NRC Inspection Manual 0609/Appendix B
text
NRC INSPECTION MANUAL NSIR
INSPECTION MANUAL CHAPTER 0609, APPENDIX B
SIGNIFICANCE DETERMINATION PROCESS
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1.0 INTRODUCTION
The U.S. Nuclear Regulatory Commission’s (NRC’s) Emergency Preparedness Significance
Determination Process (EP SDP) described in this appendix utilizes risk-informed qualitative
analyses to estimate the risk significance of inspection findings related to licensee performance
in meeting EP Cornerstone objectives and performance expectations. Attachment 3,
“Significance Determination Process Basis Document,” to Appendix B, “Technical Basis for
Emergency Preparedness Significance Determination Process,” to Inspection Manual
Chapter 0308, “Reactor Oversight Process (ROP) Basis Document,” provides the technical
2.0 DEFINITIONS, ABBREVIATIONS, AND ACRONYMS1
The following terms, which are capitalized throughout the remainder of this appendix, are
defined for the purpose of the EP SDP only. The individual section in which each term is
primarily used provides additional clarification and guidance. The terms are ordered such that
each definition builds on the preceding definitions.
a. EMERGENCY PLAN (E–plan): The document, or documents, that the licensee prepares
and maintains that identifies and describes its methods for maintaining emergency
preparedness (EP) and responding to emergencies.
b. EMERGENCY RESPONSE ORGANIZATION (ERO): The licensee’s organization
identified in the E–plan for responding to emergencies at the licensee’s facility. The
ERO includes the on shift staff and the augmentation staff in the designated licensee
emergency response facilities.
c. PLANNING STANDARD2
(PS): One of the 16 EP planning standards established in
Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b) that the E–plan must
meet and which are supported by the corresponding sections of Appendix E,
“Emergency Planning and Preparedness for Production and Utilization Facilities,” to
10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities.”
d. EP REQUIREMENT: Any requirement within the purview of the EP Cornerstone,
including the PS, Appendix E to 10 CFR Part 50, 10 CFR 50.54(q), 10 CFR 50.54(t), the
E–plan, Commission orders, other commitments, and licensee self-imposed
requirements necessary for demonstrating compliance with the PS and Appendix E to
10 CFR Part 50, and commitments made under 10 CFR 50.47(c) and
1
In this document, acronyms may be plural or singular and are to be read in the context of the
statement in which they appear.
2 As used in this appendix, “PLANNING STANDARD” includes RISK-SIGNIFICANT PLANNING
STANDARDs, but “RISK-SIGNIFICANT PLANNING STANDARD” excludes non risk-significant
PLANNING STANDARDs.
Issue Date: 09/22/15 2 0609, Appendix B
e. RISK-SIGNIFICANT PLANNING STANDARD (RSPS): A subset of the PS, which
includes the following four PS: 10 CFR 50.47(b)(4) — emergency classification system,
(b)(5) — emergency notifications, (b)(9) — emergency assessment capability, or
(b)(10) — emergency protective actions, and supported by the corresponding sections of
Appendix E to 10 CFR Part 50. (Note that parts of 10 CFR 50.47(b)(10) are treated as
not risk significant. See Section 5.10 of this appendix for more information.)
f. PLANNING STANDARD FUNCTION (PSF): One or more functions that are considered
essential to complying with a RSPS or PS. PSF are identified for assessing the
significance of a finding that involves noncompliance with a RSPS or PS.
g. PROGRAM ELEMENTS (PE): Items that comprise the implementation aspects of a
PSF. Such items correspond to the evaluation criteria (e.g., contained in
NUREG-0654/FEMA-REP-1, “Criteria for Preparation and Evaluation of Radiological
Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,” or
the licensee’s E–plan) that provides specific acceptable methods for complying with a
PS. Note that the failure of a single PE does not always mean that a PSF cannot be
accomplished.
h. FAILURE TO COMPLY (FTC): A finding that an EP program is noncompliant with a EP
REQUIREMENT. An FTC is associated with preparedness issues, whereas an FTI is
associated with response issues. Attachment 2 illustrates the significance determination
logic for an FTC.
i FAILURE TO IMPLEMENT (FTI): A finding of an FTC during an actual radiological
event that precluded effective implementation of a PE. In this case, the PE complies
with the PS, and the PSF would have been accomplished had it been implemented by
the ERO. An FTI is associated with response issues, whereas an FTC is associated
with preparedness issues. Attachment 1 depicts the significance determination logic for
an FTI.
j. LOSS OF RSPS [PS] FUNCTION: An FTC finding that one or more PE is not adequate,
not compliant with the RSPS [PS], or otherwise not functional to such an extent that the
RSPS [PS] FUNCTION would not be accomplished if an actual radiological emergency
were to occur. One or more of the following reasons may apply:
Certain E–plan commitments are not met.
The E–plan is less than adequate.
Implementing procedures are not effective.
ERO personnel are not capable of implementing the PE.
The EP program design is not fully adequate.
Although licensees must comply with all EP REQUIREMENTS, a LOSS OF RSPS [PS]
FUNCTION will likely have greater significance than a noncompliance with other EP
REQUIREMENTS (e.g., 10 CFR 50.54(t)).
Issue Date: 09/22/15 3 0609, Appendix B
k. DEGRADATION OF RSPS [PS] FUNCTION: An FTC finding that one or more PE is not
adequate or not compliant with the RSPS [PS], but reasonable assurance exists that the
RSPS [PS] FUNCTION, although degraded, would be accomplished if an actual
radiological emergency were to occur. One or more of the following reasons may apply:
Certain E–plan commitments are not met.
The E–plan is less than adequate.
Implementing procedures are not effective.
The EP program design is not fully adequate.
However, diverse or redundant PE, or other circumstances, would allow for the RSPS
[PS] FUNCTION to still be accomplished, albeit in a degraded manner, if an actual
radiological emergency had occurred.
l. WEAKNESS: A level of ERO performance demonstrated during an exercise, drill, or
training that provides performance opportunities to develop, maintain, or demonstrate
key skills that would preclude effective implementation of the E–plan if it were to occur
during an actual radiological emergency.
1. A WEAKNESS identified by the licensee in its CRITIQUE is not a performance
deficiency (PD) and is, therefore, neither an FTC nor an FTI.
2. A deficient PE uncovered by the exercise and identified by the licensee in its
CRITIQUE is a licensee-identified PD and is evaluated as an FTC. If identified by the
inspector, the deficient PE is an NRC-identified PD and is evaluated as an FTC.
3. A licensee’s failure to identify a WEAKNESS in a CRITIQUE, or failure to take
timely corrective actions, is a PD and is evaluated as an FTC with PS
m. CRITIQUE: A formal or documented licensee assessment of the ERO performance
following an exercise, drill, or training that provides performance opportunities to
develop, maintain, or demonstrate key skills. In a CRITIQUE, which may occur in
various venues and formats, WEAKNESSES are identified and subsequently entered
into a corrective action system.
n. FULL-SCALE DRILL OR EXERCISE: An event that tests the integrated capability of the
ERO to accomplish a major portion of the PSF(s). A FULL-SCALE DRILL OR
EXERCISE is not limited to the evaluated biennial exercise, but does involve the
following:
1. participation or simulation of multiple emergency response facilities (ERFs),
2. assessment by a team of evaluators, and,
3. a subset of a “full participation exercise,” as defined in Appendix E to
Issue Date: 09/22/15 4 0609, Appendix B
o. OFFSITE RESPONSE ORGANIZATIONS (OROs): Those entities having responsibility
for managing the implementation of measures to protect public health and safety within
the plume exposure pathway, ingestion pathway, and emergency planning zones (EPZs)
in the event of an emergency. This would typically include State, county, municipal, or
Tribal emergency management agencies, as applicable.
p. TIME OF DISCOVERY: The point in time when the licensee “knew or should have
known” of a condition. See Section 5.0.2.f of this appendix for further discussion.
q. MITIGATING FACTORS: Considerations that an inspector may evaluate in determining
whether or not a noncompliant PE is a LOST RSPS [PS] FUNCTION or a DEGRADED
RSPS [PS] FUNCTION. Such factors might include the existence of a redundant
emergency action level (EAL), backup capabilities identified in the E–plan, or other
capabilities that allow the inspector to conclude that the PSF could be completed despite
the inadequate PE. Generally, these factors must have been in place before the TIME
OF DISCOVERY. These factors are credited only in determining the significance of the
noncompliance. See Section 5.0.2.b of this appendix for further clarification.
r. COMPENSATORY MEASURES: An interim action taken by a licensee after discovery
of a noncompliant PE to compensate for an inadequate PE such that there is a
reasonable expectation that the associated PSF would be accomplished, albeit in a
degraded manner, should an actual radiological emergency occur before the completion
of corrective actions to restore compliance. COMPENSATORY MEASURES, which
must be viable, are credited only in determining the significance of the noncompliance.
See Section 5.0.2.h of this appendix for further clarification.
In addition to the abbreviations and acronyms identified above, this appendix uses the following
acronyms and abbreviations:
ANS—alert and notification system
DEP PI—drill and exercise performance (DEP) performance indicator
EAL—emergency action level
EOF—emergency operations facility
EP—emergency preparedness/emergency planning
EP SDP—emergency preparedness significance determination process
EPIP—emergency plan implementing procedure
EPZ—emergency planning zone
ERF—emergency response facility
FEMA—Federal Emergency Management Agency
IC—initiating condition
JIC—joint information center
KI—potassium iodide
OSC—onsite/operations support center
PAR—protective action recommendation
PD—performance deficiency (See IMC0612 for definition)
ROP—reactor oversight process
SDP—significance determination process
TSC—technical support center
3.0 ENTRY CONDITIONS AND GENERAL INSTRUCTIONS
3.1 Entry Conditions
a. An NRC inspector enters this EP SDP for findings related to EP REQUIREMENTS as
directed by Appendix B, “Issue Screening,” of Inspection Manual Chapter 0612, “Power
Reactor Inspection Reports.” In performing this screening, the inspector should consider
the guidance in Appendix G, “Emergency Planning Cornerstone-Specific Supplemental
Guidance for Appendix B Screening Figures 1 and 2,” of IMC 0612. The EP SDP is not
used to assess the significance of a finding under the EP Cornerstone that is caused by
a finding under a different cornerstone3
if the following is true:
the licensee’s performance would have been compliant if the finding in the other
cornerstone had not occurred, and,
if a finding is being issued under the other cornerstone, and the deficiency will be
corrected.
If either condition is not met, then the EP SDP is to be used to ensure that corrective action will be
taken.
3.2 General Instructions
a. Any finding related to an EP REQUIREMENT will be assessed for significance in
accordance with this appendix, including findings associated with violations being
treated under traditional enforcement (TE), if any.
b. If the findings are related to EP REQUIREMENTS that are not associated with a PS (i.e.,
10 CFR 50.54(t) and requirements in Appendix E to 10 CFR Part 50 that do not support
a PS4
), then assign Green significance, and return to IMC 0612.
c. Identify the PSF(s) affected by the finding and assess the significance of each finding.
1. A finding may affect two or more PSF and each should be assessed for
significance.
2. Include all associated issues in the inspection report to provide a complete
record. This can be particularly important when additional information from the licensee
causes the staff to reconsider a preliminary finding.
d. Assess the significance of each issue of concern associated with a finding (e.g., multiple
contributing issues).
3 This situation typically occurs when the E–plan relies upon equipment under the control of
another cornerstone (e.g., an effluent radiation monitor used in the EAL scheme).
4 Sections 5.1 through 5.16 of this SDP, where applicable, identify the requirements of Appendix E
to 10 CFR Part 50 that support the PS of 10 CFR 50.47(b).
Issue Date: 09/22/15 6 0609, Appendix B
1. If the finding involved an actual radiological emergency (i.e., FTI), go to
Section 4.3 of this appendix to assess the significance of the finding.
2. If the finding was identified during a baseline or a program inspection, or
identified by the licensee (i.e., FTC), go to Section 5.0.3 of this appendix to assess the
significance of the finding.
4.0 ACTUAL EVENT IMPLEMENTATION ISSUE (FAILURE TO IMPLEMENT)
4.1 Background
This branch of the EP SDP is used to assess the significance of a finding that occurs during an
actual radiological emergency (i.e., an FTI). An FTI signifies that a licensee has failed to follow
its E–plan, which is a noncompliance with 10 CFR 50.54(q)(2). An FTI is associated with an
emergency response issue, rather than an emergency preparedness issue.
4.2 Criteria
a. The significance of an FTI is assessed based on (1) the declared emergency
classification and (2) whether the affected PSF is risk significant or not, as shown in
Attachment 1.
b. An FTI typically results from a PD on the part of the ERO. However, it is important to
note that a PD that occurs during an actual radiological emergency may not rise to the
level of an FTI, particularly if the deficiency is self-identified by the ERO and corrected in
a timely manner such that the PSF is successfully accomplished. In addition, the failure
of the ERO to implement a single PE does not always mean that the associated PSF
was not accomplished. Examples include the following:
An operations support center (OSC) team was not fully briefed and had to return
for tools but the assigned task was successfully completed.
Engineering efforts initially misdiagnosed the accident sequence, but the
diagnosis was corrected by peer checking.
A notification form was not peer checked as required by emergency plan
implementing procedures (EPIPs), but the information was found to be accurate.
c. NRC EP regulations require licensees to have the capability of making classifications,
declarations, notifications, and initial protective action recommendations (PARs) within
specific periods of time. Although explicit timeliness requirements are not provided in
regulation for follow-up PARs or the notification of such PARs, the NRC expects that
licensees will make follow-up PAR decisions as soon as possible after indications are
Issue Date: 09/22/15 7 0609, Appendix B
available that a PAR threshold has been exceeded and will notify OROs of such PARs
as soon as possible.5
1. Although a failure to meet these timeliness requirements may be a failed
opportunity under the Drill and Exercise Performance (DEP) Performance Indicator (PI),
there may be defensible reasons for a delay during an actual radiological emergency if
the delay has a minimal impact on the EP Cornerstone objective. Emergency
classifications, declarations, notifications, and PARs that take longer than the specified
time should be evaluated and a determination made as to whether the delay was
justifiable. Generally, if the delay was caused by the licensee actively performing
necessary safety-related actions to protect the public health and safety, and the delays
did not deny OROs the opportunity to implement actions to protect public health and
safety, a FINDING would not be issued. Return to IMC 0612 and reconsider the
determination of a more than minor PD. Each event response must be evaluated on a
case-by-case basis.
2. Delays in classification, declaration, notification, or PARs caused by factors that
were reasonably within the licensee’s ability to foresee and prevent likely represent an
FTC and should also be assessed in accordance with Section 5.0.3 of this appendix.
d. The NRC expects that licensees will make accurate emergency declarations, PAR
decisions, and notifications. The inspector should evaluate the effects of inaccurate
declarations, PAR decisions, and notifications against the affected risk-significant PSF to
determine whether the errors rise to the level of an FTI. For example, although an error
on a completed notification form (e.g., an erroneous time) may be a failed opportunity
under the DEP PI, a similar error during an actual radiological emergency might have
little or no impact on ORO response efforts and a finding may not be warranted. Return
to IMC 0612 and reconsider the determination of a more than minor PD.
e. A PD that occurs in another ROP cornerstone can cause an emergency declaration
issue. Consider the following examples:
Shift personnel concluded, based on an erroneous protection signal that a main
steam line break had occurred when all other plant indications suggested
otherwise. Given this misdiagnosis, the shift manager declared an Alert based
on an EAL threshold of “main steam line break,” when no such declaration was
warranted.
Because of a misinterpretation of a technical specification action statement, a
plant was not placed in the required mode until 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after the specified
5 Section IV.D.3 of Appendix E to 10 CFR Part 50 requires the licensee to have the capability to
notify State and local governmental agencies within 15 minutes after declaring an emergency.
PS 10 CFR 50.47(b)(5) requires that the content of initial and follow-up messages to the OROs
and the public be established. Evaluation Criterion II.E.3 in NUREG-0654/FEMA-REP-1 states
that the initial notification should contain information as to whether offsite protective measures
may be necessary. Some licensees have included these criteria in their E–plans or implementing
procedures.
Issue Date: 09/22/15 8 0609, Appendix B
completion time. An EAL required a Notification of Unusual Event (NOUE)
declaration (e.g., inability to reach required shutdown within technical
specification limits). In this case, no declaration was made, as the mistaken
interpretation was not recognized until after the plant entered the required mode.
In both of these examples, the emergency classification would have likely been correct if
the performance in the other cornerstone had been adequate. As such, the issue of
concern needs to be evaluated under that cornerstone, rather than the EP Cornerstone,
if a finding will be issued under the other cornerstone. Otherwise, the PD should be
treated as an FTI and assessed for significance under Section 4.3 of this appendix.
f. Since the significance of a finding identified during actual radiological emergencies is
based, in part, on the emergency classification level, an inaccurate declaration could
affect the significance determination. The appropriate emergency classification level is
to be used in Attachment 1 for assessing the significance of the finding, including the
10 CFR 50.47(b)(4) finding for the misclassification itself.
1. The missed or delayed declaration may have caused another ERO PD to occur
(e.g., the declaration of an NOUE instead of an Alert would have prevented timely
augmentation of the on shift staff.) In these cases, the inspection report should identify
the associated issues, but only the 10 CFR 50.47(b)(4) finding would be identified as an
FTI and assessed for significance under Section 4.3 of this appendix.
2. However, if the additional PD was caused or exacerbated by factors other than
the delayed or missed classification, an additional finding may be appropriate (e.g., the
licensee failed to notify the NRC of the missed declaration within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of identification.)
4.3 Significance Determination
a. Identify the EP REQUIREMENT affected by the finding.
b. Determine whether the finding is an FTI.
1. If the finding did not involve a failure to implement a PS or RSPS, an FTI is not
warranted. Return to IMC 0612 and reconsider the determination of a more than minor
PD.
2. An FTI is analogous to a LOST RSPS [PS] FUNCTION, examples of which are
provided in Section 5.0 of this appendix. Those examples, while applicable only to an
FTC, may be useful in informing the FTI determination.
3. A finding that did not rise to the level of an FTI should be identified to the
licensee as an opportunity for improvement. Return to IMC 0612 and reconsider the
determination of a more than minor PD.
Issue Date: 09/22/15 9 0609, Appendix B
c. Identify the emergency classification declared by the licensee and evaluate its
appropriateness. If the classification was appropriate or under classified, proceed to
Step 4.3.e below.
d. If the licensee over classified the actual event, then assess the significance of the
10 CFR 50.47(b)(4) finding as follows and continue with Step 4.3.f:
1. The minimum significance level for a misclassification during an actual
radiological emergency is Green.
2. If public officials implemented protective actions other than evacuation (e.g.,
sheltering, early closure of schools) for members of the public,
6
then the significance
level is White.
3. If public officials implemented an evacuation of the general public,
6
then the
significance level is Yellow.
e. Assess the significance of the FTI using Attachment 1 and the appropriate emergency
classification level that was or should have been declared.
f. If the cause of the finding was one or more noncompliant PE (e.g., procedure or training
shortcomings), also evaluate the finding as an FTC under Section 5.0.3 of this appendix.
If this results in a higher significance, treat the finding as an FTC.
g. Return to IMC 0612 to document the basis for the significance determination in the
inspection report.
5.0 FAILURE TO COMPLY
5.0.1 Background
a. This branch of the EP SDP, illustrated in Attachment 2, is used to assess the
significance of an FTC. An FTC signifies that an EP program is noncompliant with an
EP REQUIREMENT.
1. An FTC is generally identified during normal program inspection activities and is
related to an emergency preparedness issue, rather than an emergency response issue.
2. However, a finding of an FTI during an actual emergency event may uncover an
inadequate or noncompliant PE (e.g., procedure or training shortcomings), the
significance of which should also be assessed under this branch of the EP SDP, with the
higher significance finding cited.
6
If the ORO response was clearly inappropriate for the conditions present (e.g., ordering an
evacuation of the EPZ upon receiving notification of an Alert emergency), assign Green
significance.
Issue Date: 09/22/15 10 0609, Appendix B
b. Sections 5.1 through 5.16 of the appendix correspond respectively to PS
10 CFR 50.47(b)(1) through (b)(16). Each section does the following:
Identifies the PS and the associated PSF(s).Identifies references to supporting
requirements in Appendix E to 10 CFR Part 50 and the informing criteria of
NUREG-0654/FEMA-REP-1.
Provides examples of finding(s) corresponding to, as appropriate, LOSS OF
RSPS [PS] FUNCTION, DEGRADED RSPS [PS] FUNCTION, and Green finding.
c. The significance examples are neither all inclusive nor exclusive; instead, the examples
are intended to inform significance determinations. These examples may or may not
fully envelop the finding being considered. If no significance example envelops the
finding being considered, it will be necessary to compare the finding against the
definitions of LOSS OF RSPS [PS] FUNCTION, or DEGRADED RSPS [PS] FUNCTION
in conjunction with Attachment 2.
5.0.2 Criteria
a. Multiple PE may comprise the implementation aspects of each PS. These PE are
developed from the PS, the supporting requirements in Appendix E to 10 CFR Part 50,
the evaluation criteria guidance in NUREG-0654/FEMA-REP-1, and commitments made
in the approved E–plan. PS functionality does not require compliance with every PE.
An FTC with one or even a few inadequate PE is not necessarily a LOSS OF RSPS [PS]
FUNCTION. Consequently, the inspector must determine whether the PSF could be
accomplished in spite of the inadequate PE.
b. There may be circumstances in which the PE is found to be noncompliant but, because
of mitigating factors, the inspector is able to determine that reasonable assurance exists
that the PSF would be accomplished, albeit in a degraded manner, if an actual
radiological emergency were to occur. In such cases, the PSF would be degraded
rather than lost.
1. For example, an initiating condition that addresses a radioactive release contains
two EALs: an indication on an effluent radiation monitor or a certain result from an
analysis on a sample obtained from the effluent release stream. The licensee
determined that the radiation monitor indication was in error — a noncompliance.
Although the sample analysis results could provide a basis for an emergency
declaration, there would be a delay in identifying and classifying an abnormal release. In
this case, the PSF may be found to be degraded rather than lost.
2. To be considered in significance determinations, mitigating factors must have
already been in place before the TIME OF DISCOVERY. Section 5.0.2.h. of this
appendix addresses measures implemented by the licensee to compensate after
identification of the noncompliance.
c. Several significance examples address unavailability issues related to equipment and
facilities. These examples are intended to encompass equipment, systems, and
Issue Date: 09/22/15 11 0609, Appendix B
facilities specifically identified in the E–plan, or relied upon by the E–plan, as PE. Some
of these resources may serve other functions in the plant design or operations.
However, only the functions specifically identified in the E–plan should be considered
when assessing the significance of the finding. For example, an effluent radiation
monitor skid may include several monitor channels of which only one is used in an EAL
threshold. Only a finding with that channel would be assessed significance under this
d. Time limits and percentages are provided to inject objectivity and thus consistency to the
assessment process. These values should be used for any applicable finding in the
absence of extenuating circumstances for which the predetermined criteria need to be
reconsidered. In those rare cases, a different characterization of the finding could be
appropriate so long as the basis for the deviation is justified and agreed to by the SDP
and Enforcement Review Panel.
e. NRC EP regulations require licensees to have the capability of making classifications,
declarations, notifications, and initial PARs within specific periods of time. Licensees
establish these capabilities by providing sufficient personnel, procedures, equipment,
training, instrumentation, and other resources necessary to perform the functions in a
timely and accurate manner. A finding may exist if there is an issue of concern
regarding the licensee’s capability to make timely declarations, notifications, or PARs,
should an actual radiological emergency occur. Consider the following examples:
The licensee no longer has the personnel on shift to evaluate a seismic reading
used in the EAL scheme.
The licensee’s dose assessment capability no longer supports PAR
development.
The licensee’s EAL scheme allows an indeterminate delay in classifying a fire to
await verification of a fire alarm.
Although explicit timeliness requirements are not provided in regulation for follow-up
PARs or the notification of such PARs, the NRC expects that licensees will make followup PAR decisions as soon as possible after indications are available that a PAR
threshold has been exceeded and will notify OROs of such PARs as soon as possible.7
f. Many of the significance examples incorporate the concept of TIME OF DISCOVERY. It
should be assumed that the condition occurred at this time including, as necessary,
timely confirmation or analysis of raw indications (i.e., when the licensee “knew”).
7 Section IV.D.3 of Appendix E to 10 CFR Part 50 requires the licensee to have the capability to
notify State and local governmental agencies within 15 minutes after declaring an emergency.
PS 10 CFR 50.47(b)(5) requires that the content of initial and follow up messages to the public be
established. Evaluation Criterion II.E.3 in NUREG-0654/FEMA-REP-1 provides that the initial
notification contain information as to whether offsite protective measures may be necessary.
Some licensees have included these criteria in their E–plans or implementing procedures.
Issue Date: 09/22/15 12 0609, Appendix B
1. If a condition existed before it was discovered and it can be shown that the
licensee missed an earlier opportunity to recognize the condition, the TIME OF
DISCOVERY is the first missed opportunity (i.e., when the licensee “should have
known”). A missed opportunity occurs when the activity failed to identify a condition or
when corrective actions were not implemented upon identification.
2. Opportunities to identify conditions and initiate corrective actions may include
normal surveillances, log reviews, self-assessments, audits, quality assurance activities,
NRC generic communications, industry operating experience reports, condition reports,
and inspection reports.
3. Consideration should be given to the opportunities for identification; the ease of
discovery; specificity, relevance, and timing of a prior notification; and action(s) taken by
the licensee.
g. A finding related to licensee identification of a PD that occurred in the past (normally
older than 3 years) in engineering, design, or installation that is not reasonably linked to
the licensee’s present performance may be a candidate for enforcement discretion. See
IMC0305 11.05 for complete details. Examples of such findings for the EP Cornerstone
could be miscalculated EAL thresholds for installed radiation monitors or deficiencies in
emergency response facility design.
h. Some of the significance examples explicitly provide credit for viable measures that
compensate for the inadequate PE. Many of these significance examples also specify
duration for the condition, for example “...longer than 7 days from TIME OF DISCOVERY
and no COMPENSATORY MEASURES were implemented.”8 The following criteria
should be considered before crediting a COMPENSATORY MEASURE in a significance
determination:
1. The measure must be capable of accomplishing the affected PSF in a
reasonably comparable manner. For example, a company microwave link may be a
viable COMPENSATORY MEASURE for a failure of a private telephone bridge if all
OROs can still be notified without significant delay. However, “comparable” does not
require the COMPENSATORY MEASURES to meet the same performance
requirements as the primary method.
2. The measure must be in place before the end of the specified duration. If no
duration is specified, the measure must have been implemented in a timely manner
following discovery.
3. The specified duration is measured from the TIME OF DISCOVERY. If the
condition is first identified by the inspector, it will be necessary to assess when the
licensee should have known of the condition in determining the COMPENSATORY
MEASURE credit.
8
If the licensee did implement COMPENSATORY MEASURES that met the guidance of this
section, within the specified duration, the example threshold has not been exceeded.
Issue Date: 09/22/15 13 0609, Appendix B
4. The inspector should determine the following:
The measure was addressed in procedures, night orders, or the like, and
ERO members were made aware of the measure.
ERO personnel expected to implement the measure have received
training (unless the measure reasonably falls within the definition of “skill
of the craft”).
The necessary equipment and personnel were readily available to
implement the measure.
The licensee is placing an appropriate priority on completing corrective
actions.
5. A COMPENSATORY MEASURE is used only in assessing significance; as such,
a measure generally cannot be used to show compliance.
6. See Section 5.5 of this appendix for additional criteria for COMPENSATORY
MEASURES for ANS outages.
7. The EP SDP allows COMPENSATORY MEASURES to continue to be used in
certain situations in which the noncompliant PE was caused by major disruptive events
(e.g., hurricanes, fires, explosions, loss of offsite power) or are the result of a planned
outage of certain systems or facilities. The EP SDP recognizes that there may be delays
in implementing corrective actions that are not completely under the control of the
licensee. In these situations, such measures continue to be acceptable as long as the
licensee implements the corrective actions with appropriate priority. The significance
examples to which this provision applies are annotated to this effect.
5.0.3 Significance Determination
a. If the finding is related to EP REQUIREMENTS that are not associated with a PSF (e.g.,
10 CFR 50.54(q),10 CFR 50.54(t), and requirements in Appendix E to 10 CFR Part 50
that do not support a PSF), assign Green significance. Return to IMC 0612.
b. Identify the PSF(s) 9 affected by the finding. A finding may affect two or more PSF and
each should be assessed for significance.
c. Compare the identified finding to the examples tabulated in the appropriate section, and
if needed, Attachment 2, to identify the significance. The language of the PSF is
generally broad and the determination of the significance of a finding may not always be
obvious.
9 Sections 5.1 through 5.16, as applicable, of this EP SDP identify the requirements of Appendix E
to 10 CFR Part 50 that support the PS of 10 CFR 50.47(b).
Issue Date: 09/22/15 14 0609, Appendix B
1. The examples provided for each PSF are not intended to be all-inclusive or all
exclusive.
2. More than one PE may be associated with the PSF, and varied facility-specific
methods of implementation and a particular finding may not correspond directly to any
particular example provided.
3. Extenuating circumstances may need to be considered.
4. In making the significance determination, the analyst will need to use judgment,
informed by the examples that are provided. The cited supporting requirements and
informing criteria should be considered as necessary. Reviewing previous inspection
reports for a similar finding, where available, can provide additional insight.
d. Return to IMC 0612 to document the basis for the significance determination in the
inspection report.
5.1 10 CFR 50.47(b)(1), Emergency Response Responsibility
PLANNING STANDARD: Primary responsibilities for emergency response by the nuclear
facility licensee and by State and local organizations within the
Emergency Planning Zones have been assigned, the emergency
responsibilities of the various supporting organizations have been
specifically established, and each principal response organization
has staff to respond and to augment its initial response on a
continuous basis.
PS FUNCTIONS: 1. Responsibility for emergency response is assigned.
2. The response organization has the staff to respond and
augment on a continuing basis (24/7 staffing) in accordance
with the E–plan.
Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.A.1 through IV.A.8
Issue Date: 09/22/15 15 0609, Appendix B
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.A, and the licensee’s
approved E–plan
Table 5.1-1
Significance Examples for
LOSS OF PS FUNCTION:
White Finding
The ERO assigned responsibilities in the E–plan no longer
has the authority or resources to respond on a continuing
(24/7) basis.
DEGRAD. OF PS FUNC.
Green Finding:
An individual plant staffing change created an inability to
assign responsibility on a continuous basis.
Additional Guidance: None
5.2 10 CFR 50.47(b)(2), Onsite Emergency Organization
PLANNING STANDARD: On-shift facility licensee responsibilities for emergency response
are unambiguously defined, adequate staffing to provide initial
facility accident response in key functional areas is maintained at
all times, timely augmentation of response capabilities is available,
and the interfaces among various onsite response activities and
offsite support and response activities are specified.
PS FUNCTIONS: 1. Process ensures that on shift emergency response
responsibilities are staffed and assigned.
2. Process for timely augmentation of on shift staff is established
and maintained.
Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.A.2.a, b, c; IV.A.3;
IV.A.9; and IV.C
Informing Criteria: NUREG-0654,Section II.B and the licensee’s approved E–plan
Significance Examples
See Table 5.2.1
Additional Guidance:
EPPOS-3, “Emergency Preparedness Position (EPPOS) on Requirement for Onshift Dose
Assessment Capability,” dated November 8, 1995 [ML023040473]
Issue Date: 09/22/15 16 0609, Appendix B
Nuclear Energy Institute (NEI) 99-02, “Regulatory Assessment Performance Indicator
Guideline,” Revision 6, [ML092931123], identifies key ERO members.
NSIR/DPR-ISG-001, “Emergency Planning for Nuclear Power Plants” [ML113010523]
Information Notice (IN) 93-81, “Implementation of Engineering Expertise on Shift,” dated
October 12, 1993, http://www.nrc.gov/reading-rm/doc-collections/#gen
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS OF PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(2)
Process ensures that on shift
emergency response responsibilities are
staffed and assigned.
Process for timely augmentation of on
shift staff is established and maintained.
N/A
An EP responsibility for any key ERO
member function is not assigned.
ERO staffing levels are less than the
staffing levels provided for by the
licensee’s on shift staffing analysis to
the extent that more than one required
ERO functional area (in accordance with
E–plan commitments) would not be
staffed.
Scheduling and/or processes (not
personnel error) for on shift staffing
would allow two or more shifts to go
below E–plan minimum staffing
requirements within 30 days (e.g., 2 of 4
weekends in a month, 2 or more
backshifts over a 30-day period).
–––
Staffing augmentation processes are
routinely not capable of ensuring timely
augmentation of the on shift emergency
response staff to the extent that more
than one required ERO functional area
(in accordance with E–plan
commitments) would not be filled (e.g.,
repetitive activation test failures or
augmentation process design
inadequacies).
Failure to recognize loss of minimum
ERO staffing for more than a short
duration (e.g., 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) on two or more
shifts in a 30-day period.
Staffing processes would permit a shift
to go below E–plan minimum staffing
requirements, but there were no actual
instances in which such shortages
occurred.
(b)(2)
Table 5.2-1 -- Significance Examples §50.47(b)(2)
Issue Date: 09/22/15 17 0609, Appendix B
Issue Date: 09/22/15 18 0609, Appendix. B
5.3 10 CFR 50.47(b)(3), Emergency Response Support and Resources
PLANNING STANDARD: Arrangements for requesting and effectively using assistance
resources have been made, arrangements to accommodate State
and local staff at the licensee's Emergency Operations Facility
have been made, and other organizations capable of augmenting
the planned response have been identified.
PS FUNCTIONS: 1. Arrangements for requesting and using offsite assistance have
been made.
2. State and local staff can be accommodated at the EOF in
accordance with the E–plan.
Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.A.6 and IV.A.7
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.C, and the licensee’s
approved E–plan
Significance Examples
See Table 5.3-1
Additional Guidance: None
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS OF PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(3)
Arrangements for requesting and using
offsite assistance have been made.
State and local staff can be
accommodated at the EOF in
accordance with the E–plan.
N/A
E–plan commitments for offsite
assistance would no longer be met for
medical, fire, or law enforcement
support, including assistance for
response to hostile actions.
–––
The EOF has been changed in such a
manner that it would no longer
accommodate OROs in accordance with
the E–plan.*
- Some E–plans accommodate OROs
through means other than the physical
presence of personnel in the EOF (e.g.,
video teleconferencing).
E–plan elements have degraded to the
point that E–plan commitments for offsite
assistance would no longer be met for
support other than medical, fire, or law
enforcement support, including
assistance for response to hostile
actions.
Agreements with organizations
committed in the E–plan as supporting
the response effort have been allowed to
lapse and are currently not being sought,
but the agency remains willing to support
the E–plan.
(b)(3)
Table 5.3-1 -- Significance Examples §50.47(b)(3)
Issue Date: 09/22/15 19 0609, Appendix B
Issue Date: 09/22/15 20 0609, Appendix B
5.4 10 CFR 50.47(b)(4), Emergency Classification System
PLANNING STANDARD: A standard emergency classification and action level scheme, the
bases of which include facility system and effluent parameters, is
in use by the nuclear facility licensee, and State and local
response plans call for reliance on information provided by facility
licensees for determinations of minimum initial offsite response
measures.
RSPS FUNCTION: A standard scheme of emergency classification and action levels
is in use.
Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.B and IV.C
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.D, and the licensee’s
approved E–plan
The NRC has endorsed standard emergency classifications and
action level schemes in Regulatory Guide 1.101, “Emergency
Planning and Preparedness for Nuclear Reactors,” as being
acceptable alternatives for demonstrating compliance with this
RSPS FUNCTION. Additionally, the NRC has allowed certain
modifications to the classification schemes as outlined in
EPPOS-1, “Acceptable Deviations from Appendix 1 of NUREG0654 Based Upon the Staff's Regulatory Analysis of
NUMARC/NESP-007, ‘Methodology for Development of
Emergency Action Levels’” dated June 1, 1995.
Significance Examples
See Table 5.4-1 and
Figure 5.4-1
Additional Guidance:
NSIR/DPR-ISG-001, “Emergency Planning for Nuclear Power Plants” [ML113010523]
IN 1989-72, “Failure of Licensed Senior Operators to Classify Emergency Events Properly,”
dated October 24, 1989, http://www.nrc.gov/reading-rm/doc-collections/#gen
IN 2005-19, “Effect of Plant Configuration Changes on the Emergency Plan,” dated July 18,
2005, http://www.nrc.gov/reading-rm/doc-collections/#gen
Regulatory Issue Summary (RIS) 2003-18, “Use of NEI 99-01, ‘Methodology for Development of
Emergency Action Levels,’ Revision 4, Dated January 2003,” dated October 8, 2003,
http://www.nrc.gov/reading-rm/doc-collections/#gen
Issue Date: 09/22/15 21 0609, Appendix B
RIS 2003-18, Supplement 1, “Use of NEI 99-01, ‘Methodology for Development of Emergency
Action Levels,’ Revision 4, Dated January 2003,” dated July 13, 2003,
http://www.nrc.gov/reading-rm/doc-collections/#gen
EAL schemes typically have a series of initiating conditions (IC), which represent the condition
being classified and, for each IC, one or more EALs, which represent indications that the IC may
be exceeded. As used herein, an EAL is ineffective when it no longer results in a timely and
accurate declaration for the IC. A particular EAL may be a single indication or may include a list
of redundant instrument channels. In either case, it is treated as a single EAL for significance
purposes.
The significance examples differ by the licensee’s ability to make the proper emergency
declaration even with the ineffective EAL. An EAL may be rendered ineffective by changes to
facility procedures, systems, or equipment; errors in numeric thresholds; or any other cause that
could result in an IC, which should be declared, not being declared in a timely and accurate
manner following the change(s). These ineffective EAL examples do not apply to instruments
that are temporarily out of service if timely corrective actions are being taken to restore the
instrument(s).
EAL schemes often have either redundant or diverse indications for the same IC. Credit is to be
given to these alternative EALs as MITIGATING FACTORS if they were part of the licensee’s
approved emergency classification scheme before the ineffective EAL was identified. Other ICs
generally may not be credited as MITIGATING FACTORS. One of the following two
significance situations may exist:
(1) If the alternative EALs are such that an accurate declaration of the IC would still be
made, but delayed beyond the 15-minute timeliness capability requirement, the
classification function is degraded. An example would be waiting on an analysis of a
grab sample in lieu of observing a reading on a direct-indicating instrument.
(2) If the alternative EALs are such that an accurate and timely declaration of the IC would
still be made, the classification function is neither lost nor degraded. In this context,
timely means within the 15-minute timeliness capability requirement. For example, loss
or potential loss of the fuel barrier IC may include EALs such as reactor pressure vessel
(RPV) level and drywell radiation monitor. A decreased RPV level is a precursor to core
damage and can adequately compensate for an ineffective drywell radiation monitor
threshold because the declaration will still be timely and accurate. However, a
classification based on drywell radiation monitor threshold rather than an ineffective RPV
level would likely be delayed (as the core damage must first occur for the radiation
monitor to indicate).
The NRC expects declarations to be timely and accurate (See Section 5.0.2 of this EP SDP).
Unnecessary public protective actions caused by an overclassification are a concern since the
public could be placed at increased health risks without realizing the dose avoidance benefit of
a necessary protective action. The NRC encourages conservative decisionmaking in uncertain
events. However, the licensee’s emergency classification process should, to the extent
possible, support timely and accurate declarations should an emergency occur. A deficient
emergency classification process that would result in an overclassification and cause the
Issue Date: 09/22/15 22 0609, Appendix B
licensee to make a protective action recommendation, or cause OROs to implement protective
actions (e.g., a nondiscretionary precautionary evacuation of schools on a Site Area
Emergency) by procedure, should be identified as a DEGRADATION OF RSPS FUNCTION. A
deficient emergency classification process that would result in an overclassification, but would
not result in unnecessary public protective measures, should be identified as a Green finding.
See NSIR/DPR-ISG-001 for guidance on the timeliness criteria, including when the “clock” starts
and stops for classification and declaration.
PLANNING STANDARD
FUNCTION(s)
LOSS of RSPS FUNCTION
Yellow Finding
Yellow Finding
DEGRADED RSPS FUNCTION
White Finding Green Finding
(b)(4)
A standard scheme of emergency
classification and action levels is in use.
Continued
An EAL has been rendered ineffective
such that any General Emergency would
not be declared for a particular
off-normal event.
An EAL has been rendered ineffective
such that any General Emergency would
not be declared for a particular
off-normal event, but because of other
EALs, an appropriate declaration could
be made in a degraded manner (e.g.,
delayed).
An EAL has been rendered ineffective
such that any Site Area Emergency
would not be declared for a particular
off-normal event.
The EAL classification process* is not
capable of classifying a General
Emergency or a Site Area Emergency
within 15 minutes or declaring the
emergency promptly once the
appropriate classification level is
determined.
An EAL has been rendered ineffective
such that any General Emergency would
not be declared for a particular
off-normal event, but because of other
EALs, an appropriate declaration could
be made in an accurate and timely
manner.
An EAL has been rendered ineffective
such that any Site Area Emergency
would not be declared for a particular
off-normal event, but because of other
EALs, an appropriate declaration could
be made in a degraded manner (e.g.,
delayed).
An EAL has been rendered ineffective
such that any Alert or NOUE would not
be declared, or declared in a degraded
manner for a particular off-normal event.
The EAL classification process* is not
capable of classifying an Alert or NOUE
within 15 minutes or declaring the
emergency promptly once the
appropriate classification level is
determined.
- EAL classification process includes
facility procedures; training; ERO
staffing; system, instrumentation, or
equipment; or other resources or
capabilities necessary to complete a
classification or declaration.
(b)(4)
Table 5.4-1 -- Significance Examples §50.47(b)(4)
Issue Date: 09/22/15 23 0609, Appendix B
PLANNING STANDARD
FUNCTION(s)
LOSS of RSPS FUNCTION
Yellow Finding
Yellow Finding
DEGRADED RSPS FUNCTION
White Finding Green Finding
(b)(4) Continued
A standard scheme of emergency
classification and action levels is in use.
The EAL classification process* would
result in an over classification that would
procedure (i.e., a non-discretionary
action), unnecessary protective actions
for the public. (In making this
determination, consider only those
public protective actions that would be
triggered by an ORO receiving
notification of a particular emergency
classification (e.g., “when the plant
reports this then do this”). This condition
should also be considered met if the
licensee would make a PAR to the
OROs because of the
overclassification.)
- EAL classification process includes
facility procedures; training; ERO
staffing; system, instrumentation, or
equipment; or other resources or
capabilities necessary to complete a
classification or declaration.
The EAL classification process* would
result in an over-classification causing
an unnecessary emergency declaration.
Annual EAL review is not conducted with
State and local governmental authorities.
(b)(4)
Table 5.4-1 (Continued) -- Significance Examples §50.47(b)(4)
Issue Date: 09/22/15 24 0609, Appendix B
Issue Date: 09/22/15 25 0609, Appendix. B
Figure 5.4-1
Significance Determination for Ineffective EALs and Overclassification
EAL Deficiency Classification Level Impact of Deficient EAL
Yellow Event would not be declared
White Event would be declared in a degraded manner 1
Green Event would be declared in a timely and accurate manner 1
White Event would not be declared
Green Event would be declared in a degraded manner 1
No Finding Event would be declared in a timely and accurate manner 4
1
General Emergency
Site Area Emergency
Green Event would not be declared
Green Event would be declared in a degraded manner 1
No Finding Event would be declared in a timely and accurate manner 4
1
NOUE or Alert
Ineffective EAL 2
Would result in unnecessary PARs for the public White
3
Would result in unnecessary classification Green EAL Overclassification
EAL Issue
Finding
1 Emergency condition would be declared because of unaffected redundant or diverse EAL thresholds.
2 An EAL is ineffective when it, in of itself, no longer results in a timely and accurate declaration for the initiating condition.
3
In making this determination, consider only those public protective actions that would be triggered by an ORO receiving notification of
a particular emergency classification (e.g., an invalid General Emergency declaration). This significance logic does not apply to over
classifications during an actual event.
4. Return to IMC 0612 and reconsider the more-than-minor determination.
Issue Date: 09/22/15 26 0609, Appendix. B
Significance Examples
See Table 5.5-1
Additional Guidance:
The significance examples provide for COMPENSATORY MEASURES as means of mitigating
the significance of certain finding(s). See Section 5.0.2.h. of this appendix for additional
guidance.
IN 2002-25, “Challenges to Licensee’s Ability to Provide Prompt Public Notification and
Information During an Emergency Preparedness Event,” dated August 26, 2002,
http://www.nrc.gov/reading-rm/doc-collections/#gen
5.5 10 CFR 50.47(b)(5), Emergency Notifications
PLANNING STANDARD: Procedures have been established for notification, by the licensee,
of State and local response organizations and for notification of
emergency personnel by all organizations; the content of initial
and follow-up messages to response organizations and the public
has been established; and means to provide early notification and
clear instruction to the populace within the plume exposure
pathway Emergency Planning Zone have been established.
RSPS FUNCTIONS: 1. Procedures for notification of State and local governmental
agencies are capable of alerting them of the declared
emergency within 15 minutes after declaration of an
emergency and providing subsequent follow-up notifications.
2. Administrative and physical means have been established for
alerting and providing prompt instructions to the public within
the plume exposure pathway.
3. The public alert and notification system meets the design
requirements of FEMA-REP-10, “Guide for Evaluation of Alert
and Notification Systems for Nuclear Power Plants,” or
complies with the FEMA approved ANS design report and
supporting FEMA approval letter.
Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.D.1 and IV.D.3
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.E and Appendix 3, and the
licensee’s approved E–plan
Additional criteria integral to this RSPS FUNCTION is found in
FEMA REP-10.
Issue Date: 09/22/15 27 0609, Appendix. B
IN 2005-06, “Failure to Maintain Alert and Notification System Tone Alert Radio Capability,”
dated March 30, 2005, http://www.nrc.gov/reading-rm/doc-collections/#gen
In the notification significance examples, the scope of OROs is limited to those agencies that
the licensee must directly notify of an emergency as described in the E–plan. This would
typically include State, county, municipal, and Tribal emergency management agencies, but
may include others that are notified by the licensee within 15-minutes of an emergency
declaration.
Section IV.D.3 of Appendix E to 10 CFR Part 50 requires the licensee to demonstrate that the
primary and backup ANS administrative and physical means of alerting the public have been
established. The NRC uses the FEMA-approved final ANS design report as evidence that the
means have been established. The following applies:
Since the final ANS design report is approved by FEMA, licensee-proposed measures to
compensate for ANS outages or failures must meet the criteria in Section 5.0.2.h, and be
reviewed by FEMA for acceptability, before being credited in determining significance.
The Office of Nuclear Security and Incident Response/Division of Preparedness and
Response (NSIR/DPR) staff will refer the issue to FEMA Headquarters for additional
input.
FEMA must approve substantive changes to the ANS, hardware, testing, and
maintenance under 44 CFR 350, “Review and Approval of State and Local Radiological
Emergency Plans and Preparedness.” A review under 10 CFR 50.54(q)(3) is not
sufficient.
FEMA evaluation of licensee deviations from the FEMA-approved final ANS design
report (e.g., licensee fails to perform maintenance described in the design report) will be
obtained before citing a finding related to these deviations. The NSIR/DPR staff will
refer the issue to FEMA Headquarters for its input. Subsequent enforcement will
depend on the input received from FEMA.
An approved prearranged backup method of notification, described in the FEMA approved ANS
design report that meets the performance requirements described in Section IV.D.3 of Appendix
E to 10 CFR Part 50 for the primary notification means may be credited for determining
compliance. Otherwise, the prearranged backup method can serve as a COMPENSATORY
MEASURE only for determining significance. Primary ANS outages caused by planned
maintenance and testing as identified in the FEMA-approved ANS Design Report are generally
not FTCs.
There is an extensive record of case law related to intervener contentions regarding the
requirements in 10 CFR 50.47(b)(5) or Section IV.D of Appendix E to 10 CFR Part 50
particularly, the “...about 15-minute...” performance criteria. In general, such rulings have
precedence only for the contested docket, but may be useful in informing staff decisions.
Assistance should be sought from NRC counsel. Some significant rulings include the following:
Generic CLI-80-40, 12 NRC 636; Indian Point 18 NRC 811, 18 NRC 939 San Onofre 15 NRC
1163, 17 NRC 346, 17 NRC 528; Seabrook 29 NRC 527, 31 NRC 213, 32 NRC 57; Shearon
Harris 23 NRC 294, 24 NRC 532; Shoreham 21 NRC 644, 27 NRC 85, 28 NRC 275, 28 NRC
603; Vermont Yankee CLI-74-40, 8 AEC 809
PLANNING STANDARD
FUNCTION(s)
LOSS of RSPS FUNCTION
Yellow Finding
Yellow Finding
DEGRADED RSPS FUNCTION
White Finding Green Finding
(b)(5)
Procedures for notification of State and
local governmental agencies are
capable of alerting them of the declared
emergency within 15 minutes after
declaration of an emergency and
providing subsequent follow-up
notifications.
Administrative and physical means have
been established for alerting and
providing prompt instructions to the
public within the plume exposure
pathway
The public ANS meets the design
requirements of FEMA-REP-10 or
complies with the FEMA approved ANS
design report and supporting FEMA
approval letter.
Continued
The notification process (e.g.,
procedures, systems, and resources) is
not capable of alerting ANY responsible
ORO of the declared emergency within
15 minutes after declaring an
emergency.
–––
Loss of both the primary and backup
methods of alerting the populations
within 0–5 miles of the plant.
–––
Deficiencies in the licensee’s program for
performing ANS testing and
maintenance results in a major loss of
the system for a significant period from
the TIME OF DISCOVERY (e.g., 100%
over 35 days, greater than 80% over 45
days, greater than 40% over 90 days,
greater than 20% over 6 months).
The notification process (e.g.,
procedures, systems, and resources) is
not capable of alerting ALL responsible
OROs of the declared emergency within
15 minutes after declaring an
emergency.
–––
Loss of both the primary and backup
methods of alerting the population within
5–10 miles of the plant.
Loss of the primary method of alerting
100% of the population within 0–5 miles
of the plant with the prearranged backup
capability still available. (See Additional
Guidance section regarding a planned
ANS outage.)
–––
Deficiencies in the licensee’s program for
performing ANS testing and
maintenance degrade a portion of the
system for a significant period from the
TIME OF DISCOVERY (e.g., 100% over
25 days, greater than 48% over 45 days,
greater than 24% over 90 days, greater
than 12% over 6 months).
The notification process (e.g.,
procedures, systems, and resources) is
not capable of providing follow-up
notifications to ANY responsible OROs
during an emergency.
–––
Loss of the approved backup method of
alerting the population within the plume
exposure EPZ with the primary capability
still available.
–––
An individual siren has been available
less than 70% of the time over a period
of 12 months as a result of inadequate or
delayed corrective actions.
An individual siren has not been
available for a continuous period of
greater than 4 months with inadequate or
delayed corrective actions.
(b)(5)
Table 5.5-1 -- Significance Examples §50.47(b)(5)
Issue Date: 09/22/15 28 0609, Appendix. B
PLANNING STANDARD
FUNCTION(s)
LOSS of RSPS FUNCTION
Yellow Finding
DEGRADED RSPS FUNCTION
White Finding Green Finding
(b)(5) Continued
The public ANS meets the design
requirements of FEMA-REP-10 or
complies with the FEMA approved ANS
design report and supporting FEMA
approval letter.
Licensee ANS test and maintenance
programs do not comply with requirements
in the ANS design report.
Licensee made changes to the ANS or the
testing and maintenance program,
described in the ANS design report,
without prior FEMA approval.
Loss of an ANS design feature (e.g.,
feedback system, battery backup, loud
hailing features) identified in the ANS
design report.
NOTE: See text on Page B-25 of this
appendix with regard to obtaining FEMA
evaluation of deviations from the ANS
design report before citing a finding
against one of these three examples.
(b)(5)
Table 5.5-1 (Continued)-- Significance Examples §50.47(b)(2)
Issue Date: 09/22/15 29 0609, Appendix. B
Issue Date: 09/22/15 30 0609, Appendix B
Significance Examples
See Table 5.6-1
Additional Guidance:
The significance examples provide for COMPENSATORY MEASURES as means of mitigating
the significance of certain finding(s). See Section 5.0.2.h. of this appendix for additional
guidance.
NEI 99-02, “Regulatory Assessment Performance Indicator Guideline,” [ML092931123],
identifies key ERO members.
5.6 10 CFR 50.47(b)(6), Emergency Communications
PLANNING STANDARD: Provisions exist for prompt communications among principal
response organizations to emergency personnel and to the public.
PS FUNCTIONS: 1. Systems are established for prompt communication among
principal emergency response organizations.
2. Systems are established for prompt communication to
emergency response personnel.
Supporting Requirements: 10 CFR Part 50, Appendix E, Section IV.E.9
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.F, and the licensee’s
approved E–plan
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS OF PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(6)
Systems are established for prompt
communication among principal
emergency response organizations.
Systems are established for prompt
communication to emergency response
personnel.
N/A
Communications systems have
degraded such that no communications
channel between any two key ERO
members is available in the TSC, EOF,
or control room, including alternate
facilities, or no communication channel
between the ERO and OROs is available
for longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the TIME
OF DISCOVERY and no COMPENSATORY MEASURES were implemented.*
Loss of communications capability, for
longer than 7 days from the TIME OF
DISCOVERY such that no
communications channel between any
key ERO member and any individual,
group, or organization with whom that
key ERO member is expected to
interface (e.g., field teams, OROs) and
no COMPENSATORY MEASURES
were implemented.*
Backup power supplies for at least one
onsite and one offsite communications
systems are not functional for more than
30 days from the TIME OF DISCOVERY
and no COMPENSATORY MEASURES
were implemented.
- In the event of major disruptive events (e.g.,
hurricane, fire, explosion, loss of power) or
planned outages, COMPENSATORY
MEASURES are acceptable while repair
activities proceed with high priority.
Communications equipment for key ERO
members in an emergency facility is
degraded (e.g., many phones) at the
TIME OF DISCOVERY and no COMPENSATORY MEASURES were
implemented.*
Backup power supplies for at least one
onsite and one offsite communications
systems, as required by Appendix E to
10 CFR Part 50, are not functional for
more than 3 days from the TIME OF
DISCOVERY and no COMPENSATORY
MEASURES were implemented.*
(b)(6)
Table 5.6-1 -- Significance Examples §50.47(b)(6)
Issue Date: 09/22/15 31 0609, Appendix B
Issue Date: 09/22/15 32 0609, Appendix B
Significance Examples
See Table 5.7-1
Additional Guidance:
The significance examples provide for COMPENSATORY MEASURES as means of mitigating
the significance of certain finding(s). See Section 5.0.2.h. of this appendix for additional
guidance.
EPPOS-5, “Emergency Preparedness Position (EPPOS) on Emergency Planning Information
Provided to the Public,” dated December 4, 2002, [ML023040492]
5.7 10 CFR 50.47(b)(7), Emergency Public Information
PLANNING STANDARD: Information is made available to the public on a periodic basis on
how they will be notified and what their initial actions should be in
an emergency (e.g., listening to a local broadcast station and
remaining indoors), the principal points of contact with the news
media for dissemination of information during an emergency
(including the physical location or locations) are established in
advance, and procedures for coordinated dissemination of
information to the public are established.
PS FUNCTIONS: 1. EP information is made available to the public on a periodic
basis within the plume exposure pathway EPZ.
2. Coordinated dissemination of public information during
emergencies is established.
Supporting Requirements: 10 CFR Part 50, Appendix E, Section IV.D.2
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.G; NUREG-0696; and the
licensee’s approved E–plan
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS OF PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(7)
EP information is made available to the
public on a periodic basis within the
plume exposure pathway EPZ.
Continued
N/A
Processes do not provide for the
complete dissemination of EP-related
public information such that the licensee
does not provide information to all
transient areas, EPZ segments, or other
specialized/localized groups (e.g., hotels,
recreational parks, select phone books,
zip codes).
EP-related public information documents
do not contain the required information
(e.g., how the public will be notified, what
their actions should be, and principal
points of contact for information during
an emergency).
Locations within the licensee’s owner
controlled area, accessible by individuals
who have not completed appropriate
access training, are not provided
appropriate EP-related public information
to which the licensee committed in the
E–plan or, in the absence of E–plan
commitment, Federal regulation.*
- For some locations, signs and the like
may be appropriate for disseminating
public information.
Processes or procedures for
disseminating information to the public
are not maintained, such that significant
elements of the public information
process are degraded (e.g., contact lists
are not effective, approval process
cannot be implemented because of
organizational changes, news releases
are untimely, licensee news briefings are
not coordinated with OROs).
EP-related public information has not
been disseminated for a period longer
than that to which the licensee
committed in the E–plan or, in the
absence of E–plan commitment, Federal
regulation.
Locations within the licensee’s owner
controlled area, accessible by individuals
who have not completed appropriate
access training, are not provided
EP-related public information for a period
longer than that to which the licensee
committed in the E–plan or, in the
absence of E–plan commitment, Federal
regulation.*
(b)(7)
Table 5.7-1 -- Significance Examples §50.47(b)(7)
Issue Date: 09/22/15 33 0609, Appendix B
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS OF PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(7) Continued
Coordinated dissemination of public
information during emergencies is
established.
N/A
Licensee processes would not provide
for timely and accurate information
releases to such an extent that the health
and safety of the public would be
compromised during emergencies (e.g.,
the ERO members are not knowledgeable with regard to emergency news
center operations, procedures for
disseminating information are not
established, augmentation (call-out)
processes would not ensure timely
activation of the emergency news center,
or untimely methods for information
approval).
Licensee processes would not
coordinate news briefings to such an
extent that the health and safety of the
public would be compromised during
emergencies (e.g., information is
inaccurate, contradictory, or delayed).
Licensee processes at the joint
information center would not provide for
the issuance of a news release during an
NOUE or Alert declaration in accordance
with E–plan commitments.
Familiarization programs for news media
are not conducted as the licensee
committed in the E–plan or, in the
absence of E–plan commitment, Federal
regulation.
(b)(7)
Table 5.7-1 (Continued)-- Significance Examples §50.47(b)(7)
Issue Date: 09/22/15 34 0609, Appendix B
Issue Date: 09/22/15 35 0609, Appendix. B
Significance Examples
See Table 5.8-1
Additional Guidance:
The significance examples provide for COMPENSATORY MEASURES as means of mitigating
the significance of certain finding(s). See Section 5.0.2.h. of this appendix for additional
guidance.
The principal functional areas of emergency response are, as established in 10 CFR Part 50,
Appendix E, §IV.F.2.b: management and coordination of emergency response, accident
assessment, event classification, notification of offsite authorities, assessment of the onsite and
offsite impact of radiological releases, protective action recommendation development,
protective action decision making, plant system repair, and mitigative action implementation.
IN 2004-19, “Problems Associated with Back-up Power Supplies to Emergency Response
Facilities and Equipment,” dated November 4, 2004,
http://www.nrc.gov/reading-rm/doc-collections/#gen
The TSC, and the EOF in certain cases, have habitability requirements in NUREG-0696 that
derive in part from the habitability requirements for the main control room. Although neither
document is explicitly applicable to TSCs or EOFs, the following additional guidance may be
useful in informing issues related to TSC and EOF habitability.
GL 2003-01, “Control Room Habitability,” dated June 12, 2003. http://www.nrc.gov/readingrm/doc-collections/gen-letters/2003/gl03001.pdf
RIS 2006-04, “Experience With Implementation of Alternative Source Terms,” dated March 7,
2006, http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2006/ri200604.pdf
5.8 10 CFR 50.47(b)(8), Emergency Facilities and Equipment
PLANNING STANDARD: Adequate emergency facilities and equipment to support the
emergency response are provided and maintained.
PS FUNCTIONS: 1. Adequate facilities are maintained to support emergency
response.
2. Adequate equipment is maintained to support emergency
response.
Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.E1–4, IV.E.8, IV.G
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.G; NUREG-0696; and the
licensee’s approved E–plan
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS OF PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(8)
Adequate facilities are maintained to
support emergency response.
Continued
N/A
The OSC, TSC, or EOF is not functional,
to the extent that any principal functional
area of emergency response assigned to
the facility could not be performed, for a
period of longer than 7 days from the
TIME OF DISCOVERY and no
COMPENSATORY MEASURES were
implemented.*
A backup or alternative emergency
response facility is no longer capable of
being activated in accordance with the
E–plan for a period of longer than 30
days from the TIME OF DISCOVERY,
and no COMPENSATORY MEASURES
were implemented.*
- In the event of major disruptive events
(e.g., hurricane, fire, explosion, loss of
power) or planned outages, COMPENSATORY MEASURES are acceptable
while repair activities proceed with high
priority.
The OSC, TSC, or EOF is not functional
to the extent that any principal functional
area of emergency response assigned to
the facility could not be performed, for a
period of longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the
TIME OF DISCOVERY, and no COMPENSATORY MEASURES were
implemented.*
A backup or alternative emergency
response facility is no longer capable of
being activated in accordance with the
E–plan for a period of longer than 7 days
from the TIME OF DISCOVERY, and no
COMPENSATORY MEASURES were
implemented.*
Changes have been made to the OSC,
TSC, or EOF that do not comply with the
E–plan, but the facilities remain
functional.
A licensee having a primary EOF greater
than 25 miles from a reactor site has not
maintained adequate provisions for
locating the NRC and offsite responders
closer to the site (e.g., inadequate
space, communication links with other
computer links with internet access, or
copying equipment and office supplies.
(b)(8)
Table 5.8-1 -- Significance Examples §50.47(b)(8)
Issue Date: 09/22/15 36 0609, Appendix B
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS OF PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(8) Continued
Adequate equipment is maintained to
support emergency response.
N/A
–––
Equipment necessary to implement the
E–plan is not available or not functional,
to the extent that any principal functional
area of emergency response could not
be performed, for a period of longer than
7 days from the TIME OF DISCOVERY,
and no COMPENSATORY MEASURES
were implemented. (e.g., lack of
engineering documents would prevent
TSC technical support from performing
function). The availability of additional
onsite equipment, in a reasonably timely
manner, is considered to be a
COMPENSATORY MEASURE for this
PSF.
–––
A significant amount of equipment
necessary to implement the E–plan is
not available or functional to the extent
that any principal functional area or
emergency response could not be
performed, and no COMPENSATORY
MEASURES were implemented.
(b)(8)
Table 5.8-1 (Continued)-- Significance Examples §50.47(b)(8)
Issue Date: 09/22/15 37 0609, Appendix B
Issue Date: 09/22/15 38 0609, Appendix. B
5.9 10 CFR 50.47(b)(9), Emergency Assessment Capability
PLANNING STANDARD: Adequate methods, systems, and equipment for assessing and
monitoring actual or potential offsite consequences of a
radiological emergency condition are in use.
RSPS FUNCTION: Methods, systems, and equipment for assessment of radioactive
releases are in use.
Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.B and IV.E.2
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.I, and the licensee’s
approved E–plan
Significance Examples
See Table 5.9-1
Additional Guidance:
The significance examples provide for COMPENSATORY MEASURES as means of mitigating the
significance of certain finding(s). See Section 5.0.2.h of this appendix for additional guidance.
EPPOS-3, “Emergency Preparedness Position (EPPOS) on Requirement for Onshift Dose Assessment
Capability,” dated November 8, 1995. [ML023040473]
Some significance examples refer to an incapability of providing technically adequate estimates of
projected releases and doses. As with all significance examples, the focus is on a PD that is reasonably
under the licensee’s control to identify and prevent. Quantification of the magnitude of the error is not
required. These errors may be identified during exercise when licensee results are compared to those
performed by other entities. The following conditions are generally under the licensee’s control:
Inadequate procedures and training may cause users to select processing options or make data
entries that are not appropriate for the particular projections being performed.
Use of a dose projection model that does not account for site-specific and plant-specific
meteorological regimes, terrain characteristics, release pathway configuration (e.g., elevated
versus ground, building wake)
Site- and unit-specific data files that adapt the modeling to a particular site (e.g., monitor
efficiencies, terrain heights, stack heights, etc.) are inconsistent with the site configuration.
Conversely, the inherent uncertainties in the components of a dose projection — source term,
meteorology, and dose calculation — are generally not under the control of the licensee, and therefore
are not PDs.
PLANNING STANDARD
FUNCTION(s)
LOSS of RSPS FUNCTION
Yellow Finding
DEGRADED RSPS FUNCTION
White Finding Green Finding
(b)(9)
Methods, systems, and equipment for
assessment of radioactive releases are
in use.
The dose projection process is
incapable* of providing technically
adequate estimates of radioactive
material releases to the environment or
projected offsite doses in any case.
Equipment or systems necessary for
dose projection are not functional for
longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the TIME OF
DISCOVERY, to the extent that the
licensee has no capability for immediate
dose projection.
The field monitoring function (at least
dose rate measurement and iodine
presence determination) is unavailable
for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the TIME
OF DISCOVERY and no COMPENSATORY MEASURES were implemented**.
The dose projection process is
incapable* of providing technically
adequate estimates of radioactive
material releases to the environment or
projected offsite doses in some cases.
Equipment or systems necessary for
dose projection are not functional for
longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the TIME OF
DISCOVERY, to the extent that the
licensee has no capability for immediate
dose projection in facility emergency
response centers as committed to in the
E–plan.
- Because of a systematic deficiency in
input data, calculational methodology
and assumptions, user procedures, user
training, etc. Systematic deficiencies do
not include normal uncertainties inherent
to the dose assessment process or end
user errors.
- In the event of major disruptive events
(e.g., hurricane, fire, explosion, loss of
power) or planned outage,
COMPENSATORY MEASURES are
acceptable while repair activities
proceed with high priority.
The field monitoring function in
accordance with the E–plan is
unavailable for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from
the TIME OF DISCOVERY, and no
COMPENSATORY MEASURES were
implemented**.
The dose projection process is
incapable* of providing technically
adequate estimates of radioactive
material releases to the environment or
projected offsite doses beyond 10 miles
but less than 50 miles
Equipment or systems necessary for
dose projection are not functional for
longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the TIME OF
DISCOVERY and no COMPENSATORY
MEASURES were implemented or
corrective actions are inadequate or
delayed.
(b)(9)
.
Table 5.9-1 -- Significance Examples §50.47(b)(9)
Issue Date: 09/22/15 39 0609, Appendix B
Issue Date: 09/22/15 40 0609, Appendix B
Significance Examples
See Table 5.10-1
Additional Guidance:
The significance examples provide for COMPENSATORY MEASURES as means of mitigating
the significance of certain finding(s). See Section 5.0.2.h of this appendix for additional
guidance.
5.10 10 CFR 50.47(b)(10), Emergency Protective Actions
PLANNING STANDARD: A range of protective actions has been developed for the plume
exposure pathway EPZ for emergency workers and the public. In
developing this range of actions, consideration has been given to
evacuation, sheltering, and, as a supplement to these, the
prophylactic use of potassium iodide (KI), as appropriate.
Evacuation time estimates have been developed by applicants
and licensees. Licensees shall update the evacuation time
estimates on a periodic basis. Guidelines for the choice of
protective actions during an emergency, consistent with Federal
guidance, are developed and in place, and protective actions for
the ingestion exposure pathway EPZ appropriate to the locale
have been developed.
RSPS FUNCTIONS:
PS FUNCTIONS:
1. A range of public PARs (excluding KI) is available for
implementation during emergencies.
2. ETEs for the population located in the plume exposure
pathway EPZ are available to support formulation of PARs and
have been provided to State and local governmental
authorities.
1. A range of protective actions is available for emergency
workers during emergencies, including hostile action events.
2. KI is available for implementation as a protective action
recommendation in those jurisdictions that chose to provide KI
to the public.
Supporting Requirements: Appendix E,Section IV.I
Informing Criteria: NUREG-0654/FEMA-REP-1, Sections II.J.1–8, II.J.2–6, and
II.J.10; Supplement 3 to NUREG-0654; and the licensee’s
approved E–plan
Issue Date: 09/22/15 41 0609, Appendix B
NUREG/CR-7002, “Criteria for Development of Evacuation Time Estimates Studies”
[ML113010515]
NUREG-0654/FEMA-REP-1, Supplement 3, “Guidance for Protective Action Strategies”
[ML113010596]
NSIR/DPR-ISG-001, “Emergency Planning for Nuclear Power Plants” [ML113010523]
(Remaining documents can be found at http://www.nrc.gov/reading-rm/doc-collections/#gen )
IN 1998-20, “Problems with Emergency Preparedness Respiratory Programs,” dated
June 3, 1998
RIS 2002-14, “Ensuring a Capability to Evacuate Individuals, Including Members of the Public,
From the Owner-Controlled Area,” dated April 8, 2002
RIS 2002-21, “National Guard and Other Emergency Responders Located in Licensee’s
Controlled Area,” dated November 8, 2002
RIS 2003-12, “Clarification of NRC Guidance for Modifying Protective Actions,” dated
June 24, 2003
RIS-2004-13, “Consideration of Sheltering in Licensee's Range of Protective Action
Recommendations,” dated August 2, 2004, and Supplement 1, dated March 10, 2005
RIS-2005-08, “Endorsement of Nuclear Energy Institute (NEI) Guidance ‘Range of Protective
Actions for Nuclear Power Plant Incidents,’” dated June 6, 2005
IN 2002-14, “Ensuring a Capability to Evacuate Individuals, Including Members of the Public,
from the Owner-Controlled Area” dated April 8, 2002
PLANNING STANDARD
FUNCTION(s)
LOSS of RSPS FUNCTION
Yellow Finding
DEGRADED RSPS FUNCTION
White Finding Green Finding
(b)(10)
A range of public PARs (excluding KI) is
available for implementation during
emergencies.
Approved ETEs for the population in the
plume exposure pathway EPZ are
available to support formulation of PARs
and have been provided to State and
local governmental authorities.
Continued
The PAR process* does not provide for
timely initial and subsequent PARs that
are in accordance with E–plan
commitments or Federal guidance to the
extent that necessary evacuation or
sheltering PARs would not be issued to
cover affected areas** within 5 miles of
the site.
The capability to implement protective
actions within the owner controlled area
(refer to IN 2002-14) is deficient to the
extent that procedures, equipment, or
personnel would not be capable of timely
evacuation and processing of members
of the public who might be present.
–––
The PAR process* does not provide for
timely initial and subsequent PARs that
are in accordance with E–plan
commitments or Federal guidance to the
extent that necessary evacuation or
sheltering PARs would not be issued to
cover affected areas** within 5 to 10
miles of the site.
The capability to implement protective
actions within the owner controlled area
(refer to IN 2002-14) is deficient to the
extent that procedures, equipment, or
personnel would not consistently provide
assurance of timely evacuation and
processing of members of the public who
might be present.
–––
The ETE analysis has not been updated
as required.
The PAR process* does not provide for
timely initial and subsequent PARs that
are in accordance E–plan commitments
or Federal guidance to the extent that
necessary evacuation or sheltering
PARs would not be issued to cover
affected areas** beyond the plume
exposure pathway EPZ.
The PAR process* provides an initial or
subsequent PAR that recommends
members of the public be evacuated
unnecessarily from areas where the
PAGs are not predicted to be exceeded
based upon the existing or projected
plant conditions, meteorological
conditions, or dose assessments.
–––
ETEs and updates to the ETEs were not
provided to responsible OROs.
The current public protective action
strategies documented in EPIPs are not
consistent with the current ETE.
(b)(10)
Table 5.10-1 -- Significance Examples §50.47(b)(10)
Issue Date: 09/22/15 42 0609, Appendix B
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS of PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(10) (Continued)
A range of protective actions is available
for emergency workers during
emergencies, including hostile action
events.
Continued
N/A
–––
A significant fraction (e.g., greater than
25%) of the onsite notification system
(e.g., plant page speakers) is out of
service in occupied areas that would
need to be evacuated during an
emergency for longer than 7 days from
the TIME OF DISCOVERY, and no
COMPENSATORY MEASURES were
implemented.
The site evacuation process is deficient
to the extent that it cannot be
accomplished during an emergency.
The accountability process is deficient to
the extent that it cannot ensure that
onsite accountability is achieved and
maintained during an emergency.
The site process for implementing
protective actions during hostile action
events is deficient to the extent that the
site’s capability to safely shut down the
reactor or perform the RSPS functions of
the E–plan is lost.
Onsite respiratory protective equipment
is degraded, or personnel are not
qualified to use it, to the extent that the
minimum complement of control room
operators could not be protected for at
least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (if needed) from the TIME
OF DISCOVERY, and no COMPENSATORY MEASURES were
implemented.
–––
A fraction (e.g., greater than 10%) of the
onsite notification system (e.g., plant
page speakers) is out of service in
occupied areas that would need to be
evacuated during an emergency for
longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the TIME OF
DISCOVERY, and no COMPENSATORY MEASURES were implemented.
The site process for implementing
protective actions during hostile action
events is deficient to the extent that the
site’s capability to perform the functions
of the E–plan is lost.
Onsite respiratory protective equipment
is not maintained in accordance with
regulations or E–plan commitments.
Emergency workers who would be
required to use respiratory protective
equipment are not qualified or trained to
use that equipment.
The KI program is not maintained in
accordance with regulations or E–plan
commitments.
(b)(10)
Table 5.10-1 (Continued)-- Significance Examples §50.47(b)(10)
Issue Date: 09/22/15 43 0609, Appendix B
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS of PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(10) (Continued)
KI is available for implementation as a
PAR in those jurisdictions that choose to
provide KI to the public.
N/A
–––
The PAR process* does not provide for
timely initial and subsequent KI PARs
that are in accordance with E–plan
commitments or Federal guidance to the
extent that necessary KI PARs would not
be issued to cover affected populated
areas** within the plume exposure
pathway EPZ in those jurisdictions that
opt to provide KI to the public.
- Process” includes the licensee’s PAR
strategy, procedures, equipment,
training, and ERO staffing necessary to
develop a PAR.
- Includes any area where the public
may be present including areas over
water.
(b)(10)
Table 5.10-1 (Continued)-- Significance Examples §50.47(b)(10)
Issue Date: 09/22/15 44 0609, Appendix B
Issue Date: 09/22/15 45 0609, Appendix. B
5.11 10 CFR 50.47(b)(11), Emergency Radiological Exposure Control
PLANNING STANDARD: Means for controlling radiological exposures, in an emergency,
are established for emergency workers. The means for controlling
radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity
Protective Action Guides.
PS FUNCTION: The resources for controlling radiological exposures for
emergency workers are established.
Supporting Requirements: 10 CFR Part 50, Appendix E, Section IV.E.1
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.K, and the licensee’s
approved E–plan
Table 5.11-1
Significance Examples for
LOSS OF PS FUNCTION:
White Finding
Radiological control equipment, instrumentation, processes
and/or personnel necessary to control emergency workers’
exposure is not available (e.g., out of service or calibration) to
the extent that emergency work necessary to protect the
health and safety of the public could not be performed during
emergencies. The availability of additional equipment, on
site, in a reasonably timely manner is considered a
COMPENSATORY MEASURE for the PS.
Resources for controlling exposures during emergencies will
not ensure that exposures are maintained in accordance with
E–plan commitments.
DEGRAD. OF PS FUNC.
Green Finding:
Radiological control equipment, instrumentation, processes,
and/or personnel necessary to control emergency workers’
exposure is not available to the extent that emergency work
necessary to protect the health and safety of the public would
be impaired during emergencies. The availability of additional
equipment, on site, in a reasonably timely manner is
considered a COMPENSATORY MEASURE for the PSF.
Additional Guidance: None
Issue Date: 09/22/15 46 0609, Appendix. B
5.12 10 CFR 50.47(b)(12), Emergency Medical Support
PLANNING STANDARD: Arrangements are made for medical services for contaminated
injured individuals.
PS FUNCTION: Arrangements are made for medical services for contaminated,
injured individuals.
Supporting Requirements: 10 CFR Part 50, Appendix E, Section IV.E.5-7
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.L, and the licensee’s
approved E–plan
Table 5.12-1
Significance Examples for
LOSS OF PS FUNCTION:
White Finding
No agreement exists with any qualified and properly equipped
hospital or ambulance service for the care of contaminated,
injured individuals.
DEGRAD. OF PS FUNC.
Green Finding:
An agreement for medical support with an organization has
been allowed to lapse, but the organization remains willing to
support the E–plan.
Additional Guidance: None
Issue Date: 09/22/15 47 0609, Appendix. B
Table 5.13-1
Significance Examples for
LOSS OF PS FUNCTION:
White Finding
None
DEGRAD. OF PS FUNC.
Green Finding:
Recovery efforts are not preplanned.
The recovery process is not exercised within an 8-year
period.
Additional Guidance:
Because of the nonemergency nature of recovery efforts, no LOSS OF PS FUNCTION would
be assigned for failures in this area (i.e., any FTC would not exceed a Green finding).
5.13 10 CFR 50.47(b)(13), Recovery and Reentry Planning
PLANNING STANDARD: General plans for recovery and reentry are developed.
PS FUNCTIONS: Plans for recovery and reentry are developed.
Supporting Requirements: None
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.M, and the licensee’s
approved E–plan
Issue Date: 09/22/15 48 0609, Appendix. B
Significance Examples
See Table 5.14-1 and
Figures 5.14-1 and 5.14-2
Additional Guidance:
See guidance in Section 6.0 regarding correction of WEAKNESSES.
Identification of WEAKNESSES
A WEAKNESS is defined as a level of ERO performance demonstrated during an exercise, drill,
or training that provides performance opportunities to develop, maintain, or demonstrate key
skills that would preclude effective implementation of the E–plan, if the weakness were to occur
during an actual emergency.
A failure of a CRITIQUE to identify a WEAKNESS observed by NRC inspectors is a CRITIQUE
finding and should be processed against 10 CFR 50.47(b)(14) and Section IV.F.2.g of
Appendix E, if the WEAKNESS could preclude effective implementation of the E–plan in an
actual emergency (i.e., FTI).
5.14 10 CFR 50.47(b)(14), Drill and Exercise Program
PLANNING STANDARD: Periodic exercises are (will be) conducted to evaluate major
portions of emergency response capabilities, periodic drills are
(will be) conducted to develop and maintain key skills, and
deficiencies identified as a result of exercises or drills are (will be)
corrected.
PS FUNCTIONS: 1. A drill and exercise program (including, for example,
radiological, medical, health physics) is established.
2. All exercises, drills, and training that provide performance
opportunities to develop, maintain, and demonstrate key skills
are assessed via a CRITIQUE process to identify
WEAKNESSES.
3. Identified WEAKNESSES are corrected.
Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.F.1–2
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.N, and the licensee’s
approved E–plan
Issue Date: 09/22/15 49 0609, Appendix. B
Since a WEAKNESS is defined in the context of ERO performance, a PROGRAM ELEMENT
issue related to the effectiveness and adequacy of the E–plan or its implementing procedures10
is not a WEAKNESS. Accordingly:
A deficient PE uncovered by the exercise and identified by the licensee in its critique is a
licensee-identified PD and is evaluated as a FTC.
If identified by the inspector, the deficient PE is an NRC-identified PD and is evaluated
as a FTC.
Because of this dichotomy, inspectors will need to remain alert to the possibility that a
WEAKNESS may have uncovered one or more inadequate PE.
A mistake or a misstep by ERO members that only detracts from the overall ERO performance
should not be treated as a de facto WEAKNESS. Mistakes are likely to happen in the course of
an exercise and many are corrected by the ERO (e.g., peer-checking), which should be viewed
as an organizational strength. Failure to identify these mistakes as a WEAKNESS in the
CRITIQUE is generally not a PD.
Inspectors must remain alert to exercise controller actions (e.g., coaching, prompting) that have
the effect of masking an ERO WEAKNESS such that corrective actions might not be
implemented. Failure of the licensee’s CRITIQUE to identify the ERO performance
WEAKNESS masked by the controller action is a CRITIQUE finding. (Even if identified in the
CRITIQUE, the controller’s action could result in a DEP PI opportunity being considered as a
failure. See ROP FAQ No. 405 dated July 21, 2005.)
Classifications, PARs, and notifications could be accurate and timely (DEP PI opportunity
successes) and there still be a WEAKNESS. Such a WEAKNESS needs to be identified and
corrected since, under different circumstances, it could affect activities necessary for protecting
the health and safety of the public. A failure to identify such a WEAKNESS in a CRITIQUE
should be classified as a Green finding because of its lesser significance. Examples include the
following:
An emergency classification is made as anticipated by the scenario, but the classification
was based on misinformation, lack of information, invalid indicators, or reliance on
emergency director judgment EALs when explicit EALs were applicable.
A PAR is developed as anticipated by the scenario, but the PAR was based on a dose
assessment performed using erroneous input parameters (e.g., improper release
duration, credit for filtration when none available).
Licensees perform CRITIQUES in many different ways and the inspectors should be flexible in
accepting mechanisms for WEAKNESS identification. The critical feature of any CRITIQUE is
10 The E–plan contains the licensee’s commitments to NRC regulations. The implementing
procedures are the licensee’s methods of implementing those commitments and may be used to
judge effective, timely, and accurate implementation.
Issue Date: 09/22/15 50 0609, Appendix. B
that a WEAKNESS is captured and entered into a corrective action system with appropriate
priority, regardless of whether the WEAKNESS was verbalized at a CRITIQUE meeting.
If the inspector can be assured that all WEAKNESSES will be entered into a corrective action
system, before disclosing the identified issues, the CRITIQUE should be considered acceptable.
However, if the inspector does not have assurance that a WEAKNESS has or will be captured
and entered into the corrective action system, the CRITIQUE was not acceptable and a
CRITIQUE finding exists.
The disposition of CRITIQUE observations also varies among sites. In any given exercise, the
licensee will evaluate numerous evaluator observations, identify which observations rise to the
level of a WEAKNESS, and prioritize resources for correction. Care should be taken to
understand the logic underlying the suggested disposition before identifying it as a CRITIQUE
finding. If the inspector identifies that a well-founded, evaluator-identified WEAKNESS was
improperly dispositioned and was not entered into the corrective action system, a CRITIQUE
finding exists since the NRC expects the licensee to enter identified WEAKNESSES and enter
them into a corrective action system.
If the ERO performance during a biennial exercise is degraded to the extent that the inspector
cannot find that reasonable assurance exists that adequate protective measures can be taken in
the event of an actual radiological emergency or cannot find that the ERO has maintained key
skills specific to emergency response, the NRC may require the conduct of a remedial exercise
under Section IV.F.2.f of Appendix E to 10 CFR Part 50.
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS of PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(14)
A drill and exercise program (including,
for example, radiological, medical, health
physics) is established.
Continued
N/A
More than two drills or exercises (e.g.,
radiological, medical, health physics)
(excluding the biennial exercise) during a
2-year (calendar) period have not been
conducted in accordance with the E–
plan.
A biennial exercise is not conducted
during a 2-year (calendar) period without
receiving an exemption.
Exercises and drills are not sufficiently
varied to ensure that all RSPS PE are
tested within the exercise planning cycle
ERO performance is such that a
remedial exercise is required because
the NRC cannot find reasonable
assurance that adequate protective
measures can be taken in the event of a
radiological emergency or the ERO
failed to maintain and demonstrate key
skills.
A drill has not been conducted during a
2–year (calendar) period in accordance
with the E–plan.
Exercises and drills are not sufficiently
varied to ensure that all PS PE are
tested within the exercise planning cycle.
A biennial exercise does not provide
opportunities for the ERO to
demonstrate key emergency response
skills identified in Appendix E
Section IV.F.2.b in the control room,
Biennial exercises are not sufficiently
varied to ensure ERO proficiency in
responding to scenario elements
identified in Appendix E Section IV.F.2.j
and to minimize anticipatory responses
caused by preconditioning of
participants.
A biennial exercise is not sufficiently
technically accurate or challenging to
adequately test the plans, procedures,
equipment, and implementation of the
licensee’s emergency response
capabilities.
(b)(14)
Table 5.14-1 -- Significance Examples §50.47(b)(14)
Issue Date: 09/22/15 51 0609, Appendix B
PLANNING STANDARD
FUNCTION(s) Yellow Finding LOSS of PS FUNCTION
White Finding
DEGRADED PS FUNCTION
Green Finding
(b)(14) Continued
All exercises, drills, and training that
provide performance opportunities to
develop, maintain, and demonstrate key
skills, are assessed via a formal
CRITIQUE process to identify
WEAKNESSES.
Identified WEAKNESSES are corrected.
N/A
–––
Formal CRITIQUES are not conducted
for more than two scheduled drills or
exercises.
The CRITIQUE process does not
properly identify a WEAKNESS
associated with an RSPS that is
determined (by the NRC) to be a DEP PI
opportunity failure during a FULL-SCALE
DRILL OR EXERCISE.
–––
The licensee failed to correct an RSPS
WEAKNESS. (See Section 6.0,
“Corrective Actions.”)
–––
Formal CRITIQUES are not conducted
for more than two scheduled training
evolutions.
The CRITIQUE process does not identify
a WEAKNESS associated with a RSPS
that is determined (by the NRC) as a
DEP PI successful opportunity during a
FULL-SCALE DRILL OR EXERCISE.
The CRITIQUE process does not identify
a WEAKNESS associated with a nonRSPS during a FULL-SCALE DRILL OR
EXERCISE or any PS WEAKNESS
during a limited facility interaction drill in
which there is a limited team of
evaluators (e.g., facility tabletop training
drill, operator training simulator drill,
individual facility training drill).
The CRITIQUE process does not
properly identify a WEAKNESS
associated with RSPS
–––
The licensee failed to correct a nonRSPS WEAKNESS. (See Section 6.0,
“Corrective Actions.”)
(b)(14)
Table 5.14-1 (Continued)-- Significance Examples §50.47(b)(14)
Issue Date: 09/22/15 52 0609, Appendix B
Issue Date: 09/22/15 53 0609, Appendix B
Figure 5.14-1
Significance Determination for CRITIQUE Findings
Scope of Drill or Exercise Weakness PS PI Opportunity Status* Finding Significance
Failure
White
Success
Non-RSPS
CRITIQUE FULL-SCALE
Finding
Green
Green
Limited Participation Green
. *As determined by the NRC inspector.
With regard to the PI opportunity status branch, if the licensee fails to identify a RSPS
WEAKNESS observed during a FULL-SCALE DRILL OR EXERCISE that is determined by the
inspector to be a PI opportunity failure, the significance is White. All other CRITIQUE findings
are assigned Green significance.
Figure 5.14-2
Significance Determination for Failure to Correct a WEAKNESS
Planning Standard Repetition Current DEP PI Status Finding Significance
Green
White
White
RSPS b(4), b(5), b(10)
RSPS b(9)
No Finding** Failure
To
Correct
>10% failure* White
<10% failure*
non-RSPS
>10% failure* Green
<10% failure* **
- Including all observed WEAKNESSES having a common uncorrected root cause (e.g.,
inadequate ERO training). See Section 6.0.
- Return to IMC 0612 and reconsider the more-than-minor determination.
Issue Date: 09/22/15 54 0609, Appendix B
Table 5.15-1
Significance Examples for
LOSS OF PS FUNCTION:
White Finding
ERO personnel would not be available (e.g., lapsed training)
to provide continuous coverage (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) for a key ERO
function (as defined by NEI 99-02). NOTE: If the DEP and
ERO PIs have been Green for the previous eight quarters, the
significance should be Green.
DEGRAD. OF PS FUNC.
Green Finding:
ERO personnel would not be available (e.g., lapsed training)
to provide continuous coverage (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) for any ERO
position listed in the licensee’s E–plan. Unqualified personnel
(e.g., lapsed training) are maintained on the ERO duty roster
and are relied upon to respond during an emergency.11
Additional Guidance:
NEI 99-02, “Regulatory Assessment Performance Indicator Guideline,” Revision 6,
[ML092931123], identifies key ERO members.
11 Since the PS applies only to personnel relied upon to respond during an emergency, a PD does
not exist if personnel were removed from the ERO duty roster when their training qualification
lapsed. Return to IMC 0612 and reconsider the more-than-minor determination.
5.15 10 CFR 50.47(b)(15), Emergency Responder Training
PLANNING STANDARD: Radiological emergency response training is provided to those
who may be called on to assist in an emergency.
PS FUNCTION: Training is provided to ERO personnel.
Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.F.1–2
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.O, and the licensee’s
approved E–plan
Issue Date: 09/22/15 55 0609, Appendix B
5.16 10 CFR 50.47(b)(16), Emergency Plan Maintenance
PLANNING STANDARD: Responsibilities for plan development and review and for
distribution of emergency plans are established, and planners are
properly trained.
PS FUNCTION: 1. Responsibility for E–plan development and review is
established.
2. Planners responsible for E–plan development and
maintenance are properly trained.
Supporting Requirements: None
Informing Criteria: NUREG-0654/FEMA-REP-1,Section II.P, and the licensee’s
approved E–plan
Table 5.16-1
Significance Examples for
LOSS OF PS FUNCTION:
White Finding
None.
DEGRAD. OF PS FUNC.
Green Finding:
Responsibilities for E–plan development are not established.
Planners did not receive initial and/or continuing training.
Additional Guidance:
Because of the nonemergency nature of E–plan development efforts, no LOSS OF PS
FUNCTION would be assigned for failures in this area (i.e., any FTC would not exceed a Green
finding).
Issue Date: 09/22/15 56 0609, Appendix B
6.0 GUIDANCE ON CORRECTIVE ACTIONS
6.1 Timeliness Guidelines
a. The NRC expects that licensees will resolve an identified WEAKNESS in a timely
manner consistent with its risk significance. That said, it is important to note that the
time it takes to correct a WEAKNESS may depend on various factors, not all of which
may be under the licensee’s direct control. The licensee determines the risk significance
of a WEAKNESS and sets resolution priorities in accordance with its corrective action
programs and other commitments. Root cause and extent of cause analyses may take
60 days or longer to complete. While immediate corrective actions, such as procedure
changes, briefings, lessons-learned summaries, or COMPENSATORY MEASURES may
be implemented rapidly, multiple longer term corrective actions may be necessary to
fully resolve the WEAKNESS and prevent its reoccurrence.
b. This guidance, which should be interpreted as flexible guidelines, is intended to inform
an inspector’s evaluation of the timeliness of the corrective actions for an identified
WEAKNESS. The following guidance is to be used when assessing timeliness of
corrective actions:
1. An RSPS-related WEAKNESS is typically corrected within 90 days of
identification.
2. A PS-related WEAKNESS is typically corrected within 180 days of identification.
3. Resolution of other WEAKNESSES is expected within the next evaluated
biennial exercise cycle because of the lower risk significance of these efforts and
expected lower priority of such efforts.
4. EP-related corrective action systems may track enhancement suggestions that
result from the drill program. These enhancement suggestions often add value to the
EP program, but are not required and do not address WEAKNESSES. There is no NRC
timeliness expectation for resolution of enhancement suggestions.
6.2 Considerations
a. If a WEAKNESS is corrected in less time than that suggested in Section 6.1.(b), above,
further review of the timeliness of the corrective actions by the inspector is probably not
necessary. If a WEAKNESS is not corrected within the time periods suggested in
Section 6.1.(b), the inspector should review:
1. the licensee’s schedule and prioritization rationale
2. reasons for the delay
3. any actions being taken to accelerate completion (if any)
Issue Date: 09/22/15 57 0609, Appendix B
4. the effect of any immediate corrective actions that may have already been taken
b. If the inspector finds that the licensee is not making a best effort to complete the
corrective actions, or that the delay could potentially impact the effectiveness of the
E–plan to protect public health and safety, an FTC with PS 10 CFR 50.47(b)(14) finding
should be pursued.
6.3 Effectiveness of Corrective Actions
a. Although a licensee may have properly identified a WEAKNESS, entered it into the
licensee’s corrective action program, and implemented necessary corrective actions to
prevent reoccurrence, the associated ERO performance may recur in subsequent drills
and exercises. It is important to note that a single repetition of a WEAKNESS in a
subsequent drill or exercise may not indicate a failure to correct a WEAKNESS.
Conversely, success in a drill or exercise (e.g., by one well-drilled team) might not be a
valid demonstration that a WEAKNESS has been corrected.
b. When a previously identified WEAKNESS in a particular PS recurs in a subsequent drill
or exercise, the inspector should do the following:
1. Review the specific corrective actions identified.
2. Verify that the corrective actions are complete.
3. Review associated root cause and extent of condition analyses, if performed.
4. Consider similar occurrences during responses to actual events, drills, exercises,
and training evolutions.
5. Consider the status of relevant PIs; for the DEP PI, review the performance for
the individual RSPS as well as that for the overall PI (good performance in two RSPS
can mask poor performance in the third).
6. Review corrective actions, self-assessment, and inspection records for an entire
inspection cycle with emphasis on similar performance deficiencies.
c. Assessment of the effectiveness of the corrective actions should be based on the
complete history of the issue. The intent of the reviews suggested above is to uncover a
pattern of recurring performance deficiencies in similar activities as a means to identify
ineffective corrective actions.
d. A specific root cause of a WEAKNESS in a particular RSPS may have been corrected,
and yet another WEAKNESS in the same RSPS but with a different root cause may be
observed in a subsequent drill or exercise. A trend in such repetitive WEAKNESSES,
even though each may have a different root cause, could indicate that the root cause
and extent of cause analyses may have been ineffective such that an unidentified (and
uncorrected) root cause still exists. Accordingly, the WEAKNESS is uncorrected and a
Issue Date: 09/22/15 58 0609, Appendix B
failure to correct a WEAKNESS needs to be considered as provided for in this section.
In addition, a trend of repetitive WEAKNESSES may indicate the need to perform a root
cause analysis of the trend.
e. If corrective actions are aggressive and appear to be complete but not yet fully effective,
consideration may be given to allow more time for performance improvement (future
drills should show such improvement).
Issue Date: 09/22/15 Att1-1 0609, Appendix B
Attachment 1
FAILURE TO IMPLEMENT (ACTUAL EVENT) SIGNIFICANCE LOGIC
FAILURE TO IMPLEMENT
General Emergency RED
YELLOW RSPS
FAILURE TO IMPLEMENT: FAILURE TO COMPLY with a REGULATORY REQUIREMENT during an actual event in which the failure precluded effective implementation of PROGRAM ELEMENTs. RSPS: Risk Significant Planning Standard; PS: Planning Standard
PS GREEN
Yes
Yes
No
Yes
No
Site Area Emergency YELLOW
WHITE RSPS
PS GREEN
Yes
Yes
No
Yes
No
No
Alert Emergency WHITE
GREEN RSPS
GREEN
Yes Yes No
No
No
Issue Date: 09/22/15 Att2-1 0609, Appendix B
Attachment 2
FAILURE TO COMPLY SIGNIFICANCE LOGIC
FAILURE TO COMPLY
Loss of RSPS Function
RSPS Degraded Function
Loss of PS* Function
No
No
Yes
Yes
Yes No
YELLOW
WHITE
WHITE
GREEN FAILURE TO COMPLY: A program is noncompliant with a REGULATORY FUNCTION. LOSS OF RSPS FUNCTION: PROGRAM ELEMENTs are not adequate, not compliant with the PLANNING STANDARDS, or otherwise not functional to such an extent that the RISK SIGNIFICANT PLANNING STANDARD FUNCTION is not available for emergency response. DEGRADATION OF THE RSPS FUNCTION: PROGRAM ELEMENTs are not adequate or not compliant, but the RISK SIGNIFICANT PLANNING STANDARD FUNCTION, although degraded is available for emergency response. LOSS OF PLANNING STANDARD FUNCTION: PROGRAM ELEMENTs are not adequate, not compliant with the PLANNING STANDARDS, or otherwise not functional to such an extent that the PLANNING STANDARD FUNCTION is not available for emergency response. *RSPS functions are a subset of the PS functions. Thus, a RSPS function that is not loss or degraded would be Green.
Issue Date: 09/22/15 Att3-1 0609, Appendix B
Attachment 3
Revision History for IMC 0609, App B
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description of
Training Required
and Completion Date
Comment and
Feedback
Resolution
Accession Number
(Pre-Decisional,
Non-Public)
n/a 04/21/00
CN-00-07
Initial Issue n/a n/a
n/a 12/29/00
CN-00-30
EP SDP has been revised to include guidance for
implementing EP SDP, which was not included in the
initial issuance of this appendix. Revisions to the
guidance was made based on regional comments.
n/a n/a
n/a 03/06/03
CN-03-07
EP SDP has been revised to incorporate lessonslearned and to provide a white path for the risk
significant planning standards. This revision also
more closely aligns the EP Cornerstone with the
other cornerstones.
n/a n/a
n/a ML120090270
02/24/12
CN 12-003
A complete re-write of the EP SDP initiated to
address (1) new EP rule-making, (2) incorporate
lessons-learned, (3) address use of EP SDP for
assessing significance for traditional enforcement
violations, (4) incorporate regional comments, (5)
implement a new assessment protocol for
§50.47(b)(4) findings, and (6) editorial reformatting to
improve usability.
November 8, 2011
via VTC. All regional
EP inspectors
participated
Issue Date: 09/22/15 Att3-2 0609, Appendix B
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description of
Training Required
and Completion Date
Comment and
Feedback
Resolution
Accession Number
(Pre-Decisional,
Non-Public)
09/23/14
CN 14-021
Note: this revision to the EP SDP was issued for
regional review three times due to the identification
of additional needed changes from review
comments. Some of the proposed changes have
since been rendered moot by other revisions. The
comments were combined in a single resolution: The
change listing below is a delta from the 2/24/2012
version.
Several changes were made to the EP SDP address
experience in implementing the 2/24/2012 revision:
(1) References to §50.72 in the definition of
REGULATORY REQUIRE-MENT were omitted as
the failure to make a required report is not a PD
under the EP Cornerstone and is treated under TE;
(2) conforming changes for (1); (3) changed “EAL IC”
in §5.4 to read “EAL” to remove confusion; (4)
additional guidance was added to §5.8 regarding
TSC/EOF habitability and examples were revised;
The changes to the
discussed with
regional personnel
through
presentations at the
annual EP
counterpart meetings
(most recent: May
2013)
Issue Date: 09/22/15 Att3-3 0609, Appendix B
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description of
Training Required
and Completion
Date
Comment and
Feedback
Resolution
Accession Number
(Pre-Decisional,
Non-Public)
(5) In §§5.6, 5.8, 5.9, and 5.10 changed “in absence of
COMPENSATORY MEASURES” to read “and no
COMPENSATORY MEASURES were implemented,” to
address mistaken interpretation of the original
language; (6) revised several examples in §5.8 to
replace the emphasis on the ability of one key ERO
member with an emphasis instead on the facilities’
ability to perform principal functional areas of
emergency response; (7) added guidance on principal
functional areas to §5.8. In response to comments that
the EP SDP repeated guidance already in IMC 0612,
made several changes: (8) omitted definitions of
PERFORMANCE DEFICIENCY, FINDING, an
VIOLATION, and made instances of those terms lower
case in the text; (9) changed definition of
REGULATORY REQUIREMENT to read EP
REQUIREMENT to address mistaken interpretation that
the EP SDP didn’t address findings that were not
violations; (10) Clarified definition of WEAKNESS;
(11) made several changes to section 3.1 and 3.2; (12)
Section 7.0 was deleted (See IMC0612 App G); (13)
omitted the “no finding” column from the significance
example tables; (14) other references to “no finding”
were modified (in footnotes) to direct the user to IMC 0612 Appendix B and to reconsider the more-thanminor determination. Clarified “populated area” in Table
5.10-1.
Issue Date: 09/22/15 Att3-4 0609, Appendix B
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description of
Training Required
and Completion
Date
Comment and
Feedback
Resolution
Accession Number
(Pre-Decisional,
Non-Public)
09/22/15
CN 15-017
Changes made to significance examples in Table 5.10-
1 to provide an example for an over-conservative PAR.
Conforming changes made to other examples in this
table. Addresses issues that arose in processing
Enforcement Action EA 15-072. Editorial changes
made to other examples in this table for clarity
Regional EP
specialists were
made aware of this
changes during the
development of the
change and during
the comment
period. Changes
were also
discussed during
monthly
counterpart calls.
07/09/2015