Text

Draft Comments on NEI 99-02 Rev. 8 Draft Regulatory Assessment Performance Indicator Guideline Section 2.4 Emergency Preparedness Cornerstone, Emergency Response Organization Drill Participation Indicator
	ML24264A018
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/20/2024
From:	; Nuclear Energy Institute
To:	; Office of Nuclear Security and Incident Response
References
	99-02 Rev. 8
	Download: ML24264A018 (1)
	v • d • e

1

NEI 99-02 [Revision 8]

TBD 2023

2 2.4 EMERGENCY PREPAREDNESS CORNERSTONE The objective of this cornerstone is to ensure that the licensee is capable of implementing adequate measures to protect the public health and safety during a radiological emergency. Licensees maintain this capability through Emergency Response Organization (ERO) participation in drills, exercises, actual events, training, and subsequent problem identification and resolution. The Emergency Preparedness performance indicators provide a quantitative indication of the licensees ability to implement adequate measures to protect the public health and safety. These performance indicators create a licensee response band that allows NRC oversight of Emergency Preparedness programs through a baseline inspection program. These performance indicators measure onsite Emergency Preparedness programs. Offsite programs are evaluated by FEMA.

The protection of public health and safety is assured by a defense in depth philosophy that relies on: safe reactor design and operation, the operation of mitigation features and systems, a multi-layered barrier system to prevent fission product release, and emergency preparedness.

The Emergency Preparedness cornerstone performance indicators are:

Drill/Exercise performance (DEP),

Emergency Response Organization Drill Participation (ERO),

Alert and Notification System Reliability (ANS)

DRILL/EXERCISE PERFORMANCE Purpose This indicator monitors the ability to make accurate and timely emergency classifications, protective action recommendations (PARs), and notifications to offsite authorities, and when presented with opportunities during performance enhancing activities such as drills, exercises and real events. It is the ratio, in percent, of timely and accurate performance of those actions to total opportunities.

Indicator Definition The percentage of accurate and timely emergency classifications, protective action recommendations (PARs), and notifications to offsite authorities performed by Key Positions, as defined in the ERO Drill Participation performance indicator, during the previous eight quarters.

Data Reporting Elements The following data are required to calculate this indicator:

The number of drill, exercise, and actual event opportunities during the previous quarter.

The number of drill, exercise, and actual event opportunities performed timely and accurately during the previous quarter.

NEI 99-02 [Revision 8]

TBD 2023

3 The indicator is calculated and reported quarterly. (See clarifying notes)

Calculation The site average values for this indicator are calculated as follows:

100 quarters 8

previous the during PARs ons notificati

tions, classifica perform to ies opportunit total The quarters 8

previous the during AEs DE from PARs

ons, notificati

tions, classifica accurate timely of

DE & AEs = Drills, Exercises, and Actual Events Definition of Terms Opportunities include:

each initial declaration of an emergency classification level each PAR developed each initial notification of a declared emergency classification level each initial notification of a PAR Timely means:

classifications are made within 15 minutes after the availability of indications that an emergency action level has been met PARs are made within 15 minutes after the availability of indications that PAR decision criteria have been met offsite notifications are initiated within 15 minutes of an emergency declaration and/or completion of PAR development Accurate means:

The emergency classification and/or PAR are appropriate to the event conditions as specified in the site emergency plan and implementing procedures (see clarifying notes)

The initial notification form is completed appropriate to the event, to include (see clarifying notes):

Class of emergency EAL number*

Description of emergency*

Wind direction and speed*

PAR Whether a release is taking place Date* and time of declaration of emergency Whether the event is a drill or actual event Plant and unit* as applicable

NEI 99-02 [Revision 8]

TBD 2023

4 The meaning of the asterisks (*) is addressed below in the clarifying notes.

Clarifying Notes At a minimum, performance opportunities from an evaluated exercise or an actual declared emergency, including those for which the event notification made pursuant to 10 CFR 50.72 is later retracted per the guidance in NUREG-1022, are to be included in this performance indicator (PI). In cases where the licensee retracts the event notification, the success or failure of the opportunities associated with the emergency (e.g., emergency classification and notifications) should be determined by evaluating the information available to the decision-maker at the time of the event. Even though it may provide a basis for retracting the event notification of the emergency declaration, information learned after the event has no relevance to the assessment of the opportunities. The reporting of PI opportunities notwithstanding, the NRC will inspect licensee responses to all actual emergencies and evaluated exercises.

Beyond evaluated exercises and actual declared emergencies, opportunities from a performance-based activity conducted by the licensee to enhance the proficiency of ERO Key Members (i.e., a performance enhancing activity) may also be included in the DEP indicator data at the licensees discretion. The licensee should identify, in advance, the opportunities from a performance enhancing activity (PEA) that will be included in the DEP indicator data; the method of identification should be available for NRC review. Once identified and performed, an opportunity cannot be discarded from the indicator data (i.e., not counted) due to poor performance or the opportunity being missed. The criteria for an acceptable PEA are provided under the Clarifying Notes for the ERO PI.

A licensee may also identify, in advance, the opportunities that will not be included in the DEP indicator data; the method of identification should be available for NRC review. For example, the drill opportunities associated with an Alert declaration will be included but those from a subsequent Site Area Emergency declaration will not. Or that emergency classifications will be included but notifications will not. This provision facilitates training and practice on the response to more challenging events and use of alternative/contingency measures.

If a controller intervenes with an individual performing an opportunity (e.g., coaching or prompting),

then that opportunity should be considered a failure.

Linkage between DEP and ERO PIs If an individual is receiving ERO PI credit for participation in a PEA, then the DEP indicator opportunities performed by the individual during the activity (both successes and failures) must also be included in the DEP indicator data. For example, if an individual assigned to the ERO as a Shift Communicator performs an initial notification during a drill, then the opportunity must be credited to both the DEP indicator and the ERO PI. Individuals responding to a common ERO facility (e.g., a common EOF) may receive ERO PI credit at more than one site; however, to receive such credit, any DEP indicator opportunities performed by the individual during a PEA in support of one site must be included in the DEP indicator data for each site where ERO PI credit is given. The guidance for giving participation credit to individuals reporting to a common ERO facility is in the Clarifying Notes for the ERO PI.

NEI 99-02 [Revision 8]

TBD 2023

5 The guidance in the paragraph above notwithstanding, a DEP opportunity failure recorded at a common EOF may be assigned to only the participating site if the failure was solely caused by a performance deficiency at the site (i.e., performance at the common EOF did not contribute to the failure). For example, if a site provides inaccurate information to a common EOF and that information is transmitted during a notification opportunity, then the associated notification failure should be reported only for the participating site. This provision promotes an accurate portrayal of performance in the ROP EP Cornerstone by not assigning a DEP opportunity failure to the non-participating sites.

When DEP indicator opportunities occur before the performing individual is fully qualified for their ERO position (e.g., the opportunity is provided as part of the qualification process), the opportunities identified in advance should be included in the DEP indicator data for the quarter in which the individual is placed on the active ERO roster. This approach obviates the need to process changes to previously submitted DEP indicator data. The individuals participation date, as tracked by the ERO PI, should be the actual opportunity performance date.

Emergency Classification The regulatory requirement concerning emergency classification may be found in 10 CFR 50, Appendix E, section C.2. NRC staff expectations related to the 15-minute emergency classification requirement can be found in NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants. Refer to Section IV.H, Emergency Declaration Timeliness. This guidance may be used to inform the assessment of emergency classification opportunities.

An emergency classification is completed when the designated ERO Key Position, identified in the site emergency plan, declares (i.e., announces) the emergency classification to the staff in a facility. When the announcement is made, the DEP classification opportunity is considered complete for both accuracy and timeliness. Any subsequent change made to an incorrect or correct declaration within the 15-minute declaration window would not alter the determination of the DEP classification opportunity as a failure or success, respectively.

The failure to make an accurate emergency classification does not affect the assessment of the subsequent PAR and/or notification opportunities (i.e., the classification failure is not carried forward and causes only one DEP failure). The associated PAR and/or notification opportunities should be assessed for timeliness and accuracy in all other respects, i.e., excluding the inaccurate classification.

Additionally, if an accurate classification is changed to an inaccurate classification within the 15-minute declaration window, then the initial notification of the incorrect classification is considered inaccurate and thus a DEP notification failure (because classification opportunity is counted as successful so the change to an inaccurate classification does carry forward to the notification opportunity).

A scenario could present events resulting in two or more emergency action levels (EALs) being exceeded during a 15-minute classification assessment period. In these cases, an opportunity may be counted as successful provided the highest expected emergency classification level is declared based on one of the EALs listed in the scenario guide and all other applicable opportunity success criteria are met.

NEI 99-02 [Revision 8]

TBD 2023

6 An emergency classification may not always occur in the way described in a scenario guide. Situations can arise in which the assessment of a classification opportunity becomes subjective due to the deviation from the expected scenario path. This could occur for several reasons including conservative decision-making, a judgement-based declaration by the Emergency Director, or a scenario with plant or personnel response-dependent forks in the timeline. In such cases, the opportunity should be evaluated to determine if it was a success or failure. The evaluation should be documented, include a rationale that is consistent with the site emergency plan and implementing procedures, and retained for NRC inspection.

If an expected emergency classification is missed because the met EAL was not recognized within 15 minutes of indication availability and the same emergency classification level is subsequently (i.e.,

beyond the original 15-minute assessment period) declared based on a EAL not described in the scenario guide, then the subsequent emergency classification is not considered to be a DEP indicator opportunity. This is because the subsequent classification was not timely with respect to the original 15-minute clock. This approach ensures that a DEP failure is assessed for missing the first/expected EAL but not for the second/unexpected classification, which would not have been timely.

If an event occurs and results in an emergency classification when no EAL was met, then the incorrect classification should be considered a missed opportunity. The subsequent notification should be considered an opportunity and assessed for timeliness and accuracy, excluding the inaccurate emergency classification.

An emergency classification (and the associated notification) that is a downgrade from a previously higher emergency classification level is not counted as an opportunity. This position reflects the fact that downgrades could occur during an event with plant or offsite conditions that exceed multiple lower-level EALs. It is therefore impractical to evaluate these opportunities.

If a licensee discovers after-the-fact (greater than 15 minutes) that an event or condition had existed which exceeded an EAL, but no emergency had been declared and the EAL is no longer exceeded at the time of discovery, then the following guidance applies:

If the indication of the event or condition was not available to the operator, then the event should not be evaluated for DEP indicator purposes.

If the indication of the event was available to the operator but not recognized, then it should be considered a failed classification opportunity.

In either case, the licensee should assess the event notification requirements of 10 CFR 50.72 and the associated guidance in NUREG-1022; if an event notification is made, it should not be evaluated as a DEP opportunity.

Emergency Notification Notification opportunities associated with emergency classifications and PARs may be included in this indicator if they are performed to the point of filling out the appropriate forms and demonstrating sufficient knowledge to make the actual notification. The demonstration of sufficient knowledge entails the performance of the procedurally required notification actions in the facility, and the use of communications equipment to contact designated Offsite Response Organizations (OROs) and transmit the notification information in accordance with site-specific procedures. Performance of follow-up notifications are not included in the DEP indicator data.

NEI 99-02 [Revision 8]

TBD 2023

7 The notification timeliness criterion is met when the licensee makes contact with the first State or local governmental agency within 15 minutes of an emergency declaration or PAR approval. If a computer application is used to send an electronic notification message, then the notification timeliness criterion is met by a confirmation that the message was accessed (e.g., a read or opened receipt, or other acknowledgement that the notification message was displayed, or validation of receipt by an independent phone call) by at least one agency within 15 minutes. This success criterion normalizes the notification capabilities of licensees, regardless of the number of site-specific offsite notification requirements. As such, NRC and licensees can assess a sites specific capability to a common industry baseline to identify the possible need for additional inspection resources. Further, the notification opportunity provides the NRC assurance that a licensee is conducting the notification process in its entirety and evaluating compliance with the regulatory offsite notification requirement of 10 CFR 50, Appendix E, Section IV.D.3.

It is not expected that OROs will be available to support all the PEAs conducted by a licensee; therefore, notification opportunities may be provided using simulated ORO communicators. The licensee should have provisions in place to reasonably simulate ORO contacts and support the use of communications equipment by the participants.

Some licensees have specific arrangements with their ORO authorities that provide for different notification time requirements than those prescribed by this PI (e.g., within one hour instead of 15 minutes). In these instances, the licensee should determine the success of an opportunity against the time requirements described in the site emergency plan.

It is recognized that ERO Key Positions in the Control Room may not perform the actual communication with offsite agencies as part of the notification process, and that personnel filling non-key positions for contacting offsite agencies (e.g., a phone-talker) may not be available during simulator training. If an evaluator role-plays a phone-talker during a simulator session, then an actual phone-talker is required to complete the notification process during an out-of-sequence activity (e.g., the notification form completed in the simulator is provided to a phone-talker at a later time and the phone-talker demonstrates the use of the telephone equipment to an evaluator). Expected interactions between the appropriate ERO Key Position, simulated by an evaluator, and the phone-talker (e.g., receiving instruction, discussion of the notification and correction of errors in the notification form) should be demonstrated. The total time of the notification opportunity is determined by adding the time required to complete the notification form (in the simulator) to the time required by the phone-talker to interact with the simulated ERO Key Position and perform the notification using the appropriate communications equipment. DEP notification credit is given once for each completed notification form regardless of how many phone-talkers use the form (i.e., cannot receive more than one DEP credit if multiple phone-talkers perform notification actions using the same form).

It is understood that initial notification forms are negotiated with ORO authorities, and that one or more of the form elements listed above under the accuracy criteria may not appear on a form and need not be added. When included on a form, the notification accuracy elements listed above without an asterisk should be assessed for DEP indicator accuracy. Any of the other elements, identified with an asterisk, appearing on a form should also be assessed for DEP indicator accuracy if required by an ORO to make a protective action decision (PAD) (i.e., asterisked elements identified by an ORO as not necessary to formulating a PAD do not need to be assessed for DEP indicator accuracy). This determination should be

NEI 99-02 [Revision 8]

TBD 2023

8 made in conjunction with the appropriate ORO and documented. Examples of cases where a DEP indicator accuracy assessment would not be required are presented below.

EAL number and/or Description of emergency: The ORO uses the Class of emergency entry (e.g., a General Emergency has been declared) to make a PAD, and considers the EAL number and/or Description of emergency to be supplemental information.

Wind direction and speed: The ORO uses the PAR entry (e.g., evacuate and shelter specified subareas) to make a PAD, and considers the Wind direction and speed entries to be supplemental information.

Date and time of declaration of emergency: The ORO determines that an incorrect date would not impede a PAD. The time of declaration of the emergency entry is NOT asterisked and should be retained as a DEP indicator accuracy criterion.

For Plant and unit as applicable: The ORO determines that incorrect unit identification would not impede a PAD. This determination should consider potential PAD impacts caused by an emergency occurring at different facilities or technologies on a site (e.g., a PWR unit and a BWR unit, two units with different PWR technologies, etc.). The Plant entry is NOT asterisked and should be retained as an accuracy criterion.

The documentation supporting a determination to not include an asterisked form element within the site-specific DEP indicator accuracy criteria should be retained for inspection.

If an initial notification form includes elements in addition to those listed above, they need not be assessed for DEP indicator accuracy. It is, however, expected that any entry errors involving the asterisked form elements not assessed for DEP indicator accuracy or additional elements will be critiqued and addressed through a corrective action system.

The following information provides additional clarification on the topic of notification accuracy:

The description of the event causing the classification may be brief and need not include all plant conditions. At some sites, the EAL number is the description.

Release means a radiological release attributable to the emergency event.

Minor discrepancies in the wind speed and direction entered on the emergency notification form need not count as a missed notification opportunity provided the discrepancy would not result in an incorrect PAR.

The assessment of the Whether the event is a drill or actual event accuracy criterion should be made consistent with the expectations of the licensees emergency preparedness program and/or the applicable training program. Not marking either drill or actual event, regardless of expectations, is a failed opportunity.

NEI 99-02 [Revision 8]

TBD 2023

9 Protective Action Recommendations All PARs associated with a General Emergency (i.e., initial and any subsequent changes) should be counted towards the DEP indicator. Although not a regulatory requirement, the development of a PAR is expected to be completed within 15 minutes after the availability of indications to plant operators that a PAR is warranted in accordance with the licensees PAR scheme. The 15-minute goal is a reasonable period of time to develop or change a PAR, and should not be interpreted as a grace period in which the licensee may attempt to restore conditions and avoid making a PAR. Plant conditions, meteorological data, field monitoring data, and/or radiation monitor data should provide sufficient information to determine the need for initial or changed PARs. When onsite data sources are sufficient for a PAR assessment, it is not appropriate to wait for field monitoring results to become available to confirm the need to issue or change a PAR.

A PAR notification is counted separately from a concurrent notification associated with an emergency classification. For example, an initial General Emergency declaration would represent a total of 4 opportunities: 1 for classification of the General Emergency, 1 for notification of the General Emergency to the OROs, 1 for development of a PAR, and 1 for notification of the PAR to the OROs.

PARs issued at the Site Area Emergency (SAE) classification level should be counted as opportunities only when; 1) they are described in the site emergency plan, and; 2) require assessment and decision-making to develop. SAE PARs requiring minimal or no assessment and decision-making (e.g., a default/automatic PAR) should not be included in the DEP indicator data. A notification opportunity associated with an SAE PAR should be included in the DEP indicator data only when the PAR opportunity is included (i.e., notifications of a default/automatic PAR do not count towards the indicator).

PARs associated with the ingestion exposure pathway (e.g., livestock or crops) should not be counted.

If the objectives for a PEA (e.g., a drill) identify that EPA Protective Action Guidelines (PAGs) will be exceeded beyond the 10-mile plume exposure pathway emergency planning zone (EPZ) boundary, then the assessment of this condition would constitute a DEP indicator opportunity. In addition, there is a DEP indicator opportunity associated with the timeliness of the notification of the PAR to offsite agencies. Essential to understanding that these opportunities exist is realizing that it is a regulatory requirement for a licensee to develop and communicate a PAR when EPA PAG doses may be exceeded beyond the 10-mile plume exposure pathway EPZ. However, a licensee always has the latitude to identify, in advance, which DEP opportunities from a PEA will or will not be included in the indicator data. Thus, a licensee may choose to not include a PAR beyond the 10-mile EPZ in the DEP indicator data.

FAQs incorporated into this revision of the DEP PI:

13-07, Correctly Scoring Classification Opportunities (DCPP) (ML16285A323) 19-01, Initial Notification Form Accuracy (ML19169A262) 20-04, Crediting Automated Notifications in the DEP PI (ML20335A061) 21-02, Counting DEP Opportunities from an Emergency Following Retraction of the NRC Emergency Notification (ML21048A140)

NEI 99-02 [Revision 8]

TBD 2023

10 Data Example 3Q/20 4Q/20 1Q/21 2Q/21 3Q/21 4Q/21 1Q/22 2Q/22 Successful Classifications, Notifications & PARs over qtr 7

72 14 27 31 14 24 29 Opportunities to Perform Classifications, Notifications, & PARs in qtr 7

72 14 29 32 14 24 30 Total # of succesful Classifications, Notifications, & PARs in 8 qtrs 200 238 154 141 116 165 189 218 Total # of opportunities to perform Classification, Notifications & PARs in 8 qtrs 202 240 155 143 119 168 192 222 99.0%

99.2%

99.4%

98.6%

97.5%

98.2%

98.4%

98.2%

Threshold Green 90%

White

< 90%

Yellow

< 70%

Red Not Applicable Indicator expressed as a percentage of Opportunities to perform Classifications, Communications & PARs 60.0%

70.0%

80.0%

90.0%

100.0%

3Q/20 4Q/20 1Q/21 2Q/21 3Q/21 4Q/21 1Q/22 2Q/22 Indicator Quarter EP Drill/Exercise Performance YELLOW Note: No Red Threshold WHITE

NEI 99-02 [Revision 8]

TBD 2023

11 EMERGENCY RESPONSE ORGANIZATION DRILL PARTICIPATION Purpose This performance indicator (PI) tracks participation in performance enhancing activities by individuals filling ERO Key Positions and, through linkage to the DEP indicator, ensures that the performance of the risk-significant functions of emergency classification, notification, and PAR development are evaluated and included in the PI process. This indicator measures the percentage of ERO members assigned to fill Key Positions who have participated in recent performance-enhancing activities such as drills, exercises, and actual events.

Indicator Definition The percentage of ERO members filling Key Positions that have participated in a performance enhancing activity, such as a drill, exercise or actual event, during the previous eight quarters, as measured on the last calendar day of the quarter.

Data Reporting Elements The following data are required to calculate this indicator and are reported:

total number of ERO members assigned to fill Key Positions total number of ERO members assigned to fill Key Positions that have participated in a performance enhancing activity in the previous eight quarters The indicator is calculated and reported quarterly, based on participation over the previous eight quarters (see clarifying notes).

Calculation The site indicator is calculated as follows:

100 Members ERO to assigned Positions Key of number Total qrts 8

previous event the actual or exercise

drill, in ed participat have that Positions Key to assigned members ERO of

Definition of Terms Key Positions are defined below Control Room Shift Manager (on-shift Emergency Director) - Performs or provides oversight/approval of emergency classifications and declarations, formulation of PARs, and notifications to OROs. Supervision of reactor operations, responsible for classification, notification, and determination of protective action recommendations

NEI 99-02 [Revision 8]

TBD 2023

12 Shift Communicator - performs initial provides initial offsite (state/local) nnotifications to OROs.

Technical Support Center (TSC)

Command and Control (Senior TSC Manager) - Performs or provides oversight/approval of emergency classifications and declarations, formulation of PARs, and notifications to OROs.Management of plant operations/corporate resources Key Operations Support Supervision of Site RP ActivitiesKey Radiological Controls - Develops offsite PARs, and performs or provides oversight/approval of offsite dose assessments, including aspects related to field monitoring.Radiological effluent and environs monitoring, assessment, and dose projections Key TSC Communicator - performs initial notifications to OROs. provides offsite (state/local) notification Key Technical Support Emergency Operations Facility (EOF)

Command and Control (Senior EOF Manager) - Performs or provides oversight/approval of emergency classifications and declarations, formulation of PARs, and notifications to OROs. Management of corporate resources Supervision of EOF RP Activities - Develops offsite PARs, and performs or provides oversight/approval of offsite dose assessments, including aspects related to field monitoring.Key Protective Measures - Radiological effluent and environs monitoring, assessment, and dose projections Key EOF Communicator - performs initial notifications to OROs.provides offsite (state/local) notification Operational Support Center (OSC)

Key OSC Operations Manager Assigned: Those ERO personnel that fill a filling Key Position ass listed ion anthe EROlicensee duty roster/database on the last day of the quarter of the reporting period.

When mapping the above descriptions to their site-specific ERO positions, a licensee may adjust the assigned functions to align with assignments described in their approved emergency plan.

For example, if the emergency classification and declaration function is retained in the TSC (i.e.,

not transferred to the EOF), then that function would not be applicable to the EOF Command and Control (Senior EOF Manager) position.

Formatted: Indent: Left: 0.5" Formatted: Not Highlight Formatted: Not Highlight Formatted: Normal, Indent: Left: 0", Numbered + Level: 1

+ Numbering Style: Bullet + Start at: 1 + Alignment: Left +

Aligned at: 0.25" + Indent at: 0.5" Formatted: Tab stops: -0.5", Left + 0.25", Left + 0.5",

Left + 1.19", Left + 1.5", Left + 2.31", Left Formatted: Tab stops: Not at -0.5" + 0.25" + 0.5" +

1.19" + 1.5" + 2.31" Formatted: Indent: Left: 0", Tab stops: 0.06", Left + Not at 0.25"

NEI 99-02 [Revision 8]

TBD 2023

13 Clarifying Notes An individual may receive ERO PI credit for participation in a performance-based activity that provides a meaningful opportunity to enhance their proficiency with one or more of the assigned EROemergency plan functions listed above (i.e., a performance enhancing activity). At a minimum, ERO PI credit shall be extended for participation in an evaluated exercise and an actual declared emergency, including those for which the NRC notification is later retracted in accordance with NUREG-1022. Additional performance enhancing activities may include, but are not limited to, a simulator exam, a functional or facility drill, a tabletop drill, or a mini-drill; it is the licensees decision whether to include participation in any of these activities in the ERO PI data.

ERO PI credit may be granted for participation as a player, controller, evaluator, mentor, or coach, but not as an observer. Multiple assignees to a given Key Position could take credit for the same performance enhancing activity (PEA) if their participation is a meaningful opportunity to gain proficiency.

A PEA need not include all ERO facilities or staff; however, the activity should reasonably simulate the interactions between appropriate facilities and/or individuals that would be expected to occur during an emergency. For example, controllers could simulate the TSC and offsite agencies during an EOF facility drill, or the TSC and damage control teams during an OSC facility drill. In the simulator, instructors could play the role of offsite agencies notified by the Control Room.

Should an external event beyond the licensees control (e.g., a public health emergency) inhibit the safe conduct of PEAs, then it is acceptable to grant a reasonable extension of the ERO PI end date for each key responder, beyond the normal eight-quarter window. The amount of time that is considered reasonable is event-specific and will be provided by the NRC to ensure consistent application and understanding. The permitted time will consider the nature of the external event (e.g., ending a public health emergency) and the amount of time needed to schedule and implement necessary PEAs. Extensions of ERO PI end dates for specific events will be documented in NRC-approved ROP FAQs.

Linkage between DEP and ERO PIs When the participation of a Key Position in a PEA includes the performance of a Drill/Exercise Performance (DEP) indicator opportunity (i.e., emergency classification, notification, and PAR formulation), the individual may be granted ERO PI credit only if the opportunity also contributes to the DEP indicator.

As stated in the DEP indicator Clarifying Notes, a licensee can declare in advance which performance opportunities presented during a PEA will be included in the DEP indicator data (i.e., each one, some, or none). In all cases, the individuals filling ERO Key Positions that do not perform DEP indicator opportunities may receive ERO PI credit for participation in the PEA.

For example, if the licensee declares that emergency classification opportunities performed during a PEA will not contribute to the DEP indicator, then all individuals in Key Positions can receive participation credit for the ERO PI except those in positions responsible for performing emergency classifications.

NEI 99-02 [Revision 8]

TBD 2023

14 Participation Credit/Counting If an ERO member has participated in more than one PEA during the eight-quarter period, then the ERO PI data should use the most recent participation date.

All individuals qualified as a Control Room Shift Manager (Emergency Director) and currently qualified to stand watch should be included in this PI.

The Communicator positions are the ERO positions that fill out the initial notification form, seek Emergency Director approval, and transmit the information to offsite agencies. Senior managers who do not perform these duties should not be considered Communicators even though they may approve the form and supervise the work of a Communicator. There may be cases where a senior manager fills out a notification form and, after approval, hands it off to a phone-talker to transmit the information to offsite agencies. In these cases, the senior manager is the Communicator for ERO PI purposes. Individuals filling phone-talker positions that do not have form completion responsibilities are not Communicators and do not need to be tracked for this PI.

To receive ERO PI credit as a Communicator, an individual must demonstrate the ability to perform a notification of an emergency declaration and/or a PAR to required offsite agencies as discussed in the Clarifying Notes for the DEP indicator. This means that either the Communicator performs the notification, or the Communicator completes the notification form and the notification is performed by a phone-talker, either during the same PEA or as a separate (subsequent) activity. Documentation of the opportunity should be sufficient to allow an Inspector to independently reach the conclusion that the opportunity was adequately performed.

If a change occurs in the number of ERO members filling Key Positions, this change should be reflected in both the numerator and denominator of the indicator.

Some hostile action-based (HAB) drills or exercises may have all DEP indicator opportunities performed solely in the Control Room (e.g., initial declaration of a Site Area Emergency with escalation to a General Emergency prior to activation of other ERO facilities), while others could have initial opportunities performed in the Control Room and subsequent opportunities performed in the TSC and/or EOF. ERO credit can be granted to Key Positions for participation in a DEP-evaluated HAB drill or exercise without a DEP opportunity for all Key ERO positions as long as the Key Positions are observed evaluating the need to upgrade to the next higher classification level and/or evaluating the need to change protective action recommendations. The key TSC Communicator and Key EOF Communicator may be granted participation credit as long as the communicator performs a minimum of one offsite (ORO) update notification. If an individual participates in more than one Security-related drill or exercise without a DEP opportunity in a three-year period, then only one of the HAB drills/exercises can be credited. A station cannot run more than one credited HAB drill or exercise that does not include DEP opportunities for the TSC and/or EOF personnel in any consecutive 4-quarter period. There is no credit limitation on HAB drills and exercises that include DEP opportunities for the TSC and/or EOF personnel. ERO participation credit should be assigned in the normal manner for these drills and exercises. Objective evidence shall be documented to demonstrate the above requirements were met.

NEI 99-02 [Revision 8]

TBD 2023

15 When an ERO member is assigned to multiple Key Positions, the individuals participation should be counted separately for each Key Position (i.e., participation in one Key Position does not provide credit for other assigned Key Positions). This means an individual assigned to more than one Key Position is counted in the denominator for each position held and in the numerator only for the positions for which there has been participation over the previous 8 quarters. This approach ensures that the ERO member is provided an opportunity to participate in a PEA for each assigned Key Position or else the PI will reflect the lack of participation in one or more assigned positions. A single PEA may be credited as participation in two or more Key Positions provided the performance skill set between the Key Positions is similar. For example, an individual assigned as both a Shift Communicator and a Key TSC Communicator may receive credit for both positions through drill participation in either position provided the communications forms and equipment are essentially the same in the Control Room and TSC.

An individual may receive ERO PI credit for participation in a PEA that occurred prior to their assignment to the ERO (e.g., drill participation is a position qualification requirement). The participation date should be tracked by the indicator when the individual is placed on the active ERO roster. The intent to count the participation should be documented in advance of the activity and the documentation should be available for NRC inspection. Any associated DEP opportunities performed by the individual during the activity must contribute to the DEP indicator; refer to the DEP PI Clarifying Notes for guidance in counting these DEP opportunities If an ERO member assignment is changed from one Key Position to a different Key Position, then the last PEA participation date from the old position may count towards the new position provided the skills needed to perform the functions of each position are similar. If the skills needed to perform the functions of the two positions are significantly different, then the last participation date from the old position would not count towards to new position.

Scenario Confidentiality Scenarios used in PEAs credited towards the ERO PI should be maintained with a reasonable level of confidentiality. A licensee need not develop a new scenario for each PEA or each ERO team; however, it is expected that the confidentiality of a scenario shared between two or more PEAs will be maintained such that the activities provide valid participation opportunities.

Practices that challenge scenario confidentiality include assigning an individual to play in a drill and the individual served as a controller, evaluator, or mentor, in a recent (i.e., within the past 12 months) drill that used the same scenario.

In some cases, a PEA could provide a valid participation opportunity even if a portion of the scenario were inadvertently revealed in advance. Corrective measures could include statements signed by players attesting that they do not know the scenario, documentation that controllers made a confidentiality inquiry to the players, or revising the scenario to vary at least one EAL or the failure mechanisms meeting an EAL. If a scenario has been sufficiently compromised (e.g.,

most or all the events are known by players in advance), then the associated PEA is not a valid opportunity and participation in it should not be credited towards the ERO PI.

Common ERO Facilities

NEI 99-02 [Revision 8]

TBD 2023

16 A licensee may designate an ERO position responding to a common ERO facility (e.g., a common EOF) as a common ERO position for multiple sites. In such cases, an individual participating in a PEA may receive ERO PI credit for different sites provided that 1) they participate in a facility that supports more than one site (e.g., a common EOF) and 2) the skills necessary to perform the position functions are similar across all the supported sites. In this case, participation in a PEA may be credited towards the ERO PI of all the sites supported by the common facility; however, the licensee may choose to grant participation credit for only certain sites (e.g., just the participating site). Skills are considered similar when the procedures, processes, and protocols necessary to accomplish a response function are essentially the same across the supported units and sites. Examples of similar skills are provided below. The counting of the associated DEP opportunities is discussed in the Clarifying Notes for the DEP indicator.

Emergency Classification The skills for classification of emergencies are similar when emergency classification procedures, processes and protocols are essentially the same. For example, all units use an emergency classification scheme based on NEI 99-01 or, in the case of an advanced passive light water reactor unit, NEI 07-01. Training for individuals filling the ERO Key Positions responsible for emergency classification must include the unit-specific and/or technology-specific aspects of the site emergency classification schemes (e.g., ISFSI layouts, unique site hazards, design considerations, etc.).

Dose Assessment The skills for dose assessment are similar when dose projection methodologies and tools (e.g., dose projection software) are essentially the same. The definition of a radiological release during an emergency must also be essentially the same. Training for ERO Key Positions performing this function must include unit-specific differences in effluent monitors and release pathways, local meteorological regimes and topography effects, and how these differences impact dose assessment.

Protective Action Recommendations (PARs)

The skills for PAR determination are similar when protective action strategy procedures, processes and protocols are essentially the same. For example:

Decision-making aids such as flow charts may differ (e.g., because of population differences among the sites) but serve the same purpose and are used in the same way.

Protective action areas/zones may differ but the process used to identify the recommended action for an area/zone is essentially the same.

Implementation of potassium iodide (KI) strategies may differ based on the implementation strategies of the responsible OROs, but the procedures, processes and protocols used to determine if KI is warranted should be essentially the same.

PAR development discussion strategies should be essentially the same for each site.

NEI 99-02 [Revision 8]

TBD 2023

17 Emergency Notifications The skills for emergency notifications are similar when procedures, processes and protocols use notification forms that have essentially the same design and content. Emergency communicators are trained on all notification procedure, process and protocol differences including, but not limited to, offsite contacts, form content, methods, and equipment.

Performance deficiencies identified at a common facility during a PEA should be entered into a corrective action program (or programs, depending on the fleet quality assurance requirements).

Corrective actions and lessons learned from the PEA should be shared with all the sites served by the common facility. In addition, this material should be reviewed with the individuals staffing the affected ERO Key Positions in the common facility.

FAQs incorporated into this revision of the ERO PI:

15-04, Clarification on Granting Participation Credit During a HAB Drill/ Exercise (ML16285A336) 20-02, EP ERO Performance Indicator (ML20352A482)

NEI 99-02 [Revision 8]

TBD 2023

18 Data Example Emergency Response Organization (ERO) Drill Participation 4Q/21 1Q/22 2Q/22 3Q/22 Total number of Key ERO personnel 56 56 64 64 Number of Key personnel participating in drill/event in 8 qtrs 48 52 54 53 4Q/21 1Q/22 2Q/22 3Q/22 Indicator percentage of Key ERO personnel participating in a drill in 8 qtrs 86%

93%

84%

83%

Thresholds Green 80%

White

<80%

Yellow

<60%

No Red Threshold 50%

60%

70%

80%

90%

100%

4Q/21 1Q/22 2Q/22 3Q/22 Indicator Quarter ERO Drill Participation WHITE YELLOW Note: No Red threshold

NEI 99-02 [Revision 8]

TBD 2023

19 ALERT AND NOTIFICATION SYSTEM RELIABILITY Purpose This indicator monitors the reliability of the offsite Alert and Notification System (ANS), a critical link for alerting and notifying the public of the need to take protective actions. It provides the percentage of the sirens that are capable of performing their safety function based on regularly scheduled tests.

Indicator Definition The percentage of ANS sirens that are capable of performing their function, as measured by periodic siren testing in the previous 12 months.

Periodic tests are the regularly scheduled tests (documented in the licensees test plan or guidelines) that are conducted to actually test the ability of the sirens to perform their function (e.g., silent, growl, siren sound test). Tests performed for maintenance purposes should not be counted in the performance indicator database. Actions that could affect the as found condition of sirens prior to testing are not allowed.

Data Reporting Elements The following data are reported: (see clarifying notes) the total number of ANS siren-tests during the previous quarter the number of successful ANS siren-tests during the previous quarter Calculation The site value for this indicator is calculated as follows:

100 qtrs 4

previous in the tests siren of number total qtrs 4

previous in the tests siren succesful of

Definition of Terms Siren-Tests: the number of sirens times the number of times they are tested. For example, if 100 sirens are tested 3 times in the quarter, there are 300 siren-tests.

Successful siren-tests are the sum of sirens that performed their function when tested. For example, if 100 sirens are tested three times in the quarter and the results of the three tests are:

first test, 90 performed their function; second test, 100 performed their function; third test, 80 performed their function. There were 270 successful siren-tests.

Clarifying Notes The purpose of the ANS PI is to provide a uniform industry reporting approach and is not intended to replace the FEMA Alert and Notification reporting requirement at this time.

NEI 99-02 [Revision 8]

TBD 2023

20 A site with a FEMA-approved primary public alerting method(s) that does not use sirens will not report data for this indicator and may stop reporting data beginning with the quarter the method is implemented (e.g., implementation of Integrated Public Alert and Warning System (IPAWS) to replace sirens as the primary alerting method). In this case, the licensees ANS will be evaluated through the NRC baseline inspection program. When reporting ROP Cornerstone PI data, a licensee that does not use sirens as the primary public alerting method should leave the ANS PI data fields blank (i.e., no entries) and add a comment stating: Sirens are not part of the sites primary ANS. ANS will be inspected via IP 71114.02.

If a siren is out of service for maintenance or is inoperable at the time a regularly scheduled test is conducted, then it counts as both a siren test and a siren failure. Regularly scheduled tests missed for reasons other than siren unavailability (e.g., out of service for planned maintenance or repair) should be considered non opportunities. The failure to perform a regularly scheduled test should be noted in the comment field. Additionally, if the sirens are not available for operation because of intentional actions to disable them, and the area is deemed uninhabitable by State and/or Local agencies, then the sirens in question are not required to be counted in the numerator or denominator of the Performance Indicator for testing throughout the event. The conditions causing the suspension of testing, its duration and restoration are to be noted in the comment field for the indicator.

For plants where scheduled siren tests are initiated by local or state governments, if a scheduled test is not performed either intentionally or accidentally, the missed test is not considered as valid test opportunities. Missed test occurrences should be entered in the plants corrective action program.

If a siren failure is determined to be due only to testing equipment, and subsequent testing shows the siren to be operable (verified by telemetry or simultaneous local verification) without any corrective action having been performed, the siren test should be considered a success.

Maintenance records should be complete enough to support such determinations and validation during NRC inspection.

A licensee may change ANS test methodology at any time consistent with regulatory guidance.

For the purposes of this performance indicator, only the testing methodology in effect on the first day of the quarter shall be used for that quarter. Neither successes nor failures beyond the testing methodology at the beginning of the quarter will be counted in the PI. (No actual siren activation data results shall be included in licensees ANS PI data.) Any change in test methodology shall be reported as part of the ANS Reliability Performance Indicator effective the start of the next quarterly reporting period. Changes should be noted in the comment field.

Siren systems may be designed with equipment redundancy, multiple signals or feedback capability. It may be possible for sirens to be activated from multiple control stations or signals.

If the use of redundant control stations or multiple signals is in approved procedures and is part of the actual system activation process then activation from either control station or any signal should be considered a success. A failure of both systems would only be considered one failure, whereas the success of either system would be considered a success. If the redundant control station is not normally attended, requires setup or initialization, it may not be considered as part of the regularly scheduled test. Specifically, if the station is only made ready for the purpose of siren tests it should not be considered as part of the regularly scheduled test.

NEI 99-02 [Revision 8]

TBD 2023

21 Actions specifically taken to improve the performance of a scheduled test are not appropriate.

The test results should indicate the actual as-found condition of the ANS. Such practices will result in an inaccurate indication of ANS reliability.

Examples of actions that are NOT allowed and DO affect the as found conditions of sirens (not an all-inclusive list):

o Preceding test with an unscheduled test with the sole purpose to validate the siren is functional.

o Prior to a scheduled test, adjustment or calibration of siren system activation equipment that was not scheduled to support post maintenance testing.

o Prior to a scheduled test, testing siren system activation equipment or an individual siren(s) unless the equipment is suspected damaged from adverse weather, vandalism, vehicular strikes, etc.

o Prior to a scheduled test, testing siren system activation equipment or an individual siren(s) unless the equipment is suspected as being non-functional as a result of a computer hardware or software failure, radio tower failure, cut phone line, etc.

However, in no case should response preclude the timely correction of ANS problems and subsequent post-maintenance testing, or the execution of a comprehensive preventive maintenance program.

Testing opportunities that will be included in the ANS performance indicator are required to be defined in licensee ANS procedures. These are typically: bi-weekly, monthly quarterly and annual tests. The site specific ANS design and testing document approved by FEMA is a reference for the appropriate types of test, however licensees may perform tests in addition to what is discussed in the FEMA report.

Examples of actions that ARE allowed and do not affect the as found conditions of sirens (not an all-inclusive list):

o Regardless of the time, an unscheduled diagnostic test and subsequent maintenance and repair followed by post maintenance testing after any event that causes actual or suspected damage, such as:

1. Severe/inclement weather (high winds, lightning, ice, etc.),

2. Suspected or actual vandalism,

3. Physical damage from impact (vehicle, tree limbs, etc.),

4. Computer hardware and software failures,

5. Damaged communication cables or phone lines.

6. Problems identified by established routine use of the siren feedback systems.

NEI 99-02 [Revision 8]

TBD 2023

22 o Scheduled polling tests for the purpose of system monitoring to optimize system availability and functionality.

If a siren is out of service for scheduled planned refurbishment or overhaul maintenance performed in accordance with an established program, or for scheduled equipment upgrades, the siren need not be counted as a siren test or a siren failure. However, sirens that are out of service due to unplanned corrective maintenance would continue to be counted as failures. Unplanned corrective maintenance is a measure of program reliability. The exclusion of a siren due to temporary unavailability during planned maintenance/upgrade activities is acceptable due to the level of control placed on scheduled maintenance/upgrade activities. It is not the intent to create a disincentive to performing maintenance/upgrades to ensure the ANS performs at its peak reliability.

As part of a refurbishment or overhaul plan, it is expected that each utility would communicate to the appropriate state and/or local agencies the specific sirens to be worked and ensure that a functioning backup method of public alerting would be in-place. The acceptable timeframe for allowing a siren to remain out of service for system refurbishment or overhaul maintenance should be coordinated with the state and local agencies. Based on the impact to their organization, these timeframes should be specified in upgrade or system improvement implementation plans and/or maintenance procedures. Deviations from these plans and/or procedures would constitute unplanned unavailability and would be included in the PI.

Siren testing conducted at redundant control stations, such as county EOCs that are staffed during an emergency by an individual capable of activating the sirens, may be credited provided the redundant control station is in an approved facility as documented in the FEMA ANS design report.

In initiating EP03 reporting data for a new siren system (where there were no sirens previously),

data is entered over the 12-month period starting from the system implementation date. Each quarter results will be submitted in accordance with NEI 99-02. Zero should be entered for the 12-month quarterly average until four quarters of data have accumulated. The EP03 PI will be valid once four quarters of data have been accrued.

FAQs incorporated into this revision of the ANS PI:

14-05, Reporting New Siren System Data (ML16285A328) 21-03, Reporting ANS Data Following a Transition to IPAWS (ML21244A427)

NEI 99-02 [Revision 8]

TBD 2023

23 Data Example Alert & Notification System Reliability Quarter 3Q/97 4Q/97 1Q/98 2Q/98 3Q/98 4Q/98 Prev. Q Number of succesful siren-tests in the qtr 47 48 49 49 49 54 52 Total number of sirens tested in the qtr 50 50 50 50 50 55 55 Number of successful siren-tests over 4 qtrs 193 195 201 204 Total number of sirens tested over 4 qtrs 200 200 205 210 2Q/98 3Q/98 4Q/98 Prev. Q Indicator expressed as a percentage of sirens 96.5%

97.5%

98.0%

97.1%

Thresholds Green 94%

White

<94%

Yellow

<90%

Red N/A 80.0%

82.0%

84.0%

86.0%

88.0%

90.0%

92.0%

94.0%

96.0%

98.0%

100.0%

2Q/98 3Q/98 4Q/98 Prev. Q Indicator Quarter ANS Reliability GREEN WHITE YELLOW Note: No Red Threshold

NEI 99-02 [Revision 8]

TBD 2023

H-1 NOTE Licensees are in the process of replacing their offsite siren systems with the Integrated Public Alert and Warning System (IPAWS) as the primary method for performing prompt public alerting during an emergency. Once a site no longer uses sirens as a primary alerting method, it ceases to report ANS PI data. The ERFER PI bBelow has been is the performance indicator approved by the NRC Commission to proposed as a rreplacement for the current ANS PI. The proposed performance indicatorERFER PI is discussed taken fromin ROP FAQ 22-01, Replace the ANS PI and with an Emergency Response Facility and Equipment Readiness (ERFER) PISECY-23-0010, Recommendation for Approval to Retire the Reactor Oversight Process Performance Indicator for Licensee Alert and Notification System Availability and to Develop a Performance Indicator for Emergency Response Facility and Equipment Readiness (ML23004A013ML22055A562). The PI described below may be revised if needed to address NRC staff comments or direction from the Commission. It is intended that tThe replacement of the ANS PI with the ERFER PI will affect all power reactor licensees at the same time. i.e., there will be one PI implementation (cutover) date for all sites, regardless of any given sites intent or status concerning IPAWS implementation.

Purpose The Emergency Response Facility and Equipment Readiness (ERFER) performance indicator measures licensee performance in maintaining the emergency response facilities and equipment of greater importance to the protection of public health and safety. It reflects the ability of the licensee to perform the surveillance, testing, inventory, and preventative and corrective maintenance activities that contribute to the availability of emergency response facilities and equipment necessary to implement Risk Significant Planning Standard (RSPS) functions and response actions.

Indicator Definition The number of occurrences during a quarter that the Technical Support Center (TSC) or Emergency Operations Facility (EOF) is nonfunctional, or equipment necessary to implement the emergency plan is not available or functional, such that an RSPS function or response action could not be performed for greater than 168 continuous hours from the Time of Discovery (TOD) and no Compensatory Measure(s) was implemented.

Data Reporting Elements The number of occurrences that the TSC or EOF is nonfunctional, or equipment necessary to implement the emergency plan is not available or functional, such that an RSPS function or response action could not be performed for greater than 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months from the TOD and no Compensatory Measure(s) was implemented.

Emergency Response Facility and Equipment Readiness (ERFER)

NEI 99-02 [Revision 8]

TBD 2023

H-2 Calculation Count the number of occurrences that the TSC or EOF is nonfunctional, or equipment necessary to implement the emergency plan is not available or functional, such that an RSPS function or response action could not be performed for greater than 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months from the TOD and no Compensatory Measure(s) was implemented.

Definition of Terms The definition of the terms Risk Significant Planning Standard function, Time of Discovery, and Compensatory Measure are those described in NRC Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process.1 Clarifying Notes The ERFER PI reflects the ability of a licensee to perform the surveillance, testing, inventory, and preventative and corrective maintenance activities that contribute to the availability of the facilities and equipment necessary to accomplish RSPS functions and response actions.

The focus of the ERFER PI is on the facilities and equipment maintained by the EP staff.

Specifically, the TSC and EOF, and the equipment in those facilities that are necessary to implement RSPS functions. That equipment is described in a site emergency plan and typically defined in a sites Equipment Important to Emergency Response (EITER) program/procedure. If needed, refer to SECY-23-0010 for additional information concerning the development and scope of the ERFER PI.

Consistent with the Indicator Definition, a facility or equipment issue must be impactful enough to prevent the performance of an RSPS function or response action; a degraded capability to perform a function or action should not be counted. A Compensatory Measure need not meet the same design or operating requirements as the methods normally used to perform an RSPS function or response action; however, its effectiveness should be sufficient to ensure that the supported function or action would be accomplished during an actual emergency, albeit in a possibly degraded manner.

To be counted towards the performance indicator, the occurrence of a given facility or equipment issue must exceed 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months during one continuous period (i.e., continuous hours) in one quarter.

The starting point of the issue should be determined in accordance with the Time of Discovery guidance in NRC Inspection Manual Chapter 0609, Appendix B. Further, if an equipment issue affects performance of an RSPS function or response action at multiple facilities (e.g., loss of common computer or communications system) but the impact started at different times depending on the facility, then the performance indicator assessment should use the longest out-of-service time.

1 See Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, Issue Date September 22, 2015, (ADAMS ML15128A462), Section 2.0, Definitions, Abbreviations, and Acronyms.

NEI 99-02 [Revision 8]

TBD 2023

H-3 A loss of the TSC or EOF, or associated equipment, that precludes the performance of an RSPS function or response action for 12-hours from TOD should be documented (e.g., in the licensees corrective action program). The Compensatory Measure implemented in response to the facility or equipment issue should also be documented.

If the licensee reports a lost RSPS function or response action under this performance indicator but later determines that the capability was not lost (e.g., through a subsequent engineering analysis), then the performance indicator data should be revised accordingly. The basis for this determination should be documented and the documentation retained for inspection.

NOTE: The ROP ERFER PI and the ERFER PI described in NEI White Paper, Implementing a 24-Month Frequency for Emergency Preparedness Program Reviews, dated November 2019 (ML19344C419) use the same approach but with different threshold values, reflecting their different purposes. The NEI white paper is endorsed in Regulatory Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors. In addition to monitoring performance indicators, licensees implementing a 24-month review frequency, per 10 CFR 50.54(t)(1)(ii), will need to conduct periodic evaluations of the adequacy of interfaces with State and local governments as described in the NEI white paper.

Data Example Threshold White 1/quarter Yellow 3/quarter Red N/A

ML24264A018

Text

Navigation menu

Search