Emergency Plan (Generic Letter 80-94)


                               NOV 13, 1980 



The final regulations for emergency planning published in the Federal 
Register on August 19, 1980 (45FR55402), which became effective November 3, 
1980, contain a revised Appendix E to 10 CFR 50. "Emergency Planning and 
Preparedness for Production and Utilization Facilities", which established 
minimum requirements for emergency plans in attaining an acceptable state of
onsite emergency preparedness and a new Section 50.47. "Emergency Plans", 
which specifies standards that must be met for both onsite and offsite 
emergency response. This latter section also incorporates the Joint 
NRC/Federal Emergency Management Agency (FEMA) standards for use in 
evaluating State and local radiological emergency plans and preparedness. A 
related proposed FEMA rule will be conformed to the NRC rule language with 
respect to these standards in its final form. The proposed FEMA rule, 44 CFR
350, "Review and Approval of State Radiological Emergency Plans and 
Preparedness", was published for comment in the Federal Register on June 24,
1980 (45FR42341). 

For operating reactors, the schedule for submittal of revised radiological 
emergency response plans is found in new paragraphs to 10 CFR 50, Section 
50.54, "Conditions of Licenses", which requires that 60 days after the 
effective date of the rule (January 2, 1981), holders of nuclear power plant
operating licenses must submit 13 copies of plans (10 to NRR and 3 to I&E) 
for coping with emergencies (50.54 (u)), plus 13 copies of State and local 
government radiological emergency response plans within the 10 mile plume 
exposure pathway (EPZ) as well as those State plans within the 50 mile in-
gestion pathway EPZ (50.64(s)(1)). Additionally, 13 copies of the imple-
menting procedures for your emergency plan must be submitted by March 1, 
1981. All licensee, State and local emergency response plans shall be 
implemented by April 1, 1981, except for the prompt notification provision 
which must be implemented by July 1, 1981. 

Applicants should submit their radiological emergency response plans with 
their Final Safety Analysis Report and should submit their implementing 
procedures 180 days prior to scheduled issuance of an operating license. For
applicants already at the operating license review stage, these plans should
be submitted with sufficient lead time for staff review prior to the 
issuance of the Safety Evaluation Report supporting the NRC review of the 
application for operating license. 


                                 - 2 - 

The state of preparedness at and around your site will be determined by a 
review of your plan against the standards listed in 50.47 (b), the 
requirements of 10 CFR 50, Appendix E issued in August 1980 and effective 
November 3, 1980, and the guidance found in the joint NRC/FEMA report, 
NUREG-6454/FEMA-REP-1,     "Criteria for Preparation and Evaluation of 
Radiological Emergency Response Plans and Preparedness in Support of Nuclear 
Power Plants", of January 1980. The Joint NRC/FEMA document is currently 
under revision as a result of comments received. The revision consists 
principally of clarification of the intent and is scheduled for final 
publication in November 1980. 

Neither Regulatory Guide 1.70 Rev. 3, "Standard Format and Content of Safety
Analysis Reports for Nuclear Power Plants", dated November 1978, nor 
NUREG-78/087. "Standard Review Plan", should be used in the preparation of 
your emergency plans. Section 13.3 of both documents currently refers to the
earlier version of Appendix E and to Regulatory Guide 1.101,  both of which 
have now been superseded. The October 10, 1979 and November 21, 1979 letters
to power reactor licensees and construction permit holders and the October 
23, 1979 letter to applicants for construction permits also are superseded 
by the rule requirements. Because the substance of these letters have been 
incorporated in the final rule, plans developed in accordance with earlier 
guidance should only require upgrading to the final rule requirements to be 
acceptable. Similarly, evacuation time estimates performed in compliance 
with the letters of November 29, 1979 or December 26, 1979, will largely 
satisfy the rule and final NUREG-0654 requirements for evacuation time 
estimates although reformatting of results may be needed.  

We recommend to licensees and applicants that you work closely with the FEMA
Regional Assistance Committees (RACs) and support your State and local 
governments in developing radiological emergency preparedness plans to 
assure adequate implementation of emergency plans in the environs around 
each nuclear power plant. The State and local governments need and, in most 
cases, will solicit your technical advice and support. 



                                   Darrell G. Eisenhut, Director  
                                   Division of Licensing  
                                   Office of Nuclear Reactor Regulation 

*For previous concurrences see attached yellow 


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