NRC INSPECTION MANUAL NMSS/FCSS

MANUAL CHAPTER 1247 APPENDIX C3

FUEL FACILITY EMERGENCY PREPAREDNESS INSPECTOR TECHNICAL PROFICIENCY 

TRAINING AND QUALIFICATION JOURNAL
Issue Date: 06/11/14 i 1247 Appendix C3

Table of Content

Introduction ..................................................................................................................................... 1

Required Health Physics Inspector Training Courses ................................................................... 1

Required Refresher Training: ......................................................................................................... 1

Fuel Facility Emergency Preparedness Inspector Study Guides .................................................. 2

(SG-EP-1) Code of Federal Regulations for Emergency Preparedness Inspectors ......... 3

(SG-EP-2) Preparation and Evaluation of Radiological Emergency Plans ....................... 5

(SG-EP-3) Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents .................................................................................................................. 7

Fuel Facility Emergency Preparedness Inspector On-the-Job Training Activities ...................... 10

(OJT-EP-1) Emergency Drill/Exercise Evaluation............................................................ 11

(OJT-EP-2) Corrective Actions for Emergency Preparedness Weaknesses .................. 15

(OJT-EP-3) Emergency Action Level and Emergency Plan Changes............................. 18

Health Physics Inspector Technical Proficiency LevelSignature Card and Certification............. 21

Form 1: Fuel Facility Emergency Preparedness Inspector Technical Proficiency-Level 

Equivalency Justification............................................................................................................... 22

Attachment 1............................................................................................................................Att1-1
Issue Date: 06/11/14 1 1247 Appendix C3

Introduction

Consult with your supervisor prior to beginning the activities or completing the courses in this 

qualification journal. In most cases, you will need to complete the Basic Inspector Certification 

Journal prior to beginning the activities in this Appendix. You may complete the General 

Proficiency requirements contained in Appendix B together with the Technical Proficiency 

requirements outlined in this journal.

Several of the topics have both an individual study guide and on-the-job training. You must 

complete the individual study guide before beginning the corresponding on-the-job training.

Before signing up for any course, be sure that you have checked and have met any 

prerequisites.

Required Emergency Preparedness Inspector Training Courses:

(These courses have the completion of Appendix A of IMC 1247 as a prerequisite)

 (F-206S) Fire Protection for Fuel Cycle Facilities Self-Study Course

Required Refresher Training:

(To be completed every three years)

 (8 hours) OSHA HAZWOPR Refresher Course or iLearn Health and Safety 

Training Suite as identified in Memorandum dated May 7, 2010, from Catherine 

Haney to NMSS Branch Chiefs (See ADAMS Accession No. ML100200563 for 

details of equivalent iLearn training modules).

 (16 Hours) Refresher Technical Training Seminar as approved by supervisor
Issue Date: 06/11/14 2 1247 Appendix C3

Fuel Facility Emergency Preparedness Inspector

Study Guides
Issue Date: 06/11/14 3 1247 Appendix C3

Fuel Facility Emergency Preparedness Inspector Study Guide

TOPIC: (SG-EP-1) Code of Federal Regulations for Emergency Preparedness 

Inspectors

PURPOSE: The purpose of this activity is to familiarize you with the regulations having 

direct application to emergency preparedness inspections and the 

licensee’s emergency management program. By ensuring that the site is 

in compliance with requirements in the Code of Federal Regulations 

(CFR), we can determine the emergency management program is 

adequate and maintained in a state of readiness to protect workers, the 

public, and the environment.

COMPETENCY

AREA: REGULATORY FRAMEWORK

TECHNICAL EXPERTISE

LEVEL OF

EFFORT: 8 hours

REFERENCES: 1. 10 CFR Part 70.22, “Contents of Applications” subsection (i)(3)

2. 10 CFR Part 70.32, “Conditions of Licenses” subsection (i)

3. 10 CFR Part 40.31, “Application for Specific Licenses” subsection 

(j)(3)

4. 10 CFR Part 40.35, “Conditions of Specific Licenses Issued 

Pursuant to Subsection 40.34” subsection (f)

5. 10 CFR Part 76.91, “Emergency Planning”

6. 10 CFR Part 76.91, “Emergency Planning” subsection (o)

7. NUREG-1520, “Standard Review Plan for the Review of a License 

Application for a Fuel Cycle Facility” (ML013380540)

EVALUATION 

CRITERIA: Upon completion of this SG, the inspector should be able to:

1. Describe each of the planning standards for an emergency 

response plan.

2. Discuss which emergency response planning standards are risk 

significant.
Issue Date: 06/11/14 4 1247 Appendix C3

3. Explain the requirements for making changes to the Emergency 

Plans as presented in 10 CFR Part 40, 10 CFR Part 70, and 10 

CFR Part 76.

4. Discuss the limits for exposure to the general public during an 

event.

TASKS: 1. Review pertinent sections of 10 CFR Part 40.31, 10 CFR Part 

70.22, and 10 CFR Part 76.91 to familiarize yourself with the 

information which must be contained in Emergency Plans.

2. Review Section 8 of NUREG-1520 for contents of an Emergency 

Plan considered acceptable by license reviewers.

3. Meet with your supervisor, the person designated as a resource, or 

a qualified Fuel Facility Emergency Preparedness Inspector to 

discuss any questions you may have as a result of these activities. 

Discuss the answers to the questions listed under the Evaluation 

Criteria section of this study guide with your supervisor or the 

person designated as a resource.

DOCUMENTATION: Fuel Facility Emergency Preparedness Inspector Proficiency Level 

Qualification Signature Card, Item SG-EP-1.
Issue Date: 06/11/14 5 1247 Appendix C3

Fuel Facility Emergency Preparedness Inspector Study Guide

TOPIC: (SG-EP-2) Preparation and Evaluation of Radiological Emergency Plans

PURPOSE: The purpose of this activity is to familiarize you with the criteria used by 

NRC licensed facilities to develop radiological Emergency Plans and 

improve emergency preparedness. Emergency Plans submitted under 10 

CFR Parts 40, 70, and 76 must include the planning standards listed in 10 

CFR Parts 40.31, 70.22, and 76.91.

COMPETENCY

AREA: TECHNICAL AREA EXPERTISE

REGULATORY FRAMEWORK 

LEVEL OF 

EFFORT: 16 hours

REFERENCES: 1. Regulatory Guide (RG) 3.67, “Standard Format and Content for 

Emergency Plans for Fuel Cycle and Material Facilities” 

(ML003739885)

2. NUREG-1520, “Standard Review Plan for the Review of a License 

Application for a Fuel Cycle Facility” (ML013380540)

3. NUREG-1140, “A Regulatory Analysis of Emergency Preparedness 

for Fuel Cycle and Other Radioactive Material Licensees” 

(ML062020791)

EVALUATION

CRITERIA: Upon the completion of this SG, the inspector should be able to: 

1. Discuss key elements of the basis for emergency planning.

2. Discuss the general topics of the emergency planning standards.

3. Discuss the difference between the two emergency classification 

levels in terms of safety significance to the public

4. Discuss the key functions performed by members of the licensee’s 

emergency response organization, including the personnel 

responsible for emergency classification during normal operations 

and back shifts.

5. Discuss the notification process and timeliness for completing offsite 

notifications (State, local, and NRC).
Issue Date: 06/11/14 6 1247 Appendix C3

6. Discuss response plans for restoring the facility to a safe status 

following an accident.

TASKS: 1. Obtain a copy of NUREG-1520 and review Section 8.0.

2. Obtain a copy of RG 3.67 and read it in its entirety.

3. Obtain a copy of NUREG-1140 and read Sections 1.0 and 2.0.

4. Meet with your supervisor, the person designated as a resource, or 

a qualified Fuel Facility Emergency Preparedness Inspector to 

discuss any questions you may have as a result of these activities. 

Discuss the answers to the questions listed under the Evaluation 

Criteria section of this study guide with your supervisor or the 

person designated as a resource.

DOCUMENTATION: Fuel Facility Emergency Preparedness Inspector Proficiency Level 

Qualification Signature Card, Item SG-EP-2
Issue Date: 06/11/14 7 1247 Appendix C3

Fuel Facility Emergency Preparedness Inspector Study Guide

TOPIC: (SG-EP-3) Manual of Protective Action Guides and Protective Actions for 

Nuclear Incidents

PURPOSE: The purpose of this activity is to familiarize you with the guidance used by 

decision makers for State, local, and NRC regarding the appropriate 

protective action recommendations (PARs) in the event of a radiological 

emergency.

COMPETENCY

AREA: INSPECTION 

TECHNICAL AREA EXPERTISE 

LEVEL OF

EFFORT: 24 hours

REFERENCES: 1. EPA 400-R-92-001, “Manual of Protective Action Guides and 

Protective Actions for Nuclear Incidents” (ML003769701)

2. NRC Response Technical Manual (RTM)

3. NUREG-1140, “A Regulatory Analysis on Emergency Preparedness 

for Fuel Cycle and other Radioactive Material Licensees” 

(ML062020791)

4. Defense Nuclear Facilities Safety Board letter regarding red oil 

dated November 13, 2003

5. Memorandum dated March 10, 2003, “Regulatory Authority Over

Chemical Hazards At Fuel Cycle Facilities” (ML030700317)

6. SECY 02-0216, “Proposed Process For Providing Information On 

Significant Nuclear Materials Issues And Adverse Licensee 

Performance” (ML022410435)

EVALUATION

CRITERIA: Upon completion of this Study Guide, the inspector should be able to: 

1. Discuss protective action guides (PAGs) and the use of PAGs in 

planning for protective actions to safeguard the public and 

environment.

2. Discuss the different phases of an accident.

3. Discuss the PAGs for the early phase of an accident.
Issue Date: 06/11/14 8 1247 Appendix C3

4. Discuss the range of possible protective action recommendations.

5. Discuss possible exceptions to implementing the protective actions.

6. Discuss the PAGs for the late phase of an accident.

7. Discuss the various exposure pathways.

8. Discuss fuel cycle events, offsite consequences, and the anticipated 

response by State, local, and Federal authorities.

9. Discuss the possible consequences of a uranium hexafluoride (UF6) 

release and determine the need for protective actions.

10. Describe the concern with the red oil phenomenon and how facilities 

protect against it.

11. Describe your Regulatory Authority Over Chemical Hazards At Fuel 

Cycle Facilities.

12. Chemical Safety Training from the University of Illinois at Chicago 

on Hydrofluoric Acid

13. Honeywell Special Chemicals Training Presentation on Hydrofluoric 

Acid

14. Interim Guidance - Inspector Duties/Responsibilities During 

Terrorist-Based Threats/Attacks at Region II Reactor and Fuel 

Facilities

TASKS: 1. Obtain a copy of EPA 400-R-92-001 and read chapters 1 through 5.

2. Obtain a current copy of the NRC RTM and review Table B-6, 

Section E, and Methods E.1, E.2, E.3, and E.4.

3. Review Section 2.0 of NUREG-1140.

4. Obtain a copy of Defense Nuclear Facilities Safety Board letter 

regarding red oil dated November 13, 2003, and review the safety 

measure to prevent red oil.

5. Obtain a copy of references on hydrofluoric acid and describe the 

precautions necessary to prevent a chemical hazard.

6. Review and describe the Interim Guidance on Inspector 

Duties/Responsibilities During Terrorist-Based Threats/Attacks at 

Region II Reactor and Fuel Facilities.
Issue Date: 06/11/14 9 1247 Appendix C3

7. Meet with your supervisor, the person designated as a resource or a 

qualified Fuel Facility Emergency Preparedness Inspector to 

discuss any questions you may have as a result of these activities. 

Discuss the answers to the questions listed under the Evaluation 

Criteria section of this study guide with your supervisor or the 

person designated as a resource.

DOCUMENTATION: Fuel Facility Emergency Preparedness Inspector Proficiency Level 

Qualification Signature Card, Item SG-EP-3
Issue Date: 06/11/14 10 1247 Appendix C3

Fuel Facility Emergency Preparedness Inspector

On-the-Job Training Activities
Issue Date: 06/11/14 11 1247 Appendix C3

Fuel Facility Emergency Preparedness Inspector On-the-Job Training

TOPIC: (OJT-EP-1) Emergency Drill/Exercise Evaluation

PURPOSE: Fuel facilities are required to conduct emergency exercises biennially. The 

biennial exercise is a full-scale test of the entire onsite emergency 

response organization and the offsite support organizations are invited to 

participate. The performance of a full-scale exercise using scenarios that 

are not known by exercise participants provides the licensee with an 

opportunity to assess the performance of the emergency organization to 

identify and correct areas of deficiencies. Areas of deficiencies may 

include personnel performance, equipment operability, and training. Upon 

completion of this on-the-job training (OJT), you should be able to evaluate 

the adequacy of a licensee’s emergency response program and the 

effectiveness of the licensee to self-identify and resolve problems related 

to their emergency preparedness program.

COMPETENCY

AREA: INSPECTION 

TECHNICAL AREA EXPERTISE 

LEVEL OF 

EFFORT: 50 hours

REFERENCES: 1. RG 3.67, “Standard Format and Content for Emergency Plans for 

Fuel Cycle and Material Facilities” (ML003739885)

2. NUREG-1520, “Standard Review Plan for the Review of a License 

Application for a Fuel Facility” (ML013380540)

3. 10 CFR Parts 70.22, 76.91, and 40.31

4. IP 88051, “Evaluation of Exercises and Drills”

5. Site Emergency Plan

6. IP 88050, “Emergency Preparedness”

7. Office of Investigation and Enforcement, Information Notice No. 89-

46, “Confidentiality of Exercise Scenarios”

8. NRC Letter (Edward McAlpine) to all Fuel Facilities dated November 

20, 1996, “Submittal of Exercise Objectives and Scenario Details”
Issue Date: 06/11/14 12 1247 Appendix C3

EVALUATION

CRITERIA: Upon completion of the tasks in this OJT, you should be able to: 

1. Review a licensee’s exercise scenario submittal package to 

determine if the scenario details would provide an adequate test of 

the Emergency Plan, Plan implementing procedures, and 

equipment.

2. Discuss the time-line requirements for exercise scenario submittal 

packages and how submittals should be submitted to the NRC.

3. Evaluate the performance of exercise participants in areas such as: 

emergency classification, offsite notifications, protective action 

recommendations (PARs), command and control, press release, 

and other areas as appropriate (see IP 88051 subsection 02.06).

4. Compare your independently identified performance concerns 

against the licensee’s identified concerns to determine whether the 

licensee is critically assessing the response and self-identifying 

performance weaknesses and deficiencies, particularly with respect 

to the risk significant topics of emergency declaration, notification, 

and PARs.

5. Determine if the licensee’s critique of exercise performance is 

effective in identifying exercise performance weaknesses and 

deficiencies, as well as concerns of lesser significance, for 

corrective action and prioritizing items for resolution.

6. Compare the biennial exercise scenario’s narrative summary and 

time line to scenarios used previously by the licensee during 

quarterly drills, practice exercises, or the previous biennial exercise 

to determine if the scenario was unacceptable due to the NRCgraded exercise containing practice scenario details.

7. Identify trends in poor performance during an emergency 

drill/exercise that may represent failures to correct weaknesses and 

deficiencies identified during the time period beginning with the 

previous biennial exercise.

8. Determine if the licensee has demonstrated an adequate capability 

for providing reasonable assurance that on-site and off-site 

protective measures can be taken in the event of a radiological 

emergency, or if a recommendation to NRC management should be 

made that the licensee conduct a remedial drill.
Issue Date: 06/11/14 13 1247 Appendix C3

TASKS: 1. Review IP 88051, “Evaluation of Exercises and Drills,” and IP 

88050, “Emergency Preparedness,” to identify the inspection 

attributes provided for drill/exercise performance evaluations. 

Discuss any questions with your supervisor, the person designated 

as a resource or a qualified Fuel Facility Emergency Preparedness 

Inspector.

2. Review licensee final exercise submittal package and become 

familiar with exercise objectives and the evaluation criteria for 

determining if objectives were met. Discuss any questions with your 

supervisor, the person designated as a resource or a qualified Fuel 

Facility Emergency Preparedness Inspector.

3. Review the regulatory requirements with regard to an exercise 

contained within 10 CFR Parts 40.31, 70.22, and 76.91.

4. Coordinate with your supervisor or the lead inspector what area of 

the licensee’s performance you may observe during the exercise 

based on the type of accident that is postulated. Refer to IP 88051 

subsection 02.06 for areas of consideration.

5. Based on the scenario details, become familiar with relevant 

portions of the licensee’s Emergency Plan and Plan Implementing 

Procedures which provide requirements for classification, 

notification, and PARs to determine if the appropriate actions are 

taken.

6. Review the exercise objectives and scenario details to determine if 

the postulated accident would provide an adequate test of the Plan. 

In the event you believe it is inadequate, notify your supervisor, the 

lead inspector and the licensee to discuss the appropriate actions 

associated with performing a remedial drill (refer to IP 88051 

subsection 02.03). Identify opportunities for event recognition, 

classification, notification, and PAR development, and the licensee’s 

criteria for determining performance success versus failure.

7. In the event weaknesses were identified during the previous 

exercise, review the corrective actions taken by the licensee and 

identify performance areas for observation to determine the 

adequacy of the corrective actions in response to the weakness.

8. During the exercise, do not interfere with the exercise players. Do 

not “prompt” exercise players or voice your opinions of players’ 

performance during the exercise (see IP 88051 subsection 03). The 

NRC assessments and comments must be held confidential until 

after the licensee’s critique presentation to the inspectors.
Issue Date: 06/11/14 14 1247 Appendix C3

9. Document examples (include the time) where licensee Controller or 

Evaluator observed prompting of exercise player(s) during the 

exercise. Refer to IP 88051 subsection 03.

10. Obtain copies of any checklists and forms used by the emergency

response organization during exercise performance with regard to 

event classification, notification, dose projection, PARs, and press 

releases.

11. Obtain records of other observed areas in which you suspect 

corrective actions may be necessary. Identify if the weakness 

indicates a programmatic problem to the point that an emergency 

planning standard was not met.

12. Attend licensee evaluator meetings and critiques. Determine if the 

licensee’s critique identified similar performance concerns as 

identified by the NRC. Pay particular attention to the 

characterization of response in areas such as event declaration, 

notification, PAR, corrective action failures, and other areas 

identified as needing improvements.

13. Verify that the licensee properly dispositions weaknesses with 

regards to the site’s corrective action program. 

14. Provide your observations and concerns to the lead inspector. 

Discuss your observations and provide a recommendation as to 

whether the licensee demonstrated the capability of providing 

reasonable assurance that adequate protective measures can be 

taken in the event of an emergency, or if a remedial exercise should 

be recommended to NRC management and the basis for the

recommendation.

15. Meet with your supervisor, the person designated as a resource or a 

qualified Fuel Facility Emergency Preparedness Inspector to 

discuss any questions that you may have as a result of these 

activities and to demonstrate that you can meet the evaluation 

criteria for this OJT.

DOCUMENTATION: Fuel Facility Emergency Preparedness Inspector Proficiency Level 

Qualification Signature Card, Item OJT-EP-1
Issue Date: 06/11/14 15 1247 Appendix C3

Fuel Facility Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-2) Corrective Actions for Emergency Preparedness Weaknesses

PURPOSE: Fuel facilities are required to identify and correct weaknesses and 

deficiencies discovered during events and through their emergency drill 

and exercise program. Upon completion of this OJT, you should be able 

to evaluate the overall ability of a licensee to self-identify and resolve 

problems related to their emergency preparedness program.

COMPETENCY

AREA: INSPECTION 

TECHNICAL AREA EXPERTISE 

LEVEL OF 

EFFORT: 24 hours

REFERENCES: 1. RG 3.67, “Standard Format and Content for Emergency Plans for 

Fuel Cycle and Material Facilities” (ML003739885)

2. NUREG-1520, “Standard Review Plan for the Review of a License 

Application for a Fuel Facility” (ML013380540)

3. 10 CFR Parts 70.22, 76.91, and 40.31

4. Emergency Plan Quality Assurance Audit

5. Site Emergency Plan

6. IP 88051, “Evaluation of Exercise and Drills”

7. IP 88050, “Emergency Preparedness”

EVALUATION

CRITERIA: Upon completion of the tasks in this OJT, you should be able to: 

1. Discuss emergency preparedness regulatory requirements for the 

identification and correction of deficiencies, weaknesses, and issues 

found during drill and event critiques.

2. Provide examples where a licensee failed to properly capture an 

item in its corrective action system.

3. Discuss a method(s) for verifying the adequacy of corrective 

actions.
Issue Date: 06/11/14 16 1247 Appendix C3

4. Discuss with your supervisor or the person designated as a 

resource the overall effectiveness of a licensee’s corrective actions 

as it relates to emergency preparedness following a review of 

corrective action documentation, interviews, and/or performance 

observation during an event, emergency drill, or exercise.

TASKS: 1. Review the following documents for expectations associated with 

correcting weaknesses and deficiencies from emergency drills and 

exercises: 

a. RG 3.67 Section 7.4

b. NUREG-1520 Section 8.4.3.1.13

c. 10 CFR 70.22 (i)(3)(xii)

d. 10 CFR 76.91 (l)

e. 10 CFR 40.31 (j)(3)(xii).

2. As determined by your supervisor or the person designated as a 

resource, perform the following tasks under the guidance of a 

qualified Fuel Facility Emergency Preparedness Inspector:

a. Review the licensee’s corrective action program to determine if 

emergency preparedness issues are being tracked for

resolution. Review if emergency preparedness issues are 

prioritized according to importance.

b. Obtain and review a copy of the exercise and/or drill critique 

items entered into the licensee’s corrective action program 

since the previous inspection. Determine if the data indicates

trends in areas such as event classification, notification,

protective action recommendation, monitoring, and command 

and control. Discuss your conclusions with a qualified Fuel 

Facility Emergency Preparedness Inspector.

c. If available, review documentation associated with an 

activation of the emergency response organization in response

to an actual emergency classification. Determine if 

documentation was adequate to support independent 

conclusions concerning the following: 

1) Were the classification and offsite notifications performed 

correctly?

2) Were there problems associated with Emergency Plan 

implementation during the event(s)?

Determine if negative performance or program issues were 

identified and captured in the corrective action program. 

Discuss your conclusions with a qualified Fuel Facility 

Emergency Preparedness Inspector.

d. Review the most recent independent audit required by the 

Emergency Plan. Verify that performance or program issues 

identified in the audit were captured in the corrective action 

program.
Issue Date: 06/11/14 17 1247 Appendix C3

e. Request for review the final report or critique comments from 

an emergency drill or actual event for the period(s) in which 

the emergency response facility was activated since the last 

inspection. If reviewing a drill or exercise, review the following 

details: 

1) Drill scenario.

2) Participant and evaluator logs.

3) Offsite notification forms.

4) Dose projection worksheets.

5) Environmental monitoring team sheets.

6) Significant event logs.

7) Post-drill critique notes and comment forms. 

Determine if all performance or program issues that were 

reviewed in the documentation were captured in the exercise 

report and the corrective action program. Discuss your 

conclusions with a qualified Fuel Facility Emergency

Preparedness Inspector, the person designated as a resource

or your supervisor.

f. During a site visit, select corrective actions associated with an 

emergency organization activation (drill or event) and obtain 

the detailed corrective action descriptions. As a guide for 

selection of corrective actions to review, consider items 

associated with emergency planning standards (e.g. 

emergency classification, notification, protective action 

recommendations). Verify the actions taken were adequate.

g. If available for review, observe the adequacy of corrective 

actions during a performance activity such as a drill or 

exercise. As an alternative, depending on the issue, a 

walkthrough with response personnel may be used in place of 

a drill or exercise. Obtain the description of the corrective 

action and verify the completion of each corrective action 

through direct observation.

3. Meet with your supervisor, the person designated as a resource or a 

qualified Fuel Facility Emergency Preparedness Inspector to 

discuss any questions that you may have as a result of these 

activities and demonstrate that you can meet the evaluation criteria 

listed above.

DOCUMENTATION: Fuel Facility Emergency Preparedness Inspector Proficiency Level 

Qualification Signature Card, Item OJT-EP-2
Issue Date: 06/11/14 18 1247 Appendix C3

Fuel Facility Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-3) Emergency Action Level and Emergency Plan Changes

PURPOSE: Licensee Emergency Plans provide a description of the personnel, 

facilities, activities, and methods used to respond to any site postulated 

emergency condition. Emergency Action Levels (EALs) provide entry 

criteria for classifying emergency conditions based on measurable and/or 

observable conditions. Standards for contents of Emergency Plans and 

EALs are found in NRC regulations and other guidance documents. In 

accordance with 10 CFR Parts 40.35(f), 70.32(i), and 76.91(o), licensees 

are allowed to make changes to their Emergency Plan and EALs without 

NRC prior approval if the changes do not decrease the effectiveness of the 

Plan. Upon completion of this on-the-job training (OJT), you will be able to 

determine whether licensee Emergency Plan changes are in accordance 

with the requirements in 10 CFR Parts 40 and 70.

COMPETENCY

AREA: INSPECTION 

TECHNICAL AREA EXPERTISE

REGULATORY FRAMEWORK

LEVEL OF 

EFFORT: 32 hours

REFERENCES: 1. RG 3.67, “Standard Format and Content for Emergency Plans for 

Fuel Cycle and Material Facilities” (ML003739885)

2. NUREG-1520, “Standard Review Plan for the Review of a License 

Application for a Fuel Facility” (ML013380540)

3. 10 CFR Parts 40.31, 70.22, and 76.91

4. EPA 400-R-92-001, “Manual of Protective Action Guides and 

Protective Actions for Nuclear Incidents” (ML003769701)

5. Site Integrated Safety Analysis or Safety Analysis Report

6. Site Emergency Plan

7. Regulatory Information Summary (RIS) 2005-02, “Clarifying the 

Process for Making Plan Changes”
Issue Date: 06/11/14 19 1247 Appendix C3

8. NUREG-1140, “A Regulatory Analysis on Emergency Preparedness 

for Fuel Cycle and Other Radioactive Material Licensees” 

(ML062020791)

9. Licensee procedures for evaluating and making changes to the 

Emergency Plan and emergency action levels, and for evaluating 

potential decreases of effectiveness of the Plan and implementing 

procedures.

EVALUATION

CRITERIA: Upon completion of the tasks in this OJT, you should be able to: 

1. Describe the NRC process for an in-depth review of Emergency 

Action Level and Emergency Plan changes that have been 

submitted to the NRC

2. Describe what is meant by a “decrease in effectiveness” of the 

Emergency Plan, EALs, and/or Emergency Plan Implementing 

Procedures. 

3. Describe the regulatory requirements for licensees to make and 

implement changes to their Emergency Plan and/or EALs.

4. Describe where to find the regulatory requirements for the contents 

of Emergency Plans and where to find regulatory guidance.

5. Review a submitted Emergency Plan change and determine 

whether the change requires an in-depth review.

6. Review a submitted Plan or EAL change to determine if the change 

results in a decrease in effectiveness of the Emergency Plan.

TASKS: 1. Review RIS 2005-02 to identify the attributes used to determine if a 

change to an Emergency Plan or EAL constitutes a decrease in 

effectiveness.

2. Become familiar with the content of the following guidance 

documents for the development of PARs in the event of Emergency 

Plan changes involving PARs:

a. EPA 400-R-92-001, Chapters 1, 2, and 5

b. NUREG-1140 “A Regulatory Analysis on Emergency 

Preparedness for Fuel Cycle and Other Radioactive Material 

Licensees” 

3. If available, obtain and review one NRC inspection report detailing 

the inspection of changes to a licensee’s EALs or Emergency Plan.
Issue Date: 06/11/14 20 1247 Appendix C3

4. Meet with your supervisor, the person designated as a resource or a 

qualified Fuel Facility Emergency Preparedness Inspector to 

discuss any questions that you may have as a result of these 

activities and demonstrate that you can meet the evaluation criteria 

listed above.

DOCUMENTATION: Fuel Facility Emergency Preparedness Inspector Proficiency Level 

Qualification Signature Card, Item OJT-EP-3
Issue Date: 06/11/14 21 1247 Appendix C3

Fuel Facility Emergency Preparedness Inspector Technical Proficiency Level

Signature Card and Certification

Inspector Name: ___________________________

Employee

Initials / Date

Supervisor’s 

Signature / 

Date

A. Training Courses

Fire Protection for Fuel Cycle Facilities (F-206S)

B. Study Guides

(SG-EP-1) Code of Federal Regulations for Emergency 

Preparedness Inspectors

(SG-EP-2) Preparation and Evaluation of Radiological 

Emergency Plans

(SG-EP-3) Manual of Protection Action Guides and 

Protective Actions for Nuclear Incidents

C. On-the-Job Activities

(OJT-EP-1) Emergency Drill/Exercise Evaluation

(OJT-EP-2) Corrective Actions for Emergency 

Preparedness Weaknesses

(OJT-EP-3) Emergency Action Level and Emergency 

Plan Changes 

Supervisor’s signature indicates successful completion of all required courses and activities 

listed in this journal and readiness to appear before the Oral Board.

Supervisor’s Signature: ________________________________ Date: _____________

This signature card and certification must be accompanied by Form 1, Fuel Facility Emergency 

Preparedness Inspector Technical Proficiency Level Equivalency Justification, if applicable.

Copies: Inspector

HR Office

Supervisor
Issue Date: 06/11/14 22 1247 Appendix C3

Form 1: Fuel Facility Emergency Preparedness Inspector Technical Proficiency-Level 

Equivalency Justification

Inspector Name:_____________________

Identify equivalent training and experience 

for which the inspector is to be given 

credit.

A. Training Courses

Fire Protection for Fuel Cycle Facilities 

(F-206S)

B. Study Guides

(SG-EP-1) Code of Federal Regulations for 

Emergency Preparedness Inspectors

(SG-EP-2) Preparation and Evaluation of 

Radiological Emergency Plans

(SG-EP-3) Manual of Protection Action Guides 

and Protective Actions for Nuclear Incidents

C. On-the-Job Activities

(OJT-EP-1) Emergency Drill/Exercise 

Evaluation

(OJT-EP-2) Corrective Actions for Emergency 

Preparedness Weaknesses

(OJT-EP-3) Emergency Action Level and 

Emergency Plan Changes 

Supervisor’s Recommendation: Signature / Date: ______________________________

Division Director’s Approval: Signature / Date: ______________________________

Copies to: Inspector 

HR Office

Supervisor
Issue Date: 06/11/14 Att1-1 1247 Appendix C-3

Attachment 1

Revision History for IMC 1247 Appendix C-3

Commitment 

Tracking 

Number

Accession 

Number 

Issue Date 

Change Notice 

Description of Change Description of 

Training Required 

and Completion Date 

Comment and 

Feedback Resolution 

Accession Number

N/A 02/18/09

CN 09-006

Researched commitments for 4 

years and found none.

New inspection manual chapter to 

specify qualification requirements 

for NRC fuel facility operations, 

health physics, emergency 

preparedness, security, material 

control and accounting, and 

construction inspectors.

N/A ML090400917

N/A ML13217A219

06/11/14

CN 14-012

This document has been revised to 

update the refresher training 

requirements. Some of the training 

is no longer available. 16 hours of 

Refresher Technical Training 

seminar has been added as a 

Refresher training requirement.

None ML14084A481