
s tr
aini
ng –
com
plet
e pr
ior
to a
ssig
nmen
t Tr
aini
ng
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
roce
ss
Not
e 2
26
.22
– T
rain
ing
of s
upe
rvis
ors
and
esco
rts
10 C
FR 2
6.22
(c)
Trai
ning
of
supe
rvis
ors
and
esco
rts
Trai
ning
B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
cess
N
ote
2
26
.23
- C
ontr
acto
rs a
nd
ven
dors
10 C
FR 2
6.23
(b)
Cont
ract
ors
and
vend
ors
– pr
ogra
m a
nd a
udits
O
vers
ight
C
Post
pone
N
ote
1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-8
Rev
isio
n 1
Dec
embe
r 20
07
26
.24
– C
hem
ical
an
d al
coh
ol t
esti
ng
10 C
FR 2
6.24
(a)
Chem
ical
and
alc
ohol
tes
ting
– im
plem
ent
prog
ram
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
roce
ss
Susp
end
test
ing
durin
g pa
ndem
ic (
IN
2005
-18)
2
6.2
5 –
Em
ploy
ee a
ssis
tan
ce p
rogr
ams
(EA
P)
10 C
FR 2
6.25
Em
ploy
ee a
ssis
tanc
e pr
ogra
ms
(EAP
)
Prog
ram
B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
cess
N
ote
2
26
.27
– M
anag
emen
t ac
tion
s an
d sa
nct
ion
s to
be
impo
sed
10 C
FR 2
6.27
(a)(
1)
Man
agem
ent
actio
ns a
nd
sanc
tions
to
be im
pose
d –
writ
ten
stat
emen
t fr
om in
divi
dual
s Ad
min
C
Post
pone
N
ote
1
26
.29
– P
rote
ctio
n o
f in
form
atio
n
10 C
FR 2
6.29
(a)
Prot
ectio
n of
info
rmat
ion
– fil
es
syst
em a
nd p
roce
dure
s
Proc
edur
es
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
roce
ss
Not
e 2
26
.71
– R
ecor
dkee
pin
g re
quir
emen
ts
10 C
FR 2
6.71
Rec
ordk
eepi
ng r
equi
rem
ents
Ad
min
C
Post
pone
N
ote
1 2
6.7
3 –
Rep
orti
ng
requ
irem
ents
10 C
FR 2
6.73
(a)
Rep
ortin
g re
quire
men
ts –
info
rm
the
Com
mis
sion
of
sign
ifica
nt
fitne
ss-f
or-d
uty
even
ts
Rep
ortin
g B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
cess
N
ote
2
26
.80
– A
udi
ts
10 C
FR 2
6.80
(a)
Audi
ts –
ann
ual
Adm
in
C Po
stpo
ne
Not
e 1
10-
CFR 2
6.80
(c)
Audi
ts –
rep
orts
Rep
ortin
g C
Post
pone
N
ote
1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-9
Rev
isio
n 1
Dec
embe
r 20
07
P
art
50
– D
omes
tic
Lice
nsi
ng
of P
rodu
ctio
n a
nd
Uti
lizat
ion
Fac
iliti
es
50
.9 –
Com
plet
enes
s an
d ac
cura
cy o
f in
form
atio
n
10 C
FR 5
0.9(
b)
Com
plet
enes
s an
d ac
cura
cy o
f in
form
atio
n –
notif
y th
e Co
mm
issi
on o
f in
form
atio
n id
entif
ied
by t
he a
pplic
ant
or
licen
see
as h
avin
g a
sign
ifica
nt
impl
icat
ion
for
publ
ic h
ealth
and
sa
fety
or
com
mon
def
ense
and
se
curit
y
Rep
ortin
g B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
cess
N
ote
2
50
.12
– S
peci
fic
exem
ptio
ns
10 C
FR 5
0.12
Ap
plic
atio
n fo
r ex
empt
ion
from
Pa
rt 5
0 Ad
min
A
Com
ply
50
.30
– F
ilin
g of
app
licat
ion
for
lice
nse
s; o
ath
or a
ffir
mat
ion
10 C
FR 5
0.30
(b)
Filin
g of
app
licat
ion
for
licen
se –
oa
th o
r af
firm
atio
n Ad
min
B
Alte
rnat
ive
Use
writ
ten
stat
emen
t ra
ther
tha
n no
tary
5
0.4
6 –
Acc
epta
nce
cri
teri
a fo
r EC
CS
for
ligh
t-w
ater
nu
clea
r po
wer
rea
ctor
s
10 C
FR 5
0.46
(3)(
i)
Acce
ptan
ce c
riter
ia f
or E
CCS
for
light
-wat
er n
ucle
ar p
ower
pla
nts
– ev
alua
te c
hang
es/e
rror
s in
LO
CA m
odel
s
Proc
ess
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
roce
ss
Not
e 2
10 C
FR 5
0.46
(3)(
ii)
Acce
ptan
ce c
riter
ia f
or E
CCS
for
light
-wat
er n
ucle
ar p
ower
pla
nts
– re
port
cha
nges
/err
ors
in L
OCA
m
odel
s
Rep
ortin
g B
Post
pone
N
ote
1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
0 Rev
isio
n 1
Dec
embe
r 20
07
50
.47
– E
mer
gen
cy p
lan
s
10 C
FR 5
0.47
(b)(
1)
Emer
genc
y pl
ans
– O
ffsi
te
emer
genc
y re
spon
se p
lann
ing
stan
dard
s Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 5
0.47
(b)(
2)
Emer
genc
y pl
ans
– O
nsite
em
erge
ncy
resp
onse
pla
nnin
g st
anda
rds
Prog
ram
B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
gram
N
ote
2
50
.48
– F
ire
prot
ecti
on
10 C
FR 5
0.48
(a)(
1)
Fire
pro
tect
ion
– fir
e pr
otec
tion
plan
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
50
.49
– E
Q o
f el
ectr
ic e
quip
men
t im
port
ant
to s
afet
y fo
r n
ucl
ear
pow
er p
lan
ts
10 C
FR 5
0.49
(a)
Envi
ronm
enta
l qua
lific
atio
n of
el
ectr
ic e
quip
men
t im
port
ant
to
safe
ty –
EQ
pro
gram
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
50
.54
– C
ondi
tion
s of
lice
nse
s
10 C
FR 5
0.54
(a)
Cond
ition
s of
lice
nses
– Q
A pr
ogra
m c
hang
e co
ntro
l pro
cess
Pr
oces
s B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
cess
N
ote
2
10 C
FR 5
0.54
(f)
Cond
ition
s of
lice
nses
– r
espo
nse
to in
form
atio
n re
ques
ts
Rep
ortin
g A
Com
ply,
but
res
ched
ule
and
m
inim
ize
requ
ests
10 C
FR 5
0.54
(k)
Cond
ition
s of
lice
nses
– li
cens
ed
oper
ator
“at
the
con
trol
s”
Staf
fing
A Co
mpl
y
10 C
FR 5
0.54
(m)(
1)
Cond
ition
s of
lice
nses
– S
enio
r lic
ense
d op
erat
or p
rese
nt a
t th
e fa
cilit
y or
rea
dily
ava
ilabl
e St
affin
g A
Com
ply
10 C
FR
50.5
4(m
)(2)
(i)
Cond
ition
s of
lice
nses
– L
icen
see
shal
l mee
t op
erat
or s
taff
ing
requ
irem
ents
spe
cifie
d in
a T
able
St
affin
g A
Lice
nsin
g ac
tion
to a
llow
N-1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
1 Rev
isio
n 1
Dec
embe
r 20
07
10 C
FR
50.5
4(m
)(2)
(ii)
Cond
ition
s of
lice
nses
- S
enio
r lic
ense
d op
erat
or(s
) fo
r fu
eled
un
its
Staf
fing
A Co
mpl
y
10 C
FR
50.5
4(m
)(2)
(iii)
Cond
ition
s of
lice
nses
- S
enio
r lic
ense
d op
erat
or “
in t
he c
ontr
ol
room
” an
d lic
ense
d op
erat
or “
at
the
cont
rols
”
Staf
fing
A Co
mpl
y
10 C
FR
50.5
4(m
)(2)
(iv)
Cond
ition
s of
lice
nses
- S
enio
r lic
ense
d op
erat
or p
rese
nt d
urin
g co
re a
ltera
tion
Staf
fing
A Co
mpl
y
10 C
FR 5
0.54
(p)(
1)
Cond
ition
s of
lice
nses
–
safe
guar
ds c
ontin
genc
y pl
an
chan
ge c
ontr
ol p
roce
ss
Proc
ess
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
roce
ss
Not
e 2
10 C
FR 5
0.54
(p)(
3)
Cond
ition
s of
lice
nses
– m
aint
ain
safe
guar
ds c
ontin
genc
y pl
an
Prog
ram
B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
gram
N
ote
2
10 C
FR 5
0.54
(q)
Cond
ition
s of
lice
nses
– m
aint
ain
emer
genc
y pl
an
Prog
ram
B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
gram
N
ote
2
10 C
FR 5
0.54
(t)(
1)
Cond
ition
s of
lice
nses
–
impl
emen
t EP
pro
gram
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 5
0.54
(w)(
1)
Cond
ition
s of
lice
nses
–
rest
orat
ion
of m
inim
um in
sura
nce
cove
rage
Pr
ogra
m
C Po
stpo
ne
Not
e 1
10 C
FR 5
0.54
(w)(
3)
Cond
ition
s of
lice
nses
-
insu
ranc
e co
vera
ge r
epor
t Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 5
0.54
(x)
Cond
ition
s of
lice
nses
– d
epar
ture
fr
om a
lice
nse
cond
ition
or
TS in
an
em
erge
ncy
Ope
ratio
n A
Com
ply
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
2 Rev
isio
n 1
Dec
embe
r 20
07
10 C
FR 5
0.54
(y)
Cond
ition
s of
lice
nses
– a
ppro
val
of d
epar
ture
fro
m a
lice
nse
cond
ition
or
TS in
an
emer
genc
y O
pera
tion
A Co
mpl
y
10 C
FR 5
0.54
(z)
Cond
ition
s of
lice
nses
– n
otify
N
RC
Ope
ratio
ns C
ente
r of
em
erge
ncy
even
ts (
Part
72)
Rep
ortin
g A
Com
ply
10 C
FR 5
0.54
(dd)
Co
nditi
ons
of li
cens
es –
dep
artu
re
from
a li
cens
e co
nditi
on o
r TS
in
a na
tiona
l sec
urity
em
erge
ncy
Ope
ratio
n A
Com
ply
50
.55
a –
Cod
es a
nd
stan
dard
s
10 C
FR
50.5
5a(a
)(1)
(3)
Code
s an
d st
anda
rds
– re
ques
t fo
r al
tern
ativ
es t
o ce
rtai
n pa
rts
of
10 C
FR 5
0.55
a Pr
oces
s A
Com
ply,
but
res
ched
ule
ISI,
IS
T, &
ILR
T fo
r co
mpl
etio
n no
la
ter
than
the
nex
t re
fuel
ing
outa
ge
10 C
FR
50.5
5a(b
)(2)
(viii
)(D
) Co
des
and
stan
dard
s –
ISI
sum
mar
y re
port
Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR
50.5
5a(f
)(5)
(ii)
Code
s an
d st
anda
rds
– co
nfor
man
ce o
f IS
T pr
ogra
m w
ith
TS
Prog
ram
A
Com
ply,
but
res
ched
ule
IST
for
com
plet
ion
no la
ter
than
the
ne
xt r
efue
ling
outa
ge
50
.59
– C
han
ges,
tes
ts a
nd
expe
rim
ents
10
CFR
50
.59(
c)(1
)(2)
Ch
ange
s, t
ests
and
exp
erim
ents
–
crite
ria f
or p
rior
NRC
appr
oval
O
vers
ight
A
Com
ply
10 C
FR 5
0.59
(d)(
1)
Chan
ges,
tes
ts a
nd e
xper
imen
ts
– re
cord
s
Adm
in
C Po
stpo
ne
Not
e 1
10 C
FR 5
0.59
(d)(
2)
Chan
ges,
tes
ts a
nd e
xper
imen
ts
– re
port
s
Rep
ortin
g C
Post
pone
N
ote
1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
3 Rev
isio
n 1
Dec
embe
r 20
07
50
.65
– R
equ
irem
ents
for
mon
itor
ing
the
effe
ctiv
enes
s of
mai
nte
nan
ce a
t n
ucl
ear
pow
er p
lan
ts
10 C
FR 5
0.65
(a)(
1)
Req
uire
men
ts f
or m
onito
ring
the
effe
ctiv
enes
s of
mai
nten
ance
–
mon
itor
the
perf
orm
ance
or
cond
ition
SSC
s ag
ains
t lic
ense
e-es
tabl
ishe
d go
als
Prog
ram
A
Com
ply,
but
res
ched
ule
non-
esse
ntia
l mai
nten
ance
10 C
FR 5
0.65
(a)(
3)
Ref
uelin
g cy
cle
(24-
mon
th)
eval
uatio
n of
per
form
ance
and
co
nditi
on m
onito
ring
activ
ities
an
d as
soci
ated
goa
ls.
Prog
ram
C
Post
pone
N
ote
1
50
.70
– I
nsp
ecti
ons
10 C
FR 5
0.70
(a)
Lice
nsee
mus
t pe
rmit
insp
ectio
n,
by a
utho
rized
rep
rese
ntat
ives
of
the
NRC
Ove
rsig
ht
A Co
mpl
y, b
ut r
esch
edul
e no
n-es
sent
ial i
nspe
ctio
ns
50
.71
– M
ain
ten
ance
of
reco
rds,
mak
ing
of r
epor
ts
10 C
FR 5
0.71
(a)
Mai
nten
ance
of
reco
rds,
mak
ing
of r
epor
ts –
mai
ntai
n re
cord
s an
d m
ake
repo
rts
Rec
ords
; Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 5
0.71
(e)(
4)
Mai
nten
ance
of
reco
rds,
mak
ing
of r
epor
ts –
tim
ing
of F
SAR
upda
te
Rep
ortin
g C
Post
pone
N
ote
1
50
.72
– I
mm
edia
te n
otif
icat
ion
req
uir
emen
ts f
or o
pera
tin
g n
ucl
ear
pow
er r
eact
ors
10 C
FR 5
0.72
(a)(
1)
Imm
edia
te n
otifi
catio
n re
quire
men
ts –
crit
eria
for
re
port
ing
to N
RC
Ope
ratio
ns
Cent
er
Rep
ortin
g A
Com
ply
50
.73
– L
icen
see
even
t re
port
sys
tem
10 C
FR 5
0.73
(a)(
1)
Lice
nsee
eve
nt r
epor
t sy
stem
–
crite
ria f
or L
ERS
Rep
ortin
g B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
gram
N
ote
2
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
4 Rev
isio
n 1
Dec
embe
r 20
07
50
.74
– N
otif
icat
ion
of
chan
ge in
ope
rato
r or
sen
ior
oper
ator
sta
tus
10 C
FR 5
0.74
Not
ifica
tion
of c
hang
e in
ope
rato
r or
sen
ior
oper
ator
sta
tus
– cr
iteria
for
rep
ortin
g op
erat
or
stat
us
Rep
ortin
g C
Post
pone
N
ote
1
50
.75
– R
epor
tin
g an
d re
cord
keep
ing
for
deco
mm
issi
onin
g pl
ann
ing
10 C
FR 5
0.75
(f)(
1)
Rep
ortin
g an
d re
cord
keep
ing
for
deco
mm
issi
onin
g pl
anni
ng –
tim
ing
of r
epor
ts
Rep
ortin
g C
Post
pone
N
ote
1
50
.80
– T
ran
sfer
of
licen
ses
10 C
FR 5
0.80
Tr
ansf
er o
f lic
ense
s Pr
oces
s A
Com
ply,
but
res
ched
ule
licen
se
tran
sfer
act
iviti
es
50
.90
– A
pplic
atio
n f
or a
men
dmen
t of
lice
nse
or
con
stru
ctio
n p
erm
it
10 C
FR 5
0.90
Ap
plic
atio
n fo
r am
endm
ent
of
licen
se o
r co
nstr
uctio
n pe
rmit
– cr
iteria
for
prio
r N
RC
appr
oval
Pr
oces
s A
Com
ply,
but
res
ched
ule
non-
esse
ntia
l LAR
s
50
.91
– N
otic
e fo
r pu
blic
com
men
t; S
tate
con
sult
atio
n
10 C
FR 5
0.91
N
otic
e fo
r pu
blic
com
men
t; S
tate
co
nsul
tatio
n Pr
oces
s A
Com
ply,
but
res
ched
ule
non-
esse
ntia
l LAR
s
50
.92
– I
ssu
ance
of
amen
dmen
t
10 C
FR 5
0.92
Is
suan
ce o
f am
endm
ent
Proc
ess
A Co
mpl
y, b
ut r
esch
edul
e no
n-es
sent
ial L
ARs
50
.12
0 –
Tra
inin
g an
d qu
alif
icat
ion
of
nu
clea
r po
wer
pla
nt
pers
onn
el
10 C
FR 5
0.12
0(b)
(1)
Trai
ning
and
qua
lific
atio
n –
esta
blis
h, im
plem
ent,
and
m
aint
ain
a tr
aini
ng p
rogr
am
Prog
ram
C
Post
pone
N
ote
1
10 C
FR 5
0.12
0(b)
(2)
Trai
ning
and
qua
lific
atio
n –
perio
dica
lly e
valu
ate
and
revi
se
the
trai
ning
pro
gram
Pr
ogra
m
C Po
stpo
ne
Not
e 1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
5 Rev
isio
n 1
Dec
embe
r 20
07
10
CFR
50
, App
endi
x E
– E
mer
gen
cy P
lan
nin
g an
d P
repa
redn
ess
for
Pro
duct
ion
an
d U
tiliz
atio
n F
acili
ties
10
CFR
50,
Ap
pend
ix E
.IV.
B Co
nten
t of
em
erge
ncy
plan
s;
repo
rt E
AL c
hang
es
Chan
ge
Cont
rol
C Po
stpo
ne
Not
e 1
10 C
FR 5
0,
Appe
ndix
E.I
V.D
Not
ifica
tion
proc
edur
es;
year
ly
diss
emin
atio
n of
info
rmat
ion
to
the
publ
ic
Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 5
0,
Appe
ndix
E.I
V.F
Trai
ning
; ex
erci
ses,
dril
ls, a
nd
trai
ning
Tr
aini
ng
C Po
stpo
ne
Not
e 1
10 C
FR 5
0,
Appe
ndix
E.V
Im
plem
enta
tion
proc
edur
es;
subm
it ch
ange
s w
ithin
30
days
Pr
oced
ures
C
Post
pone
N
ote
1
10 C
FR 5
0,
Appe
ndix
E.V
I Em
erge
ncy
resp
onse
dat
a sy
stem
(E
RD
S) t
estin
g Te
stin
g B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
cess
N
ote
2
10
CFR
50
, App
endi
x G
– F
ract
ure
Tou
ghn
ess
Req
uir
emen
ts
10 C
FR 5
0,
Appe
ndix
G.I
II
Frac
ture
tou
ghne
ss t
estin
g pe
r AS
ME
Code
Te
stin
g C
Post
pone
N
ote
1
10
CFR
50
, App
endi
x H
– R
eact
or V
esse
l Mat
eria
l Su
rvei
llan
ce P
rogr
am R
equ
irem
ents
10
CFR
50,
Appe
ndix
H.I
V Rep
ort
of t
est
resu
lts
Rep
ortin
g C
Post
pone
N
ote
1
10
CFR
50
, App
endi
x I
– N
um
eric
al G
uid
es f
or D
esig
n O
bjec
tive
s an
d LC
O t
o M
eet
the
Cri
teri
on A
LAR
A
10 C
FR 5
0,
Appe
ndix
I.I
V Rep
ort
rele
ase
of e
fflu
ents
to
unre
stric
ted
area
s Rep
ortin
g C
Post
pone
N
ote
1
10
CFR
50
, App
endi
x J
– P
rim
ary
Rea
ctor
Con
tain
men
t Le
akag
e Te
stin
g fo
r W
ater
-Coo
led
Pow
er R
eact
ors
10 C
FR 5
0,
Appe
ndix
J
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
roce
ss
Not
e 2
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
6 Rev
isio
n 1
Dec
embe
r 20
07
10
CFR
50
, App
endi
x R
– F
ire
Pro
tect
ion
Pro
gram
for
Nu
clea
r P
ower
Fac
iliti
es O
pera
tin
g P
rior
to
Janu
ary
1, 1
97
9
10 C
FR 5
0,
Appe
ndix
R.I
II.H
Fi
re B
rigad
e co
mpl
emen
t St
affin
g B
Alte
rnat
ive
(N-1
) N
ote
2
Par
t 5
2 -
Ear
ly S
ite
Per
mit
s; S
tand
ard
Des
ign
Cer
tifi
cati
ons;
an
d C
ombi
ned
Lic
ense
s 10
CFR
52.
1 th
roug
h 52
.113
Ap
plic
atio
ns a
nd N
RC
revi
ews
pert
aini
ng t
o ne
w p
lant
s Pr
oces
s A
Com
ply,
but
res
ched
ule
new
pl
ant
licen
sing
act
iviti
es
Par
t 5
4 –
Req
uir
emen
ts f
or R
enew
al o
f O
pera
tin
g Li
cen
ses
10 C
FR 5
4.1
thro
ugh
54.4
3 Ap
plic
atio
ns a
nd N
RC
revi
ews
pert
aini
ng t
o lic
ense
ren
ewal
Pr
oces
s A
Com
ply,
but
res
ched
ule
licen
se
rene
wal
a
ctiv
ities
Par
t 5
5 –
Ope
rato
rs’ L
icen
ses
55
.21
– M
edic
al e
xam
inat
ion
10 C
FR 5
5.21
M
edic
al e
xam
inat
ion
– m
edic
al
exam
fre
quen
cy
Prog
ram
C
Post
pone
N
ote
1
55
.25
– I
nca
paci
tati
on b
ecau
se o
f di
sabi
lity
or il
lnes
s
10 C
FR 5
5.25
Com
plem
ents
50.
74;
notif
y w
ithin
30
day
s if
oper
ator
is d
iagn
osed
w
ith a
per
man
ent
cond
ition
tha
t af
fect
s co
mpl
ianc
e w
ith 5
5.21
Prog
ram
C
Post
pone
N
ote
1
55
.53
– C
ondi
tion
s of
lice
nse
s
10 C
FR 5
5.53
(h)
Com
plet
e a
requ
alifi
catio
n pr
ogra
m a
s de
scrib
ed b
y 55
.59.
Pr
ogra
m
C Po
stpo
ne
Not
e 1
10 C
FR 5
5.53
(i)
Bien
nial
med
ical
exa
min
atio
n Pr
ogra
m
C Po
stpo
ne
Not
e 1
55
.55
- E
xpir
atio
n
10 C
FR 5
5.55
Ren
ew e
xpiri
ng li
cens
e at
leas
t 30
day
s be
fore
des
igna
ted
expi
ratio
n da
te
Prog
ram
C
Post
pone
N
ote
1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
7 Rev
isio
n 1
Dec
embe
r 20
07
55
.59
– R
equ
alif
icat
ion
10 C
FR 5
5.59
(a)(
1)
Req
ualif
icat
ion
– 24
-mon
th
requ
alifi
catio
n pr
ogra
m
Trai
ning
C
Post
pone
N
ote
1
10 C
FR 5
5.59
(a)(
2)
Req
ualif
icat
ion
- pa
ss
com
preh
ensi
ve w
ritte
n ex
am a
nd
oper
atin
g te
st.
Trai
ning
C
Post
pone
N
ote
1
10 C
FR 5
5.59
(c)(
1)
Req
ualif
icat
ion
– du
ratio
n an
d pe
riodi
city
of
requ
alifi
catio
n pr
ogra
m
Trai
ning
C
Post
pone
N
ote
1
Par
t 7
2 –
Lic
ensi
ng
Req
uir
emen
ts f
or t
he
Inde
pen
den
t St
orag
e of
Spe
nt
Nu
clea
r Fu
el, H
LW, a
nd
> C
lass
C W
aste
7
2.7
0 –
Saf
ety
anal
ysis
rep
ort
upd
atin
g
10 C
FR 7
2.70
(a)
Safe
ty a
naly
sis
repo
rt u
pdat
ing
– to
incl
ude
late
st r
equi
rem
ents
for
IS
FSI
or M
RS
Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 7
2.70
(c)(
6)
Safe
ty a
naly
sis
repo
rt u
pdat
ing
– tim
ing
for
ISFS
I or
MRS
SAR
upda
te
Rep
ortin
g C
Post
pone
N
ote
1
72
.74
– R
epor
ts o
f ac
cide
nta
l cri
tica
lity
or lo
ss o
f sp
ecia
l nu
clea
r m
ater
ial
10 C
FR 7
2.74
(a)
Rep
orts
of
acci
dent
al c
ritic
ality
or
loss
of
spec
ial n
ucle
ar m
ater
ial –
1-
hour
not
ifica
tion
of a
ccid
enta
l cr
itica
lity
or lo
ss o
f SN
M
Rep
ortin
g A
Com
ply
72
.75
– R
epor
t re
quir
emen
t fo
r sp
ecif
ic e
ven
ts a
nd
con
diti
ons
10 C
FR 7
2.75
(a)
Rep
ortin
g re
quire
men
ts f
or
spec
ific
even
ts a
nd c
ondi
tions
–
notif
y N
RC
Ope
ratio
ns C
ente
r w
ithin
1 h
our
of d
ecla
ring
an
emer
genc
y pe
r 72
.32
Rep
ortin
g A
Com
ply
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
8 Rev
isio
n 1
Dec
embe
r 20
07
72
.76
– M
ater
ial s
tatu
s re
port
s
10 C
FR 7
2.76
(a)
Mat
eria
l sta
tus
repo
rts
– re
port
s of
phy
sica
l inv
ento
ry
Rep
ortin
g C
Post
pone
N
ote
1
72
.19
2 –
Ope
rato
r tr
ain
ing
and
cert
ific
atio
n p
rogr
am
10 C
FR 7
2.19
2 O
pera
tor
trai
ning
and
cer
tific
atio
n pr
ogra
m –
tra
inin
g pr
ogra
m f
or
ISFS
I an
d M
RS p
erso
nnel
Tr
aini
ng
C Po
stpo
ne
Not
e 1
72
.24
8 –
Saf
ety
anal
ysis
rep
ort
upd
atin
g
10 C
FR 7
2.24
8(c)
(6)
Safe
ty a
naly
sis
repo
rt u
pdat
ing
– tim
ing
of C
oC F
SAR u
pdat
e Rep
ortin
g C
Post
pone
N
ote
1
Par
t 7
3 –
Ph
ysic
al P
rote
ctio
n o
f P
lan
ts a
nd
Mat
eria
ls
73
.26
– T
ran
spor
tati
on p
hys
ical
pro
tect
ion
sys
tem
s, s
ubs
yste
ms,
com
pon
ents
, an
d pr
oced
ure
s
10 C
FR 7
3.26
(d)(
1)
Tran
spor
tatio
n se
curit
y or
gani
zatio
n Pr
ogra
m
A Co
mpl
y, b
ut r
esch
edul
e tr
ansp
orta
tion
activ
ities
10 C
FR 7
3.26
(d)(
3)
Tran
spor
tatio
n m
anag
emen
t sy
stem
Pr
ogra
m
A Co
mpl
y, b
ut r
esch
edul
e tr
ansp
orta
tion
activ
ities
10 C
FR 7
3.26
(e)
Safe
guar
ds c
ontin
genc
y pl
an
Prog
ram
A
Com
ply,
but
res
ched
ule
tran
spor
tatio
n ac
tiviti
es
10 C
FR 7
3.26
(h)
Test
/mai
nten
ance
of
phys
ical
pr
otec
tion
rela
ted
devi
ces
and
equi
pmen
t Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
73
.40
– P
hys
ical
pro
tect
ion
: G
ener
al r
equ
irem
ents
at
fixe
d si
tes
10 C
FR 7
3.40
N
RC-
appr
oved
sec
urity
pla
n Pr
ogra
m
A Co
mpl
y
73
.46
– F
ixed
sit
e ph
ysic
al p
rote
ctio
n s
yste
ms,
su
bsys
tem
s, c
ompo
nen
ts, a
nd
proc
edu
res
10 C
FR 7
3.46
(b)(
1)
Se
curit
y or
gani
zatio
n, in
clud
ing
guar
ds
Staf
fing
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-1
9 Rev
isio
n 1
Dec
embe
r 20
07
10 C
FR 7
3.46
(b)(
2)
1 fu
ll-tim
e m
embe
r of
sec
urity
or
gani
zatio
n w
ith a
utho
rity
to
dire
ct a
ctiv
ities
sha
ll be
ons
ite a
t al
l tim
es
Staf
fing
A Co
mpl
y
10 C
FR 7
3.46
(b)(
4)
Tact
ical
Res
pons
e Te
am (
TRT)
–
trai
ning
; eq
uipm
ent;
ann
ual
requ
alifi
catio
n; d
ocum
enta
tion
Prog
ram
C
Post
pone
N
ote
1
10 C
FR 7
3.46
(b)(
7)
TRT
– ad
ditio
nal a
nnua
l re
qual
ifica
tion
requ
irem
ents
Tr
aini
ng
C Po
stpo
ne
Not
e 1
10 C
FR 7
3.46
(b)(
9)
TRT
& g
uard
exe
rcis
es –
eve
ry 4
m
onth
s; 1
/3 f
orce
-on-
forc
e;
annu
al e
xerc
ise
obse
rved
by
NRC;
not
ify N
RC
60 d
ays
in
adva
nce
of e
xerc
ise
Trai
ning
C
Post
pone
N
ote
1
10 C
FR 7
3.46
(b)(
10)
Cont
inui
ng p
hysi
cal f
itnes
s tr
aini
ng p
rogr
am
Trai
ning
C
Post
pone
N
ote
1
10 C
FR
73.4
6(b)
(10)
(ii)
Asse
ss f
itnes
s of
TRT,
arm
ed
resp
onde
rs, a
nd g
uard
s ev
ery
4 m
onth
s Pr
ogra
m
C Po
stpo
ne
Not
e 1
10 C
FR
73.4
6(b)
(10)
(iii)
Med
ical
exa
m w
ithin
30
days
be
fore
sta
rt o
f fit
ness
pro
gram
Pr
ogra
m
C Po
stpo
ne
Not
e 1
10 C
FR
73.4
6(b)
(11)
(i)
Fitn
ess
crite
ria;
annu
al
dem
onst
ratio
n Pr
ogra
m
C Po
stpo
ne
Not
e 1
10 C
FR
73.4
6(b)
(11)
(ii)
Tim
ing
requ
irem
ents
for
mee
ting
qual
ifica
tion
crite
ria
Prog
ram
C
Post
pone
N
ote
1
10 C
FR
73.4
6(b)
(11)
(iii)
Annu
al m
edic
al e
xam
for
TRT,
ar
med
res
pond
ers,
and
gua
rds
Prog
ram
C
Post
pone
N
ote
1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-2
0 Rev
isio
n 1
Dec
embe
r 20
07
10 C
FR
73.4
6(b)
(11)
(iv)
Rea
ssig
n TR
T, a
rmed
res
pond
ers
& g
uard
s to
oth
er jo
bs if
rem
edia
l fit
ness
tra
inin
g is
nec
essa
ry
Prog
ram
B
Alte
rnat
ive
– pe
rmit
cont
inue
d pa
rtic
ipat
ion
on T
RT
Not
e 2
10 C
FR
73.4
6(b)
(11)
(v)
Lice
nsee
may
wai
ve p
erfo
rman
ce
test
ing
(tem
pora
ry),
but
in
divi
dual
can
not
be o
n TR
T Pr
ogra
m
B Al
tern
ativ
e –
perm
it us
e on
TR
T N
ote
2
10 C
FR
73.4
6(b)
(11)
(vi)
Alar
m/p
orta
l gua
rds
exem
pt f
rom
pe
rfor
man
ce t
estin
g, p
rovi
ded
no
resp
onse
dut
ies
Prog
ram
B
Alte
rnat
ive
– ca
n be
ass
igne
d to
bac
kup
resp
onse
dut
ies
Not
e 2
10 C
FR
73.4
6(b)
(12)
(ii)
Phys
ical
per
form
ance
tes
t al
tern
ativ
e to
(b)
(10)
and
(b)
(11)
Pr
ogra
m
C Po
stpo
ne
Not
e 1
10 C
FR 7
3.46
(d)(
4)(i)
Co
ntro
l of
acce
ss (
vehi
cles
and
pe
rson
nel)
to p
rote
cted
are
a Pr
ogra
m
A Co
mpl
y
10 C
FR
73.4
6(d)
(4)(
ii)
Pat-
dow
n se
arch
es f
or c
ause
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.46
(d)(
5)
Pack
age
sear
ches
at
acce
ss
poin
ts
Prog
ram
A
Com
ply
10 C
FR 7
3.46
(d)(
6)
Prot
ecte
d ar
ea d
eliv
ery
sear
ches
Pr
ogra
m
A Co
mpl
y
10 C
FR 7
3.46
(d)(
7)
Tran
spor
tatio
n ve
hicl
e se
arch
es
Prog
ram
A
Com
ply,
but
res
ched
ule
tran
spor
tatio
n ac
tiviti
es
10 C
FR 7
3.46
(d)(
8)
Prot
ecte
d ar
ea v
ehic
le s
earc
hes
Prog
ram
A
10 C
FR 7
3.46
(d)(
9)
Cont
rol o
f ac
tive
mat
eria
l acc
ess
poin
ts;
at le
ast
2 ar
med
gua
rds
Staf
fing
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.46
(d)(
10)
2 in
divi
dual
s sc
an a
nd s
eal d
rum
s of
con
tam
inat
ed w
aste
bef
ore
exit
from
mat
eria
l acc
ess
area
St
affin
g B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
gram
N
ote
2
10 C
FR 7
3.46
(d)(
11)
2 in
divi
dual
s pa
ck a
nd s
eal
stra
tegi
c SN
M f
or s
hipm
ent
offs
ite
Staf
fing
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-2
1 Rev
isio
n 1
Dec
embe
r 20
07
10 C
FR 7
3.46
(d)(
12)
SNM
acc
ess
cont
rol
Prog
ram
A
Com
ply
10 C
FR 7
3.46
(d)(
13)
Esco
rts
in p
rote
cted
are
as
Staf
fing
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.46
(g)
Test
& m
aint
enan
ce p
rogr
am
Prog
ram
B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
gram
N
ote
2
10 C
FR 7
3.46
(g)(
3)(i)
Te
st in
trus
ion
alar
ms
at le
ast
once
eve
ry 7
day
s Te
stin
g B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
gram
N
ote
2
10 C
FR
73.4
6(g)
(3)(
ii)
Test
com
mun
icat
ions
equ
ipm
ent
at le
ast
once
per
shi
ft
Test
ing
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.46
(g)(
5)
2 tr
aine
d in
divi
dual
s re
pair
and
mai
ntai
n ph
ysic
al p
rote
ctio
n eq
uipm
ent;
not
ify s
ecur
ity
orga
niza
tion
befo
re &
aft
er
Staf
fing
A Co
mpl
y, b
ut r
esch
edul
e no
n-es
sent
ial m
aint
enan
ce
10 C
FR 7
3.46
(g)(
6)
Inde
pend
ent
annu
al r
evie
w o
f se
curit
y pr
ogra
m
Ove
rsig
ht
C Po
stpo
ne
Not
e 1
10 C
FR 7
3.46
(h)(
1)
Safe
guar
ds c
ontin
genc
y pl
an f
or
resp
ondi
ng t
o th
reat
s Pr
ogra
m
A Co
mpl
y
10 C
FR 7
3.46
(h)(
2)
Res
pons
e ar
rang
emen
ts w
ith
loca
l law
enf
orce
men
t Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.46
(h)(
3)
5-m
embe
r Ta
ctic
al R
espo
nse
Team
(TR
T), p
lus
back
up f
orce
ba
sed
on s
ite-s
peci
fic
char
acte
ristic
s
Staf
fing
B Al
tern
ativ
e (N
-1)
Not
e 2
10 C
FR 7
3.46
(h)(
7)
2 se
curit
y pe
rson
nel m
ust
asse
ss
(by
rem
ote
mea
ns)
alar
ms
in
unoc
cupi
ed m
ater
ial a
cces
s ar
eas
Staf
fing
A Co
mpl
y
10 C
FR 7
3.46
(h)(
8)
Addi
tiona
l sea
rch
requ
irem
ents
to
supp
lem
ent
(h)(
8) f
or
enca
psul
ated
SN
M
Prog
ram
B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
gram
N
ote
2
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-2
2 Rev
isio
n 1
Dec
embe
r 20
07
73
.50
– R
equ
irem
ents
for
ph
ysic
al p
rote
ctio
n o
f lic
ense
d ac
tivi
ties
10 C
FR 7
3.50
(a)(
1)
Req
uire
men
ts f
or p
hysi
cal
prot
ectio
n of
lice
nsed
act
iviti
es
Prog
ram
A
Com
ply
N/A
10 C
FR 7
3.50
(a)(
2)
1 su
perv
isor
on
site
at
all t
imes
St
affin
g A
Com
ply
N/A
10
CFR
73.
50(a
)(4)
An
nual
qua
lific
atio
n Tr
aini
ng
C D
efer
N
ote
1
10 C
FR 7
3.50
(f)
Test
/mai
nten
ance
req
uire
men
ts
Test
ing
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.50
(h)
Trai
ning
/qua
lific
atio
n pl
an
Trai
ning
C
Def
er
Not
e 1
73
.51
– R
equ
irem
ents
for
th
e ph
ysic
al p
rote
ctio
n o
f st
ored
spe
nt
nu
clea
r fu
el a
nd
hig
h-l
evel
rad
ioac
tive
was
te
10 C
FR 7
3.51
(b)(
1)
Esta
blis
h a
phys
ical
pro
tect
ion
syst
em
Prog
ram
A
Com
ply
N/A
10 C
FR 7
3.51
(b)(
2)
Acce
ss c
ontr
ol a
nd
com
mun
icat
ions
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.51
(d)(
4)
Ran
dom
pat
rols
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.51
(d)5
) Tr
aine
d se
curit
y or
gani
zatio
n to
m
onito
r de
tect
ion
syst
ems
and
cond
uct
surv
eilla
nce
Staf
fing
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.51
(d)(
9)
Sear
chin
g in
divi
dual
s, v
ehic
les,
an
d pa
ckag
es
Prog
ram
A
Com
ply
N/A
10 C
FR 7
3.51
(d)(
10)
Mai
ntai
n pr
oced
ures
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.51
(d)(
11)
Line
sup
ervi
sion
of
dete
ctio
n sy
stem
s St
affin
g B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
gram
N
ote
2
10 C
FR 7
3.51
(d)(
12)
24-m
onth
rev
iew
of
phys
ical
pr
otec
tion
prog
ram
Ad
min
C
Def
er
Not
e 1
10 C
FR 7
3.51
(d)(
13)
Doc
umen
tatio
n (a
cces
s,
scre
enin
g, p
atro
l log
s, a
larm
s,
repo
rts)
Rec
ords
C
Def
er
Not
e 1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-2
3 Rev
isio
n 1
Dec
embe
r 20
07
73
.55
– R
equ
irem
ents
for
ph
ysic
al p
rote
ctio
n o
f lic
ense
d ac
tivi
ties
in n
ucl
ear
pow
er r
eact
ors
agai
nst
rad
iolo
gica
l sab
otag
e
10 C
FR 7
3.55
(a)
Ons
ite o
rgan
izat
ion;
crit
eria
for
su
spen
sion
of
safe
guar
ds
mea
sure
s in
an
emer
genc
y Pr
ogra
m
A Co
mpl
y
10 C
FR 7
3.55
(b)(
2)
1 fu
ll-tim
e m
embe
r of
sec
urity
or
gani
zatio
n w
ith s
uper
viso
ry
auth
ority
on
site
at
all t
imes
St
affin
g A
Com
ply
10 C
FR 7
3.55
(b)(
4)(i)
An
nual
req
ualif
icat
ion
Trai
ning
C
Post
pone
N
ote
1
10 C
FR 7
3.55
(d)(
7)(i)
Ac
cess
aut
horiz
atio
n sy
stem
Pr
ogra
m
A
Com
ply
until
an
alte
rnat
ive
is
appr
oved
by
NRC
(i.e.
, a
tem
pora
ry s
trea
mlin
ed
prog
ram
)
Not
e 2
10 C
FR
73.5
5(d)
(7)(
i)(A)
Curr
ent
auth
oriz
atio
n ac
cess
list
fo
r al
l vita
l are
as;
mon
thly
up
date
s an
d qu
arte
rly a
ppro
vals
Rec
ords
B
Alte
rnat
ive
– te
mpo
rary
st
ream
lined
pro
gram
N
ote
2
10 C
FR 7
3.55
(g)
Test
and
mai
ntai
n al
arm
s,
com
mun
icat
ions
equ
ipm
ent,
ph
ysic
al b
arrie
rs, a
nd o
ther
de
vice
s
Test
ing
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.55
(g)(
2)
Test
intr
usio
n al
arm
s at
leas
t on
ce e
very
7 d
ays
Test
ing
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.55
(g)(
3)
Test
com
mun
icat
ions
equ
ipm
ent
at b
egin
ning
of
shift
(on
ce p
er
day
for
offs
ite c
omm
unic
atio
ns
equi
pmen
t)
Test
ing
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
10 C
FR 7
3.55
(g)(
4)(i)
In
depe
nden
t se
curit
y pr
ogra
m
revi
ew (
12 &
24
mon
ths)
O
vers
ight
C
Post
pone
N
ote
1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-2
4 Rev
isio
n 1
Dec
embe
r 20
07
10 C
FR 7
3.55
(h)(
3)
Nom
inal
10
guar
ds f
or r
espo
nse
requ
irem
ents
; no
less
tha
n 5
Staf
fing
A
Com
ply
until
an
alte
rnat
ive
is
appr
oved
by
NRC
(i.e
., a
tem
pora
ry s
trea
mlin
ed
)pro
gram
)
Not
e 2
73
.56
– P
erso
nn
el a
cces
s au
thor
izat
ion
req
uir
emen
ts f
or n
ucl
ear
pow
er p
lan
ts
10 C
FR 7
3.56
(b)(
1)
Mai
ntai
n ac
cess
aut
horiz
atio
n
prog
ram
Pr
ogra
m
A Co
mpl
y
10 C
FR 7
3.56
(g)(
1)
Audi
t at
leas
t ev
ery
24 m
onth
s O
vers
ight
C
Post
pone
N
ote
1
10 C
FR 7
3.56
(g)(
2)
Cont
ract
or/v
endo
r au
dits
eve
ry
12 m
onth
s O
vers
ight
C
Post
pone
N
ote
1
73
.67
– L
icen
see
fixe
d si
te a
nd
in-t
ran
sit
requ
irem
ents
for
th
e ph
ysic
al p
rote
ctio
n o
f SN
M
10 C
FR 7
3.67
(d)(
8)
At le
ast
1 w
atch
man
per
shi
ft t
o as
sess
/res
pond
to
unau
thor
ized
ac
tiviti
es in
con
trol
led
acce
ss
area
s
Staf
fing
A Co
mpl
y
10 C
FR
73.6
7(e)
(3)(
vii)
1-ho
ur n
otifi
catio
n of
lost
sh
ipm
ent
Rep
ortin
g A
Com
ply
73
.71
– R
epor
tin
g of
saf
egu
ards
eve
nts
10 C
FR 7
3.71
(a)(
1)
1-ho
ur n
otifi
catio
n of
lost
sh
ipm
ent
Rep
ortin
g A
Com
ply
10 C
FR 7
3.71
(a)(
4)
60-d
ay f
ollo
wup
rep
ort
of lo
st
ship
men
t Rep
ortin
g C
Post
pone
N
ote
1
10 C
FR 7
3.71
(a)(
5)
Supp
lem
enta
l rep
orts
as
war
rant
ed
Rep
ortin
g C
Post
pone
N
ote
1
10
CFR
73
, App
endi
x B
– G
ener
al C
rite
ria
for
Secu
rity
Per
son
nel
Appe
ndix
B
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-2
5 Rev
isio
n 1
Dec
embe
r 20
07
10
CFR
73
, App
endi
x C
– L
icen
see
Safe
guar
ds C
onti
nge
ncy
Pla
ns
Appe
ndix
C
Pr
ogra
m
B Al
tern
ativ
e –
tem
pora
ry
stre
amlin
ed p
rogr
am
Not
e 2
Par
t 7
4 –
Mat
eria
l Con
trol
an
d A
ccou
nti
ng
of S
peci
al N
ucl
ear
Mat
eria
l
10 C
FR 7
4.7
Spec
ific
exem
ptio
ns –
fro
m P
art
74
Proc
ess
A Co
mpl
y
Par
t 1
40
– F
inan
cial
Pro
tect
ion
Req
uir
emen
ts a
nd
Inde
mn
ity
Agr
eem
ents
10 C
FR 1
40.8
Sp
ecifi
c ex
empt
ions
– f
rom
Par
t 14
0 Pr
oces
s A
Com
ply
Stan
dard
Tec
hn
ical
Spe
cifi
cati
ons
– C
hap
ter
5 (
Adm
inis
trat
ive
Con
trol
s)
Tech
Spe
cs
Non
-lice
nsed
ope
rato
r as
sign
men
ts f
or f
uele
d re
acto
rs
and
at-p
ower
rea
ctor
s St
affin
g B
Alte
rnat
ive
(N-1
) N
ote
2
Tech
Spe
cs
Shift
cre
w le
ss t
han
50.5
4(m
)(2)
(i), 5
.2.2
.a, o
r 5.
2.2.
f fo
r no
mor
e th
an 2
hou
rs
Staf
fing
B Al
tern
ativ
e (N
-1)
Not
e 2
Tech
Spe
cs
Wor
k ho
ur c
ontr
ols
for
licen
sed
oper
ator
s, h
ealth
phy
sici
sts,
au
xilia
ry o
pera
tors
, and
key
m
aint
enan
ce p
erso
nnel
Staf
fing
B Al
tern
ativ
e –
tem
pora
ry
incr
ease
in w
ork
hour
lim
its
Not
e 2
Tech
Spe
cs
Advi
sory
tec
hnic
al s
uppo
rt t
o th
e sh
ift c
rew
St
affin
g B
Alte
rnat
ive
– in
crea
se n
umbe
r of
per
sonn
el a
utho
rized
to
supp
ort
the
shift
cre
w;
rem
ote
com
mun
icat
ions
Not
e 2
Tech
Spe
cs
Prog
ram
mat
ic r
equi
rem
ents
Pr
ogra
ms
C Po
stpo
ne
Not
e 1
N
EI W
hite
Pap
er
Pand
emic
Lic
ensi
ng P
lan
Tabl
e 1
Eval
uat
ion
of
Staf
fin
g R
equ
irem
ents
T1-2
6 Rev
isio
n 1
Dec
embe
r 20
07
M
isce
llan
eou
s
Co
mm
itmen
ts
Prog
ram
A
Com
ply,
but
info
rm N
RC
of
com
mitm
ents
tha
t ca
nnot
be
met
Co
rrec
tive
Actio
n Pr
ogra
m
Prog
ram
A
Impl
emen
t no
rmal
CAP
; co
rrec
tive
actio
n du
e da
tes
can
be e
xten
ded
for
defic
ienc
ies
that
are
not
saf
ety
sign
ifica
nt
N
RC
insp
ectio
ns
Prog
ram
A
As r
equi
red
by I
MC
2515
and
IM
C 25
15 A
ppen
dix
E
N
RC
mee
tings
O
vers
ight
C
As-n
eede
d N
ote
1
NRC
plan
t vi
sits
O
vers
ight
C
Post
pone
N
ote
1
Perf
orm
ance
indi
cato
rs
Ove
rsig
ht
C Po
stpo
ne
Not
e 1
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
2
M
AJO
R D
EPA
RTM
ENT
STA
FFIN
G G
UID
ELIN
ES
T2-1
Rev
isio
n 1
Dec
embe
r 20
07
Dep
artm
ent
Mul
tiple
Uni
t Si
te S
taff
ing
Sing
le U
nit
Site
Sta
ffin
g
Ope
ratio
ns
(exc
ludi
ng r
equi
red
licen
sed
pers
onne
l ad
dres
sed
abov
e)
7 (3
for
Fire
Brig
ade,
3 f
or S
afe
Shut
dow
n, 1
fo
r ou
tsid
e ro
unds
) 6
(3 f
or F
ire B
rigad
e, 2
for
Saf
e Sh
utdo
wn,
1
for
outs
ide
roun
ds)
Mai
nten
ance
17
tot
al (
3 su
perv
isor
s an
d 14
tec
hnic
ians
per
sh
ift)
11 t
otal
(3
supe
rvis
ors
and
8 te
chni
cian
s pe
r sh
ift)
Rad
iatio
n Pr
otec
tion
6 to
tal (
3 t
echn
icia
ns p
er s
hift
) 6
tota
l ( 3
tec
hnic
ians
per
shi
ft)
Chem
istr
y 8
tota
l ( a
nd 4
tec
hnic
ians
per
shi
ft)
4 to
tal (
2 te
chni
cian
s pe
r sh
ift)
Engi
neer
ing
Base
d on
nee
d an
d av
aila
bilit
y of
rem
ote
supp
ort
Base
d on
nee
d an
d av
aila
bilit
y of
rem
ote
supp
ort
Secu
rity
Safe
guar
ds I
nfor
mat
ion
Safe
guar
ds I
nfor
mat
ion
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-1
Rev
isio
n 1
Dec
embe
r 20
07
Tabl
e 3
is a
list
of
surv
eilla
nce
test
inte
rval
s th
at c
ould
com
e du
e du
ring
a pa
ndem
ic.
The
Tabl
e co
ntai
ns s
ix c
olum
ns:
C
olu
mn
C
onte
nts
1
Tech
nica
l spe
cific
atio
n nu
mbe
r1 2
Sum
mar
y de
scrip
tion
of s
urve
illan
ce r
equi
rem
ent2 ,3
3 Su
rvei
llanc
e te
st in
terv
al4 ,5
4 Rel
ief
cate
gory
6 5
Type
of
relie
f7 6
Basi
s fo
r re
lief8,
9
1 Ba
sed
on N
UREG
-143
1, R
ev. 3.
1, S
TS f
or W
estin
ghou
se P
lant
s (D
ecem
ber
1, 2
005)
. Ea
ch li
cens
ee is
exp
ecte
d to
ada
pt t
he N
EI w
hite
pap
er t
o its
pl
ant-
spec
ific
Tech
Spe
cs.
2 In
clud
es s
urve
illan
ce r
equi
rem
ents
tha
t ar
e ap
plic
able
in M
ode
1, h
ave
a re
curr
ing
freq
uenc
y, a
nd a
re a
ssoc
iate
d w
ith T
S LC
Os
that
cou
ld le
ad t
o pl
ant
shut
dow
n or
sig
nific
ant
pow
er r
educ
tion
if no
t m
et.
3 Ex
clud
ing
even
t-ba
sed
surv
eilla
nces
(e.
g., r
eact
or s
tart
up).
4
h =
hou
rs;
d =
day
s; E
FPD
= e
ffec
tive
full
pow
er d
ays.
5
Excl
udin
g ST
Is g
reat
er t
han
six
mon
ths
(184
day
s) a
nd S
TIs
defin
ed in
the
con
text
of
a pr
ogra
mm
atic
req
uire
men
t (e
.g.,
ISI,
IST
, ste
am g
ener
ator
in
spec
tion
prog
ram
, etc
.).
6 A
= m
inim
al r
elie
f; B
= p
artia
l rel
ief.
7 Co
mpl
y =
no
relie
f; x
2 =
the
STI
may
be
doub
led
durin
g a
pand
emic
. 8
Not
e 3
= N
ot r
isk
sign
ifica
nt d
urin
g a
pand
emic
(es
timat
ed 6
-wee
k du
ratio
n).
N/A
= n
ot a
pplic
able
. 9
Not
e 4
= I
f th
e su
rvei
llanc
e fa
lls d
urin
g th
e pa
ndem
ic p
erio
d, it
can
be
post
pone
d fo
r on
e su
rvei
llanc
e in
terv
al
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-2
Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f
3.1.
1.1
Verif
y SD
M t
o be
with
in t
he li
mits
spe
cifie
d in
the
CO
LR
24 h
B
x2
N
ote
3
3.1.
2.1
Verif
y m
easu
red
core
rea
ctiv
ity is
with
in ±
1%
Δk/
k of
pr
edic
ted
valu
es.
31 E
FPD
A
3.1.
4.1
Verif
y in
divi
dual
rod
pos
ition
s w
ithin
alig
nmen
t lim
it.
12 h
B
x2
N
ote
3
3.1.
4.2
Verif
y ro
d fr
eedo
m o
f m
ovem
ent
(cap
abili
ty t
o tr
ip)
by
mov
ing
each
rod
not
ful
ly in
sert
ed in
the
cor
e ≥
10
step
s in
eith
er d
irect
ion.
92
d
A
3.1.
5.1
Verif
y ea
ch s
hutd
own
bank
is w
ithin
the
inse
rtio
n lim
its
spec
ified
in t
he C
OLR
. 12
h
B x2
Not
e 3
3.1.
6.2
Verif
y ea
ch c
ontr
ol b
ank
inse
rtio
n is
with
in t
he in
sert
ion
limits
spe
cifie
d in
the
CO
LR.
12 h
B
x2
N
ote
3
3.1.
6.3
Verif
y se
quen
ce a
nd o
verla
p lim
its s
peci
fied
in t
he C
OLR
ar
e m
et f
or c
ontr
ol b
anks
not
ful
ly w
ithdr
awn
from
the
co
re.
12 h
B
x2
N
ote
3
3.2.
1.1
Verif
y m
easu
red
valu
es o
f FQ
(Z)
are
with
in li
mits
sp
ecifi
ed in
the
CO
LR.
31 E
FPD
A
3.2.
1.2
Verif
y F
^C_
XY
< F^
L_XY
. 31
EFP
D
A
3.
2.2.
1 Ve
rify
F^NΔH
is w
ithin
lim
its s
peci
fied
in t
he C
OLR
. 31
EFP
D
A
3.2.
3.1
Verif
y AF
D is
with
in li
mits
for
eac
h O
PERAB
LE e
xcor
e ch
anne
l. 7
d A
3.2.
3.2
Upd
ate
targ
et f
lux
diff
eren
ce.
31 E
FPD
A
3.2.
3.3
Det
erm
ine,
by
mea
sure
men
t, t
he t
arge
t flu
x di
ffer
ence
. 92
EFP
D
A
3.2.
4.1
Verif
y Q
PTR is
with
in li
mit
by c
alcu
latio
n.
7 d
A
3.3.
1.1
Perf
orm
CH
ANN
EL C
HEC
K.
12 h
B
x2
N
ote
3
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-3
Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f
3.3.
1.2
Com
pare
res
ults
of
calo
rimet
ric h
eat
bala
nce
calc
ulat
ion
to p
ower
ran
ge c
hann
el o
utpu
t. Ad
just
pow
er r
ange
ch
anne
l out
put
if ca
lorim
etric
hea
t ba
lanc
e ca
lcul
atio
ns
resu
lts e
xcee
d po
wer
ran
ge c
hann
el o
utpu
t by
mor
e th
an +
2% R
TP.
24 h
B
x2
N
ote
3
3.3.
1.3
Com
pare
res
ults
of
the
inco
re d
etec
tor
mea
sure
men
ts t
o N
ucle
ar I
nstr
umen
tatio
n Sy
stem
(N
IS)
AFD
. Ad
just
NIS
ch
anne
l if
abso
lute
diff
eren
ce is
≥ 3
%.
31 E
FPD
A
3.3.
1.4
Perf
orm
TAD
OT.
62 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
1.5
Perf
orm
ACT
UAT
ION
LO
GIC
TES
T.
92 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
1.6
Calib
rate
exc
ore
chan
nels
to
agre
e w
ith in
core
det
ecto
r m
easu
rem
ents
. 92
EFP
D
A
3.3.
1.9
Perf
orm
TAD
OT.
92
d
A
3.3.
2.1
Perf
orm
CH
ANN
EL C
HEC
K.
12 h
B
x2
N
ote
3
3.3.
2.2
Perf
orm
ACT
UAT
ION
LO
GIC
TES
T.
92 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
2.3
Perf
orm
ACT
UAT
ION
LO
GIC
TES
T.
31 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
2.4
Perf
orm
MAS
TER R
ELAY
TES
T.
92 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
2.6
Perf
orm
SLA
VE R
ELAY
TES
T.
92 d
A
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-4
Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f 3.
3.2.
7 Pe
rfor
m T
ADO
T.
92 d
A
3.3.
3.1
Perf
orm
CH
ANN
EL C
HEC
K fo
r ea
ch r
equi
red
inst
rum
enta
tion
chan
nel t
hat
is n
orm
ally
ene
rgiz
ed.
31 d
A
3.3.
4.1
Perf
orm
CH
ANN
EL C
HEC
K fo
r ea
ch r
equi
red
inst
rum
enta
tion
chan
nel t
hat
is n
orm
ally
ene
rgiz
ed.
31 d
A
3.3.
5.1
Perf
orm
CH
ANN
EL C
HEC
K.
12 h
B
x2
N
ote
3 3.
3.5.
2 Pe
rfor
m T
ADO
T.
31 d
A
3.3.
6.1
Perf
orm
CH
ANN
EL C
HEC
K.
12h
B x2
Not
e 3
3.3.
6.2
Perf
orm
ACT
UAT
ION
LO
GIC
TES
T.
31 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
6.3
Perf
orm
MAS
TER R
ELAY
TES
T.
31 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
6.4
Perf
orm
ACT
UAT
ION
LO
GIC
TES
T.
92 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
6.5
Perf
orm
MAS
TER R
ELAY
TES
T.
92 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
6.6
Perf
orm
CO
T.
92 d
A
3.3.
6.7
Perf
orm
SLA
VE R
ELAY
TES
T.
92 d
A
3.3.
7.1
Perf
orm
CH
ANN
EL C
HEC
K.
12 h
B
x2
N
ote
3 3.
3.7.
2 Pe
rfor
m C
OT.
92
d
A
3.3.
7.3
Perf
orm
ACT
UAT
ION
LO
GIC
TES
T.
31 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-5
Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f
3.3.
7.4
Perf
orm
MAS
TER R
ELAY
TES
T.
31 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
7.5
Perf
orm
ACT
UAT
ION
LO
GIC
TES
T.
92 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
7.6
Perf
orm
MAS
TER R
ELAY
TES
T.
92 d
on
a ST
AGG
ERED
TE
ST B
ASIS
A
3.3.
7.7
Perf
orm
SLA
VE R
ELAY
TES
T.
92 d
A
3.3.
8.1
Perf
orm
CH
ANN
EL C
HEC
K.
12 h
B
x2
N
ote
3
3.3.
8.2
Perf
orm
CO
T.
92 d
B
x2
N
ote
3
3.3.
8.3
Perf
orm
ACT
UAT
ION
LO
GIC
TES
T.
31 d
on
a ST
AGG
ERED
TE
ST B
ASIS
B
x2
N
ote
3
3.4.
1.1
Verif
y pr
essu
rizer
pre
ssur
e is
gre
ater
tha
n or
equ
al t
o th
e lim
it sp
ecifi
ed in
the
CO
LR.
12 h
A
3.4.
1.2
Verif
y RCS
ave
rage
tem
pera
ture
is le
ss t
han
or e
qual
to
the
limit
spec
ified
in t
he C
OLR
. 12
h
A
3.4.
1.3
Verif
y RCS
tot
al f
low
rat
e is
≥ [
284,
000]
gpm
and
gr
eate
r th
an o
r eq
ual t
o th
e lim
it sp
ecifi
ed in
the
CO
LR.
12 h
A
3.4.
2.1
Verif
y RCS
Tav
g in
eac
h lo
op ≥
[54
1]°F
. 12
h
A
3.
4.4.
1 Ve
rify
each
RCS
loop
is in
ope
ratio
n.
12 h
A
3.4.
9.1
Verif
y pr
essu
rizer
wat
er le
vel i
s ≤
[92
]%.
12 h
A
3.4.
11.1
Pe
rfor
m a
com
plet
e cy
cle
of e
ach
bloc
k va
lve.
92
d
B
Not
e 4
3.4.
13.1
Ve
rify
RCS
ope
ratio
nal L
EAKA
GE
is w
ithin
lim
its b
y pe
rfor
man
ce o
f RCS
wat
er in
vent
ory
bala
nce.
72
h
A
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-6
Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f
3.4.
13.2
Ve
rify
prim
ary
to s
econ
dary
LEA
KAG
E is
≤ 1
50 g
allo
ns
per
day
thro
ugh
any
one
SG.
72 h
A
3.4.
15.1
Perf
orm
CH
ANN
EL C
HEC
K of
the
req
uire
d co
ntai
nmen
t at
mos
pher
e ra
dioa
ctiv
ity m
onito
r.
12 h
B
x2
N
ote
3
3.4.
15.2
Pe
rfor
m C
OT
of t
he r
equi
red
cont
ainm
ent
atm
osph
ere
radi
oact
ivity
mon
itor.
92
d
B
Not
e 4
3.4.
16.1
Ve
rify
reac
tor
cool
ant
gros
s sp
ecifi
c ac
tivity
≤ 1
00/Ē
μC
i/gm
. 7
d B
x2
N
ote
3
3.4.
16.2
Ve
rify
reac
tor
cool
ant
DO
SE E
QU
IVAL
ENT
I-13
1 sp
ecifi
c ac
tivity
≤ 1
.0 μ
Ci/g
m.
14 d
B
x2
N
ote
3
3.4.
17.1
Ve
rify
each
RCS
loop
isol
atio
n va
lve
is o
pen
and
pow
er
is r
emov
ed f
rom
eac
h lo
op is
olat
ion
valv
e op
erat
or.
31 d
B
N
ote
4
3.5.
1.1
Verif
y ea
ch a
ccum
ulat
or is
olat
ion
valv
e is
ful
ly o
pen.
12
h
B x2
Not
e 3
3.5.
1.2
Verif
y bo
rate
d w
ater
vol
ume
in e
ach
accu
mul
ator
is ≥
[7
853
gallo
ns (
)%
and
≤ 8
171
gallo
ns (
)%
].
12 h
B
x2
N
ote
3
3.5.
1.3
Verif
y ni
trog
en c
over
pre
ssur
e in
eac
h ac
cum
ulat
or is
≥
[385
] ps
ig a
nd ≤
[48
1] p
sig.
12
h
B x2
Not
e 3
3.5.
1.4
Verif
y bo
ron
conc
entr
atio
n in
eac
h ac
cum
ulat
or is
≥
[190
0] p
pm a
nd ≤
[21
00]
ppm
. 31
d
A
3.5.
1.5
Verif
y po
wer
is r
emov
ed f
rom
eac
h ac
cum
ulat
or
isol
atio
n va
lve
oper
ator
whe
n RCS
pre
ssur
e is
≥ [
2000
] ps
ig.
31 d
A
3.5.
2.1
Verif
y th
e fo
llow
ing
valv
es a
re in
the
list
ed p
ositi
on w
ith
pow
er t
o th
e va
lve
oper
ator
rem
oved
. 12
h
B x2
Not
e 3
3.5.
2.2
Verif
y ea
ch E
CCS
man
ual,
pow
er o
pera
ted,
and
au
tom
atic
val
ve in
the
flo
w p
ath,
tha
t is
not
lock
ed,
seal
ed, o
r ot
herw
ise
secu
red
in p
ositi
on, i
s in
the
cor
rect
po
sitio
n.
31 d
A
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-7
Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f 3.
5.2.
3 Ve
rify
ECCS
pip
ing
is f
ull o
f w
ater
. 31
d
B
Not
e 4
3.5.
4.1
Verif
y RW
ST b
orat
ed w
ater
tem
pera
ture
is ≥
[35
]°F
and
≤ [
100]
°F.
24 h
B
x2
N
ote
3
3.5.
4.2
Verif
y RW
ST b
orat
ed w
ater
vol
ume
is ≥
[46
6,20
0 ga
llons
( )%
].
7 d
B x2
Not
e 3
3.5.
4.3
Verif
y RW
ST b
oron
con
cent
ratio
n is
≥ [
2000
] pp
m a
nd
≤ [
2200
] pp
m.
7 d
B x2
Not
e 3
3.5.
5.1
Verif
y m
anua
l sea
l inj
ectio
n th
rott
le v
alve
s ar
e ad
just
ed
to g
ive
a flo
w [
resi
stan
ce]
[of ≤
[40
gpm
] w
ith [
cent
rifug
al c
harg
ing
pum
p di
scha
rge
head
er]
pres
sure
≥ [
2480
] ps
ig a
nd t
he [
char
ging
flo
w]
cont
rol v
alve
ful
l ope
n or
≥ [
0.21
17]
ft/g
pm2
or w
ithin
th
e lim
it of
Fig
ure
3.5.
5-1.
]
31 d
B
x2
N
ote
3
3.5.
6.1
Verif
y BI
T bo
rate
d w
ater
tem
pera
ture
is ≥
[14
5]°F
. 24
h
B x2
Not
e 3
3.5.
6.2
Verif
y BI
T bo
rate
d w
ater
vol
ume
is ≥
[11
00]
gallo
ns.
7 d
B x2
Not
e 3
3.5.
6.3
Verif
y BI
T bo
ron
conc
entr
atio
n is
≥ [
20,0
00]
ppm
and
≤
[22,
500]
ppm
. 7
d B
x2
N
ote
3
3.6.
3.1
Verif
y ea
ch [
42]
inch
pur
ge v
alve
is s
eale
d cl
osed
, ex
cept
for
one
pur
ge v
alve
in a
pen
etra
tion
flow
pat
h w
hile
in C
ondi
tion
E of
thi
s LC
O.
31 d
B
x2
N
ote
3
3.6.
3.2
Verif
y ea
ch [
8] in
ch p
urge
val
ve is
clo
sed,
exc
ept
whe
n th
e [8
] in
ch c
onta
inm
ent
purg
e va
lves
are
ope
n fo
r pr
essu
re c
ontr
ol, A
LARA
or a
ir qu
ality
co
nsid
erat
ions
for
per
sonn
el e
ntry
, or
for
Surv
eilla
nces
th
at r
equi
re t
he v
alve
s to
be
open
.
31 d
B
x2
N
ote
3
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-8
Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f
3.6.
3.3
Verif
y ea
ch c
onta
inm
ent
isol
atio
n m
anua
l val
ve a
nd
blin
d fla
nge
that
is lo
cate
d ou
tsid
e co
ntai
nmen
t an
d no
t lo
cked
, sea
led,
or
othe
rwis
e se
cure
d an
d re
quire
d to
be
clo
sed
durin
g ac
cide
nt c
ondi
tions
is c
lose
d, e
xcep
t fo
r co
ntai
nmen
t is
olat
ion
valv
es t
hat
are
open
und
er
adm
inis
trat
ive
cont
rols
.
31 d
B
x2
N
ote
3
3.6.
3.5
Verif
y th
e is
olat
ion
time
of e
ach
auto
mat
ic p
ower
op
erat
ed c
onta
inm
ent
isol
atio
n va
lve
is w
ithin
lim
its.
92 d
B
N
ote
4
3.6.
3.6
Cycl
e ea
ch w
eigh
t or
spr
ing
load
ed c
heck
val
ve t
esta
ble
durin
g op
erat
ion
thro
ugh
one
com
plet
e cy
cle
of f
ull
trav
el, a
nd v
erify
eac
h ch
eck
valv
e re
mai
ns c
lose
d w
hen
the
diff
eren
tial p
ress
ure
in t
he d
irect
ion
of f
low
is ≤
[1
.2]
psid
and
ope
ns w
hen
the
diff
eren
tial p
ress
ure
in
the
dire
ctio
n of
flo
w is
≥ [
1.2]
psi
d an
d <
[5.
0] p
sid.
92 d
B
N
ote
4
3.6.
4.1
Verif
y co
ntai
nmen
t pr
essu
re is
with
in li
mits
. 12
h
B x2
Not
e 3
3.6.
5.1
Verif
y co
ntai
nmen
t av
erag
e ai
r te
mpe
ratu
re is
with
in
limit.
24
h
B x2
Not
e 3
3.6.
6.1
Verif
y ea
ch c
onta
inm
ent
spra
y m
anua
l, po
wer
ope
rate
d,
and
auto
mat
ic v
alve
in t
he f
low
pat
h th
at is
not
lock
ed,
seal
ed, o
r ot
herw
ise
secu
red
in
posi
tion
is in
the
cor
rect
pos
ition
.
31 d
A
3.6.
6.2
Ope
rate
eac
h [r
equi
red]
con
tain
men
t co
olin
g tr
ain
fan
unit
for ≥
15
min
utes
. 31
d
B x2
Not
e 3
3.6.
6.3
Verif
y ea
ch [
requ
ired]
con
tain
men
t co
olin
g tr
ain
cool
ing
wat
er f
low
rat
e is
≥ [
700]
gpm
. 31
d
B x2
Not
e 3
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-9
Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f
3.6.
7.1
Verif
y ea
ch s
pray
add
itive
man
ual,
pow
er o
pera
ted,
and
au
tom
atic
val
ve in
the
flo
w p
ath
that
is n
ot lo
cked
, se
aled
, or
othe
rwis
e se
cure
d in
pos
ition
is in
the
cor
rect
po
sitio
n.
31d
B x2
Not
e 3
3.6.
8.1
Verif
y an
nulu
s ne
gativ
e pr
essu
re is
> [
5] in
ches
wat
er
gaug
e.
12 h
B
x2
N
ote
3
3.6.
8.2
Verif
y on
e sh
ield
bui
ldin
g ac
cess
doo
r in
eac
h ac
cess
op
enin
g is
clo
sed.
31
d
B x2
Not
e 3
3.6.
9.1
Ope
rate
eac
h H
MS
trai
n fo
r ≥
15
min
utes
. 92
d
B
Not
e 4
3.6.
10.1
En
ergi
ze e
ach
HIS
tra
in p
ower
sup
ply
brea
ker
and
verif
y ≥
[32
] ig
nite
rs a
re e
nerg
ized
in e
ach
trai
n.
92 d
A
3.6.
10.2
Verif
y at
leas
t on
e hy
drog
en ig
nite
r is
OPE
RAB
LE in
eac
h co
ntai
nmen
t re
gion
.
92 d
A
3.6.
11.1
Ope
rate
eac
h IC
S tr
ain
for
[≥ 1
0 co
ntin
uous
hou
rs w
ith
heat
ers
oper
atin
g or
(fo
r sy
stem
s w
ithou
t he
ater
s) ≥
15
min
utes
].
31 d
B
x2
N
ote
3
3.6.
13.1
Ope
rate
eac
h SB
ACS
trai
n fo
r [≥
10
cont
inuo
us h
ours
w
ith h
eate
rs o
pera
ting
or (
for
syst
ems
with
out
heat
ers)
≥
15
min
utes
].
31 d
B
x2
N
ote
3
3.6.
14.1
Verif
y ea
ch A
RS
fan
star
ts o
n an
act
ual o
r si
mul
ated
ac
tuat
ion
sign
al, a
fter
a d
elay
of ≥
[9.
0] m
inut
es a
nd ≤
[1
1.0]
min
utes
, and
ope
rate
s fo
r ≥
15
min
utes
. 92
d
B
Not
e 4
3.6.
14.2
Verif
y, w
ith t
he A
RS
fan
dam
pers
clo
sed,
eac
h AR
S fa
n m
otor
cur
rent
is ≥
[20
.5]
amps
and
≤ [
35.5
] am
ps
[whe
n th
e fa
n sp
eed
is ≥
[84
0] r
pm a
nd ≤
[90
0] r
pm].
92
d
B
Not
e 4
3.6.
14.3
Verif
y, w
ith t
he A
RS
fan
not
oper
atin
g, e
ach
ARS
fan
dam
per
open
s w
hen ≤
[11
.0]
lb is
app
lied
to t
he
coun
terw
eigh
t.
92 d
B
N
ote
4
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-1
0 Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f
3.6.
14.4
Verif
y ea
ch m
otor
ope
rate
d va
lve
in t
he h
ydro
gen
colle
ctio
n he
ader
tha
t is
not
lock
ed, s
eale
d, o
r ot
herw
ise
secu
red
in p
ositi
on, o
pens
on
an a
ctua
l or
sim
ulat
ed
actu
atio
n si
gnal
aft
er a
del
ay o
f ≥
[9.
0] m
inut
es a
nd ≤
[1
1.0]
min
utes
.
92 d
A
3.6.
15.1
Ve
rify
max
imum
ice
bed
tem
pera
ture
is ≤
[27
]°F.
12
h
B x2
Not
e 3
3.6.
16.1
Ve
rify
all i
nlet
doo
rs in
dica
te c
lose
d by
the
Inl
et D
oor
Posi
tion
Mon
itorin
g Sy
stem
. 12
h
B x2
Not
e 3
3.6.
16.2
Ve
rify,
by
visu
al in
spec
tion,
eac
h in
term
edia
te d
eck
door
is
clo
sed
and
not
impa
ired
by ic
e, f
rost
, or
debr
is.
7 d
B x2
Not
e 3
3.6.
16.7
Verif
y, b
y vi
sual
insp
ectio
n, e
ach
top
deck
[do
or]:
a. I
s in
pla
ce;
and
b. H
as n
o co
nden
satio
n, f
rost
, or
ice
form
ed o
n th
e [d
oor]
tha
t w
ould
res
tric
t its
ope
ning
.
92 d
B
N
ote
4
3.6.
18.1
Verif
y, b
y vi
sual
insp
ectio
n, t
hat:
a. E
ach
refu
elin
g ca
nal
drai
n pl
ug is
rem
oved
, b. E
ach
refu
elin
g ca
nal d
rain
is
not
obst
ruct
ed b
y de
bris
, and
c. N
o de
bris
is p
rese
nt in
th
e up
per
com
part
men
t or
ref
uelin
g ca
nal t
hat
coul
d ob
stru
ct t
he r
efue
ling
cana
l dra
in.
92 d
B
N
ote
4
3.7.
5.1
Verif
y ea
ch A
FW m
anua
l, po
wer
ope
rate
d, a
nd
auto
mat
ic v
alve
in e
ach
wat
er f
low
pat
h, [
and
in b
oth
stea
m s
uppl
y flo
w p
aths
to
the
stea
m t
urbi
ne d
riven
pu
mp,
] th
at is
not
lock
ed, s
eale
d, o
r ot
herw
ise
secu
red
in p
ositi
on, i
s in
the
cor
rect
pos
ition
.
31 d
B
x2
N
ote
3
3.7.
6.1
Verif
y th
e CS
T le
vel i
s ≥
[11
0,00
0 ga
l].
12 h
B
x2
N
ote
3
3.7.
7.1
Verif
y ea
ch C
CW m
anua
l, po
wer
ope
rate
d, a
nd
auto
mat
ic v
alve
in t
he f
low
pat
h se
rvic
ing
safe
ty r
elat
ed
equi
pmen
t, t
hat
is n
ot lo
cked
, sea
led,
or
31 d
B
x2
N
ote
3
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-1
1 Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f ot
herw
ise
secu
red
in p
ositi
on, i
s in
the
cor
rect
pos
ition
.
3.7.
8.1
Verif
y ea
ch S
WS
man
ual,
pow
er o
pera
ted,
and
au
tom
atic
val
ve in
the
flo
w p
ath
serv
icin
g sa
fety
rel
ated
eq
uipm
ent,
tha
t is
not
lock
ed, s
eale
d, o
r ot
herw
ise
secu
red
in p
ositi
on, i
s in
the
cor
rect
pos
ition
.
31 d
B
x2
N
ote
3
3.7.
9.1
Verif
y w
ater
leve
l of
UH
S is
≥ [
562]
ft
[mea
n se
a le
vel].
24
h
B x2
Not
e 3
3.7.
9.2
Verif
y av
erag
e w
ater
tem
pera
ture
of
UH
S is
≤ [
90]°
F.
24 h
B
x2
N
ote
3
3.7.
9.3
Ope
rate
eac
h co
olin
g to
wer
fan
for
≥ [
15]
min
utes
. 31
d
B x2
Not
e 3
3.7.
12.1
Ope
rate
eac
h EC
CS P
REA
CS t
rain
for
[≥
10
cont
inuo
us
hour
s w
ith t
he h
eate
rs o
pera
ting
or (
for
syst
ems
with
out
heat
ers)
≥ 1
5 m
inut
es].
31
d
B x2
Not
e 3
3.7.
14.1
Ope
rate
eac
h PR
EACS
tra
in f
or [≥
10
cont
inuo
us h
ours
w
ith h
eate
rs o
pera
ting
or (
for
syst
ems
with
out
heat
ers)
≥
15
min
utes
].
31 d
B
x2
N
ote
3
3.7.
18.1
Ve
rify
the
spec
ific
activ
ity o
f th
e se
cond
ary
cool
ant
is ≤
[0
.10]
μCi
/gm
DO
SE E
QU
IVAL
ENT
I-13
1.
31 d
B
x2
N
ote
3
3.8.
1.1
Verif
y co
rrec
t br
eake
r al
ignm
ent
and
indi
cate
d po
wer
av
aila
bilit
y fo
r ea
ch [
requ
ired]
off
site
circ
uit.
7
d A
3.8.
1.2
Verif
y ea
ch D
G s
tart
s fr
om s
tand
by c
ondi
tions
and
ac
hiev
es s
tead
y st
ate
volta
ge ≥
[37
40]
V an
d ≤
[45
80]
V, a
nd f
requ
ency
≥ [
58.8
] H
z an
d ≤
[61
.2]
Hz.
31 d
B
x2
N
ote
3
3.8.
1.3
Verif
y ea
ch D
G is
syn
chro
nize
d an
d lo
aded
and
ope
rate
s fo
r ≥
60
min
utes
at
a lo
ad ≥
[45
00]
kW a
nd ≤
[50
00]
kW.
31 d
B
x2
N
ote
3
3.8.
1.4
Verif
y ea
ch d
ay t
ank
[and
eng
ine
mou
nted
tan
k]
31 d
B
x2
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-1
2 Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f co
ntai
ns ≥
[22
0] g
al o
f fu
el o
il.
Not
e 3
3.8.
1.5
Chec
k fo
r an
d re
mov
e ac
cum
ulat
ed w
ater
fro
m e
ach
day
tank
[an
d en
gine
-mou
nted
tan
k].
31 d
B
x2
N
ote
3
3.8.
1.6
Verif
y th
e fu
el o
il tr
ansf
er s
yste
m o
pera
tes
to
[aut
omat
ical
ly]
tran
sfer
fue
l oil
from
sto
rage
tan
k[s]
to
the
day
tank
[an
d en
gine
-mou
nted
tan
k].
92 d
A
3.8.
3.1
Verif
y ea
ch f
uel o
il st
orag
e ta
nk c
onta
ins ≥
[33
,000
] ga
l of
fue
l. 31
d
B x2
Not
e 3
3.8.
3.2
Verif
y lu
bric
atin
g oi
l inv
ento
ry is
≥ [
500]
gal
. 31
d
B x2
Not
e 3
3.8.
3.4
Verif
y ea
ch D
G a
ir st
art
rece
iver
pre
ssur
e is
≥ [
225]
ps
ig.
31 d
A
3.8.
3.5
Chec
k fo
r an
d re
mov
e ac
cum
ulat
ed w
ater
fro
m e
ach
fuel
oil
stor
age
tank
. 31
d
B x2
Not
e 3
3.8.
4.1
Verif
y ba
tter
y te
rmin
al v
olta
ge is
gre
ater
tha
n or
equ
al
to t
he m
inim
um e
stab
lishe
d flo
at v
olta
ge.
7 d
B x2
Not
e 3
3.8.
6.1
Verif
y ea
ch b
atte
ry f
loat
cur
rent
is ≤
[2]
am
ps.
7 d
B x2
Not
e 3
3.8.
6.2
Verif
y ea
ch b
atte
ry p
ilot
cell
volta
ge is
≥ [
2.07
] V.
31
d
B x2
Not
e 3
3.8.
6.3
Verif
y ea
ch b
atte
ry c
onne
cted
cel
l ele
ctro
lyte
leve
l is
grea
ter
than
or
equa
l to
min
imum
est
ablis
hed
desi
gn
limits
. 31
d
B x2
Not
e 3
3.8.
6.4
Verif
y ea
ch b
atte
ry p
ilot
cell
tem
pera
ture
is g
reat
er t
han
or e
qual
to
min
imum
est
ablis
hed
desi
gn li
mits
. 31
d
B x2
Not
e 3
3.8.
6.5
Verif
y ea
ch b
atte
ry c
onne
cted
cel
l vol
tage
is ≥
[2.
07]
V.
92 d
B
x2
N
ote
3
3.8.
7.1
Verif
y co
rrec
t in
vert
er v
olta
ge, [
freq
uenc
y], a
nd
alig
nmen
t to
req
uire
d AC
vita
l bus
es.
7 d
A
NEI
Whi
te P
aper
Pa
ndem
ic L
icen
sing
Pla
n Ta
ble
3
EV
ALU
ATI
ON
OF
TS S
UR
VEI
LLA
NC
E TE
ST I
NTE
RV
ALS
(ST
Is)
T3-1
3 Rev
isio
n 1
Dec
embe
r 20
07
TS #
D
escr
ipti
on
STI
Rel
ief
Cat
egor
y Ty
pe o
f R
elie
f
Bas
is f
or R
elie
f 3.
8.9.
1 Ve
rify
corr
ect
inve
rter
vol
tage
, [fr
eque
ncy,
] an
d al
ignm
ent
to r
equi
red
AC v
ital b
uses
. 7
d A
NEI White Paper Pandemic Licensing Plan
Revision 1
December 2007
APPENDIX A
Excerpts from 10 CFR and Technical Specifications
NEI White Paper Pandemic Licensing Plan
A-1 Revision 1
December 2007
Summary of Regulatory Requirements Containing Explicit or Implicit Staffing Requirements
PART 19 – NOTICES, INSTRUCTIONS, AND REPORTS TO WORKERS
§ 19.11 Posting of notices to workers.
(a) Each licensee shall post current copies of the following documents: [see the regulation for details]
(e) Commission documents posted pursuant to paragraph (a)(4) of this section shall be posted within 2 working days after receipt of the documents from the Commission; the licensee's response, if any, shall be posted within 2 working days after dispatch by the licensee. Such documents shall remain posted for a minimum of 5 working days or until action correcting the violation has been completed, whichever is later.
§ 19.12 Instruction to workers.
(a) All individuals who in the course of employment are likely to receive in a year an occupational dose in excess of 100 mrem (1 mSv) shall be [see the regulation for details].
§ 19.13 Notifications and reports to individuals.
(a) Radiation exposure data for an individual, and the results of any measurements, analyses, and calculations of radioactive material deposited or retained in the body of an individual, shall be reported to the individual as specified in this section.
§ 19.31 Application for exemptions.
The Commission may upon application by any licensee or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not result in undue hazard to life or property.
PART 20 – STANDARDS FOR PROTECTION AGAINST RADIATION
§ 20.1101 Radiation protection programs.
(a) Each licensee shall develop, document, and implement a radiation protection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions of this part. [See § 20.2102 for recordkeeping requirements relating to these programs.]
(c) The licensee shall periodically (at least annually) review the radiation protection program content and implementation.
NEI White Paper Pandemic Licensing Plan
A-2 Revision 1
December 2007
§ 20.2102 Records of radiation protection programs.
(a) Each licensee shall maintain records of the radiation protection program, including: (1) The provisions of the program; and (2) Audits and other reviews of program content and implementation.
§ 20.2103 Records of surveys.
(a) Each licensee shall maintain records showing the results of surveys and calibrations required by §§ 20.1501 and 20.1906(b). The licensee shall retain these records for 3 years after the record is made.
(b) The licensee shall retain each of the following records until the Commission terminates each pertinent license requiring the record: ...
§ 20.2104 Determination of prior occupational dose.
(a) For each individual who is likely to receive in a year, an occupational dose requiring monitoring pursuant to § 20.1502 the licensee shall-- (1) Determine the occupational radiation dose received during the current year; and ... (b) Prior to permitting an individual to participate in a planned special exposure, the licensee shall determine-- (1) The internal and external doses from all previous planned special exposures; and (2) All doses in excess of the limits (including doses received during accidents and emergencies) received during the lifetime of the individual. (e) If the licensee is unable to obtain a complete record of an individual's current and previously accumulated occupational dose, the licensee shall assume-- (1) In establishing administrative controls under § 20.1201(f) for the current year, that the allowable dose limit for the individual is reduced by 1.25 rem(12.5 mSv) for each quarter for which records were unavailable and the individual was engaged in activities that could have resulted in occupational radiation exposure; and (2) That the individual is not available for planned special exposures.
§ 20.2105 Records of planned special exposures.
(a) For each use of the provisions of § 20.1206 for planned special exposures, the licensee shall maintain records that describe-- ...
§ 20.2106 Records of individual monitoring results.
(a) Recordkeeping requirement. Each licensee shall maintain records of doses received by all individuals for whom monitoring was required pursuant to § 20.1502, and records of doses received during planned special exposures, accidents, and emergency conditions. These records5 must include, when applicable-- ...
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§ 20.2107 Records of dose to individual members of the public.
(a) Each licensee shall maintain records sufficient to demonstrate compliance with the dose limit for individual members of the public (see § 20.1301).
§ 20.2108 Records of waste disposal
(a) Each licensee shall maintain records of the disposal of licensed materials made under §§ 20.2002, 20.2003, 20.2004, 20.2005, 10 CFR part 61 and disposal by burial in soil, including burials authorized before January 28, 1981.
§ 20.2201 Reports of theft or loss of licensed material.
(a) Telephone reports. (1) Each licensee shall report by telephone as follows:
(b) Written reports. (1) Each licensee required to make a report under paragraph (a) of this section shall, within 30 days after making the telephone report, make a written report setting forth the following information:
§ 20.2202 Notification of incidents.
(a) Immediate notification. Notwithstanding any other requirements for notification, each licensee shall immediately report any event involving byproduct, source, or special nuclear material possessed by the licensee that may have caused or threatens to cause any of the following conditions-- ...
§ 20.2203 Reports of exposures, radiation levels, and concentrations of radioactive material exceeding the constraints or limits.
(a) Reportable events. In addition to the notification required by § 20.2202, each licensee shall submit a written report within 30 days after learning of any of the following occurrences: ...
§ 20.2204 Reports of planned special exposures.
The licensee shall submit a written report to the Administrator of the appropriate NRC Regional Office listed in appendix D to part 20 within 30 days following any planned special exposure conducted in accordance with § 20.1206, informing the Commission that a planned special exposure was conducted and indicating the date the planned special exposure occurred and the information required by § 20.2105.
§ 20.2205 Reports to individuals of exceeding dose limits.
When a licensee is required, pursuant to the provisions of §§ 20.2203, 20.2204, or 20.2206, to report to the Commission any exposure of an identified occupationally exposed individual, or an identified member of the public, to radiation or radioactive material, the licensee shall also provide a copy of the report submitted to the Commission to the individual. This report must be transmitted at a time no later than the transmittal to the Commission.
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§ 20.2206 Reports of individual monitoring.
(a) This section applies to each person licensed by the Commission to-- ... (b) Each licensee in a category listed in paragraph (a) of this section shall submit an annual report of the results of individual monitoring carried out by the licensee for each individual for whom monitoring was required by § 20.1502 during that year. The licensee may include additional data for individuals for whom monitoring was provided but not required. The licensee shall use Form NRC 5 or electronic media containing all the information required by Form NRC 5. (c) The licensee shall file the report required by § 20.2206(b), covering the preceding year, on or before April 30 of each year. The licensee shall submit the report to the REIRS Project Manager by an appropriate method listed in § 20.1007 or via the REIRS Web site at http://www.reirs.com.
§ 20.2207 Reports of transactions involving nationally tracked sources.
Each licensee who manufactures, transfers, receives, disassembles, or disposes of a nationally tracked source shall complete and submit a National Source Tracking Transaction Report as specified in paragraphs (a) through (e) of this section for each type of transaction.
PART 21 – REPORTING OF DEFECTS AND NONCOMPLIANCES
§ 21.7 Exemptions.
The Commission may, upon application of any interested person or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. Suppliers of commercial grade items are exempt from the provisions of this part to the extent that they supply commercial grade items.
§ 21.21 Notification of failure to comply or existence of a defect and its evaluation.
(a) Each individual, corporation, partnership, dedicating entity, or other entity subject to the regulations in this part shall adopt appropriate procedures to [see the regulation for details].
§ 21.51 Maintenance and inspection of records.
(a) Each individual, corporation, partnership, dedicating entity, or other entity subject to the regulations in this part shall prepare and maintain records necessary to accomplish the purposes of this part, specifically [see the regulation for details].
PART 25 – ACCESS AUTHORIZATION FOR LICENSEE PERSONNEL
§ 25.11 Specific exemptions.
The NRC may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part.
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§ 25.13 Maintenance of records.
(a) Each licensee or organization employing individuals approved for personnel security access authorization under this part, shall maintain records as prescribed within the part. These records are subject to review and inspection by CSA representatives during security reviews.
§ 25.21 Determination of initial and continued eligibility for access authorization.
(b) The CSA must be promptly notified of developments that bear on continued eligibility for access authorization throughout the period for which the authorization is active.
§ 25.23 Notification of grant of access authorization.
The determination to grant or renew access authorization will be furnished in writing to the licensee or organization that initiated the request. Upon receipt of the notification of original grant of access authorization, the licensee or organization shall obtain, as a condition for grant of access authorization and access to classified information, an executed "Classified Information Nondisclosure Agreement" (SF-312) from the affected individual.
§ 25.25 Cancellation of requests for access authorization.
When a request for an individual's access authorization or renewal of an access authorization is withdrawn or canceled, the requestor shall notify the CSA immediately by telephone.
§ 25.31 Extensions and transfers of access authorizations.
(c) Requests for an extension or transfer of an access authorization.
§ 25.33 Termination of access authorizations.
(b) A representative of the licensee or other organization that employs the individual whose access authorization will be terminated shall immediately notify the CSA.
(c) When an access authorization is to be terminated, a representative of the licensee or other organization shall conduct a security termination briefing of the individual involved.
PART 26 – FITNESS FOR DUTY PROGRAMS
§ 26.20 Written policy and procedures.
Each licensee subject to this part shall establish and implement written policies and procedures.
§ 26.21 Policy communications and awareness training.
(a) Persons assigned to activities within the scope of this part shall be provided with appropriate training.
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(b) Initial training must be completed prior to assignment to activities within the scope of this part. Refresher training must be completed on a nominal 12-month frequency, or more frequently, where the need is indicated.
§ 26.22 Training of supervisors and escorts.
(c) Initial training must be completed prior to assignment of duties within the scope of this part and within 3 months after initial supervisory assignment, as applicable.
§ 26.23 Contractors and vendors.
(b) Each licensee subject to this part shall assure that contractors whose own fitness-for-duty programs are relied on by the licensee adhere to an effective program, which meets the requirements of this part, and shall conduct audits pursuant to § 26.80 for this purpose.
§ 26.24 Chemical and alcohol testing.
(a) To provide a means to deter and detect substance abuse, the licensee shall implement the following chemical testing programs [see the regulation for details].
§ 26.25 Employee assistance programs (EAP).
Each licensee subject to this part shall maintain an employee assistance program.
§ 26.27 Management actions and sanctions to be imposed.
(a)(1) The licensee shall obtain a written statement from the individual as to whether activities within the scope of this part were ever denied the individual.
§ 26.29 Protection of information.
(a) Each licensee subject to this part, who collects personal information on an individual for the purpose of complying with this part, shall establish and maintain a system of files and procedures for the protection of the personal information.
§ 26.71 Recordkeeping requirements.
Each licensee subject to this part and each contractor and vendor implementing a licensee approved program under the provisions of § 26.23 shall [see the regulation for details].
§ 26.73 Reporting requirements.
(a) Each licensee subject to this part shall inform the Commission of significant fitness-for-duty events.
§ 26.80 Audits.
(a) Each licensee subject to this part shall audit the fitness-for-duty program nominally every 12 months.
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(c) The result of the audit, along with recommendations, if any, must be documented and reported to senior corporate and site management.
PART 50 – DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES
§ 50.9 Completeness and accuracy of information.
(b) Each applicant or licensee shall notify the Commission of information identified by the applicant or licensee as having for the regulated activity a significant implication for public health and safety or common defense and security.
§ 50.30 Filing of application for licenses; oath or affirmation.
(b) Oath or affirmation. Each application for a license, including whenever appropriate a construction permit, or amendment of it, and each amendment of each application must be executed in a signed original by the applicant or duly authorized officer thereof under oath or affirmation.
§ 50.46 Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors.
(3)(i) Each applicant for or holder of an operating license or construction permit shall estimate the effect of any change to or error in an acceptable evaluation model or in the application of such a model to determine if the change or error is significant.
(ii) For each change to or error discovered in an acceptable evaluation model or in the application of such a model that affects the temperature calculation, the applicant or licensee shall report the nature of the change or error and its estimated effect on the limiting ECCS analysis to the Commission at least annually as specified in § 50.4. If the change or error is significant, the applicant or licensee shall provide this report within 30 days and include with the report a proposed schedule for providing a reanalysis or taking other action as may be needed to show compliance with § 50.46 requirements.
§ 50.47 Emergency plans.
(b) The onsite and, except as provided in paragraph (d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards: [see the regulation for details].
§ 50.48 Fire protection.
(a)(1) Each operating nuclear power plant must have a fire protection plan that satisfies Criterion 3 of appendix A to this part.
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§ 50.49 Environmental qualification of electric equipment important to safety for nuclear power plants.
(a) Each holder of or an applicant for a license for a nuclear power plant, other than a nuclear power plant for which the certifications required under § 50.82(a)(1) have been submitted, shall establish a program for qualifying the electric equipment defined [see the regulation for details].
§ 50.54 Conditions of licenses.
(m)(1) A senior operator licensed pursuant to part 55 of this chapter shall be present at the facility or readily available on call at all times during its operation, and shall be present at the facility during initial start-up and approach to power, recovery from an unplanned or unscheduled shut-down or significant reduction in power, and refueling, or as otherwise prescribed in the facility license.
(m)(2)(i) Each licensee shall meet the minimum licensed operator staffing requirements in the following table: [see the regulation for details].
(m)(2)(ii) Each licensee shall have at its site a person holding a senior operator license for all fueled units at the site who is assigned responsibility for overall plant operation at all times there is fuel in any unit.
(m)(2)(iii) When a nuclear power unit is in an operational mode other than cold shutdown or refueling, as defined by the unit's technical specifications, each licensee shall have a person holding a senior operator license for the nuclear power unit in the control room at all times. In addition to this senior operator, for each fueled nuclear power unit, a licensed operator or senior operator shall be present at the controls at all times.
(m)(2)(iv) Each licensee shall have present, during alteration of the core of a nuclear power unit (including fuel loading or transfer), a person holding a senior operator license or a senior operator license limited to fuel handling to directly supervise the activity and, during this time, the licensee shall not assign other duties to this person.
(p)(1) The licensee shall prepare and maintain safeguards contingency plan procedures in accordance with appendix C of part 73 of this chapter for effecting the actions and decisions contained in the Responsibility Matrix of the safeguards contingency plan. The licensee may make no change which would decrease the effectiveness of a security plan, or guard training and qualification plan.
(p)(3) The licensee shall provide for the development, revision, implementation, and maintenance of its safeguards contingency plan.
(q) A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans.
(t)(1) The licensee shall provide for the development, revision, implementation, and maintenance of its emergency preparedness program.
(w)(1) If a licensee's [insurance] coverage falls below the required minimum, the licensee shall within 60 days take all reasonable steps to restore its coverage to the required minimum.
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(w)(3) The licensee shall report to the NRC on April 1 of each year the current levels of this insurance or financial security it maintains and the sources of this insurance or financial security.
(x) A licensee may take reasonable action that departs from a license condition or a technical specification (contained in a license issued under this part) in an emergency when this action is immediately needed to protect the public health and safety and no action consistent with license conditions and technical specifications that can provide adequate or equivalent protection is immediately apparent.
(y) Licensee action permitted by paragraph (x) of this section shall be approved, as a minimum, by a licensed senior operator, or, at a nuclear power reactor facility for which the certifications required under § 50.82(a)(1) have been submitted, by either a licensed senior operator or a certified fuel handler, prior to taking the action.
(z) Each licensee with a utilization facility licensed pursuant to sections 103 or 104b of the Act shall immediately notify the NRC Operations Center of the occurrence of any event specified in § 50.72 of this part.
(dd) A licensee may take reasonable action that departs from a license condition or a technical specification (contained in a license issued under this part) in a national security emergency:
§ 50.55a Codes and standards.
(a)(1)(3) Proposed alternatives to the requirements of paragraphs (c), (d), (e), (f), (g), and (h) of this section or portions thereof may be used when authorized by the Director of the Office of Nuclear Reactor Regulation. The applicant shall demonstrate that: [see the regulation for details].
(b)(2)(viii)(D) The licensee shall report the following conditions, if they occur, in the ISI Summary Report required by IWA-6000.
(f)(5)(ii) If a revised inservice test program for a facility conflicts with the technical specification for the facility, the licensee shall apply to the Commission for amendment of the technical specifications to conform the technical specification to the revised program. The licensee shall submit this application, as specified in § 50.4, at least 6 months before the start of the period during which the provisions become applicable, as determined by paragraph (f)(4) of this section.
§ 50.59 Changes, tests and experiments.
(c)(1)(2) A licensee shall obtain a license amendment pursuant to Sec. 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would: [see the regulation for details].
(d)(1) The licensee shall maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant to paragraph (c) of this section.
(d)(2) The licensee shall submit, as specified in Sec. 50.4, a report containing a brief description of any changes, tests, and experiments, including a summary of the evaluation of each. A report must be submitted at intervals not to exceed 24 months.
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§ 50.65 Requirements for monitoring the effectiveness of maintenance at nuclear power plants.
(a)(1) Each holder of a license to operate a nuclear power plant under Secs. 50.21(b) or 50.22 shall monitor the performance or condition of structures, systems, or components, against licensee-established goals.
(a)(3) Performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle. interval
§ 50.70 Inspections.
(a) Each licensee and each holder of a construction permit shall permit inspection, by duly authorized representatives of the Commission.
§ 50.71 Maintenance of records, making of reports.
(a) Each licensee and each holder of a construction permit shall maintain all records and make all reports.
(e) Each person licensed to operate a nuclear power reactor pursuant to the provisions of § 50.21 or § 50.22 of this part shall update periodically, as provided in paragraphs (e)(3) and (4) of this section, the final safety analysis report (FSAR).
(e)(4) Subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months.
§ 50.72 Immediate notification requirements for operating nuclear power reactors.
(a)(1) Each nuclear power reactor licensee licensed under Sec. 50.21(b) or Sec. 50.22 of this part shall notify the NRC Operations Center via the Emergency Notification System of: [see the regulation for details].
§ 50.73 Licensee event report system.
(a)(1) The holder of an operating license for a nuclear power plant (licensee) shall submit a Licensee Event Report (LER) for any event of the type described in this paragraph within 60 days after the discovery of the event.
§ 50.74 Notification of change in operator or senior operator status.
Each licensee shall notify the appropriate Regional Administrator as listed in appendix D to part 20 of this chapter within 30 days of the following in regard to a licensed operator or senior operator: [see the regulation for details].
§ 50.75 Reporting and recordkeeping for decommissioning planning.
(f)(1) Each power reactor licensee shall report, on a calendar-year basis, to the NRC by March 31, 1999, and at least once every 2 years thereafter on the status of its decommissioning funding.
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§ 50.90 Application for amendment of license or construction permit.
Whenever a holder of a license or construction permit desires to amend the license or permit, application for an amendment must be filed with the Commission.
§ 50.120 Training and qualification of nuclear power plant personnel.
(b)(1) Each nuclear power plant applicant, by November 22, 1993 or 18 months prior to fuel load, whichever is later, and each nuclear power plant licensee, by November 22, 1993 shall establish, implement, and maintain a training program.
(b)(2) The training program must be periodically evaluated and revised as appropriate.
10 CFR 50, Appendix E to Part 50--Emergency Planning and Preparedness for Production and Utilization Facilities
IV.B Content of Emergency Plans
Submit a report of each EAL change made within 30 days after the change is made.
IV.D Notification Procedures
Yearly dissemination to the public within the plume exposure pathway EPZ of basic emergency planning information.
IV.F Training
Several requirements for different types of training, exercises, and drills.
V. Implementing Procedures
Submit changes to the emergency plan or procedures to NRC within 30 days of such changes.
VI. Emergency Response Data System
Test the ERDS periodically to verify system availability and operability. The frequency of ERDS testing will be quarterly unless otherwise set by NRC based on demonstrated system performance.
10 CFR 50, Appendix G to Part 50--Fracture Toughness Requirements
III. Fracture Toughness Tests
Test in accordance with the appropriate ASME Code Edition and Addenda.
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PART 55 – OPERATORS’ LICENSES
§ 55.21 Medical examination.
An applicant for a license shall have a medical examination by a physician. A licensee shall have a medical examination by a physician every two years.
§ 55.25 Incapacitation because of disability or illness.
If, during the term of the license, the licensee develops a permanent physical or mental condition that causes the licensee to fail to meet the requirements of § 55.21 of this part, the facility licensee shall notify [see the regulation for details].
§ 55.40 Implementation.
(b)(2) Pursuant to § 55.49, power reactor facility licensees shall establish, implement, and maintain procedures to control examination security and integrity.
§ 55.53 Conditions of licenses.
(h) The licensee shall complete a requalification program as described by § 55.59.
(i) The licensee shall have a biennial medical examination.
§ 55.55 Expiration.
(b) If a licensee files an application for renewal or an upgrade of an existing license on Form NRC-398 at least 30 days before the expiration of the existing license, it does not expire until disposition of the application for renewal or for an upgraded license has been finally determined by the Commission.
§ 55.59 Requalification.
(a)(1) This program shall be conducted for a continuous period not to exceed 24 months in duration.
(a)(2) Pass a comprehensive requalification written examination and an annual operating test.
(c)(1) Schedule. The requalification program must be conducted for a continuous period not to exceed two years, and upon conclusion must be promptly followed, pursuant to a continuous schedule, by successive requalification programs.
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PART 72 – LICENSING REQUIREMENTS FOR THE INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL, HIGH-LEVEL RADIOACTIVE WASTE, AND REACTOR-RELATED GREATER THAN CLASS C WASTE
§ 72.70 Safety analysis report updating.
(c)(6) Updates shall be filed every 24 months from the date of issuance of the license.
§ 72.74 Reports of accidental criticality or loss of special nuclear material.
(a) Each licensee shall notify the NRC Operations Center within one hour of discovery of accidental criticality or any loss of special nuclear material.
§ 72.75 Reporting requirements for specific events and conditions.
(a) Emergency notifications: Each licensee shall notify the NRC Headquarters Operations Center upon the declaration of an emergency as specified in the licensee's approved emergency plan addressed in § 72.32. The licensee shall notify the NRC immediately after notification of the appropriate State or local agencies, but not later than one hour after the time the licensee declares an emergency.
§ 72.76 Material status reports.
(a) Each report must be submitted within 60 days of the beginning of the physical inventory required by § 72.72(b).
§ 72.142 Quality assurance organization.
(a) The licensee, applicant for a license, certificate holder, and applicant for a CoC shall be responsible for the establishment and execution of the quality assurance program.
(c) The persons and organizations performing quality assurance functions shall report to a management level that ensures that the required authority and organizational freedom … are provided.
§ 72.192 Operator training and certification program.
The applicant for a license under this part shall establish a program for training, proficiency testing, and certification of ISFSI or MRS personnel.
§ 72.248 Safety analysis report updating.
(a) Each certificate holder for a spent fuel storage cask design shall update periodically, as provided in paragraph (b) of this section, the final safety analysis report (FSAR).
(c)(6) Updates shall be filed every 24 months from the date of issuance of the CoC.
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PART 73 – PHYSICAL PROTECTION OF PLANTS AND MATERIALS
§ 73.26 Transportation physical protection systems, subsystems, components, and procedures.
(d)(1) The licensee or his agent shall establish a transportation security organization.
(d)(3) The licensee or the licensee's agent shall establish, maintain, and follow a written management system.
(e) Contingency and Response Plans and Procedures. (1) The licensee or the licensee's agent shall establish, maintain, and follow a written safeguards contingency plan.
(h) Test and maintenance programs. The licensee or his agent shall establish, maintain, and follow a test and maintenance program for communications equipment and other physical protection related devices and equipment.
§ 73.40 Physical protection: General requirements at fixed sites.
… the licensee shall establish and maintain physical security in accordance with security plans approved by the Nuclear Regulatory Commission.
§ 73.46 Fixed site physical protection systems, subsystems, components, and procedures.
(b)(1) The licensee shall establish a security organization, including guards.
(b)(2) The licensee shall have onsite at all times at least one full time member of the security organization with authority to direct the physical protection activities of the security organization.
(b)(7) In addition to the weapons qualification and requalification criteria of appendix B of this part, Tactical Response Team members, armed response personnel, and guards shall qualify and requalify, at least every 12 months, for day and night firing with assigned weapons in accordance with Appendix H of this part.
(b)(9) The licensee shall conduct Tactical Response Team and guard exercises.
(b)(10) … each Tactical Response Team member, armed response person, and guard, except as provided in paragraph (b)(10)(v) of this section, shall participate in a physical fitness training program on a continuing basis.
(b)(10)(ii) The licensee shall assess Tactical Response Team members, armed response personnel, and guards for general fitness once every 4 months.
(b)(10)(iii) Within 30 days prior to participation in the physical fitness training program, the licensee shall give Tactical Response Team members, armed response personnel, and guards a medical examination.
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(b)(11) … Tactical Response Team members, armed response personnel, and guards shall meet or exceed the requirements in paragraphs (b)(11)(i) through (b)(11)(v) of this section, except as provided in paragraph (b)(11)(vi) of this section, initially and at least once every 12 months thereafter.
(b)(11)(ii) Within 30 days before the first administration of the physical fitness performance test, and on an annual basis thereafter, Tactical Response Team members, armed response personnel, and guards shall be given a medical examination including a determination and written certification by a licensed physician that there are no medical contraindications, as disclosed by the medical examination, to participation in the physical fitness performance test.
(g) Test and maintenance programs. The licensee shall have a test and maintenance program for intrusion alarms, emergency exit alarms, communications equipment, physical barriers, [etc.].
(6) The security program must be reviewed at least every 12 months by individuals independent of both security program management and personnel who have direct responsibility for implementation of the security program.
(3) A Tactical Response Team consisting of a minimum of five (5) members must be available at the facility.
§ 73.50 Requirements for physical protection of licensed activities.
(a)(1) The licensee shall establish a security organization, including guards.
(a)(2) At least one supervisor of the security organization shall be on site at all times.
(a)(4) Each guard, watchman, armed response person, and other member of the security organization shall requalify in accordance with appendix B to this part at least every 12 months.
(f) Testing and maintenance. Each licensee shall test and maintain intrusion alarms, emergency alarms, communications equipment, physical barriers, and other security related devices or equipment utilized pursuant to this section as follows: [see the regulation for details].
(h) Each licensee shall establish, maintain, and follow an NRC-approved training and qualifications plan.
§ 73.51 Requirements for the physical protection of stored spent nuclear fuel and high-level radioactive waste.
(d)(5) A security organization with written procedures must be established.
§ 73.55 Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage.
(a) General performance objective and requirements. The licensee shall establish and maintain an onsite physical protection system and security organization … In accordance with §§ 50.54(x) and 50.54(y) of part 50, the licensee may suspend any safeguards measures pursuant to § 73.55 in an emergency when this action is immediately needed to protect the public health and safety and no
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action consistent with license conditions and technical specification that can provide adequate or equivalent protection is immediately apparent. This suspension must be approved as a minimum by a licensed senior operator prior to taking the action. The suspension of safeguards measures must be reported in accordance with the provisions of § 73.71. Reports made under § 50.72 need not be duplicated under § 73.71.
(b)(2) At least one full time member of the security organization who has the authority to direct the physical protection activities of the security organization shall be onsite at all times.
(b)(4)(i) Each guard, watchman, armed response person, and other member of the security organization shall requalify in accordance with appendix B to this part at least every 12 months. This requalification must be documented. The licensee shall retain the documentation of each requalification as a record for three years after the requalification.
(d)(7)(i) Establish an access authorization system.
(d)(7)(i)(A) Establish a current authorization access list for all vital areas. The access list must be updated by the cognizant licensee manager or supervisor at least once every 31 days and must be re-approved at least quarterly. The licensee shall include on the access list only individuals whose specific duties require access to vital areas during non-emergency conditions.
(g) Testing and maintenance. Each licensee shall test and maintain intrusion alarms, emergency alarms, communications equipment, physical barriers, and other security related devices or equipment utilized pursuant to this section as follows: [see the regulation for details].
(g)(2) Each intrusion alarm shall be tested for performance at the beginning and end of any period that it is used for security. If the period of continuous use is longer than seven days, the intrusion alarm shall also be tested at least once every seven (7) days.
(g)(3) Communications equipment required for communications onsite shall be tested for performance not less frequently than once at the beginning of each security personnel work shift. Communications equipment required for communications offsite shall be tested for performance not less than once a day.
(g)(4)(i) The licensee shall review implementation of the security program by individuals who have no direct responsibility for the security program either:
(A) At intervals not to exceed 12 months, or
(B) As necessary, based on an assessment by the licensee against performance indicators and as soon as reasonably practicable after a change occurs in personnel, procedures, equipment, or facilities that potentially could adversely affect security but no longer than 12 months after the change. In any case, each element of the security program must be reviewed at least every 24 months.
(h)(3) The total number of guards, and armed, trained personnel immediately available at the facility to fulfill these response requirements shall nominally be ten (10), unless specifically required otherwise on a case by case basis by the Commission; however, this number may not be reduced to less than five (5) guards.
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§ 73.56 Personnel access authorization requirements for nuclear power plants.
(a) General. (1) Each licensee who is authorized on April 25, 1991, to operate a nuclear power reactor pursuant to §§ 50.21(b) or 50.22 of this chapter shall comply with the requirements of this section. By April 27, 1992, the required access authorization program must be incorporated into the site Physical Security Plan as provided for by 10 CFR 50.54(p)(2) and implemented. By April 27, 1992, each licensee shall certify to the NRC that it has implemented an access authorization program that meets the requirements of this part.
§ 73.67 Licensee fixed site and in-transit requirements for the physical protection of special nuclear material of moderate and low strategic significance.
(d)(8) Establish a security organization or modify the current security organization to consist of at least one watchman per shift able to assess and respond to any unauthorized penetrations or activities in the controlled access areas.
(e)(3)(vii) Notify the NRC Operations Center within one hour after the discovery of the loss of the shipment and within one hour after recovery of or accounting for such lost shipment in accordance with the provisions of § 73.71 of this part.
§ 73.71 Reporting of safeguards events.
(a)(1) Each licensee subject to the provisions of §§ 73.25, 73.26, 73.27(c), 73.37, 73.67(e), or 73.67(g) shall notify the NRC Operations Center within one hour after discovery of the loss of any shipment of SNM or spent fuel, and within one hour after recovery of or accounting for such lost shipment.
(a)(4) The initial telephonic notification must be followed within a period of 60 days by a written report submitted to the NRC by an appropriate method listed in § 73.4. In addition to the addressees specified in § 73.4, the licensee shall also provide one copy of the written report addressed to the Director, Division of Nuclear Security, Office of Nuclear Security and Incident Response. The report must include sufficient information for NRC analysis and evaluation.
(a)(5) Significant supplemental information which becomes available after the initial telephonic notification to the NRC Operations Center or after the submission of the written report must be telephonically reported to the NRC Operations Center and also submitted in a revised written report (with the revisions indicated) to the Regional Office and the Document Control Desk. Errors discovered in a written report must be corrected in a revised report with revisions indicated. The revised report must replace the previous report; the update must be a complete entity and not contain only supplementary or revised information. Each licensee shall maintain a copy of the written report of an event submitted under this section as record for a period of three years from the date of the report.
Appendix B to Part 73--General Criteria for Security Personnel
Appendix C to Part 73--Licensee Safeguards Contingency Plans
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Part 74 – MATERIAL CONTROL AND ACCOUNTING OF SPECIAL NUCLEAR MATERIAL
§ 74.7 Specific exemptions.
The Commission may, upon application of any interested person or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security, and are otherwise in the public interest.
PART 140--FINANCIAL PROTECTION REQUIREMENTS AND INDEMNITY AGREEMENTS
§ 140.8 Specific exemptions.
The Commission may, upon application of any interested person or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and are otherwise in the public interest.
STANDARD TECHNICAL SPECIFICATIONS, excerpts from Chapter 5, Administrative Controls (based on NUREG-1431, Rev. 3.1, STS for Westinghouse Plants, December 1, 2005).
5.1 Responsibility
5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.
5.1.2 The [Shift Supervisor (SS)] shall be responsible for the control room command
function. During any absence of the [SS] from the control room while the unit is in MODE 1, 2, 3, or 4, an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function. During any absence of the [SS] from the control room while the unit is in MODE 5 or 6, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.
5.2 Organization
5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant. a. Lines of authority, responsibility, and communication. b. The plant manager shall be responsible for overall safe operation of the plant
and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
c. A specified corporate officer shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
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5.2.2 Unit Staff
The unit staff organization shall include the following: a. A non-licensed operator shall be assigned to each reactor containing fuel and
an additional non-licensed operator shall be assigned for each control room from which a reactor is operating in MODES 1, 2, 3, or 4.
b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.
c. A radiation protection technician shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.
d. Administrative procedures shall be developed and implemented to limit the working hours of personnel who perform safety related functions (e.g., [licensed Senior Reactor Operators (SROs), licensed Reactor Operators (ROs), health physicists, auxiliary operators, and key maintenance personnel]).
e. The operations manager or assistant operations manager shall hold an SRO license.
f. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.
5.3 Unit Staff Qualifications 5.4 Procedures
5.4.1 Written procedures shall be established, implemented, and maintained. 5.5 Programs and Manuals
The following programs shall be established, implemented, and maintained. 5.5.1 Offsite Dose Calculation Manual (ODCM) 5.5.2 Primary Coolant Sources Outside Containment 5.5.3 Post Accident Sampling [if applicable] 5.5.4 Radioactive Effluent Controls Program 5.5.5 Component Cyclic or Transient Limit 5.5.6 Pre-Stressed Concrete Containment Tendon Surveillance Program [if applicable]
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5.5.7 Reactor Coolant Pump Flywheel Inspection Program 5.5.8 Inservice Testing Program 5.5.9 Steam Generator (SG) Program 5.5.10 Secondary Water Chemistry Program 5.5.11 Ventilation Filter Testing Program (VFTP) 5.5.12 Explosive Gas and Storage Tank Radioactivity Monitoring Program 5.5.13 Diesel Fuel Oil Testing Program 5.5.14 Technical Specifications (TS) Bases Control Program 5.5.15 Safety Function Determination Program (SFDP) 5.5.16 Containment Leakage Rate Testing Program 5.5.17 Battery Monitoring and Maintenance Program
5.6 Reporting Requirements
The following reports shall be submitted in accordance with 10 CFR 50.4. 5.6.1 Annual Radiological Environmental Operating Report 5.6.2 Radioactive Effluent Release Report 5.6.3 CORE OPERATING LIMITS REPORT (COLR) 5.6.4 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT
(PTLR) 5.6.5 Post Accident Monitoring Report 5.6.6 Tendon Surveillance Report [if applicable] 5.6.7 Steam Generator Tube Inspection Report
5.7 High Radiation Area
5.7.1 High Radiation Areas with Dose Rates Not Exceeding 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation
5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters
from the Radiation Source of from any Surface Penetrated by the Radiation, but less than 500 rad/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation
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APPENDIX B
INTERIM ENFORCEMENT POLICY
REGARDING ENFORCEMENT DISCRETION FOR NUCLEAR POWER PLANTS DURING A HUMAN
PANDEMIC EVENT
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NUCLEAR REGULATORY COMMISSION [NUREG-1600, Revision _] Policy and Procedure for NRC Enforcement Actions; Interim Enforcement Policy Regarding Enforcement Discretion for Nuclear Power Plants During a Human Pandemic Event AGENCY: Nuclear Regulatory Commission. ACTION: Policy statement; amendment. ----------------------------------------------------------------------- SUMMARY: The Nuclear Regulatory Commission (NRC) is amending its “General Statement of Policy and Procedure for NRC Enforcement Actions,” NUREG-1600, Revision __ (Enforcement Policy), by adding Appendix __. This amendment adds an enforcement policy that the NRC will follow to exercise enforcement discretion for noncompliance with license conditions, including technical specifications (TSs), or other applicable NRC requirements, that may occur as a result of human pandemic events. DATES: This action is effective ____________________. Comments on this revision should be submitted within 30 days of publication in the Federal Register and will be considered by the NRC prior to the next Enforcement Policy revision. ADDRESSES: Submit written comments to ____________________, Chief, Rules and Directives Branch, Division of Administrative Services, Office of Administration, Mail Stop T-6 D59, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Hand-deliver comments to 11555 Rockville Pike, Rockville, Maryland, between 7:30 a.m. and 4:15 p.m., Federal workdays. FOR FURTHER INFORMATION CONTACT: __________________________________________ __________________________________________ SUPPLEMENTARY INFORMATION: Background
A pandemic is an epidemic, or outbreak of an infectious disease, such as influenza, that spreads globally or across large regions. A pandemic can occur, for example, when a novel influenza virus arises and is readily transmitted among humans. Given the potentially serious health, social, and economic impacts of a pandemic, governmental entities at all levels, the private sector, and the international community are developing preparedness and response strategies to mitigate pandemic-related impacts. For example, the U.S. Government published the “National Strategy for Pandemic Influenza” in November 2005, followed by the "National Strategy for Pandemic Influenza – Implementation Plan" in May 2006 (available at http://www.whitehouse.gov/infocus/pandemicflu.html). That strategy seeks to provide a framework for U.S. Government pandemic-related planning efforts, and specifically recognizes the need to
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integrate non-health sectors, including the private sector and critical infrastructure entities, in those planning efforts. These goals were further reiterated in the broad "National Strategy for Homeland Security," issued in October 2007 (http://www.whitehouse.gov/infocus/pandemicflu/homeland.html).
Ongoing federal government planning is addressing potential adverse effects of pandemics
on numerous critical infrastructure sectors, including health care; energy; commercial nuclear reactors, materials and waste; transportation; telecommunications, agriculture and food; and banking and finance. One goal of such planning is to provide measures to assure that electricity production and delivery systems, two important elements of the North American economic and social infrastructure, remain dependable during a pandemic. Most other critical elements of the infrastructure depend on the availability of an interconnected, stable, and reliable supply of electrical power. Those efforts have also indicated that cascading or even localized outages of generators and transmission facilities could have serious short-term and long-term consequences.
The 104 nuclear power plant units currently operating in the U.S. constitute a critical
component of the U.S. electricity infrastructure. Safe operation of those plants during a pandemic event is paramount. To provide assurances of safe operation of nuclear power facilities, the NRC is actively planning to address the consequences of a pandemic on the nuclear component of our energy supply. These efforts are intended to address emergency measures to minimize the spread of the infectious disease among essential federal and private sector personnel, and to ensure that power plants continue to operate safely and reliably in the event of a pandemic outbreak.
The principal safety threat to nuclear and other generating facilities posed by a pandemic is
the absence of essential personnel from the workplace for extended periods, possibly on the order of weeks to months. Federal government projections suggest that in the event of a pandemic, such as might be associated with the avian flu, local absenteeism of up to 40 percent for a period of weeks, and over a period of 12 to 18 months nationally (due to multiple waves of illness), could occur. The NRC recognizes that operators of nuclear power plants may need to be accorded some regulatory flexibility if they are to maintain overall safe plant operation during a pandemic event that adversely impacts their workforces. For instance, licensees may need to dedicate qualified personnel to safety-related operational functions, rather than otherwise required administrative activities (e.g., certain reporting requirements). Such flexibility must account for the need to ensure adequate protection of the public health and safety, the common defense and security, and the environment.
Accordingly, the NRC is issuing this guidance concerning the process for exercising
enforcement discretion in certain situations where power reactor licensees encounter compliance issues caused by pandemic-related impacts. The exercise of enforcement discretion may provide the regulatory flexibility needed to allow continued plant operation so long as the licensee and the NRC have determined that safety will not be unacceptably affected. This policy is intended to provide a mechanism for assuring continued safe operation of nuclear power plants in a pandemic. The Commission recognizes that such flexibility may also minimize adverse impacts on the electrical operation infrastructure and other elements of critical infrastructures. Nonetheless, the Commission's ultimate consideration is safe operation of the plants. This policy is intended to provide an efficient mechanism for assuring that plants will continue to operate safely.
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As noted above, the NRC also is assessing the implications of a pandemic for its own workforce, with a particular focus on how to maintain mission-critical functions during extended periods of worker absenteeism. Scope
This enforcement policy provides for the exercise of enforcement discretion, if needed, to address noncompliance with operating licenses (including TSs) and other applicable NRC requirements caused by workforce shortages related to pandemic events. Thus, this interim enforcement policy applies only to situations in which plant operation is impacted by a pandemic. To the extent that normal mechanisms for regulatory relief are available and may be timely processed given available staffing of both the NRC and licensee, the Commission will pursue the continued use of those processes. Also, licensees are expected to follow the existing guidance in NRC Inspection Manual Part 9900 for Notices of Enforcement Discretion to the extent practicable, particularly regarding safety determinations and notification of the NRC. Licensees may decide to continue operations upon making a determination that it is safe and prudent to do so. Further, although the NRC does not anticipate that a pandemic would cause a loss of all communications between the NRC and its licensees, this enforcement discretion does extend to limited situations in which the licensee may be unable to communicate with the NRC. With respect to future enforcement, to the extent noncompliance with otherwise applicable requirements is involved, the NRC staff would normally take enforcement action for the root causes that led to the noncompliance for which enforcement discretion was used. In the pandemic context, the NRC would consider enforcement only if the underlying cause of the non-compliance is not pandemic related. Enforcement action also will be considered in those cases in which materially incorrect or incomplete information was provided to the NRC by a licensee in its justification. The NRC recognizes that a licensee will need to exercise judgment in making a determination under this discretion provision. Consistent with the NRC’s position involving 10 CFR 50.54(x), enforcement action for a violation of a license condition, including a TS, will not be taken unless a licensee’s action was clearly unreasonable considering all the relevant circumstances. Enforcement action could include the assessment of civil penalties and the issuance of orders.
Paperwork Reduction Statement
This interim policy statement does not contain a new or amended information collection requirement subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing requirements were approved by the Office of Management and Budget, approval number ____-____.
Public Protection Notification
If a means used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection. The NRC is revising the NRC Enforcement Policy by adding Appendix __ to read as follows:
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General Statement of Policy and Procedure for NRC Enforcement Actions * * * * * Appendix __: Interim Enforcement Policy Regarding Enforcement Discretion for Nuclear Power Plants During a Human Pandemic Event
This appendix sets forth the interim enforcement policy that will govern the exercise of enforcement discretion by the NRC staff when licensees of operating nuclear power plants find it necessary to deviate from their license, including technical specifications (TSs), and other applicable NRC requirements in the event of pandemic impacts. Under certain circumstances, this policy may extend to situations in which a licensee is unable to communicate with the NRC.
Effective Date: The policy is effective ____________________ and will remain in effect unless and until the Commission determines otherwise. This policy statement does not identify specific periods of applicability because the precise cause, timing, and duration of a pandemic outbreak are uncertain and depend on many factors. Furthermore, impacts on individual licensees could, and likely will, vary significantly. This guidance is interim insofar as it applies only when there are plant-specific impacts resulting from such conditions that warrant consideration of NRC enforcement discretion.
Initiation and Termination: This interim enforcement policy will apply only where
(1) appropriate health authorities determine that conditions are present where a pandemic risk exists
1 in the United States, and (2) a power reactor licensee determines that there are plant-specific
staffing impacts that have occurred at its nuclear station due to pandemic illness which would preclude performance of specific activities in accordance with the license, including technical specifications, or other NRC requirements, and that other relief mechanisms (including exemptions, license amendments or the current NOED policy) are not practical to pursue.
Upon licensee notification to the NRC that the above conditions are present [reference
template2], the NRC will confirm that the licensee may apply this Interim Policy only for the facility
and only for the activities specifically impacted, including associated support functions performed at other locations (e.g., license headquarters) or by contractor personnel. The licensee shall also reaffirm the applicability of pandemic impacts every 14 days with the NRC [reference template].When the pandemic ceases to cause plant-specific staffing impacts for a particular activity at its nuclear station, and the staffing levels with respect to that activity remain stable for a reasonable period of time, the licensee will determine that the pandemic event for the particular plant activity has ended and so notify the NRC [reference template].
1 The risk criteria applied are the US Federal Government Response Stages
(http://www.pandemicflu.gov/plan/federal/fedresponsestages.html). Upon entering either or both stages 3 (widespread human outbreaks in multiple locations overseas) or 4 (first human case in North America) the NRC and licensees would be in a position to reasonably believe that plant impacts can be expected in the near term.
2 NEI proposes that, for ease of administration and recordkeeping, standard templates be employed in connection
with the application of this policy, including templates for licensee notification of pandemic conditions (which will also include confirmation that the licensee has notified state and local officials), requests for discretion, and NRC confirmation of discretion approval.
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Application of Enforcement Discretion: Upon satisfaction of the applicable criteria, the NRC will consider the exercise of enforcement discretion with regard to the potential noncompliance with the license, including TSs, or other NRC regulatory requirements, in accordance with this interim policy.
This interim policy addresses both pre-established pandemic enforcement discretion for
specific requirements and plant-specific pandemic enforcement discretion to be considered when needed.
Pre-established discretion provisions are listed below in the Table, which is based on the
staff’s independent review of the NEI Pandemic Licensing Plan3,4
that was submitted to NRC by NEI letter dated December 14, 2007. The pre-established enforcement discretion actions generally provide temporary relief to licensees from administrative or surveillance requirements that can readily be deferred until the pandemic has ended. Pre-established discretion criteria also address certain site-specific staffing levels otherwise required by regulation or license, including TSs. For the pre-established enforcement discretion, a safety assessment has already been performed, and licensees do not need to conduct additional assessments. Licensees should notify the NRC in writing [reference template] of their intent to apply one or more of these provisions prior to their application. A licensee may apply these pre-established actions only to the extent that pandemic-related impacts occur in specific plant activities. A licensee should attempt to notify the NRC in writing of its intent prior to applying one or more of the pre-established discretion provisions, but in any event, the licensee must notify the NRC in writing within 30 days of its application of any of the pre established actions.
Plant-specific discretion may be sought and considered when needed where the particular relief is not set forth in the pre-established discretion provisions. Application of such discretion would require the licensee to perform a safety assessment and notify the NRC prior to taking specific action during a pandemic [reference notification template]. Based on the safety assessment the Commission may determine that any decrease in safety as a result of continued plant operation is small (considering both risk and deterministic aspects), and reasonable assurance of public health and safety, the environment, and security is maintained with the enforcement discretion. The Commission will notify the licensee of its approval or disapproval of the discretion.
[Insert Table derived from Tables 1-3 in the NEI Pandemic Licensing Plan, Revision 1]
Safety Assessments for Licensee-Specific Discretion: Licensees are expected to follow the existing guidance as stated in NRC Inspection Manual Part 9900 for Notices of Enforcement Discretion to the extent practicable, for the safety assessment performed for licensee-specific enforcement discretion requests. A licensee must provide a written justification, or in circumstances in which good cause is shown, an oral justification followed as soon as possible by written justification. The justification must document the need and safety basis for the request and provide whatever other information the NRC staff needs to make a decision regarding whether the exercise of discretion is appropriate.
The NRC staff may grant enforcement discretion on the basis of balancing the public health and safety or common defense and security of not operating against potential radiological or other hazards associated with continued operation, and a determination that safety will not be unacceptably affected by exercising the discretion. The Director of the Office of Nuclear Reactor 3 NEI letter to NRC, Jack W. Roe to Catherine Haney, “Pandemic Licensing Plan”, January 16, 2007 4 NEI letter to NRC, Jack W. Roe to Catherine Haney, “Pandemic Licensing Plan, Revision 1,” TBD
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Regulation, or designee, will orally advise the licensee whether the NRC has approved the licensee’s request and, if so, will subsequently confirm the exercise of discretion in writing. Confirmation of approval may be documented utilizing [reference template].
Enforcement discretion will only be exercised if the NRC staff is satisfied that the action is
consistent with protecting public health and safety and is warranted in the circumstances presented by the licensee. Contrary to Part 9900 Section B.3 guidance, it is not necessary for an emergency to be declared by a government entity before exercising enforcement discretion. Licensees are encouraged to contact the NRC early in their evaluation process, particularly if time is of the essence, even though complete information as specified in Part 9900 may not be available.
If the volume of requests to the NRC Headquarters Operations Center is such that the NRC
staff cannot review and approve all licensee requests in a timely fashion, the NRC staff will obtain, either orally or in writing, the safety-significant information from the licensee to enable the NRC staff to make a prompt initial assessment. Unless the initial assessment is unfavorable, the licensee would be permitted to proceed with its planned course of action based on oral approval. Documentation of this communication may be made utilizing [reference template]. The NRC staff will complete the assessments as time permits and the licensee will be advised of the results orally, if possible, and then in writing. If the NRC staff’s prompt initial assessment or subsequent assessment determines that a licensee’s actions raise safety concerns, the licensee would be so informed. The licensee would then be required to follow its license conditions, including TSs, or other applicable NRC requirements from which the licensee seeks temporary relief.
Application in the Event of Communication Difficulties: If there are communications
difficulties between the licensee and the NRC Headquarters Operations Center, the licensee is encouraged to communicate with the NRC inspector on site. The inspector should be able to facilitate communication with the NRC Headquarters Operations Center and/or the ____________________. If communication with the NRC Headquarters Operations Center is not possible, then the licensee should contact ____________________ to request enforcement discretion. Similarly, if ____________________ cannot be reached, then the licensee should attempt to contact ____________________. If communication with NRC is not possible, the licensee may continue to apply pre-established discretion criteria. With respect to the licensee-specific discretion requests, the licensee should follow the plant license conditions, including technical specifications.
Supplementation of Pre-Established Discretion: In the event experience with plant-specific discretion requests during the pandemic indicates that a particular action appropriately may be included in the pre-established discretion provisions, the NRC shall so notify licensees and such requests may thereafter be treated as meeting the requirement for pre-established discretion.
Enforcement: The decision to exercise enforcement discretion does not change the fact that the licensee will be in noncompliance, nor does it imply that enforcement discretion is being exercised for any noncompliance that may have led to the noncompliance at issue. In the pandemic context, the NRC staff will consider enforcement action if the underlying cause of the noncompliance is deemed not to have been reasonably believed to be pandemic-related. Enforcement action will also be considered in those cases in which materially incorrect or incomplete information was provided to the NRC by a licensee in its justification. The NRC recognizes that a licensee will need to exercise judgment in making a determination under this discretion provision. Consistent with the NRC’s position involving 10 CFR 50.54(x), enforcement action for a violation of a license condition, including a TS, or any other applicable NRC requirement, will not be taken unless a licensee’s action
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was clearly unreasonable considering all the relevant circumstances. Enforcement action could include assessment of civil penalties and the issuance of orders.
Dated at Rockville, Maryland, this __ day of ________, ____.