Issue Date: 11/08/11 - 1 - 82002.05

ATTACHMENT 82002.05

EMERGENCY RESPONSE ORGANIZATION ON-SHIFT STAFFING AND 

AUGMENTATION DRILLS

82002.05-01 INSPECTION OBJECTIVES

To verify, prior to fuel load of the plant, the adequacy of the licensee’s on-shift 

Emergency Response Organization (ERO) staffing and its ability to augment the ERO.

82002.05-02 INSPECTION REQUIREMENTS

02.01 Review Emergency Response Organization (ERO) on-shift staffing

a. Verify that the licensee’s detailed on-shift staffing analysis required by 10 CFR 

50, Appendix E, Section IV.A.9 has been completed and that there are no onshift staffing deficiencies.

b. Determine the adequacy of the licensee’s ERO on-shift staffing levels. 

02.02 Implement Inspection Procedure 71114, AReactor Safety - Emergency 

Preparedness,@ Attachment 71114.03, AEmergency Response Organization Staffing and 

Augmentation System.@ Implement the IP elements designated for the initial 

augmentation system design.

02.03 Review ERO Augmentation staffing. 

02.04 Review the specific elements of the ERO Augmentation drill scenario. 

02.05 Determine through observation of an ERO Augmentation drill whether ERO 

members can augment the on-shift staff in a timely manner.

02.06 Determine the effectiveness of licensee corrective actions in addressing ERO 

on-shift and augmentation staffing issues.

82002.05-03 INSPECTION GUIDANCE

03.01 Review the licensee’s on-shift staffing analysis required by 10 CFR 50, 

Appendix E, Section IV.A.9. Determine if the licensee used the scope of scenarios 

specified in NSIR/DPR-ISG-01, “Interim Staff Guidance, Emergency Planning for 

Nuclear Power Plants,” for this analysis or an alternative scope of scenarios. If an 

alternative scope of scenarios was used, review the licensee’s justification for its choice 

of scenarios.

Verify that the licensee entered any on-shift staffing deficiencies from its analysis into 

the corrective action program and either corrected those deficiencies or placed 

compensatory measures in place until final on-shift staffing levels are attained. If no on-
Issue Date: 11/08/11 - 2 - 82002.05

shift staffing deficiencies were noted in the analysis, review the licensee’s on-shift 

staffing commitments specified in the Emergency Plan against those in NUREG-0654, 

Table B-1. Verify that the licensee has provided justification for any variance from Table 

B-1 on-shift staffing levels.

03.02 No inspection guidance.

03.03 The inspector shall understand the duty roster, the minimum ERO staffing 

necessary to activate emergency response facilities (ERFs) to meet Emergency Plan 

requirements, and the reference starting time (e.g., event declaration or ERO 

notification). Conduct of the drill requires NRC inspection personnel to be stationed at 

the ERFs` to determine if responding ERO members can meet augmentation timeliness 

goals.

An ERF may not require all ERO members to be present in order to declare the facility 

functional. Some licensees’ Emergency Plans identify the minimum staff/positions 

necessary for a functional facility. In the absence of such a pre-determination, the 

guidance of NUREG-0654, Table B-1 may be used.

03.04 An ERO augmentation drill will be necessary to determine that the licensee’s EP

program can meet augmentation goals and/or has determined the extent of problem 

conditions. Elements of the augmentation drill shall include:

a. Activation of the augmentation system.

b. The time of the ERO augmentation drill must be held confidential, although the 

plan to implement such a drill may be communicated to employees as this may 

be a significant departure from normal operations. 

c. It may be appropriate to notify local authorities of the augmentation drill so as 

not to unduly alarm officials.

d. The activation must simulate emergency activation of the ERO and also notify 

personnel that it is a drill and not an actual emergency. This message would 

have to be crafted in a manner that would request personnel to respond as if it 

were an actual emergency.

e. It may be appropriate to include the actual set up and activation of facilities as 

part of the augmentation drill.

03.05 Requirements for activation of the emergency organization may be found in 10 

CFR Part 50, Appendix E, Section IV.C. The licensee's Emergency Plan, implementing 

procedures, and other relevant documentation should be reviewed to determine 

expectations for successful ERF activation. It may be useful to identify the ERO actions 

for the activation of the augmentation system, ERO personnel expected to respond, any 

offsite authorities notified as part of the augmentation, and any corporate support 

personnel expected to respond.
Issue Date: 11/08/11 - 3 - 82002.05

03.06 Request from the licensee a printout of corrective action items concerning onshift and augmentation ERO staffing deficiencies. Verify that adequate corrective 

actions were identified and implemented to correct those deficiencies.. 

82002.05-04 RESOURCE ESTIMATE

It is estimated that conduct of this attachment will take 40 hours.

END
Issue Date: 11/08/11 E1-1 82002.05

Exhibit 1

Revision History for IP 82002.05

Commitment 

Tracking Number

Issue Date Description of 

Change

Training Needed Training 

Completion Date

Comment 

Resolution 

Accession Number

N/A 11/08/11

CN 11-030

ML111040310

Initial issue to 

support inspections 

of construction 

programs described 

in IMC 2504, 

Construction 

Inspection 

Program: 

Inspection of 

Construction and 

Operational 

Programs.

Completed 4 year 

search of historical 

CNs and found no 

commitments 

related to this 

Inspection 

Procedure.

None N/A N/A