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NRC INSPECTION MANUAL NSIR

INSPECTION MANUAL CHAPTER 0609, APPENDIX B

EMERGENCY PREPAREDNESS

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

basis for the EP SDP.

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

10 CFR 50.54(s)(2)(ii).

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

10 CFR 50.47(b)(14).

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

10 CFR Part 50.

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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

EP SDP.

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

10 CFR 50.47(b)(1)

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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) 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

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

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

lead to OROs implementing, by

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

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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

licensee ERFs and with OROs,

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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

10 CFR 50.47(b)(11)

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

10 CFR 50.47(b)(12)

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

10 CFR 50.47(b)(13)

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,

TSC, OSC, EOF, or JIC.

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

10 CFR 50.47(b)(9).

–––

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

RSPS

Non-RSPS

CRITIQUE FULL-SCALE

Finding

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

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

10 CFR 50.47(b)(15)

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) 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

10 CFR 50.47(b)(16)

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

No

Yes

No

Site Area Emergency YELLOW

WHITE RSPS

PS GREEN

Yes

No

Yes

No

Alert Emergency WHITE

GREEN RSPS

GREEN

Yes Yes 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

Yes

Yes No

YELLOW

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)

ML13270A478

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

EP SDP have been

discussed with

regional personnel

through

presentations at the

annual EP

counterpart meetings

(most recent: May

2013)

ML14209B024

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)

ML15128A462

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

ML15190A137

NRC Inspection Manual 0609/Appendix B

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2.0 DEFINITIONS, ABBREVIATIONS, AND ACRONYMS1

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NRC Inspection Manual 0609/Appendix B

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1.0 INTRODUCTION

2.0 DEFINITIONS, ABBREVIATIONS, AND ACRONYMS1

3.0 ENTRY CONDITIONS AND GENERAL INSTRUCTIONS

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