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NEI White Paper

Revision 1

Pandemic Licensing Plan

December 2007

NEI White Paper Pandemic Licensing Plan

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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):

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(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.

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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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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.


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.


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.


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.


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


Revision 1

December 2007

APPENDIX A

Excerpts from 10 CFR and Technical Specifications


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.


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


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


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 ________, ____.

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