NEI 10-05 [Revision 0] 

Assessment of On-Shift

Emergency Response 

Organization Staffing 

and Capabilities 

June 2011 
[THIS PAGE IS LEFT BLANK INTENTIONALLY]
Nuclear Energy Institute, 1776 I Street N. W., Suite 400, Washington D.C. (202.739.8000) 

NEI 10-05 [Revision 0] 

Nuclear Energy Institute 

Assessment of On-Shift 

Emergency Response 

Organization Staffing 

and Capabilities 

June 2011 
ACKNOWLEDGEMENTS

This document was developed by the Nuclear Energy Institute (NEI) On-shift Emergency 

Response Organization (ERO) Staffing Analysis Task Force. 

NEI On-Shift ERO Staffing Analysis Task Force 

NEI Chairperson: David Young 

Industry Lead: Keith Kemper, Exelon Nuclear/Corporate 

Industry Member: Scott McCain – Emergency Planning Technical Consultants, Inc.

The task force wishes to acknowledge the following individuals who performed independent 

reviews of this document. 

Larry Baker – Exelon Nuclear/Corporate 

Myra Jones – Entergy Nuclear/Corporate 

NOTICE

Neither NEI, nor any of its employees, members, supporting organizations, contractors, or 

consultants make any warranty, expressed or implied, or assume any legal responsibility for the 

accuracy or completeness of, or assume any liability for damages resulting from any use of, any 

information apparatus, methods, or process disclosed in this report or that such may not 

infringe privately owned rights. 
NEI 10-05 (Revision 0) 

June 2011 

i 

EXECUTIVE SUMMARY

A nuclear power plant’s on-shift Emergency Response Organization (ERO) staff must be capable 

of implementing the site emergency plan to address a spectrum initiating events and 

consequences. Key emergency response functions and tasks are described in NUREG-0654, and 

include: 

 Shutdown the reactor and maintain safe shutdown 

 Mitigate event consequences 

 Notify augmented ERO staff and Offsite Response Organizations (OROs) 

 Determine Protective Action Recommendations (PARs) for site personnel and the public 

 Perform firefighting 

 Provide medical assistance if needed 

The on-shift ERO staff must not be assigned additional responsibilities that could detract from 

the performance of their primary emergency plan functions. 

Section IV.A.9 of 10 CFR 50, Appendix E, states that nuclear power reactor licensees shall 

perform “a detailed analysis demonstrating that on-shift personnel assigned emergency plan 

implementation functions are not assigned responsibilities that would prevent the timely 

performance of their assigned functions as specified in the emergency plan.” The NEI On-shift 

ERO Staffing Task Force has developed this document to establish a standard methodology for 

performing analyses of the ability of on-shift staff to perform all required functions and tasks 

necessary to respond to a declared emergency. Licensees may use this methodology to meet the 

requirement of 10 CFR 50, Appendix E, Section IV.A.9 in a manner acceptable to the US 

Nuclear Regulatory Commission (NRC) staff. 

A licensee may modify the methodology described in this document, or employ an alternate 

staffing analysis approach, if it is determined that the methodology is not the optimum for 

assessing their particular circumstances. For example, there are site-specific staffing, response 

commitments or technology factors that the methodology does not adequately consider. The 

modified methodology or alternate approach must be consistent with NRC requirements. 

When completed, the staffing analyses performed in accordance with this document are to be 

incorporated into the site’s emergency plan. Licensees will need to evaluate these emergency 

plan changes in accordance with 10 CFR 50.54(q) and follow the appropriate regulatory 

submittal requirements. In addition, the staffing analyses must be retained and available for 

subsequent regulatory inspection. 

The analyses should be updated as needed to address changes in shift staffing, assignment of key 

responsibilities, introduction if new technologies, etc. 

 
NEI 10-05 (Revision 0) 

June 2011 

ii 

[THIS PAGE IS LEFT BLANK INTENTIONALLY]
NEI 10-05 (Revision 0) 

June 2011 

iii 

TABLE OF CONTENTS

EXECUTIVE SUMMARY ....................................................................................................... i 

1 REGULATORY BACKGROUND DISCUSSION ............................................................. 1

2 METHODOLOGY OVERVIEW ...................................................................................... 2

2.1 ANALYSIS PROCESS DESCRIPTION .................................................................................2

2.2 ANALYSIS PROCESS STEPS .............................................................................................3

2.3 ON-SHIFT STAFF .............................................................................................................4

2.4 AUGMENTED ERO RESPONSE TIME ..............................................................................4

2.5 ANALYSIS OF REPAIR AND CORRECTIVE ACTION RESPONSES .....................................4

2.6 ANALYSIS OF RESCUE OPERATIONS AND FIRST AID RESPONSES .................................5

2.7 ANALYSIS OF RADIATION PROTECTION AND CHEMISTRY TECHNICIANS ....................5

2.8 DESIGN BASIS ACCIDENT CASE SELECTION AND ATTRIBUTES ....................................5

2.9 ANALYSIS OF A FIRE RESPONSE .....................................................................................6

2.10 ANALYSIS OF A GENERAL EMERGENCY RESPONSE ......................................................6

2.11 ANALYSIS OF A SEVERE ACCIDENT MANAGEMENT RESPONSE ....................................6

2.12 ANALYSIS OF A STATION BLACKOUT EVENT .................................................................7

2.13 ANALYSIS OF A 10 CFR 50.54(HH)(1) EVENT ................................................................7

2.14 CHANGES TO ERO RESPONSE TIMES ............................................................................8

3 ON-SHIFT STAFFING ANALYSIS .............................................................................. 12

3.1 ASSUMPTIONS AND LIMITATIONS ................................................................................12

3.2 INSTRUCTIONS ..............................................................................................................14

4 TIME MOTION STUDY PROCESS .............................................................................. 25

4.1 PROCESS ASSUMPTIONS ...............................................................................................25

4.2 PROCESS OUTLINE ........................................................................................................26

5 REFERENCES ........................................................................................................... 29

5.1 10 CFR § 50.47 Emergency plans – Section (b) ...........................................................29

5.2 10 CFR § 50.54 Conditions of licenses – Section (m) ..................................................29

5.3 10 CFR § 50.54 Conditions of licenses – Section (hh) .................................................29

5.4 10 CFR § 50.72 Immediate notification requirements for operating nuclear power 

reactors – Section (c) .....................................................................................................29

5.5 10 CFR § 73.71 Reporting of safeguards events – Section (b) .....................................29
NEI 10-05 (Revision 0) 

June 2011 

iv 

5.6 10 CFR § 50, Appendix E – Emergency Planning and Preparedness for Production and 

Utilization Facilities ......................................................................................................29

5.7 ANSI/ANS-58.8-1994, Time Response Design Criteria for Safety-Related Operator 

Actions ........................................................................................................................29

5.8 Electric Power Research Institute (EPRI) Proprietary Report TR-101869, Severe 

Accident Management Guidance Technical Basis Report, Vols. 1 and 2, 1992 ..........29

5.9 NRC Generic Letter 86-04, Policy Statement on Engineering Expertise On-Shift ......29

5.10 NRC Information Notice 91-77, Shift Staffing at Nuclear Power Plants .....................29

5.11 NRC Information Notice 93-81, Implementation of Engineering Expertise On-Shift .29

5.12 NRC Information Notice 95-48, Results of Shift Staffing Study .................................29

5.13 NSIR/DPR-ISG-01, Interim Staff Guidance – Emergency Planning for Nuclear Power 

Plants ........................................................................................................................29

5.14 NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency 

Response Plans and Preparedness in Support of Nuclear Power Plants .......................29

5.15 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for 

Nuclear Power Plants ....................................................................................................29

5.16 NUREG-1852, Demonstrating the Feasibility and Reliability of Operator Manual 

Actions in Response to Fire ..........................................................................................29

5.17 NUREG/CR-3903, Analysis of Emergency Staffing for Nuclear Power Plants ..........29

5.18 Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants .............................29

5.19 Regulatory Guide 1.8, Qualification and Training of Personnel for Nuclear Power 

Plants ........................................................................................................................29

5.20 Regulatory Guide 1.214, Response Strategies for Potential Aircraft Threats...............29

APPENDIX A .................................................................................................................... A-1

APPENDIX B .....................................................................................................................B-1

APPENDIX C .................................................................................................................... C-1

APPENDIX D .................................................................................................................... D-1

APPENDIX E .....................................................................................................................E-1

APPENDIX F ..................................................................................................................... F-1
NEI 10-05 (Revision 0) 

June 2011 

1 

ASSESSMENT OF ON-SHIFT EMERGENCY RESPONSE 

ORGANIZATION STAFFING AND CAPABILITIES

1 REGULATORY BACKGROUND DISCUSSION 

The specific requirement for establishing a shift emergency organization to respond to 

emergency events appears in 10 CFR 50.47(b)(2) which states, in part, “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...” 10 CFR 

Part 50, Appendix E, Section IV.A, requires licensees to describe the organization for coping 

with radiological emergencies, including individuals assigned to the licensee’s ERO with a 

description of emergency assignments. More specifically, Section IV.A.9 states that nuclear 

power reactor licensees shall perform “a detailed analysis demonstrating that on-shift personnel 

assigned emergency plan implementation functions are not assigned responsibilities that would 

prevent the timely performance of their assigned functions as specified in the emergency plan.” 

This document, NEI 10-05, provides a structured approach for meeting this requirement. 

NUREG-0654, Section II.B, “Onsite Emergency Organization,” presents guidance for meeting 

these requirements. The guidance describes the onsite emergency organization, including the 

staffing requirements found in Table B-1, “Minimum Staffing Requirements for NRC Licensees 

for Nuclear Power Plant Emergencies.” This table specifies a minimum of 10 on-shift responders 

in four functional areas. It also specifies 7 on-shift responders who perform response duties that 

may be performed by shift personnel who are assigned other functions. In other words, there are 

no dedicated responders to perform these functions. Finally, Table B-1 specifies two major 

functional areas, firefighting and site access control/personnel accountability, which must be 

staffed on a site-specific basis. 

NUREG-0654, Section II.B, states that the emergency plan should unambiguously define onshift responsibilities for emergency response. Evaluation Criterion B.1 states that each licensee 

shall specify the onsite emergency organization of plant staff for all shifts and its relation to the 

responsibilities and duties of the normal staff complement. To meet this criterion, all licensees 

have an emergency plan that specifies each emergency function and the emergency position 

assigned to perform it. Emergency response staffing should consider such contingencies as 

activation of the fire brigade, back-shift staffing when overall staffing levels are lowest, and the 

potential demand for radiation protection and chemistry technicians during events involving 

radiological hazards. 

The on-shift staff must be able to cope with the spectrum of events described in NSIR/DPR-ISG01, Interim Staff Guidance – Emergency Planning for Nuclear Power Plants, until augmenting 

Emergency Response Organization (ERO) staff arrives in accordance with the site’s emergency 

plan commitments. The augmented ERO responders assume many managerial, engineering, and 

administrative duties from the on-shift personnel, allowing them to focus more fully on plant 

operations. NUREG-0654 guidance recommends that there be 30-minute and 60-minute 

responders; however, many sites have different augmentation time commitments. This fact is 

recognized by the methodology described in NEI 10-05. 
NEI 10-05 (Revision 0) 

June 2011 

2 

2 METHODOLOGY OVERVIEW 

2.1 ANALYSIS PROCESS DESCRIPTION

Section IV.A.9 of 10 CFR 50, Appendix E, states that nuclear power reactor licensees shall 

perform “a detailed analysis demonstrating that on-shift personnel assigned emergency plan 

implementation functions are not assigned responsibilities that would prevent the timely 

performance of their assigned functions as specified in the emergency plan.” The methodology 

described in NEI 10-05 provides a structured approach for meeting this requirement. In order to 

make efficient use of licensee and regulatory resources, the methodology credits, where 

appropriate, results from existing Job Task Analysis (JTA) and performance-based assessment 

processes. In cases where such processes are not in place, NEI 10-05 will specify a method to 

assess the ability of on-shift personnel to perform their assigned emergency plan functions. 

The expected performance of certain on-shift positions is already analyzed by existing 

programmatic JTA processes. Examples of such positions include those responsible for plant 

operations and safe shutdown, and firefighting activities. These detailed job task analyses verify 

that on-shift personnel such as operators, firefighters and others assigned a task necessary to 

achieve safe shutdown of the plant can perform their assigned emergency response duties. To 

meet the requirements of 10 CFR Part 50, Appendix E, Section IV.A for these positions, it is 

only necessary to identify the assignment of any collateral duty that may impact expected (i.e., 

the previously analyzed) performance. NEI 10-05 accomplishes this analysis in Appendix B, 

Tables 1, 2 and 3. 

In some cases, there may be tasks which have been analyzed by an existing programmatic JTA, 

or similar process, but the potential for the performance of two or more of these tasks at the same 

time may not have been considered in the analysis (e.g., performance of duties under emergency 

conditions). Positions potentially having these types of tasks include Radiation Protection (RP) 

Technicians and Chemistry Technicians. The methodology of NEI 10-05 will verify that RP and 

Chemistry Technicians can perform all assigned emergency response duties; this analysis is 

accomplished in Appendix B, Tables 1 and 4. 

The ability to perform initial emergency plan implementing duties, those done prior to the arrival 

of the augmented ERO, is routinely assessed during operations training, and emergency response 

drills and exercises. These assessments include an appraisal of performance against regulatory 

and fleet/site standards (e.g. accuracy, time durations, etc.), and use of a Corrective Action 

Program to address inadequate performance. Since these assessments are detailed analyses of 

function and task performance, they meet the requirements of 10 CFR Part 50, Appendix E, 

Section IV.A; however, it will be necessary to identify if a particular event or accident results in 

an emergency plan implementing duty being assigned to an individual whose other duties could 

adversely impact performance. NEI 10-05 accomplishes this analysis in Appendix B, Tables 1 

and 5. 

The above description is depicted in a Table 2-1. 

The analysis methodology allows flexibility in the assignment of on-shift response functions and 

tasks, dependent upon the event or accident. For example, members of a fire brigade may be 
NEI 10-05 (Revision 0) 

June 2011 

3 

assigned other response duties if the event or accident does not include a fire. Likewise, a 

security officer might be assigned to perform offsite notifications during a DBA but not the 

DBT. 

2.2 ANALYSIS PROCESS STEPS

The NEI 10-05 methodology is composed of the following three steps. 

1. Listing the events and accidents for which staffing analyses are required. These events and 

accidents are described in NSIR/DPR-ISG-01, Interim Staff Guidance – Emergency Planning 

for Nuclear Power Plants. An analysis will be performed for each specified event and 

accident. 

2. For each event or accident, completion of an On-shift Staffing Analysis (OSA) that will 

identify on-shift ERO positions having: 

a. No emergency response functions. These positions are not assigned responsibilities that 

would prevent the timely performance emergency plan functions; they require no further 

analysis. 

b. Emergency response functions that fall within the scope of an existing JTA or 

performance-based assessment process. The response actions performed by these 

positions are within the bounds of an existing performance assessment process and 

require no further analysis. 

c. An emergency response function(s) that has not been previously analyzed by an existing 

JTA or performance-based assessment process. 

d. Emergency response functions, assessed by existing JTA or performance-based 

assessment processes, that may overlap such that the integrated performance of the 

functions has not been previously analyzed by an existing JTA or performance-based 

assessment process. This includes combinations of functions that may challenge 

effective performance due to the timing and duration of individual tasks. 

The OSA process is described in greater detail in Section 3.0 of this document. 

3. In cases c and d, above, a subsequent Time Motion Study (TMS) will be performed to verify 

the results of the OSA. The TMS is a performance-based assessment, essentially a drill, 

which will confirm or modify the results of the OSA. 

The TMS Process is described in Section 4.0 of this document. 

An overview of the methodology described above is presented in Figure 2.1. 

It is expected that the results of each completed analysis will be verified and validated to ensure 

adequacy and accuracy – this includes the OSA and, if needed, the TMS. Once these actions are 

completed, licensees are expected to promptly enter any unsatisfactory results into their 

Corrective Action Program for resolution. After submitting a condition report, it will be 

necessary to determine what interim correction measures may be necessary to meet the 

requirements of 10 CFR 50.47(b)(2) and related regulatory guidance. 
NEI 10-05 (Revision 0) 

June 2011 

4 

2.3 ON-SHIFT STAFF

Only personnel required to be on-shift can be credited in a staffing analysis. The associated 

staffing requirements (i.e., the number and composition of the on-shift staff) must be described 

in the site emergency plan. 

2.4 AUGMENTED ERO RESPONSE TIME

Performance of a staffing analysis will require use of an assumed response (arrival) time for 

members of the augmented ERO. This time should be the maximum acceptable number of 

minutes elapsed between an emergency declaration1 and the arrival of an ERO position-holder at 

a location necessary to relieve an on-shift ERO member. The times to be used are typically 

defined in, or can be derived from, the site emergency plan (e.g., in a description comparing 

augmented ERO staffing capability to NUREG 0654, Table B-1 guidance). 

2.5 ANALYSIS OF REPAIR AND CORRECTIVE ACTION RESPONSES

Table B-1 of NUREG-0654 lists one Major Task for which a need may not be specified during a 

staffing analysis - “Repair and Corrective Actions”. Following the guidance contained in 

NUREG-0654, Table B-1, repair and corrective action tasks may be performed by dedicated shift 

personnel or qualified shift personnel assigned other functions/tasks. The assignment for the 

performance of repair and corrective action tasks must be indicated within the site emergency 

plan and consistent with Table B-1. 

To promote consistency across the industry in the assignment of this task, the following 

definition should be used unless a site-specific definition is already in place. 

Repair and Corrective Action: An action that can be performed promptly to restore a nonfunctional component to functional status (e.g., resetting a breaker), or to place a 

component in a desired configuration (e.g., open a valve), and which does not require 

work planning or implementation of lockout/tagout controls to complete. 

For purposes of this document, in-plant repair and corrective actions are considered to fall into 2 

broad categories: 

• Unplanned/unexpected actions that address equipment failures. These actions are 

contingent in nature and cannot be specified in advance. 

• Planned/expected actions performed in support of operating procedure implementation, 

including severe accident management guidelines. 

To complete a staffing analysis, licensees will need to identify any site-specific planned/expected 

actions performed in-plant prior to the arrival of the augmented ERO. The actions of interest 

here are those that support implementation of abnormal or emergency operating procedures, and 

severe accident management guidelines, and that are not performed by Operations personnel 

(since actions performed by Operations personnel are assessed elsewhere). An example would 

be a procedure step that directs dispatch of an electrician to close a breaker that supports proper 

Emergency Core Cooling System (ECCS) operation. 

 

1

 An alternate start time may be used in specified in the site emergency plan. 
NEI 10-05 (Revision 0) 

June 2011 

5 

2.6 ANALYSIS OF RESCUE OPERATIONS AND FIRST AID RESPONSES

Table B-1 of NUREG-0654 lists one Major Functional Area for which a need may not be 

specified during an analysis - “Rescue Operations and First Aid”. Following the guidance 

contained in NUREG-0654, Table B-1, this contingent function may be performed by dedicated 

shift personnel or qualified shift personnel assigned other functions/tasks. The assignment for 

the performance of the rescue operations and first aid function must be indicated within the site 

emergency plan and consistent with Table B-1. 

To promote consistency across the industry in the assignment of this function, the following 

definition should be used unless a site-specific definition is already in place. 

Rescue Operations and First Aid: The tasks of locating missing personnel, removing them 

from hazardous areas, if needed, and providing necessary initial medical treatment. 

Personnel performing initial medical treatment should be trained to the level of Red Cross 

Basic First Aid, or otherwise meet minimum State and/or local standards for providing 

such assistance. 

2.7 ANALYSIS OF RADIATION PROTECTION AND CHEMISTRY TECHNICIANS

All nuclear power plants require that an individual holding the position of radiation protection 

technician or chemistry technician be qualified to perform the range of tasks expected of the 

position. Qualification is performed and documented in accordance with the appropriate 

fleet/site training program(s). Examples include taking a radiation level reading using a 

particular instrument, or obtaining and analyzing certain types of samples. 

Although training and qualification processes will ensure that a radiation protection technician or 

chemistry technician can perform individual tasks, they typically do not assess for impacts from 

potential multiple overlapping tasks that may be necessary during an emergency. In contrast, a 

simulator exam will assess not only each task performed by a Reactor Operator but also the 

overall performance of the Reactor Operator during that particular emergency response (i.e., the 

ability to perform all tasks in an effective and timely manner during the accident sequence). It 

should be recognized that, contra the implementation of an operating procedure, there is some 

variability in how and when a radiation protection or chemistry technician may perform a task. 

The analysis approach used by NEI 10-05 will identify all tasks assigned to on-shift radiation 

protection and chemistry technicians, plot the task start and duration times on a timeline, and 

then determine if any task performance timeframes overlap. Should the performance of two or 

more tasks overlap, a TMS will be required to validate acceptable performance. 

2.8 DESIGN BASIS ACCIDENT CASE SELECTION AND ATTRIBUTES

Some Design Basis Accidents may be analyzed in several cases, each case reflecting different 

initial assumptions affecting radiological consequences (e.g., RCS activity, leak rates, etc.). For 

example, an analysis may contain a conservative case (e.g., a bounding case with parameters at 

Technical Specification allowable limits) and a realistic case (e.g., using typically expected 

parameters reflecting sound operational decision-making). The staffing analysis for that 

particular Design Basis Accident may use the radiological consequences associated with the 

realistic case. 
NEI 10-05 (Revision 0) 

June 2011 

6 

If the site’s Updated Final Safety Analysis Report (UFSAR) presents multiple analyses of a 

postulated accident type reflecting different initiating event severities (e.g., a LOCA analyzed in 

both a small-break and a large break case), the one resulting in the highest emergency 

classification should be used for the staffing analysis. If the conditions of similar postulated 

accidents would result in the same emergency classification, select the case that causes the most 

severe radiological consequences. Should neither criterion differentiate between the available 

cases, the licensee may choose the case to be used for a staffing analysis. 

In cases where a Design Basis Accident analysis includes a radiological release, and the starting 

point of the release is not clearly defined, the staffing analysis may assume that the release 

begins 15-minutes after the initiating event. Licensees are free to use a starting point of less than 

15-minutes if desired. Elapsed times of greater than 15-minutes may also be used; however, a 

documented basis for the selected time should be developed and appended to the staffing 

analysis. 

2.9 ANALYSIS OF A FIRE RESPONSE

In accordance with NSIR/DPR-ISG-01, Interim Staff Guidance – Emergency Planning for 

Nuclear Power Plants, a staffing analysis must be performed for a control room fire leading to 

evacuation and remote shutdown. Within the spectrum of analyzed fire events, it is expected that 

a control room fire and evacuation will be the limiting scenario, i.e., it will require the greatest 

number of response actions on the part of the control room staff. This assumption should be 

qualitatively validated with appropriate operations and fire protection personnel. Should another 

fire analysis scenario be identified as more limiting, then that fire event will also require a 

staffing analysis. The validation and associated results must be documented and included in the 

staffing analysis. 

2.10 ANALYSIS OF A GENERAL EMERGENCY RESPONSE

In accordance with NSIR/DPR-ISG-01, Interim Staff Guidance – Emergency Planning for 

Nuclear Power Plants, the staffing analysis for at least one Design Basis Accident must include 

an assessment of the actions performed in response to a General Emergency. This same event 

must also include a radiological release that results in a dose that exceeds the Environmental 

Protection Agency’s (EPA) Protective Action Guides (PAGs) beyond the site boundary, and thus 

necessitates promulgation of a Protective Action Recommendation (PAR). Should no Design 

Basis Accident result in the declaration of a General Emergency, the licensee will need to select 

one and assume that it causes a General Emergency declaration. 

For staffing analysis purposes, it is sufficient to simply assume that 1) a General Emergency was 

declared, and 2) a significant radiological release, necessitating a PAR, is in progress at the time 

of declaration. The determination of specific failures and accident progression is not necessary. 

2.11 ANALYSIS OF A SEVERE ACCIDENT MANAGEMENT RESPONSE

NSIR/DPR-ISG-01, Interim Staff Guidance – Emergency Planning for Nuclear Power Plants, 

requires that licensees consider the ability of the on-shift staff to implement actions associated 

with initial implementation of severe accident management guidelines (i.e., those actions 

expected to occur prior to the arrival of the augmented ERO). It is recommended that a DBA 

that results in a General Emergency, or the one selected as such per step 2.9 above, be used for 
NEI 10-05 (Revision 0) 

June 2011 

7 

this assessment. As stated above, it is sufficient to simply assume that the accident progressed to 

conditions requiring a severe accident response; it is not necessary to determine specific failures 

and the accident sequence. 

The NEI 10-05 analysis of the ability to implement severe accident management guidelines 

focuses on the reasonably expected initial mitigation actions that would be performed by on-shift 

personnel other than licensed and non-licensed operators. This approach reflects the fact that 

severe accident management tasks performed by licensed and non-licensed operators - parameter 

monitoring, and direction and execution of manipulations at the main control boards/consoles 

and in-plant locations – are extensions of the operator tasks already evaluated by the Plant 

Operations and Safe Shutdown portion of the staffing assessment. The actions assessed by NEI 

10-05 are those which implement the initial site-specific Candidate High Level Action2

 assuming 

the core is not ex-vessel (i.e., no reactor vessel failure), and there is no actual or imminent 

challenge to containment integrity. 

2.12 ANALYSIS OF A STATION BLACKOUT EVENT

NSIR/DPR-ISG-01, Interim Staff Guidance – Emergency Planning for Nuclear Power Plants, 

provides guidance associated with the staffing analysis for a station blackout. Unless there is a 

compelling basis to do otherwise, licensees are strongly encouraged to perform a staffing 

analysis for a station blackout event. 

2.13 ANALYSIS OF A 10 CFR 50.54(HH)(1) EVENT

NSIR/DPR-ISG-01, Interim Staff Guidance – Emergency Planning for Nuclear Power Plants, 

requires that licensees perform “a detailed analysis to determine if the current on-shift staff can 

adequately perform all emergency response actions required by site-specific procedures for an 

‘aircraft probable threat.’ This analysis should include all emergency response actions taken 

prior to an aircraft impact in accordance with RG 1.214 for an aircraft threat that is greater than 5 

minutes, but less than 30 minutes, from the site, and should consider the dispersal of the site fire 

brigade away from target areas for firefighting.” Regulatory Guide 1.214 is entitled, “Response 

Strategies for Potential Aircraft Threats.” Following a review of the regulation and guidance, 

and related implementation across the industry, the NEI On-Shift ERO Staffing Analysis Task 

Force made the following observations. 

• The variability in how sites implemented 10 CFR 50.54(hh)(1), and Regulatory Guide 

1.214, is sufficient to preclude development of a standard assessment template. 

• Sites validated different aspects of their 10 CFR 50.54(hh)(1) response strategies and the 

level of validation also varied. 

Based on these observations, the task force has the following recommendations for performing 

this staffing analysis. 

 

2

 A generic term used in Electric Power Research Institute (EPRI), 1992, “Severe Accident Management Guidance 

Technical Basis Report,” EPRI Proprietary Report TR-101869, Vols. 1 and 2, and in subsequent vendor guidance. 
NEI 10-05 (Revision 0) 

June 2011 

8 

• Develop a site-specific list of response task for this event. These actions should generally 

reflect those listed in 10 CFR 50.54(hh)(1), as expanded upon in Regulatory Guide 1.214, 

and others required by the emergency plan. 

• Determine which of these tasks were previously analyzed through an approved station 

process (e.g., Operation Training Program, a procedure validation in involving assessed 

performance, etc.). 

• For tasks that were previously analyzed, perform a collateral duty analysis to verify that 

personnel do not have assigned responsibilities that would prevent the timely 

performance of their assigned functions as specified in the emergency plan. The 

guidance in Section 3 of this document can be used to inform this assessment. 

• For tasks that were not previously analyzed, perform a TMS to verify timely and 

effective implementation of appropriate procedures. The guidance in Section 4 of this 

document can be used to inform this assessment. 

2.14 CHANGES TO ERO RESPONSE TIMES

Although developed to meet the requirements of 10 CFR 50, Appendix E, Section IV.A.9, the 

staffing assessment methodology may be used to evaluate proposed changes to on-shift staffing 

levels or augmented ERO response times. For example, an analysis could be performed with a 

desired response time for the augmenting ERO (e.g., 90 minutes), and the results then used to 

support the basis for changing a staffing or augmentation time commitment. Licensees are 

strongly cautioned that any changes to the staffing of the on-shift ERO, or the staffing or timing 

of the augmented ERO, are subject to the requirements of 10 CFR 50.54(q) and related guidance. 
9 

Table 2.1 

Staffing Analysis Methodology for DBAs and DBT 

Major Functional Area Major Tasks Position Title or Expertise Detailed Analysis 

Task Performanc

Plant Operations and Assessment of Operational Aspects 

N/A Shift Supervisor (SRO) Operations Training 

Program 

N/A Shift Forman (SRO) Operations Training 

Program 

N/A Control Room Operators Operations Training 

Program 

N/A Auxiliary Operators Operations Training 

Program 

Emergency Direction and Control (Emergency Coordinator) 

Notify licensee, State, local and Federal personnel and maintain communication 

Shift Technical Advisor, Shift Supervisor or designated facility manager

Operations Training Program 

And

EP Drill and ExerciProgram 

Radiological Accident Assessment and Support of Operational Accident Assessment 

In-plant surveys Chemistry/ Radiochemistry 

HP Technicians Rad/Chem Technicians 

Per site-specific training program(s) 

Plant System Engineering, Repair and Corrective Actions 

Technical Support Shift Technical Advisor Per site-specific 

training program(s) 

Repair and Corrective Action Mechanical Maintenance 

Electrical Maintenance 

Per site-specific training program(s) 

Protective Actions (In-Plant) Radiation Protection: 

a. Access Control 

b. HP Coverage for repair, 

corrective actions, search and rescue first-aid & firefighting 

c. Personnel monitoring d. Dosimetry 

HP Technicians Per site-specific 

training program(s) 

Firefighting N/A N/A Firefighting Trainin
NEI 10-05 (Revision 0) 

June 2011 

10 

Major Functional Area Major Tasks Position Title or Expertise Detailed Analysis 

Task Performanc

Program 

Rescue Operations and First-Aid N/A N/A Medical response 

training program 

And

EP Drill and ExerciProgram

Site Access Control and Personnel Accountability 

Security, firefighting communications, personnel accountability 

Security Personnel Security Training 

Program 

And

Security and EP Drills and Exercises 
NEI 10-05 (Revision 0) 

June 2011 

11 

Figure 2.1 

Overview of On-Shift Staffing Analysis Process 

Define the events 

to be analyzed 

Step 3.2.1 

Define the on-shift 

ERO positions 

Step 3.2.2.2 

OSA 

Plant Operations & 

Safe Shutdown 

Step 3.2.2.3 

OSA 

Firefighting 

Step 3.2.2.4 

OSA 

RP & Chemistry 

Step 3.2.2.5 

OSA 

E-Plan 

Implementation 

Step 3.2.2.6 

Evaluate OSA 

Results 

Step 3.2.3 

Does a 

position(s) 

require further 

analysis? 

Function / 

Responsibility (Task) 

Analysis 

Step 4.2.1 

Work Activity Analysis 

Step 4.2.2 

Personnel Requirements 

(Staffing Plan) Analysis 

Step 4.2.3 

No 

Generate Corrective 

Action Program 

document as needed. 

End 
NEI 10-05 (Revision 0) 

June 2011 

12 

3 ON-SHIFT STAFFING ANALYSIS 

The on-shift assignments assessed by the On-Shift Staffing Analysis (OSA) include both the 

Major Functional Areas and Major Tasks listed in NUREG-0654, Table B-1, as well as 

additional actions identified by a review of related operating experience and regulatory 

documents. To facilitate the development of a standard and readily usable staffing assessment 

methodology, and as discussed in Section 2, these functions and tasks were grouped into four 

major response areas. 

 Plant Operations & Safe Shutdown 

 Firefighting 

 Radiation Protection & Chemistry 

 Emergency Plan Implementation 

The OSA is meant to identify on-shift positions that have emergency response assignments 

outside the bounds of an existing JTA or performance-based assessment process, or overlapping 

assignments that could potentially challenge performance of an emergency response 

function/task. These positions will require a Time Motion Study (TMS) analysis to determine if 

the duty assignments are acceptable, i.e., all actions can be performed in an effective and timely 

manner, consistent with applicable regulatory requirements and station commitments, until 

relieved by the augmenting ERO staff. 

As discussed in Section 2.0, the OSA is structured to credit task analyses performed in 

accordance with other program or process requirements. If a task is identified for which an 

analysis has not been performed, then a TMS of that task will be required per Section 4.0. 

Additional process design considerations are discussed below. 

3.1 ASSUMPTIONS AND LIMITATIONS

The following assumptions and limitations are applicable to all OSA. 

1. Unless otherwise specified in NSIR/DPR-ISG-01, Interim Staff Guidance – Emergency 

Planning for Nuclear Power Plants, or by the initial conditions of a DBA analysis, it is 

assumed that all site units are in Mode 1, Power Operations, and operating at 100% reactor 

power. 

2. The event being assessed occurs during off-normal work hours at a time when most ERO 

responders are not at the site (e.g., during a backshift, weekend or holiday). The 

augmented ERO responders will need to be notified and report to their assigned locations. 

3. The on-shift personnel complement is limited to the minimum required number and 

composition as described in the site emergency plan. If the plan commitments allow for 

different minimum staffing levels (e.g., a variance between a normal dayshift and a 

backshift), use the staffing with the smallest total number of personnel. 

4. Although the temporary absence of a position may be allowed by Technical Specifications, 

the analyses should be performed assuming that all required on-shift positions are filled. 
NEI 10-05 (Revision 0) 

June 2011 

13 

5. With respect to the DBT staffing analyses, it may be assumed that a HOSTILE FORCE 

breached the Protected Area fence but was neutralized with no adverse consequences to 

plant safety. Damage inflicted on plant systems, structures and components is not 

sufficient to prevent safe shutdown or cause a radiological release. There is no fire 

significant enough to warrant firefighting efforts prior to the arrival of offsite resources 

and/or the augmented ERO. The analysis should confirm that sufficient staff is available to 

simultaneously implement both the emergency plan and the security plan. 

6. On-shift personnel can report to their assigned response locations within timeframes 

sufficient to allow for performance of assigned actions. Licensees should verify that the 

administrative controls necessary to promote a timely response by on-shift ERO personnel 

are in place. 

7. Notwithstanding the guidance in step 3.1.6 above, the analysis of the DBT event must 

account for the expected constraints on the movement of personnel (e.g., movement not 

allowed, limited movement using the 2-person rule, etc.). Specifically, individuals must 

usually be in, or readily able to respond to, assigned response locations before being 

credited with performing a function/task that implements the emergency plan. The 

inability of an individual to reach their assigned response location may introduce a 

collateral duty assignment to another individual. 

8. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal 

dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very 

high radiation areas) without the aid of a Radiation Protection (RP) Technician. Licensees 

should verify that the on-shift staff possesses the necessary qualifications. 

9. Staffing requirements for operations personnel are established by NRC regulations and 

related guidance3

. It is assumed that personnel assigned to the major response area of Plant 

Operations & Safe Shutdown meet these requirements and guidance, and are able to 

satisfactorily perform the functions and tasks necessary to achieve and maintain safe 

shutdown. As discussed in Section 2, staff performance within this area is regularly 

analyzed through other station programs (e.g., licensed operator training) and will not be 

evaluated as part of this assessment, unless a role/function/task from another major 

response area is assigned as a collateral duty. 

Any “safety-related operator action”4

 will be done by a member of the on-shift staff as 

defined in the unit’s Technical Specifications. This includes in-plant (manual) actions 

performed to manipulate components and equipment from locations outside the main 

control room. These actions are typically performed by auxiliary (non-licensed) operators 

but may be performed by licensed operators or other on-shift staff members (e.g., an 

electrician) under some conditions. 

 

3

 Refer to 10 CFR 50.54(m) and references listed in NUREG-0800, Section 13.2.1. 

4

 The American National Standards Institute/American Nuclear Society defines "safety-related operator action" in 

ANSI/ANS-58.8-1994, as follows: A manual action required by plant emergency procedures that is necessary to 

cause a safety-related system to perform its safety-related function during the course of any DBE (design-basis 

event). The successful performance of a safety-related operator action might require that discrete manipulations 

be performed in a specific order. 
NEI 10-05 (Revision 0) 

June 2011 

14 

10. Fire Brigade staffing requirements are established by NRC regulations and related 

guidance.5

 It is assumed that personnel assigned to the major response area of Firefighting 

meet these requirements and guidance, and are able to satisfactorily perform all functions 

and tasks necessary to fight a fire. As discussed in Section 2, staff performance within this 

area is regularly analyzed through other station programs (e.g., fire drills) and will not be 

evaluated as part of this assessment, unless a role/function/task from another major 

response area is assigned as a collateral duty. 

11. Individuals holding the position of radiation protection technician or chemistry technician 

are qualified to perform the range of tasks expected of their position.6

12. The on-site security organization is able to satisfactorily perform all tasks related to Site 

and Protected Area Access Controls, under all event or accident conditions. Performance 

of this function is regularly analyzed through other station programs (e.g., Force-on-Force 

drills, emergency response drills, etc.) and will not be evaluated here, unless a role or 

function from another major response area is assigned as a collateral duty. 

13. The task of making a simple and brief communication has minimal impact on the ability to 

perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all 

positions. Examples include making a plant page announcement or placing a call for 

assistance to an offsite resource such as local law enforcement. This assumption does not 

apply to notification actions specifically called out in the assessment methodology (e.g., 

initial emergency notification to an ORO or the NRC); these actions must be assessed. 

14. The task of performing a peer check has minimal impact on the ability to perform other 

assigned functions/tasks, and is therefore an acceptable collateral duty for all positions. 

Examples include performing a peer check on a recommended emergency classification or 

notification form for transmittal to offsite authorities. 

3.2 INSTRUCTIONS

3.2.1 Complete Appendix A, Analyzed Events and Accidents. 

1. Enter each event and accident for which an analysis will be performed; these are 

described in NSIR/DPR-ISG-01, Interim Staff Guidance – Emergency Planning for 

Nuclear Power Plants. For each entry, provide: 

a. A summary description of the event or accident in column 2 (e.g., “Loss of 

Coolant Accident”). 

1. The Design Basis Threat (DBT) is already entered in the table and does not 

require a separate entry. 

b. The plant mode specified in the ISG or, for a DBA, the initial conditions of the 

analysis, in column 3. If no mode is stipulated, assume that all site units are in 

Mode 1, Power Operations. 

 

5

 Refer to Regulatory Guide 1.189, “Fire Protection for Nuclear Power Plants.” 

6

 Refer to Regulatory Guide 1.8, “Qualification and Training of Personnel for Nuclear Power Plants.” 
NEI 10-05 (Revision 0) 

June 2011 

15 

c. The associated reference document(s) describing the event or accident conditions 

and, for a DBA, the associated analysis in column 4 (e.g., “UFSAR section 

15.2.2”). 

d. The Emergency Classification Level (ECL) that would be declared in accordance 

with the site emergency classification procedure in column 5. If no emergency 

would be declared, enter “None”. 

 

NOTE

As discussed in Section 2.10, should no Design Basis Accident result in 

the declaration of a General Emergency, the licensee must select one 

and assume that it causes a General Emergency declaration for analysis 

purposes. This analysis will also include an assumed radiological 

release that results in a dose that exceeds the EPA PAGs beyond the site 

boundary, and thus necessitates promulgation of a PAR. It is 

recommended that this entry be annotated as such (e.g., “General 

Emergency with release and PAR – assumed for analysis purposes”). 

e. Determination if a staffing analysis is required. [Column 6] 

1) Enter “Yes” if the event requires an emergency declaration per the site 

emergency classification procedure. Otherwise, enter “No”. 

2. Attach additional pages as necessary and maintain the “Analysis #” sequential 

numbering. 

3.2.2 For each event or accident identified in Appendix A, complete an analysis of on-shift 

staffing adequacy using Appendix B, On-Shift Staffing Analysis, by performing the 

following steps. 

1. Enter the applicable “Analysis #” from Appendix A for which the OSA is being 

performed. This number will be entered on each page of Appendix B. 

2. Complete Table 1, On-Shift Positions, by performing the following steps. 

a. Enter each On-shift Position in column 2, On-shift Position. 

NOTE

For security personnel, list only those security positions relied upon to 

perform an emergency plan/response function. For example, if one 

Security Officer is assigned as a shift communicator and another 

Security Officer performs accountability, then list only those two 

individuals in Table 1. 
NEI 10-05 (Revision 0) 

June 2011 

16 

NOTE

If some crews have two individuals filling the Shift Manager and Shift 

Technical Advisor roles, and other crews have a dual-role individual, 

the analysis should be performed using the dual-role individual. 

For position titles with more than one position holder, assign a unique sequential 

number to each position. For example, a site with two units and two Reactor 

Operators per unit would enter Reactor Operator #1, Reactor Operator #2, Reactor 

Operator #3 and Reactor Operator #4. 

b. Enter the site emergency plan reference that describes the requirement for the 

position to be on-shift in column 3, Emergency Plan Reference. If more than one, 

enter all references that apply to this position. 

c. For the on-shift positions listed below, enter the elapsed time, in minutes, from 

the emergency declaration until the position is relieved of the function/task or 

supplemented by additional staff from the augmented ERO in column 4, 

Augmentation Elapsed Time. This should be the time(s) described in, or derived 

from, the site emergency plan (e.g., 30 minutes, 60 minutes, 90 minutes, etc.). 

• Radiation Protection Technician 

• Chemistry Technician 

d. Attach additional pages as necessary. Maintain the sequential line numbering for 

each position. 

e. Using only the On-shift Positions listed in Table 1, complete Tables 2 through 5 

by entering the on-shift position that fills a described role, or performs a specific 

function or task. Follow the instructions presented below for each Table. 

3. Complete Table 2, Plant Operations & Safe Shutdown, by performing the following 

steps. 

a. Identify the operations staffing matrix which aligns with the site unit and control 

room configuration (i.e., number of units and control rooms), and enter the 

applicable site unit(s) number next to the selected staffing matrix. 

NOTE

Sites with 3 or more units should use the combination of existing tables, 

or create a table, that best reflects their site configuration. 

b. For each generic title/role listed in the table entitled, “Minimum Operations Crew 

Necessary to Implement AOPs and EOPs, or SAMGs if applicable”, enter the 

corresponding On-shift Position from Table 1. Position definition is provided 
NEI 10-05 (Revision 0) 

June 2011 

17 

below. 

1) The Unit Supervisor is the Senior Reactor Operator (SRO) that provides 

direction to Reactor Operators during implementation of Abnormal Operating 

Procedures (AOPs) and Emergency Operating Procedures (EOPs). 

2) For On-shift Positions with multiple members, include the unique sequential 

number in each block. For example, a single unit site with three on-shift 

reactor operators would list Reactor Operator #1 and Reactor Operator #2 in 

the respective blocks of Table 2. This leaves Reactor Operator #3 available 

for assignment to another role/function. 

3) List the Auxiliary Operators (AOs) who are required to perform the in-plant 

(manual) operator actions necessary to achieve safe shutdown of the unit7

. In 

other words, these are the AOs who must be available (dedicated) to perform 

safe shutdown actions, and thus can have no other assigned functions. [This 

role is typically filled by a non-licensed operator but may be filled by a 

licensed operator in some scenarios.] Similar to the above bullet, if a single 

unit site has 5 AOs on-shift, list AO #1 and AO #2 in the respective blocks of 

Table 2. This leaves three (3) AOs available for assignment to another 

role/function. 

c. Enter any additional personnel if they are required to support implementation of 

the operating procedures necessary to respond to the event prior to the arrival the 

augmented ERO. 

1. On-shift personnel that are not part of the operating crew (i.e., not a 

licensed or non-licensed operator) must be listed in the table entitled, 

“Other (non-Operations) Personnel Necessary to Implement AOPs and 

EOPs, or SAMGs if applicable”. For example, an electrician from the 

Maintenance Department who is required to implement a planned/expected 

action necessary to complete an EOP step would be entered in this portion 

of the table. 

d. If this staffing analysis includes an assessment of the ability to implement Severe 

Accident Management (SAM) guidelines, as discussed in Section 2.11, then 

perform the following steps. 

1. Identify the SAM guideline tasks that meet all 3 of the following attributes: 

a. The task implements the first expected Candidate High Level Action 

described in the site’s SAM guidelines assuming: 

1. The core is not ex-vessel (i.e., no reactor vessel failure). 

2. There is no actual or imminent challenge to containment 

integrity. 

 

7

 This is typically the minimum Auxiliary Operator complement required by the unit’s Technical Specifications. 
NEI 10-05 (Revision 0) 

June 2011 

18 

b. The task is not performed by a licensed or non-licensed operator. 

c. It is expected that the task would be performed without the support 

of the augmented ERO (i.e., implemented by on-shift personnel 

without the assistance of the TSC and OSC). 

2. Enter the position(s) that would perform the task(s) in the table entitled, 

“Other (non-Operations) Personnel Necessary to Implement AOPs and 

EOPs, or SAMGs if applicable.” 

e. In column 4, enter the controlling method (i.e., a program or process) by which 

the collective tasks assigned to each position have been analyzed. For example, 

the capability of Reactor Operator #1 to implement assigned Plant Operations & 

Safe Shutdown tasks for a large-break LOCA is assessed and validated by the 

Operations Training Program. Enter “N/V” for a position if an assigned Plant 

Operations & Safe Shutdown task has not analyzed. 

f. In Table 1, locate each On-Shift Position assigned to Table 2. For each position, 

enter “Table 2” and the associated line number in column 5 of Table 1 (Role in 

Table#/Line#). 

1. For each position, enter “Yes” in column 6 of Table 1 (Unanalyzed Task?) 

if the position has a task that has not analyzed (i.e., an “N/V” was entered). 

Otherwise, enter “No”. 

4. Complete Table 3, Firefighting, by performing the following steps. 

a. If the event or accident being assessed does not include a fire, enter “N/A” in all 

blocks; continue to step 4.2.2.5. 

b. Enter the five (5) On-Shift Positions (from Table 1) that comprise the Fire 

Brigade. 

c. In column 3, enter the controlling method (i.e., a program or process) by which 

the collective tasks assigned to each position have been analyzed. For example, 

the capability of Auxiliary Operator #3 to implement assigned Firefighting tasks 

is assessed and validated by the Fire Protection Program. Enter “N/V” for a 

position if an assigned Firefighting task has not analyzed. 

d. In Table 1, locate each On-Shift Position assigned to Table 3. For each position, 

enter “Table 3” and the associated line number in column 5 of Table 1 (Role in 

Table#/Line#). 

1. For each position, enter “Yes” in column 6 of Table 1 (Unanalyzed Task?) 

if the position has a task that has not analyzed (i.e., an “N/V” was entered). 

Otherwise, enter “No”. 

5. Complete Table 4, Radiation Protection & Chemistry, by performing the following 

steps. 
NEI 10-05 (Revision 0) 

June 2011 

19 

NOTE

The Radiation Protection (RP) functions/tasks presented in this table are 

those performed by RP technicians. Do not include non-RP Technician 

personnel who are qualified to perform one of these functions or tasks. For 

example, an Auxiliary Operator qualified to perform self-job coverage 

should not be included. 

a. Review applicable response procedures to identify RP or Chemistry-related 

functions or tasks that must be performed during the period prior to the arrival of 

the augmenting ERO (i.e., during the time period denoted in Table 1, column 4). 

Procedures to be reviewed include AOPs, EOPs, radiation protection, chemistry 

and those implementing the emergency plan. 

b. In column 2, enter the On-shift Position (from Table 1) which performs the listed 

Function/Task required by a procedure. 

• “Offsite Radiological Assessment” refers to the task of performing offsite 

dose projections in response to a radiological release to the environment8. If 

the event or accident does not result in a radiological release, or this function 

is not performed by a Radiation Protection or Chemistry Technician, then 

enter “N/A” in this block. 

• Attach additional sheets as necessary. 

c. Based on operating experience (e.g., drills, real events, etc.), timed performance 

and/or informed judgment9

, enter an “X” in each column representing the five (5) 

minute time increments following the emergency declaration during which the 

function or task would be performed. Attach supporting information to explain 

the basis for the selected timeframes. 

d. In Table 1, locate each On-Shift Position assigned to Table 4. For each position, 

enter “Table 4” and the associated line number in column 5 of Table 1 (Role in 

Table#/Line#). 

e. For each position, enter “Yes” in column 6 of Table 1 (Unanalyzed Task?) if the 

position has a task that has not analyzed. Otherwise, enter “No”. 

6. Complete Table 5, Emergency Plan Implementation, by performing the following 

steps. 

a. In column 3, enter the On-shift Position (from Table 1) which performs the listed 

Function/Task required by an emergency plan implementing procedure. 

 

8

 The analysis should use the definition of a release specified in the site emergency plan or implementing 

procedures. 

9

 Informed judgment is the least preferred option. Its use should be limited to functions or tasks for which directly 

applicable operating experience is not available, and timed performance is not practical, or may not provide 

consistent or meaningful results. 
NEI 10-05 (Revision 0) 

June 2011 

20 

NOTE

In some cases, licensee procedures may allow for more than one 

individual to perform a given function/task (e.g., a primary and a 

backup). For analysis purposes, assume that the “primary” individual 

performs the function/task. 

1) Line 1 - “Declare the Emergency Classification Level (ECL)” refers to the 

task of declaring the emergency. 

2) Line 2 - “Approve Offsite Protective Action Recommendations” refers to 

the task of approving PARs for transmittal to offsite authorities. 

3) Line 3 - “Approve content of State/local notifications” refers to the task of 

approving emergency-related information for transmittal to offsite 

authorities. 

4) Line 4 - “Approve extension to allowable dose limits” refers to the task of 

approving increases to emergency worker dose limits. 

5) Line 5 - “Notification and direction to on-shift staff” refers to the task of 

determining appropriate instructions to provide to plant personnel (e.g., 

assemble, evacuate, etc.). 

6) Line 6 - “ERO notification” refers to the task of initiating/performing the 

callout of the ERO during a backshift, weekend or holiday. Examples 

include activating pagers, activating a callout system or service, etc. 

7) Line 7 – “Abbreviated NRC notification for DBT event” refers to the task 

of placing a brief telephone call to the NRC which provides initial 

notification of a Hostile Action. For all analyses except the DBT, enter 

“N/A”. 

8) Line 8 - “Complete State/local notification form”; self-explanatory. This 

should be the position which would receive NRC Drill/Exercise 

Performance (DEP) indicator credit for completing the offsite notification 

form. 

9) Line 9 - “Perform State/local notifications” refers to the task of placing a 

telephone call, fax, web form transmittal, etc. which provides initial event 

notification to offsite authorities. 

10) Line 10 - “Complete NRC event notification form”; self-explanatory. 

11) Line 11 - “Activate ERDS”; self-explanatory. 

12) Line 12 - “Offsite radiological assessment” refers to the task of 

performing offsite dose projections in response to a radiological release to 
NEI 10-05 (Revision 0) 

June 2011 

21 

the environment.10 If the event or accident under analysis does not result 

in a radiological release, or if the assessment is performed by a Radiation 

Protection or Chemistry Technician (as indicated in Table 4), then enter 

“N/A” in this block. 

13) Line 13 - “Perform NRC notifications” refers to the task of placing a 

telephone call which provides initial event notification to the NRC. This 

should be treated as a continuous action per 10 CFR 50.72(c)(3) and 

73.71(b)(1) which requires licensees reporting events to “maintain an open 

and continuous communication channel with the NRC Operations Center 

upon request by the NRC.” 

14) Line 14 - “Perform other site-specific event notifications (e.g., INPO, 

ANI, etc.)”; self-explanatory. Enter “N/A” if no additional, procedurally 

driven notification is required, if the notification can be completed within 

approximately 1 minute, or if it can be deferred until the arrival of the 

augmenting ERO. 

15) Line 15 - “Personnel accountability” refers to the function of generating 

the initial accountability report. For all events and accidents except the 

DBT, this is required within 30 minutes of a Site Area Emergency or 

General Emergency although some sites may have this requirement at the 

Alert level. If the emergency classification level for the event or accident 

does not result in the initiation of the personnel accountability function, 

then enter “N/A” in this block. 

16) Line 16 – “Other: Specify”. Include any additional site-specific roles, 

functions or tasks necessary to implement the emergency plan if 

performance duration exceeds approximately 1 minute. 

b. In column 4, enter the controlling method (i.e., a program or process) by which 

the capability to perform each task has been analyzed. For example, the 

capability of a Work Control Supervisor to perform State/local notifications is 

assessed and validated by the Operations Training Program and the EP Drill 

Program. Enter “N/V” for a position if an assigned Emergency Plan 

Implementation task has not analyzed. 

c. In Table 1, locate each On-Shift Position assigned to Table 5. For each position, 

enter “Table 5” and the associated line number in column 5 of Table 1 (Role in 

Table#/Line#). 

1. For each position, enter “Yes” in column 6 of Table 1 (Unanalyzed Task?) if 

the position has a task that has not analyzed (i.e., an “N/V” was entered). 

Otherwise, enter “No”. 

 

10 The analysis should use the definition of a release specified in the site emergency plan or implementing 

procedures. 
NEI 10-05 (Revision 0) 

June 2011 

22 

3.2.3 Perform an assessment of the analysis results 

1. Review Table 1, column 6, to identify the On-Shift Positions that have an unanalyzed 

task(s) (i.e., a “Yes” has been entered). 

a. For each of these positions, enter “Yes” in column 7 (TMS Required?). 

2. Review Table 1 to identify the On-shift Positions which have no or one assigned role, 

function or task, as denoted in column 5. 

a. Enter “No” in column 7 (TMS Required?) for each position unless a “Yes” has 

already been entered. 

3. The Shift Manager may be assigned the role of Shift Technical Advisor (STA)11. 

This collateral duty assignment does not require a TMS. 

4. Review Table 4 to identify time periods requiring the concurrent performance of two 

or more functions or tasks by the same on-shift position. 

a. For the on-shift positions not required to perform two or more functions or tasks 

concurrently, enter “No” in column 7 of Table 1 (TMS Required?) unless a “Yes” 

has already been entered. 

b. For the on-shift positions that are required to perform two or more functions or 

tasks concurrently, enter “Yes” in column 7 of Table 1 (TMS Required?). 

5. Review Table 1 to identify the On-Shift Positions which are assigned an emergency 

plan implementing function or task (from Table 5). 

a. Using the guidance in Table 3.1, below, enter “Yes” or “No” in column 7 (TMS 

Required?) for each position. [A “No” is entered only if a “Yes” has not already 

been entered for that position.] 

Table 3.1 

Table 5 

Line # 

Assigned E-Plan 

Role, Function or 

Task 

(from Table 5) 

On-Shift Position 

Shift 

Manager 

(SM) 

For any 

position 

not listed 

in Table 

2, 3 or 412

For any 

position 

listed in 

Table 2 

(except 

SM) 

For any 

position 

listed in 

Table 3 

or 4 

1 Declare the No No Yes Yes 

 

11 This is an acceptable collateral duty assignment per Generic Letter 86-04, Policy Statement on Engineering 

Expertise On-Shift. 12 Based on industry experience/practice, the listed emergency plan implementing tasks, with the exception of 

Offsite Radiological Assessment, are typically performed in a sequential fashion. Performance of the listed 

tasks is routinely reviewed and evaluated in emergency response drills and exercises. 
NEI 10-05 (Revision 0) 

June 2011 

23 

Table 5 

Line # 

Assigned E-Plan 

Role, Function or 

Task 

(from Table 5) 

On-Shift Position 

Shift 

Manager 

(SM) 

For any 

position 

not listed 

in Table 

2, 3 or 412

For any 

position 

listed in 

Table 2 

(except 

SM) 

For any 

position 

listed in 

Table 3 

or 4 

Emergency 

Classification 

Level (ECL) 

2 

Approve Offsite 

Protective Action 

Recommendations 

No No Yes Yes 

3 

Approve content 

of State/local 

notifications 

No No Yes Yes 

4 

Approve extension 

to allowable dose 

limits 

No No Yes Yes 

5 

Notification and 

direction to onshift staff (e.g., to 

assemble, 

evacuate, etc.) 

No No No Yes 

6 ERO Notification Yes No Yes Yes 

7 

Abbreviated NRC 

notification for 

DBT event 

No No No Yes 

8 

Complete 

State/local 

notification form 

No No Yes Yes 

9 

Perform 

State/local 

notifications 

Yes No Yes Yes 

10 

Complete NRC 

event notification 

form 

No No Yes Yes 

11 Activate ERDS No No No Yes 

12 

Offsite 

radiological 

assessment 

Yes Yes13 Yes Yes 

 

13 If this function is performed by an individual with no other assigned functions/tasks, then enter “No”. 
NEI 10-05 (Revision 0) 

June 2011 

24 

Table 5 

Line # 

Assigned E-Plan 

Role, Function or 

Task 

(from Table 5) 

On-Shift Position 

Shift 

Manager 

(SM) 

For any 

position 

not listed 

in Table 

2, 3 or 412

For any 

position 

listed in 

Table 2 

(except 

SM) 

For any 

position 

listed in 

Table 3 

or 4 

13 Perform NRC 

notifications14 Yes No Yes Yes 

14 

Perform other sitespecific event 

notifications (e.g., 

INPO, ANI, etc.) 

Yes No Yes Yes 

15 Personnel 

Accountability Yes No Yes Yes 

16 Other Yes No Yes Yes 

6. Enter “Yes” in column 7 of Table 1 (TMS Required?) for all other positions. 

7. Perform the required TMS for each position per Section 4.0. 

8. If there are no “Yes” entries in Table 1, column 7, the on-shift staffing is adequate to 

respond to this event and no further action is required. 

 

14 For assessment purposes, this task should be treated as a continuous action per 10 CFR 50.72(c)(3) and 

73.71(b)(1) which requires licensees reporting events to “maintain an open and continuous communication channel 

with the NRC Operations Center upon request by the NRC.” 
NEI 10-05 (Revision 0) 

June 2011 

25 

4 TIME MOTION STUDY PROCESS 

For the purposes of this guideline, an ERO job is defined as a group of EP related functions that 

are assigned to a single position. Functions can be associated with and grouped by planning 

standard. See Appendix C for a table of ERO performance functions and example descriptions 

for onsite personnel. 

Responsibilities, or tasks, are elements that compose the process to accomplish a particular 

function. An ERO position may be assigned one or more responsibilities to accomplish a 

function, or multiple responsibilities may be assigned to several ERO positions to accomplish a 

particular function. The below outline illustrates the hierarchy: 

A. Planning Standard – any of the §50.47(b) EP planning standards. 

1. Function – the component that defines the program element used to accomplish the 

planning standard. 

1.1. Responsibility (task) – the activity that describes the action or work performed to 

accomplish (or support the accomplishment of) a function. 

1.1.1. Action step – the detailed actions performed to accomplish the task. 

An ERO job that consists of interrelated functions and responsibilities that do not conflict would 

be coherent. An example of conflicting functions and responsibilities would be a RP Technician 

who is assigned to perform state and local event notification and in-plant radiation surveys. In 

this case, the RP Tech assigned to notifications and surveys, on Appendix B Table 1 On-Shift 

Position RP #1 in column 5 would be assigned two roles Table 4 Line 2 and Table 5 Line 8. 

Because these are not collateral duties allowed by the Table in Step 3.2.3.2.a, “TMS Required” 

was checked in column 6 of Appendix B, Table 1. Because “TMS Required” was checked yes 

the evaluator is now referred to Section 4 for further evaluation. 

A task analysis is the identification of requirements for accomplishing a particular responsibility 

and is typically used to determine initial and continuing training. Within the context of this 

guideline, the task analysis results are used to identify issues of timing, workload, etc. to 

determine resource conflicts that would affect the ability to accomplish a function and thus 

impact staffing assignments. 

For certain responsibilities, it is possible for an ERO position to perform some overlapping tasks 

without experiencing overload. This is frequently the case for personnel within an operating 

center such as the Control Room, Technical Support Center and Emergency Operations Facility. 

For other positions, task overlap cannot be accommodated. This occurs when tasks must be 

performed in isolated areas or outside of the plant. 

4.1 PROCESS ASSUMPTIONS

4.1.1 Concept of operations (Ops on-shift organization) for minimum shift RO and SRO 

requirements specified in §50.54(m)(2)(I) will not be altered. Functions and 

responsibilities assigned to licensed operators listed in Appendix B, Collateral Duty 
NEI 10-05 (Revision 0) 

June 2011 

26 

Identification Analysis, Table 2, Plant Operations & Safe Shutdown, other than for the 

Shift Manager position, will be limited to current plant status and corrective action 

bounded by EOP/AOP instruction. 

4.1.2 The functions and responsibilities will be organized by planning standard as described in 

NUREG-0654 and will be used as the standard for defining the emergency performance 

requirements of the on-shift organization. 

4.1.3 On-shift work activities analysis is performed up to the time where ERO responders are 

expected to arrive and relieve the on-shift position of the function as specified in the 

approved Emergency Plan. No credit is taken for earlier response and relief. 

4.2 PROCESS OUTLINE

4.2.1 Function/Responsibility (Task) Analysis 

Using the event analysis results developed in Section 3 that identified positions with 

collateral / multiple responsibilities assigned to their position that may overlap (tasks that 

resulted in Column 6 of Appendix B Table 1 being checked yes for TMS Required), 

perform a function / responsibility (task) analysis to document the steps required to 

perform each of the functions. 

A. For each position assigned multiple responsibilities in a particular event scenario, 

record the following on Appendix D, Function/Responsibility (Task) Analysis 

Template table: 

• Event type from Appendix A. 

• On-shift position and line # from Appendix B, Table 1. 

• Applicable overlapping functions and their associated responsibilities (tasks). 

B. Determine and list all of the action steps needed to perform the responsibilities (tasks) 

from implementing procedures or other instructional sources. Add additional rows 

for task’s action steps as needed. 

C. Document the time it takes to perform the step. Step time (or duration) can be 

determined through direct performance observation such as in a drill or exercise that 

simulates the conditions under which the task is performed. 

4.2.2 Work Activities Analysis 

Appendix E or a similar chronological timeline is used to record the work activities 

analysis information. 

A. Develop an event scenario timeline and narrative out to the time the position would 

be relieved of the responsibilities for the task. 
NEI 10-05 (Revision 0) 

June 2011 

27 

This scenario should be documented in a manner similar to a drill/exercise package 

and include a description of the methods used to perform and observe the 

accomplishment of the task actions. 

Level of detail should include defining whether the simulation starts in another 

location, travel time to the location where the activity is accomplished, delay time to 

acquire a procedure or get clearance to enter an area, environmental conditions likely 

to be present when the activity is performed (low visibility due to smoke, heat, lower 

levels of lighting for LOPs, etc.) 

Documentation of the scenario should be similar to an extent-of-play description 

typically included in exercise scenario manuals. The level of documentation for the 

scenario is determined by station processes. 

NOTE: It may be useful to include a reference to a procedure or instruction in the column 

used to record the task / action step description. 

B. Run the scenario in an appropriate setting (walkthrough, simulator session, drill, etc.) 

and record the time, event condition and action performed for each task being 

analyzed. 

C. Determine whether there is an overlap of task steps that would preclude or impact the 

ability or timeliness to perform the actions. 

4.2.3 Personnel Requirements (Staffing Plan) Analysis 

A. Evaluate the results of the work activities analysis for overlap of concurrent task 

activity steps performed by single on-shift positions. 

B. If an overlap or other conflict is identified, the issue must be documented within the 

station corrective action process, evaluated and addressed15. 

Dispositioning of an overlap or other conflict may include the following: 

• Performing additional formal task analysis (for example, Systems Approach to 

Training - SAT analysis) to determine whether the overlap can be resolved and 

justified as currently implemented, such as by prioritization of activities based on 

importance and difficulty. Refer to Appendix F for difficulty and importance 

definitions specific to EP tasks SAT analyses that may be used to assist in the 

dispositioning of overlapping responsibilities. 

• Reassigning one or more tasks or steps that caused the overlap to another on-shift 

position. Reassignment of tasks or steps would require re-analysis of the affected 

positions to ensure no new overlap was created by the reassignment. 

 

15 It is expected that analysis results will be verified and validated prior to submitting a condition report. Once a 

condition report is submitted, it will be necessary to determine whether interim corrective actions are necessary. 
NEI 10-05 (Revision 0) 

June 2011 

28 

• Implementing technology solutions that alter the steps or timing of activities 

related to the overlapping tasks (for example, replacing a manual call process with 

an automated system). 

• Adding additional personnel to the on-shift ERO. If an overlap of responsibilities 

cannot be justified, eliminated by reassignment to an existing on-shift ERO 

position (that would not create a new overlap) or removed by alteration, then 

actions to eliminate the overlap with additional permanent on-shift ERO 

personnel, and potentially immediate compensatory actions, would be required to 

address the overlap. 
NEI 10-05 (Revision 0) 

June 2011 

29 

5 REFERENCES 

5.1 10 CFR § 50.47 Emergency plans – Section (b) 

5.2 10 CFR § 50.54 Conditions of licenses – Section (m) 

5.3 10 CFR § 50.54 Conditions of licenses – Section (hh) 

5.4 10 CFR § 50.72 Immediate notification requirements for operating nuclear power reactors 

– Section (c) 

5.5 10 CFR § 73.71 Reporting of safeguards events – Section (b) 

5.6 10 CFR § 50, Appendix E – Emergency Planning and Preparedness for Production and 

Utilization Facilities 

5.7 ANSI/ANS-58.8-1994, Time Response Design Criteria for Safety-Related Operator 

Actions 

5.8 Electric Power Research Institute (EPRI) Proprietary Report TR-101869, Severe Accident 

Management Guidance Technical Basis Report, Vols. 1 and 2, 1992 

5.9 NRC Generic Letter 86-04, Policy Statement on Engineering Expertise On-Shift 

5.10 NRC Information Notice 91-77, Shift Staffing at Nuclear Power Plants 

5.11 NRC Information Notice 93-81, Implementation of Engineering Expertise On-Shift 

5.12 NRC Information Notice 95-48, Results of Shift Staffing Study 

5.13 NSIR/DPR-ISG-01, Interim Staff Guidance – Emergency Planning for Nuclear Power 

Plants 

5.14 NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency 

Response Plans and Preparedness in Support of Nuclear Power Plants 

5.15 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for 

Nuclear Power Plants 

5.16 NUREG-1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions 

in Response to Fire 

5.17 NUREG/CR-3903, Analysis of Emergency Staffing for Nuclear Power Plants 

5.18 Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants 

5.19 Regulatory Guide 1.8, Qualification and Training of Personnel for Nuclear Power Plants 

5.20 Regulatory Guide 1.214, Response Strategies for Potential Aircraft Threats 
NEI 10-05 (Revision 0) 

June 2011 

30 

[THIS PAGE IS LEFT BLANK INTENTIONALLY]
A-1 

APPENDIX A 

Analyzed Events and Accidents 

Analysis 

# Summary Description of Event or Accident Plant Mode Reference Document(s) ECL 

1 Land and/or waterborne HOSTILE ACTION directed 

against the Protected Area by a HOSTILE FORCE. 

Assume adversary characteristics defined by the Design Basis Threat (DBT). 

1 Site Area 

Emergency 

2 3 4 5 6 7 8 9 

10 
NEI 10-05 (Revision 0) 

June 2011 

A-2 

[THIS PAGE IS LEFT BLANK INTENTIONALLY]
B-1 

APPENDIX B 

On-Shift Staffing Analysis 

Complete this appendix by following the instructions in section 3.2.2.

This OSA is applicable to Analysis # _______ as identified in Appendix A. TABLE 1 – On-shift Positions 

Line On-shift Position Emergency Plan Reference Augmentation Elapsed Time (min) Role in Table#/Line# U

1.2.3.4.5.6.7.8.9.10.11.12.13.14.
NEI 10-05 (Revision 0) 

June 2011 

B-2 

On-Shift Staffing Analysis 

TABLE 1 – On-shift Positions (continued) 

Line On-shift Position Emergency Plan Reference Augmentation Elapsed Time (min) Role in Table#/Line# U

15.16.17.18.19.20.21.22.23.24.25.26.27.28.
NEI 10-05 (Revision 0) 

June 2011 

B-3 

On-Shift Staffing Analysis 

 

TABLE 2 – Plant Operations & Safe Shutdown Analysis # _______

One Unit - One Control Room Applicable to site unit(s) # ___________ 

Minimum Operations Crew Necessary to Implement 

AOPs and EOPs, or SAMGs if applicable 

Line Generic Title/Role On-Shift Position Task Analysis 

Controlling Method 

1 Shift Manager 

2 Unit Supervisor 

3 Shift Technical Advisor 

4 Reactor Operator #1 

5 Reactor Operator #2 

6 Auxiliary Operator #1 

7 Auxiliary Operator #2 

8 Other 

9 Other 

10 Other 

Other (non-Operations) Personnel Necessary to Implement 

AOPs and EOPs, or SAMGs if applicable 

Line Generic Title/Role On-Shift Position Task Analysis 

Controlling Method 

11 Mechanic 

12 Electrician 

13 I&C Technician 

14 Other 
NEI 10-05 (Revision 0) 

June 2011 

B-4 

On-Shift Staffing Analysis 

 

TABLE 2 – Plant Operations & Safe Shutdown Analysis # _______

Two Units - One Control Room Applicable to site unit(s) # ___________ 

Minimum Operations Crew Necessary to Implement 

AOPs and EOPs, or SAMGs if applicable 

Line Generic Title/Role On-Shift Position Task Analysis 

Controlling Method 

1 Shift Manager 

2 Unit Supervisor 

3 Shift Technical Advisor 

4 Reactor Operator #1 

5 Reactor Operator #2 

6 Reactor Operator #3 

7 Auxiliary Operator #1 

8 Auxiliary Operator #2 

9 Auxiliary Operator #3 

10 Other 

11 Other 

12 Other 

Other (non-Operations) Personnel Necessary to Implement 

AOPs and EOPs, or SAMGs if applicable 

Line Generic Title/Role On-Shift Position Task Analysis 

Controlling Method 

13 Mechanic 

14 Electrician 

15 I&C Technician 

16 Other 
NEI 10-05 (Revision 0) 

June 2011 

B-5 

On-Shift Staffing Analysis 

TABLE 2 – Plant Operations & Safe Shutdown (continued) Analysis # _______

Two Units - Two Control Rooms Applicable to site unit(s) # ___________ 

Minimum Operations Crew Necessary to Implement 

AOPs and EOPs, or SAMGs if applicable 

Line Generic Title/Role On-Shift Position Task Analysis 

Controlling Method 

1 Shift Manager 

2 Unit Supervisor #1 

3 Unit Supervisor #2 

4 Shift Technical Advisor 

5 Reactor Operator #1 

6 Reactor Operator #2 

7 Reactor Operator #3 

8 Reactor Operator #4 

9 Auxiliary Operator #1 

10 Auxiliary Operator #2 

11 Auxiliary Operator #3 

12 Auxiliary Operator #4 

13 Other 

14 Other 

15 Other 

16 Other 

Other (non-Operations) Personnel Necessary to Implement 

AOPs and EOPs, or SAMGs if applicable 

Line Generic Title/Role On-Shift Position Task Analysis 

Controlling Method 

17 Mechanic 

18 Electrician 

19 I&C Technician 

20 Other 
NEI 10-05 (Revision 0) 

June 2011 

B-6 

On-Shift Staffing Analysis 

TABLE 3 – Firefighting Analysis # _______

Line Performed By Task Analysis 

Controlling Method 

1 

2 

3 

4 

5 
B-7 

On-Shift Staffing Analysis 

TABLE 4 – Radiation Protection & Chemistry 

Line Position Performing Function/Task 

Performance Time Period After Emergency Declaration 

0-

5 

5- 

10

10-

15 

15-

20 

20-

25 

25-

30 

30-

35 

35- 

40 

40- 

45 

45-

50 

50-

55 

55-

60 

60-

65 

6

7

1 

In-Plant Survey On-Shift Position: 

2 

On-Site Survey On-Shift Position: 

3 

Personnel Monitoring On-Shift Position: 

4 

Job Coverage On-Shift Position: 

5 

Offsite Radiological Assessment On-Shift Position: 

6 

Other Site-Specific RP – Describe: On-Shift Position: 

7 

Chemistry function/task #1 – Describe: On-Shift Position: 

8 

Chemistry function/task #2 – Describe: On-Shift Position: 
NEI 10-05 (Revision 0) 

June 2011 

B-8 

On-Shift Staffing Analysis 

 

TABLE 5 – Emergency Plan Implementation Analysis # _______ 

Line Function/Task On-Shift Position Task Analysis 

Controlling Method

1 Declare the Emergency 

Classification Level (ECL) 

 

2 Approve Offsite Protective Action 

Recommendations 

 

3 Approve content of State/local 

notifications 

 

4 Approve extension to allowable 

dose limits 

 

5 

Notification and direction to onshift staff (e.g., to assemble, 

evacuate, etc.) 

 

6 ERO notification 

7 Abbreviated NRC notification for 

DBT event 

 

8 Complete State/local notification 

form 

 

9 Perform State/local notifications 

10 Complete NRC event notification 

form 

 

11 Activate ERDS 

12 Offsite radiological assessment 

13 Perform NRC notifications 

14 

Perform other site-specific event 

notifications (e.g., INPO, ANI, 

etc.) 

 

15 Personnel accountability 

16 Other: Specify 
C-1 

APPENDIX C 

ERO Function List (by Planning Standard)

A) Assignment of Responsibility (Organization Control): §50.47(b)(1) 

1) Coordination with Offsite Response Agencies (EM, ICP, Field Mon, etc.) 2) Continuous Staffing and Shift Relief 

B) Onsite Emergency Organization: §50.47(b)(2) 

1) Plant Operations (status monitoring and EOP actions) 2) Command and Control 3) Facility/Group Management and Supervision 4) ERO Mobilization and Response (persons receiving the notification) 

5) Use of Medical, Fire and Law Enforcement Support 

C) Emergency Response Support and Resources: §50.47(b)(3) 

1) Request, Integration and Use of Offsite Personnel within the ERFs 

2) Dispatch and Control of Offsite EOC Liaisons 3) Contact and Use of External Support Services (technical, material, etc.) 

D) Emergency Classification System: §50.47(b)(4) 

1) Event Classification 

E) Notification Methods and Procedures: §50.47(b)(5) 

1) ERO Notification 2) Local/State Event Notification (ECL and PAR) 3) NRC Event Notification 4) Siren Activation/EAS Message Development 

F) Emergency Communications: §50.47(b)(6) 

1) Inter-Facility Communications 2) NRC Emergency Telecommunications System 3) Inter-Agency/Organization Communications 4) Industry Event Communications (INPO, ANI, etc.) 

G) Public Education and Information: §50.47(b)(7) 

1) Media Statements 2) Media Briefings 3) Accommodation of News Media Personnel 4) Media Monitoring 5) Rumor Control 

H) Emergency Facility and Equipment: §50.47(b)(8) 

1) Facility/Work Area Setup 2) Facility Activation 3) Facility Operation 4) Facility Relocation 5) Facility Information Display Systems 

I) Accident Assessment: §50.47(b)(9) 

1) Accident Detection and Assessment 

a) Engineering analysis b) Plant system prognosis c) Priorities of mitigating actions 

2) Dose Assessment 

a) Meteorological assessment b) Release determination/projection 

3) Core Damage Assessment 4) Radiological Monitoring (in plant, onsite and 

5) Response Team Activities (damage assessme

a) Task development and prioritization b) Team briefing, dispatch and control 

6) Extreme Measures 

J) Protective Response: §50.47(b)(10) 

1) Assembly and Accountability (onsite and/or o

a) Search and rescue 

2) Evacuation (local area, protected area and OC

a) Precautionary dismissal b) Site access controls 

3) Authorization and use of KI 4) Offsite Protective Action Recommendations 5) Personnel Protective Equipment 

K) Radiological Exposure Control: §50.47(b)(11) 

1) Authorization and use of Emergency Exposur

2) Monitoring and Decontamination (personnel, 3) Contamination and Habitability Controls (site 

L) Medical and Public Health Support: §50.47(b)(

1) First Aid 2) Transportation of Contaminated Injured Perso3) Medical Treatment Assistance 

M) Recovery Planning and Post-accident Operatio

1) Event Termination 2) Initiation and Operation of the Recovery Org3) Environmental Sampling (ingestion pathway 

Z) ERO Fundamentals 

1) Briefings and Updates 2) Log and Record Keeping 3) Post Event Facility/Work Area Restoration A4) Human Performance Error Reduction Techni
NEI 10-05 (Revision 0) 

June 2011 

C-2 

NUREG/CR-3903 On-shift Functions

Plant Operations – activities performed or directed by licensed operators to stabilize the event 

and bring the reactor to a safe shutdown condition. 

Current plant status: activities related to monitoring the status of the major reactor systems: 

the reactor core, the primary coolant boundary, the emergency core cooling system and the 

integrity of the containment building. 

Corrective actions: all activities related to the execution of emergency operating procedures. 

Damage assessment and repair: tasks necessary to identify damaged systems or components, 

put them back into operating condition, and verify the proper performance of corrective 

maintenance. 

Firefighting: all activities needed to locate, contain and extinguish fires. 

Emergency Assessment – diagnoses of past and present plant conditions and prognoses of 

future plant conditions that guide emergency personnel in their efforts to mitigate damage to the 

plant and prevent exposure to radiation. 

Emergency classification: the comparison of key plant parameters or conditions to 

emergency action levels. 

Engineering analysis: primarily the development of solutions to mechanical, electrical, 

instrumentation and control, and core physics/thermohydraulic problems. However, it also 

includes the diagnosis of the accident causes and the development of plans and procedures 

for corrective actions. 

Plant systems prognosis: projection of the future status of the reactor core, primary coolant 

boundary, emergency core cooling system and containment integrity. 

Source term projection/assessment: evaluation of the likely release fractions of various 

isotopes from the fuel and primary coolant system, as well as the time sequence of the 

releases. The source term assessment is based upon plant systems prognosis, radiochemical 

analysis and direct measurements of inplant radiation levels. 

Radiochemical analysis: preparation and analysis of samples of reactor coolant, contaminant 

atmosphere, and stack or liquid effluents. 

Protective Response – actions taken to prevent or minimize exposure of individual s to 

unnecessary hazards. 

Radiological monitoring: dispatching of teams to any of three principal areas - inplant, onsite 

or offsite - and involves the measurement, recording and transmission of radiation survey 

data. 

Meteorological assessment: collection of primary meteorological data, calculation of 

dispersion parameters, and the forecasting of future meteorological conditions. 
NEI 10-05 (Revision 0) 

June 2011 

C-3 

Dose projection/assessment: calculation of dose rates from source term derived from one of 

three bases: (1) plant systems data (either current plant status or plant system prognosis), (2) 

inplant radiological information and effluent measurements, or (3) environmental samples. It 

also includes the projection of total (integral) dose over specified time frames. 

Protective action recommendation: determination of the appropriate protective action for 

selected individuals onsite or offsite and the communication of the recommendation to the 

responsible authorities. The primary inplant protective actions involve use of respirators, 

radioprotective drugs, protective clothing, shielding, access control and evacuation. Offsite 

protective actions are primarily sheltering and evacuation. 

Radiological exposure control: activities such as briefing of teams (e.g., exposure limits, 

routes of travel and stay times in radiation hazard areas), issuance of dosimetry and recording 

of exposures. 

Search and rescue: locating missing or injured plant personnel, diagnosing any injuries, 

administering first aid, and transporting the victim to treatment facilities. 

Decontamination: all activities required to remove surface contamination from exposed plant 

personnel. 

Environmental sampling: dispatch of survey teams, collection of air, water or soil samples, 

the recording and transmission of environmental data and the analysis of samples collected. 

Analysis of environmental samples may be used to confirm dose assessments or to form the 

basis for offsite protective responses. 

Emergency Management – activities by which the physical and human resources used to 

respond to the emergency are maintained and controlled to accomplish the goals of the 

emergency response effort. 

Activation of emergency organizations: notification of required plant personnel onsite and 

off-duty as well as members of offsite emergency organizations. 

Offsite coordination: communication of emergency conditions, analyses and actions to offsite 

organizations. These Include the State and local operations centers and support facilities, 

corporate headquarters, industry support groups (e.g., NSSS vendor, A/E, INPO, ANI), and 

the NRC. 

Onsite management: establishment and maintenance of communication and coordinated 

action among response teams performing plant operations, emergency assessment and 

protective response functions. 

Accountability: establishment and maintenance of records of the location of all onsite 

personnel and establishment of the Identity and probable location of missing persons.

Security: restriction of access to the site or controlled areas within the site and control of the 

evacuation of nonessential personnel. 

Documentation: recording of plant status and prognosis, corrective actions implemented, and 

protective actions recommended and implemented. 
NEI 10-05 (Revision 0) 

June 2011 

C-4 

Administrative and logistic support: activities required to provide additional onsite personnel, 

material or equipment, or to request offsite firefighting, medical or security support. 

Public information: periodic press releases and press conferences in coordination with local, 

state and federal response agencies. 

Several NUREG/CR-3903 function descriptions involve multiple planning standards, and 

actually consist of several functions. A table correlating the NUREG/CR-3903 generalized onshift functions with the NUREG-0654 planning standard categorized functions is provided 

below: 

NUREG/CR-3903 function PS function Comments 

Plant Operations 

Current plant status B.1 

Corrective actions B.1 

Damage assessment and repair J.6 

Firefighting J.6 

Emergency Assessment 

Emergency classification D.1 

Engineering analysis I.1 

Plant systems prognosis I.1 

Source term projection/assessment I.4 

Radiochemical analysis I.4 part of core damage assessment 

Protective Response 

Radiological monitoring I.3 

Meteorological assessment I.2 part of dose assessment 

Dose projection/assessment I.2 

Protective action recommendation E.2, J.3, K.3 / J.4 

Radiological exposure control J.6 title not consistent with description 

Search and rescue J.1 

Decontamination K.2 

Environmental sampling M.3 

Emergency Management 

Activation of emergency organizations E.1, E.2, E.3 

Offsite coordination C.1, E.4 

Onsite management J.6 title not consistent with description 

Accountability J.1 

Security J.2 

Documentation Z.2 not a planning standard 

Administrative and logistic support B.2, C.4 

Public information G.1, G.2 
D-1 

APPENDIX D 

Function / Responsibility (Task) Analysis Template 

Event: ____________________________ Position: ___________________________Function Responsibility (Task) Action Step 1. 1.1 1.1.1  1.1.2  1.1.3  1.2. 1.2.1  1.2.2  1.2.3  1.3. 1.3.1  1.3.2  1.3.3 2. 2.1 2.1.1  2.1.2  2.1.3  2.2. 2.2.1  2.2.2  2.2.3  2.3. 2.3.1  2.3.2  2.3.3 
NEI 10-05 (Revision 0) 

June 2011 

D-2 

[THIS PAGE IS LEFT BLANK INTENTIONALLY]
E-1 

APPENDIX E 

Work Activities Analysis Template 

Event: ____________________________ Position: _____________Time 

Plant/equipment/environmental events and conditions applicable to the functions and tasks 

Task / Action Step description (start & stop) 
NEI 10-05 (Revision 0) 

June 2011 

E-2 

[THIS PAGE IS LEFT BLANK INTENTIONALLY]
NEI 10-05 (Revision 0) 

June 2011 

F-1 

APPENDIX F 

EP Based Responsibility (task) ‘Difficulty’ and ‘Importance’ Rating Criteria 

One potential method to disposition an overlap in tasks would be to evaluate the importance and 

difficulty attributes of those tasks in order to provide the ability to prioritize actions formally 

within the implementing procedure instructions. 

Typically, ERO procedures are written broadly to allow actions to be taken as they apply to the 

circumstances of a particular event. While EP procedures often allow steps to be performed in 

any order or omitted as applicable, they do not always distinguish a priority or hierarchy other 

than for key risk significant activities such as classification, notification and PARs. 

If an overlap of task occurs it may be possible to justify why the overlap of actions is not a 

concern or an impact on the ability of the ERO member to perform the functions of those tasks in 

a timely manner. For example; if the action steps to notify state and local agencies of an event 

overlapped with the action steps to develop a broadcast message for non-ERO utility personnel, 

the actions of the non-critical responsibility could be delayed to a later point in the procedure to 

eliminate the timing overlap. The way this would be done would be to perform a formal task 

analysis to define the attributes applicable to the tasks and then determined whether the 

overlapping tasks could be effectively prioritized and still perform their function. 

Each training department has procedures governing the process of formal task analysis (i.e., SAT 

process). The EP based criteria for difficulty and importance is provided below to aid in a task 

analysis where overlapping actions would be evaluated within a formal process to determine 

whether a priority or hierarchy exists. If it can be shown that overlapping tasks do not need to be 

performed at the same time or otherwise be in conflict, the corrective action could be to enhance 

procedure instruction rather than to reassign the task entirely. 

Difficulty ‘D’ 

The difficulty of a responsibility (task) is based on an average of the difficulty attribute values 

associated with the responsibility (task). Numeric ratings are established from the assumption 

that experience/proficiency levels are those of an individual newly qualified to the ERO. 

Difficulty attributes and their values are as follows: 

5 points 3 points 1 point 

Complexity (# of steps) High Medium Low 

Speed Fast Medium Slow 

Duration Long Medium Short 

Distractions Many Some Few 

Locations Many Some Single 

Overlap Likely Possible Unlikely 

Complexity – Complexity is established by assessing the intricacy or number of steps 

involved with the task. 
NEI 10-05 (Revision 0) 

June 2011 

F-2 

Speed – Speed is established by assessing the pace at which the task must be performed, 

particularly in the case of time dependent activities, such as classification and notification. 

Duration – Duration is established by assessing the time it takes to complete the task and 

whether it is repeated frequently. 

Distractions – Distractions is established by assessing the environment where the task is 

performed in consideration of light, noise, nearby activity, interruption, etc. 

Locations – Locations is established by assessing the number of locations it would take an 

individual to fully perform the task (not how many places the task could be performed from). 

Overlap – Overlap is established by assessing the potential for the task to be performed at the 

same time that another task is being done. For example, Notification steps for a General 

Emergency typically overlap with steps to determine an initial PAR. 

Importance 'I' 

Note: The term Risk Significant Planning Standards refers to Planning Standards described in 

10 CFR 50.47(b)(4), (5), (9) and (10), and related material in Appendix E. 

The importance of a responsibility (task) relative to its emergency response functions or to the 

safety of the public / plant staff is based on a 1 through 5 point scale. 

Considerations for determining the level of importance are based primarily on their relationship 

to a Planning Standard (PS) or Risk Significant Planning Standard (RSPS) and include the 

following: 

High (5 points) – The responsibility (task) involves the accomplishment of a RSPS function 

and failure to perform the task would result in the failure of the RSPS function. 

-ORFailure to accomplish the responsibility (task) correctly results in the immediate risk of death 

to anyone involved in the activity. 

Medium High (4 points) – The task involves the accomplishment of a RSPS function, but 

failure to perform the task would not result in the failure of the RSPS function. 

-ORFailure to accomplish the responsibility (task) correctly creates a personnel safety hazard 

capable of serious injury or risk to health. 

Medium (3 points) – The responsibility (task) involves the accomplishment of a PS function 

and failure to perform the task would result in the failure of the PS function. 
NEI 10-05 (Revision 0) 

June 2011 

F-3 

Medium Low (2 points) – The responsibility (task) involves the accomplishment of a PS 

function, but failure to perform the task would not result in the failure of the PS function. 

Low (1 point) – The responsibility (task) does not involve the accomplishment of a RSPS or 

PS function.