Issue Date: 09/04/14 1 82501

NRC INSPECTION MANUAL NRR/NMSS

INSPECTION PROCEDURE 82501

DECOMMISSIONING EMERGENCY PREPAREDNESS PROGRAM EVALUATION

PROGRAM APPLICABILITY: 2561

82501-01 INSPECTION OBJECTIVE

To determine whether the licensee's emergency preparedness program is maintained in a state 

of operational readiness and whether changes made to the licensee's emergency preparedness 

program since the last inspection continue to meet commitments, the Nuclear Regulatory 

Commission (NRC) requirements, and have not negatively affected the licensee's overall state 

of emergency preparedness (EP).

This inspection procedure is applicable to nuclear power reactor licensee site(s) that are 

permanently shut down in accordance with 10 CFR 50.82(a) and is / are not located on a site 

with an operating nuclear power reactor. Decommissioning power reactor licensees retain their 

Part 50 or Part 52 license after permanent shutdown and remain subject to the same EP 

requirements as operating power reactors until an exemption request is submitted and approved 

by the NRC. The exemption must then be appropriately implemented in the licensee’s 

emergency response plan (E-plan) before compliance with the given regulation is no longer 

required. NSIR/DPR-ISG-02 “Interim Staff Guidance Emergency Planning Exemption Requests 

For Decommissioning Nuclear Power Plants,” provides guidance for processing exemptions to 

the EP requirements for nuclear power reactors that are undergoing the process of 

decommissioning, previously approved exemption request(s), the rationale for the approval and 

the approximate time table for exemption approvals. Inspectors should review this document for 

information as to what exemptions could be expected for a given licensee’s point in the 

decommissioning process. This procedure is not applicable to sites at which all fuel is removed 

from the spent fuel pool (SFP) and placed in dry cask storage.

82501-02 INSPECTION REQUIREMENTS

02.01 Review current E-plan and approved exemption request(s) since the last inspection for 

understanding and appropriate implementation.

02.02 Perform, as applicable to the licensee’s current E-plan, the following attachments.

a. Maintenance of Emergency Preparedness (Attachment 01)
Issue Date: 09/04/14 2 82501

b. Emergency Response Organization Staffing and Augmentation System (Attachment 02)

c. Emergency Action Level and Emergency Plan Changes (Attachment 03)

d. Alert and Notification System Evaluation (Attachment 04)

82501-03 INSPECTION GUIDANCE

The following inspection guidance section and attachments provide methods and examples of 

how the inspection requirements could be completed. Use of the following guidance is at the 

discretion of the inspector. 

03.01 Review approved exemption request(s)

a. Review the approved regulatory exemption request(s) applicable to EP and determine 

what attachments to this inspection procedure are applicable to be performed.

b. Review the sections affected by approved regulatory exemption(s), if any, of the 

licensee’s current E-plan to ensure appropriate implementation.

03.02 Perform, as applicable to the licensee’s current E-plan, the attachments to this 

procedure.

82501-04 RESOURCE ESTIMATE

Recommended average annual inspection hour efforts for this inspection procedure’s 

attachments are listed below. Actual inspection hours will be expected to move toward the 

lower end of the range as exemptions are submitted and approved.

 Attachment 1 between 9 and 20 hours

 Attachment 2 between 6 and 10 hours 

 Attachment 3 between 3 and 5 hours

 Attachment 4 between 2 and 5 hours.

82501-05 PROCEDURE COMPLETION

This procedure is considered complete when applicable inspection requirements listed in the 

procedure have been satisfied. For the purpose of reporting completion in the Reactor Program 

System (RPS), the sample size is defined as 1. A sample size of 1 will be reported in RPS 

when the procedure is completed in its entirety.
Issue Date: 09/04/14 3 82501

82501-06 REFERENCES

NSIR/DPR-ISG-02 “Interim Staff Guidance for Emergency Planning at Decommissioning Sites”

IN 05-19, “Effect Of Plant Configuration Changes On The Emergency Plan” (ML051530520)

RG 1.219, “Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors”

NUREG/CR-4831, “State of the Art in Evacuation Time Estimate Studies for Nuclear Power 

Plants,” March 1992.

NUREG/CR-6863, “Development of Evacuation Time Estimates for Nuclear Power Plants,” 

January 2005.

NUREG/CR-6451 “A Safety and Regulatory Assessment of Generic BWR and PWR 

Permanently Shutdown Nuclear Power Plants” (ML082260098)

NUREG/CR-7002, “Criteria for Development of Evacuation Time Estimate Studies

NEI 10-05, “Assessment of On-Shift Emergency Response Organization Staffing and 

Capabilities”

FEMA REP-10 “Guide for the Evaluation of Alert and Notification Systems for Nuclear Power 

Plants” (ML102510343)

NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological 

Emergency Response Plans and Preparedness in Support of Nuclear Power Plants"

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

END
Issue Date: 09/04/14 Att1-1 82501

ATTACHMENT 1

MAINTENANCE OF EMERGENCY PREPAREDNESS

01.00 INSPECTION OBJECTIVE

Evaluate the efficacy of licensee efforts to maintain their Emergency Preparedness (EP) 

programs by verifying accurate and appropriate identification and correction of EP weaknesses 

during actual event critiques, drill and exercise critiques, program assessment activities (e.g., 

EP reviews performed in accordance with 10 CFR 50.54(t)) as well as review of Letters of 

Agreement (LOA) and/or Memorandums of Understanding (MOU), 10 CFR 50.54(q) plan 

change process and practice, and licensee maintenance of facilities, systems, and equipment 

important to emergency preparedness, record(s) of evacuation time estimate (ETE) population 

evaluation and E-plan provisions for, and implementation of, primary, backup and alternate 

emergency response facility (ERF) maintenance [10 CFR Part 50.47(b)(10) and Appendix E 

IV.3, 5 & 6; IV.E.8.b] 

02.00 INSPECTION REQUIREMENTS

02.01 Review the licensee’s corrective action program (CAP) for EP issues.

02.02 Review documentation for all actual events that resulted in the implementation of the

E-plan since the last inspection to determine the adequacy of licensee actual event 

response.

02.03 Review all EP-related corrective actions identified in any actual event self-assessment 

for effectiveness and timeliness of completion.

02.04 Review a sample of drill and exercise critique documentation to determine if EP 

weaknesses are being properly identified and entered into the CAP.

02.05 Review a sample of EP corrective actions for effectiveness and timeliness of 

completion.

02.06 Review EP audit(s) performed in accordance with 10 CFR 50.54(t).

02.07 Review a sample of EP corrective actions from other EP self-assessment documents, 

such as QA assessments of EP program elements, for effectiveness and timeliness of 

completion.

02.08 Review LOA and/or MOU that support the E-plan for appropriate content and to verify 

they have not expired.

02.09 Review 10 CFR 50.54(q) plan change process and practice.
Issue Date: 09/04/14 Att1-2 82501

02.10 Review licensee maintenance of facilities, systems, and equipment important to 

emergency preparedness.

02.11 Review licensee record(s) of evacuation time estimate (ETE) population evaluation.

[10 CFR 50.47(b)(10) and Appendix E.IV.3, 5 & 6]

02.12 Review licensee E-plan provisions for, and implementation of, primary, backup and 

alternate emergency response facility (ERF) maintenance. [10 CFR Part 50.47(b)(8)

Appendix E §IV.E.8.a(i), a(ii), b, c, d & e]

03.00 INSPECTION GUIDANCE

The primary focus of this inspection is to evaluate the efficacy of a licensee’s ability to identify 

and correct EP weaknesses.

The following inspection guidance section and attachments provide methods and examples of 

how the inspection requirements could be completed. Use of the following guidance is at the 

discretion of the inspector.

03.01 Review licensee procedures for the following areas to ensure there is an adequate level 

of guidance to meet the required area task. 

a. EP CAP 

b. Identification of EP weaknesses and/or deficiencies during an actual event or during 

drills and exercises.

c. EP Audits 

d. EP Program Reviews

e. Critique Conduct 

Note: responsibility for conduct of critiques may be assigned to multiple departments, (e.g., 

Quality Assurance for audits, Emergency Preparedness for EP drills and exercises, and 

Operations Training for simulator evolutions). 

03.02 Determine the adequacy of licensee actual event response by:

a. Reviewing E-plan implementation documentation since the last inspection for:

1. Documentation of notification forms

2. Thoroughness and accuracy of logs

3. Completeness of checklists. 
Issue Date: 09/04/14 Att1-3 82501

b. Determine if:

1. The licensee effectively implemented the requirements of the E-plan. 

2. Classifications, notifications and, if performed, protective action recommendation 

(PAR) development were timely and accurate. [10 CFR Part 50.47(b)(10)]

Note: Actual event E-plan implementation may be inspected under the event follow-up 

inspection.

c. Ensuring all EP weaknesses identified during the inspector’s review of event records 

were entered into the CAP program. 

d. Determine if licensee corrective actions for weaknesses occurring during an event were 

timely and effective consistent with the safety significance of the condition.

03.04 Review a sample of licensee self-assessments of drill and exercise performance (if 

available) to verify that: 

a. Weaknesses identified for classification, notification and PARs are appropriately 

documented in the CAP. [10 CFR Part 50.47(b)(10)]

b. Emergency preparedness implementing procedures forms and checklists used to 

support and document classification, notification, and PAR development are 

consistently and accurately used.

[10 CFR Part 50.47(b)(10)]

c. Documentation summaries of the drill and exercise critique and scenario are consistent 

and accurate. 

d. The critique process properly identifies performance weakness (es) in classification, 

notification, PARs and does assessment activities. [10 CFR Part 50.47(b)(9) & (10)]

03.05 Review lists of EP-related CAP entries initiated and closed since the previous 

inspection. Select samples from each category to review for the effectiveness of 

correction actions, based on the following:

Note: Although 10 CFR 50.47(b)(14) requires that exercise weaknesses be identified and 

corrected, licensees may enter other deficiencies (e.g., procedure deficiencies, instrument 

failures, etc.) into its corrective action program. Both categories should be included in the 

sample selection. 

Note: If corrective actions appear to be complete, but not yet fully effective, consideration may 

be given to allow more time for performance improvement. Future drills and exercises would be 

expected to show such improvement. Actions taken by the licensee to enhance or improve 

performance need not be evaluated for effectiveness.
Issue Date: 09/04/14 Att1-4 82501

a. Review all corrective actions associated with classification, notification, PAR 

development, and dose assessment and note any degraded performance. 

[10 CFR Part 50.47(b)(9) & (10)]

b. Select a sample of corrective actions from other EP areas for review. The guidance 

provided in Attachment 5 “Prioritization of Additional Areas for Inspection” may be used 

to select other areas for review.

c. If repeat items or trends are noted in corrective actions:

1. Determine whether corrective actions should have precluded recurrence. 

Determination of a failure to correct a drill or exercise weakness requires a 

detailed review of the weakness and the associated corrective actions.

2. Determine if the licensee identified the trend or repeat weakness and entered it 

into the corrective action system. A single repetition of a weakness should not 

automatically be deemed an ineffective corrective action. Conversely, a single 

successful demonstration of a weakness should not necessarily be considered 

an effective corrective action.

d. Select a sample of closed corrective actions and perform a review to assess the 

completeness and effectiveness of the corrective actions.

1. Review the specific corrective actions for that weakness and similar occurrences 

of that weakness in actual events, drills, exercises, and training evolutions. 

2. Review relevant corrective actions, self-assessments, and inspection records for 

the inspection cycle with an emphasis on similar weaknesses.

3. Assess corrective action effectiveness based on the complete history of the 

issue. Obtain a complete picture of the current problem by reviewing previous 

corrective actions to identify any pattern(s) of recurring performance problems in 

similar activities that would identify other ineffective corrective actions.

e. Select a sample of corrective actions for equipment and facilities or other areas of EP 

as deemed appropriate. Perform a detailed review of: [10 CFR Part 50.47(b)(8) 

Appendix E §IV.E.8.a(i), a(ii), b, c, d & e]

1. Closure documentation,

2. Corrective actions taken, and

3. Consistency of in-field completed corrective actions and the closure 

documentation.
Issue Date: 09/04/14 Att1-5 82501

f. In reviewing the corrective actions, remain alert to program elements that have few or 

no corrective actions recorded. Although the program elements may very well not 

warrant a corrective action, the lack could be evidence of a deficient critique. The 

inspector should inspect that area for compliance with the E-plan commitments. 

03.06 Review EP audit(s) performed in accordance with 10 CFR 50.54(t).

a. Evaluate adequacy of audits for compliance with regulatory requirements. 

b. Determine if the scheduling of audits is consistent with regulatory requirements and 

licensee program changes. 

1. If the licensee is using the 10 CFR 50.54(t)(1)(ii) option, review the licensee’s 

performance indicators (See statements of consideration at 64 FR 14814 dated 

March 29, 1999).

c. Review the effectiveness of a sample of corrective actions resulting from the audit. 

Prioritization should be given to problems associated with classification, notification, 

dose assessment activities and PAR development. [10 CFR Part 50.47(b)(4), (5), (9) & 

(10)]

d. Select a sample of corrective actions from other EP audit areas for review. The 

guidance provided in Attachment 5, “Prioritization of Additional Areas for Inspection,” to 

this procedure, may be used to select other areas for review.

03.07 EP self-assessment corrective actions.

a. Review a sample of corrective actions from other EP self-assessment documents, for 

example:

1. QA assessments of drill and exercise performance

2. Emergency response organization (ERO) readiness

3. EP facility readiness [10 CFR Part 50.47(b)(8) Appendix E §IV.E.8.a(i), a(ii), b, c, d 

& e]

b. Review the disposition of the sample of corrective actions identified.

c. Determine if the licensee’s sampled corrective actions were timely and effective.

03.08 Review the licensee’s annual review / update of LOAs/MOUs described in the E-plan to 

be updated as needed and reviewed to be current on an annual basis. Verify that:
Issue Date: 09/04/14 Att1-6 82501

Note: In general, LOAs/MOUs with Federal agencies with emergency planning responsibilities 

are not needed, since the Federal agencies are required by law to provide assistance. 

However, the inspector should be alert to instances in the E-plan where it may be appropriate 

for a letter of agreement with a local Federal office or representative of a Federal agency, such 

as a local Coast Guard station.

a. Arrangements for offsite response organization (ORO) resources remain in effect and 

have not expired. 

b. The type and extent of ORO resources needed to support onsite response activities 

during an emergency including hostile action have been identified and documented.

c. Arrangements with State, local, and Federal agencies clearly identify and describe 

needed onsite support and response activities. Local agencies should include local law 

enforcement, firefighting, and medical assistance

d. Existing arrangements are updated as needed to clarify the types of assistance to be 

provided by an agency or to address any shortfalls for support of onsite response 

activities identified.

e. LOAs/MOUs may be provided in an appendix to the plan or, the plan itself may contain 

descriptions of these matters, and a signature page in the plan may serve to verify the

agreements. The signature page format is appropriate for organizations where 

response functions are covered by laws, regulations, or executive orders where 

separate written agreements are not necessary.

03.09 Review 10 CFR 50.54(q) plan change process and practice. Verify that:

a. Individuals responsible for performing the screenings and evaluation understand the 

intent and procedure steps (e.g., reviews are to be performed against the last E-plan 

with a safety evaluation report (SER)).

b. Screenings and evaluations contain a level of detail appropriate to support the change 

(e.g., does the screening block for a given planning standard describe more than just 

“yes” or “no”).

c. If the licensee is cited for a violation under 10 CFR 50.54(q)(3), could it, or should it, 

have been prevented by an appropriate and accurate screening or evaluation.

03.10 Licensee maintenance of facilities, systems and equipment important to emergency 

preparedness. 

a. Review a sample of instrumentation identified in the licensee’s emergency action level 

(EAL) scheme to ensure the instrumentation identified is correct for the intended 

application and adequate to support declaration of the effected EALs.
Issue Date: 09/04/14 Att1-7 82501

b. Review EP equipment work control history to determine if:

1. Compensatory measures taken for equipment out of service were adequate, and 

2. Any 10 CFR 50.72 reporting requirements were met.

c. Review a sample of required equipment (e.g., Self-Contained Breathing Apparatus, field 

monitoring team equipment, communication equipment, computers, etc.) to determine 

whether the equipment is functioning and meets certification/calibration requirements.

03.11 Review licensee ETE population record(s) of evaluation to ensure: 

[10 CFR 50.47(b)(10) and Appendix E.IV.3, 5 & 6]

a. The ETE is revised when new U.S. Census Bureau decennial census data is available.

b. The licensee has annually reviewed for, and/or evaluated, changes in the emergency 

planning zone populations. 

Note: Population changes should be based on data from the U.S. Census Bureau, which 

annually produces resident population estimates and State/local government population data, if 

available.

03.12 Review licensee E-plan provisions for, and implementation of, primary, backup, and 

alternate ERF maintenance as follows:

[10 CFR Part 50.47(b)(8) Appendix E §IV.E.8.a.(i), a.(ii), b, c, d & e]

a. Records of ERF current and historical condition support compliance with regulatory 

requirements and E-plan commitments for habitability.

b. Equipment required to perform the facility’s function is available and in sufficient 

quantity.

c. ERF power supplies are in compliance with regulatory requirements and E-plan 

commitments.

END
Issue Date: 09/04/14 Att2-1 82501

ATTACHMENT 2

ERO STAFFING AND AUGMENTATION SYSTEM

01.00 INSPECTION OBJECTIVE

To evaluate the adequacy of the emergency response organization (ERO) on-shift and 

augmentation staffing levels and verify that the augmentation system is adequate to allow 

meeting ERO augmentation staffing and facility activation time commitments.

02.00 INSPECTION REQUIREMENTS

02.01 Review ERO On-shift and Augmentation Staffing.

a. Determine licensee E-plan commitments for ERO on-shift and augmentation staffing 

levels including alternative emergency response facilities, and the ERO activation 

process. 

b. Verify that licensee procedures implement emergency response plan (E-plan)

commitments for ERO on-shift and augmentation staffing. [10 CFR 50 Appendix 

E.IV.A.9]

c. Determine if the processes for maintaining required ERO on-shift and augmentation 

staffing levels meets E-plan commitments. [10 CFR 50 Appendix E.IV.A.3 4, 5]

d. Review the effectiveness of corrective actions related to ERO on-shift and 

augmentation staffing levels.

02.02 Review of ERO Augmentation Activation System.

a. Review any changes to the ERO augmentation activation system and process. Initial 

procedure implementation verified the adequacy of ERO augmentation activation 

system design.

b. Review the results of ERO augmentation activation drills and/or tests.

c. Review a sample of ERO augmentation activation system program elements.

d. Review a sample of corrective actions related to ERO augmentation activation system 

and process and assess their effectiveness.
Issue Date: 09/04/14 Att2-2 82501

03.00 INSPECTION GUIDANCE

ERO augmentation tests that require personnel to report to their emergency response duty 

locations are not mandatory. They do however provide a high level of assurance that activation 

goals can be met. Many sites recognize the value of such “report-in” tests and have committed 

to perform them periodically. However, other combinations of testing and verification, if properly 

implemented, can provide a reasonable level of assurance. Commitments on this subject are 

contained in the licensee E-plan and may vary between sites.

After initial inspection of the ERO on-shift and augmentation staffing and the augmentation 

activation system design, subsequent inspections need not repeat the entire review, but should 

focus on changes to the ERO on-shift and augmentation staffing, the augmentation activation

system design, conduct of system drills and tests, and the effectiveness of corrective actions. 

The following inspection guidance section and attachments provide methods and examples of 

how the inspection requirements could be completed. Use of the following guidance is at the 

discretion of the inspector.

03.01 Review ERO On-shift Staffing and Augmentation.

a. Review the site E-plan to determine the licensee’s commitments for ERO on-shift and 

augmentation staffing levels, ERO activation timeliness, and associated facility 

activation goals. [10 CFR 50 Appendix E.IV.A.3 4, 5, 9]

1. Use the NRC approved version of the E-plan and any subsequent 

NRC-approved changes in performing this determination. Identify any changes 

to the ERO on-shift and augmentation staffing made by the licensee without prior 

NRC approval under 10 CFR 50.54(q)(4) and evaluate under 03.01.b. 

2. Review the on-shift staffing analysis to identify any subsequent changes thereto. 

A complete review of the analysis is not expected, but any changes that appear 

to be questionable should be evaluated further, particularly if they purport to 

support a reduction in on-shift staffing. If a justifiable basis cannot be 

established, the associated change in on-shift staffing may be a reduction in 

effectiveness of the E-plan. Refer to NSIR-DPR-ISG-01, “Emergency Planning 

for Nuclear Power Plants,” § IV.C, “Assignment of Multiple Functions to On-Shift 

Personnel,” if necessary. [10 CFR 50 Appendix E.IV.A.9]

3. Determine the licensee’s commitments with regard to how the emergency 

response activation timeliness is assessed (e.g., when the “clock starts” and the 

“clock stops”). In the absence of an approved alternative, the NRC expects that 

the clock starts with the declaration of an Alert or higher emergency classification 

level and ends when the facility is ready to assume its assigned functions under 

the E-plan and relieve the on-shift staff of those functions. (Although the facility 

may be ready, the on-shift staff relief may be postponed in the interest of 

completing critical tasks prior to turnover.)
Issue Date: 09/04/14 Att2-3 82501

b. Review the licensee’s ERO on-shift and augmentation staffing described in the 

licensee’s E-plan to verify the licensee’s compliance with commitments, and to verify 

that the on-shift staffing is supported by the conclusions of the staffing analysis. 

[10 CFR 50 Appendix E.IV.A.3 4, 5, 9]

1. NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of 

Nuclear Power Plants", Table B-1 (Table B-1) should be used to assess ERO onshift and augmentation staffing levels unless an NRC-approved/acceptable 

alternative is contained within the licensee’s E-plan.

[10 CFR 50 Appendix E.IV.A.3 4, 5]

2. Once the detailed on-shift staffing analysis is implemented, review the licensee’s 

ERO on-shift staffing commitments against the licensee’s on-shift staffing 

analysis to verify that the on-shift staffing is supported by the conclusions of the 

staffing analysis. [10 CFR 50 Appendix E.IV.A.9]

3. Verify that backup processes and/or procedures can be implemented in the event 

the normal ERO augmentation activation system is not available.

c. Review any changes in the design of the ERO staffing augmentation processes against 

commitments in the licensee’s E-plan. Process details may be found in the emergency 

preparedness implementing procedures. 

1. To be effective, ERO staffing augmentation processes should include the 

following elements, sufficient to provide reasonable assurance, that ERO 

activation, augmentation, and associated facility activation goals can be met.

 Current ERO duty roster that lists only qualified personnel to fill positions 

required by the E-plan.

 A process to ensure augmentation staffing levels are met and a sufficient 

number of individuals are available to staff their assigned positions on a 

continuous basis (e.g., on-shift staffing processes ensure minimum staffing 

levels are maintained, sufficient depth of qualified individuals, formal 

rotational assignment schedule).

 An ERO staffing augmentation process that is capable of ensuring timely 

augmentation of on-shift staffing and that facility activation goals can be 

met in accordance with E-plan commitments. The augmentation staff 

roster may be divided into ERO teams or the licensee may employ an “allcall” approach. The all-call approach may involve all responders, reporting 

to the site with the first to arrive assuming the ERO positions. For any 

methodology employed by the licensee to augment plant staff during an 

emergency, verify that licensee’s process is adequate to ensure that all 

positions will be filled in the required time. 
Issue Date: 09/04/14 Att2-4 82501

 Review the procedures and training provided to ERO augmentation staff 

concerning response during a hostile action event; including the use of 

alternative facilities; onsite protective measures for staff safety; and, clear 

reporting instructions in the event the plant is inaccessible.

[10 CFR 50 Appendix E.IV.A.3 4, 5, 9; IV.E.8.b, d]

2. The inspector’s review of the ERO staffing augmentation process(es) should

include the following:

 The performance of an actual event or drill where personnel reported to 

their duty locations and were timed, OR

 The performance of drills (e.g., unannounced off-hour report-in drills, 

unannounced off-hour “call-in” drills, pager/communications tests, etc.) 

where personnel response was timed. OR

 Sufficient numbers of ERO members live within the appropriate travel time 

from their duty locations.

3. Review a sample of training records of ERO duty roster members to verify that 

qualifications are current, including respirator qualifications where appropriate. 

Verify that all requalification requirements have been performed as required.

4. Review a sample of on-shift staff rosters for normal business, after hours, as well 

as recent weekends and holidays. Focus on positions which are not part of the 

normal operations on-shift crew such as health physics technicians, chemistry 

technicians, and maintenance technicians. Verify that all positions are staffed on 

a 24-hour basis in accordance with E-plan commitments.

d. Review a sample of items from the corrective action program related to ERO staffing 

inadequacies and verify that the licensee has implemented adequate corrective actions 

to correct the problems. With regard to corrective actions arising from the on-shift 

staffing analysis, licensees are expected to take interim compensatory measures to 

address any staffing shortfalls identified in the staffing analysis within 30 days of when 

the results of the staffing analysis are available, and then implement long-term 

corrective actions within 24 months of performing the staffing analysis. 

[10 CFR 50 Appendix E.IV.A.9]

03.02 Review of ERO Augmentation System.

a. Review any changes made to the ERO augmentation system hardware, software or 

procedures since the previous inspection and determine the impact on the effectiveness 

of the process. 
Issue Date: 09/04/14 Att2-5 82501

1. Determine whether the system, as modified, is still capable of ensuring timely 

augmentation of on-shift staffing and meeting activation goals for primary and 

alternate facilities in accordance with E-plan commitments. 

Hardware systems, (e.g., pagers, cell phones, automated telephone systems) 

may be vendor-owned and operated. Changes to these systems may not be 

apparent, but the licensee is expected to ensure the systems are maintained in 

proper working order through the conduct of system tests or other surveillance 

activities. 

2. Review the licensee’s process for keeping the ERO augmentation activation 

system current with ERO member names and contact information. Determine 

whether system operation is periodically verified by the licensee.

b. Review a sample of the ERO primary and backup augmentation system drills (e.g., 

call-in, report-in) results committed to in the E-plan conducted since the last inspection. 

Review all results from actual event E-plan activations that occurred since the last 

inspection. 

1. Determine whether the results have been evaluated accurately and whether the 

conclusions reached are valid. 

2. Determine whether tests of the system adequately verify ERO augmentation 

times (e.g., call-in drills are supplemented with travel time verification and/or 

report-in drills are conducted periodically).

3. If no tests, drills or implementations of the backup ERO staffing augmentation 

system have been performed, review the major elements of the backup system 

to evaluate its capabilities. Interview a sample of ERO members to determine if 

they know how to implement and respond to the backup system. 

c. Review a sample of program elements such as:

1. Verify that equipment to notify individual ERO members is available and 

functional (e.g., pagers, cell phones, automated telephone systems).

2. Review a sample of training records to verify that ERO members are trained in 

the proper response to the ERO augmentation notification system.

3. Review the procedures for ERO augmentation notification system activation to 

ensure the capability of timely augmentation of on-shift staffing and facility 

activation goals.

4. Review a sample of training records to verify that personnel expected to operate 

the ERO call out system are trained in its use.
Issue Date: 09/04/14 Att2-6 82501

d. Verify that weaknesses identified during ERO augmentation drills, or failures in system 

tests, were entered into the licensee’s corrective action program and that the licensee 

has initiated corrective actions to ensure a functional augmentation process.

1. Review a sample of the weaknesses identified during ERO augmentation drills, 

or failures in system tests, performed since the last inspection, to identify any 

trends or repeat failures and assess the effectiveness of corrective actions. 

2. Review corrective actions taken for repeat failures and assess the adequacy of 

corrective actions. 

 Consider the disposition of personnel performance problems as well as 

equipment failures. 

 A repeat item does not necessarily indicate a failure of the corrective 

actions. However, a trend of repeat failures would bring into question the 

licensee’s ability to augment the ERO and activate facilities within the

E-plan committed goals and may require additional effort to determine the 

adequacy of the corrective action process. 

 This effort may require interviews with management or other individuals 

and further review of licensee corrective action program.

3. Review licensee self-assessments, if performed, of ERO augmentation drills and 

system testing since the last inspection. 

 Determine the coverage and depth of the assessments, knowledge level of 

the reviewers, and whether the disposition of problems was appropriate.

 Determine whether identified problems were placed in the corrective action 

program and resolved.

END
Issue Date: 09/04/14 Att3-1 82501

ATTACHMENT 3

EMERGENCY ACTION LEVEL AND EMERGENCY PLAN CHANGES

01.00 INSPECTION OBJECTIVES

Recognition and subsequent classification of events is a risk-significant activity because 

classification leads to activation of the Emergency Response Organization (ERO) and 

notification of governmental authorities. This inspection activity is associated with risk 

significant planning standard 10 CFR 50.47(b)(4). However, if the emergency action level (EAL) 

scheme has been changed in a manner that results in a reduction in effectiveness (RIE) of the 

Emergency Plan (E-plan), the EALs may not produce the appropriate emergency classification. 

This inspection area verifies that the EAL scheme continues to meet the planning standard.

[10 CFR 50.47(b)(4) and Appendix E.IV.B.1]

In addition, this inspectable area provides monitoring of the effectiveness of the licensee’s 

program for implementing changes to the E-plan and verifies that the program is ensuring that 

changes meet the requirements of 10 CFR 50.54(q).

02.00 INSPECTION REQUIREMENTS

02.01 EAL Change Review

Review all EAL changes to determine if any of the changes have reduced the effectiveness of 

the E-plan, or caused the plan to no longer meet applicable regulations for which the licensee 

has not received an approved exemption.

02.02 E-plan Change Review

The inspector shall screen all E-plan change submittals. If any E-plan revision is extensive such 

that the inspector would expend an inordinate amount of time to complete a review (more than 

about 20 hours), then the inspector should consider submitting the revision to NRC

Headquarters, Office of Nuclear Security and Incident Response, (NSIR) for review under

LIC 804 “Guidelines For The Review Of Revisions To Power Reactor Radiological Emergency 

Plans And Emergency Action Levels.”

NOTE: Licensee submittals, such as license amendments, which have already been identified 

as requiring NRC approval, are reviewed by NSIR rather than as an inspection activity under 

this inspection area.

a. Based on the screening, the inspector shall perform an in-depth review of a sample of 

E-plan changes which could potentially result in a RIE. E-plan changes implementing 

classification, notification, dose assessment and protective action recommendations 

(PAR) should be given priority for review. Over the course of a year, the in-depth review 

effort should include at least one E-plan change, if any are submitted.
Issue Date: 09/04/14 Att3-2 82501

b. Any E-plan change that resulted in a RIE, or resulted in the E-plan no longer meeting

the requirements of 10 CFR 50.47(b) or Appendix E to 10 CFR Part 50, as applicable, 

and was implemented without prior NRC approval is to be evaluated in accordance with 

the Enforcement Policy (traditional enforcement) and documented accordingly.

c. Perform a review of the licensee’s 10 CFR 50.54(q) change process, and E-plan 

change documentation to ensure proper implementation for maintaining E-plan integrity 

(may be performed in the office or onsite).

03.00 INSPECTION GUIDANCE

The following inspection guidance section and attachments provide methods and examples of 

how the inspection requirements could be completed. Use of the following guidance is at the 

discretion of the inspector.

03.01 EAL Change Review

Section IV.B.2 of Appendix E to 10 CFR Part 50 states that a licensee desiring to change its 

entire EAL scheme is required to obtain prior NRC approval for the change. All other EAL 

changes are made under 10 CFR 50.54(q)(3). This rule allows the licensee to make changes to 

its E-plan only if it performed and retained an analysis that demonstrates that the changes do 

not reduce the effectiveness of the plan and that the plan continues to meet the standards of 

10 CFR 50.47(b) and the requirements in 10 CFR 50 Appendix E, as applicable. The 

requirements for obtaining prior NRC approval are provided in 10 CFR 50.54(q)(4). Regulatory 

Guide 1.219, “Guidance on Making Changes to Emergency Plans For Nuclear Power Plants,” 

November 2011, [ML102510626], provides guidance on processing EAL changes under 

10 CFR 50.54(q)(3) and should be used in inspecting EAL changes implemented after February 

21, 2012.

Regulatory Issue Summary (RIS) 2005-02, “Clarifying the Process for Making Emergency Plan 

Changes,” February 14, 2005, provides additional guidance in determining whether changes to 

the E-plan would reduce its effectiveness, should be used for changes implemented prior to 

February 21, 2012, and may be used for subsequent changes to the extent that it does not 

conflict with the guidance in RG 1.219.

Licensees normally use an NRC-endorsed EAL scheme when submitting their required 

emergency classification and action level scheme but may propose an acceptable alternative 

method. 

Guidance on acceptable EAL change methodology is contained in RIS 2003-18, “Use of 

NEI 99-01, Methodology for Development of Emergency Action Levels,” Revision 4, Dated 

January 2003,” and its supplements, should be used for changes implemented prior to

February 21, 2012, and may be used for subsequent changes to the extent that it does not 

conflict with the guidance in RG 1.219. NRC HQ NSIR/Division of Preparedness & Response

(DPR) assistance may be requested for review and approval of EAL changes which involve a 

significant portion of the EAL scheme or incorporate an alternative EAL methodology.
Issue Date: 09/04/14 Att3-3 82501

Perform the EAL change review in accordance with Figure 1, “EAL Change Review Flowchart.” 

The following comments are intended to clarify expectations:

• Administrative changes are considered to be changes a licensee made to correct 

typographical errors or other information that does not affect the outcome of the EAL.

• Contact NRC HQ NSIR/DPR if it appears that a RIE may have occurred, or when assistance 

in determining a potential RIE is needed. 

• Review the licensee’s documentation used to support their 10 CFR 50.54(q) determination. 

Evaluate this documentation to determine if the licensee’s position is justifiable and 

appropriate.

• If the licensee made the EAL change(s) due to receipt of a Safety Evaluation Report (SER)

or NRC direction via orders, bulletins, etc., review the change and evaluate if the change 

was made in accordance with the stated NRC guidance or SER.

• The report should state that a review was performed against 10 CFR 50.54(q) and that no 

apparent RIE(s) was/were identified. See Section 03.02.b for example documentation 

wording. For EAL changes, see Section 03.02.c.

Verify that the licensee performed the annual EAL review with State/County authorities in 

accordance with the requirements of 10 CFR 50, Appendix E, Section IV.B (may be performed 

in the office or onsite during the EP inspection).

03.02 E-plan Change Review

a. E-plans may undergo extensive changes (e.g., the combination of multiple plans from 

different sites due to a change of site ownership). E-plan changes may be implemented 

without prior approval if the changes are in accordance with 

10 CFR 50.54(q)(3). Based upon the complexity of the change(s), the resource 

allocation may be at the upper end, or above the direct inspection effort estimate in 

order to ensure an adequate sample of changes are inspected. 

b. Review of E-plan changes is to be performed on a sample basis. Review changes that 

are not purely administrative (e.g., typographical corrections) and compare against the 

licensee’s E-plan as defined in Regulatory Guide 1.219, Position C.3.5. Refer to 

Figure 2 “Emergency Plan Review Flowchart” to assist in screening E-plan changes.

As explained in RG 1.219, Position C.3.6, the 10 CFR 50.54(q)(3) E-plan change process 

initiates when the licensee decides to make a content change to its E-plan — an intentional act 

on the part of the licensee. For example, the retirement of a seismic instrument is not a change, 

if the E-plan still contains the approved description. However, the retired seismic instrument 

may represent a failure to follow and maintain the effectiveness of the plan and may be an 

apparent violation of 10 CFR 50.54(q)(2). If the E-plan was revised to omit the retired seismic 

instrument’s description, then 10 CFR 50.54(q)(3) applies.
Issue Date: 09/04/14 Att3-4 82501

For the sample chosen, perform an in-depth review against 10 CFR 50.47(b) and the 

requirements of Appendix E, and the original NRC-approved E-plan. NUREG-0654, Section II, 

may be used to inform decisions when the NRC-approved plan is silent with regard to a 

questionable program element. If it appears that an E-plan element is not in compliance with 

the requirements of 10 CFR 50.47(b) and Appendix E, or is an RIE, the issue is an apparent 

violation of 10 CFR 50.54(q)(3). Refer to RG 1.219 to aid in determining if the change is a 

potential RIE.

RG 1.219 Position 1.5 clarifies that the inspector is performing a review of changes made to the 

E-plan and that this does not constitute approval of the Plan change(s). Sample documentation 

wording for EAL and E-plan changes with no apparent RIE is as follows:

Since the last NRC inspection of this program area, Emergency Plan 

Revision(s) XX to XX were implemented based on your determination, in 

accordance with 10 CFR 50.54(q), that the changes resulted in no 

reduction in effectiveness of the Plan, and that the revised Plan continued 

to meet the requirements of 10 CFR 50.47(b) and Appendix E to 

10 CFR 50. The inspectors conducted a {(1) sampling review of the 

Emergency Plan changes, or (2) review of EAL changes} to evaluate for 

potential reductions in effectiveness of the Plan. However, this review is 

not a formal safety evaluation and does not constitute formal NRC 

approval of the changes. Therefore, these changes remain subject to 

future NRC inspection in their entirety.

c. E-plan changes determined to be a RIE are violations of 10 CFR 50.54(q) which may 

impact the NRC’s ability to perform its regulatory function and are dispositioned using 

the traditional enforcement process. The severity level is assigned after consideration 

of appropriate factors for the particular regulatory process violation in accordance with 

the NRC Enforcement Policy. Generally, the process would involve the following:

1. Assessment of the licensee’s 50.54(q) change evaluation for adequacy;

2. Discussion of the assessment of the licensee’s 50.54(q) evaluation and the 

apparent RIE with licensee EP staff and NRC Regional management; and

3. Consideration for enforcement action if the issue concerns the failure to comply 

with a 10 CFR 50.47(b) Planning Standard.

4. Completion of the evaluation for the violation and coordination with the regional 

enforcement coordinator for assignment of severity level. Section 2.2.2 of the 

Enforcement Policy provides general guidance for the assignment of severity 

levels to violations. Section 6.6 provides severity level examples for emergency 

preparedness. 
Issue Date: 09/04/14 Att3-5 82501

d. Inspectors should request that licensees provide a copy of the procedure(s) which 

governs the 10 CFR 50.54(q) change process and review, at a minimum, the following 

documentation (may be performed in the office or onsite during the EP inspection):

1. Change documentation for all E-plan changes reviewed.

2. Sample of change documentation for lower tier documents which contain E-plan 

commitments removed from the E-plan, but must be maintained under

the 10 CFR 50.54(q) change process. These lower tier documents should be 

administratively tracked by the licensee to ensure E-plan integrity, and must be 

available for NRC inspection.

END
Issue Date: 09/04/14 F1-1 82501

No further review 

required.

Verify SER obtained prior to 

implementation and licensee 

implemented SER as approved.

Is this an 

admin 

change?

only?

 Change in EAL setpoint?

 Addition or removal of equipment/instrumentation needed 

for timely EAL declaration?

 Change to Fission Barrier EALs that impact logic for EAL 

declaration?

 Change made due to NRC guidance (threat advisories, 

RIS’s, etc.).

 Elimination of an EAL or IC.

 Change is significantly different than previous EAL.

Compare new 

EAL/EAL Basis 

against last NRC 

‘approved’ EAL/EAL 

Basis and/or NRC 

guidance.

Licensee 

changed an 

EAL(s) or EAL 

Bases 

Document.

Yes

Yes

Yes

No

No

NO

NO No

Are any of 

these 

triggers 

present?

Is this an EAL 

scheme change 

submitted via 10 

CFR App E or an 

EAL change 

submitted via 10 

CFR 50.54(q)?

Review 10CFR 

50.54(q) evaluation

Contact NRC 

HQ for 

assistance

Potential 

reduction in 

effectivenes

s

Yes

No

Figure 1: EAL Change Review Flowchart
Issue Date: 09/04/14 F2-1 82501

 Change to on-shift staffing.

 Change to ERO augmentation staffing and/or response 

time.

 Change to emergency response facility activation times.

 Change to State, County, and/or Federal notification 

process.

 Change to dose projection system and/or process.

 Change to Protective Action Recommendations and/or 

process.

 Removal of E-plan content to lower tier document

Licensee 

changed 

the E-plan.

No further 

review required.

No

No

No

No

Yes

Yes

Yes

Yes

Figure 2: Emergency Plan Change Review Flowchart

Are any of 

these 

triggers 

present?

Is this 

change 

IAW an 

SER?

Is this an 

admin 

change 

only?

Review 10 CFR 

50.54(q) evaluation.

Contact 

NRC HQ for 

assistance.

Compare new 

wording against last 

“approved” wording

RIE?
Issue Date: 09/04/14 Att4-1 82501

ATTACHMENT 4

ALERT AND NOTIFICATION SYSTEM EVALUATION

01.00 INSPECTION OBJECTIVE

To evaluate the licensee’s compliance with the testing and maintenance requirements specified 

in the Federal Emergency Management Agency (FEMA)-approved Alert and Notification System 

(ANS) Design Report and supporting letters for the primary and backup ANS to the extent that 

the licensee has assumed responsibility for the testing and maintenance of those systems. If 

the ANS is maintained and tested by a local government, this procedure does not apply. Initial 

implementation of this procedure will require an understanding of the FEMA-approved design 

report and verification of the approved system tests.

02.00 INSPECTION REQUIREMENTS

02.01 Primary and Backup ANS Testing System Design Evaluation. [10 CFR 50.47(b)(5) and 

Appendix E.IV.D.1, 3, 4]

a. Review the FEMA-approved primary and backup ANS design report for any approved 

changes (since the last inspection) for understanding. Review any changes to testing 

procedure and maintenance program for continued consistency with the requirements 

in the design report. 

b. Review the licensee’s Emergency Plan (E-plan) commitments, if any, concerning the 

primary and backup ANS testing and procedure(s) to determine licensee compliance 

with the design report and E-plan.

c. Evaluate the adequacy of primary and backup ANS testing.

02.02 Program Review. [10 CFR 50.47(b)(5) and Appendix E.IV.D.1, 3, 4]

a. Review any changes to the primary and backup ANS methods or systems for 

consistency with the FEMA design report.

b. Review primary and backup ANS testing and maintenance program and procedures. If 

possible, interview individuals responsible for the maintenance of the system.

c. Observe, if possible, a primary and/or backup ANS test and evaluate procedure usage 

(e.g., determine the timeliness of data collection and effectiveness of interaction 

between licensee and responsible governmental staffs on apparent siren test

malfunctions).

d. Review a sample of corrective actions related to the primary and backup ANS.
Issue Date: 09/04/14 Att4-2 82501

e. Determine whether corrective actions have been effective in correcting primary and 

backup ANS problems.

02.03 Requirements for Non-Siren ANS systems. [10 CFR 50.47(b)(5) and 

Appendix E.IV.D.1, 3, 4]

a. Review the notification system design for any FEMA-approved changes (since the last 

inspection) for understanding.

b. Evaluate testing, corrective actions, and maintenance.

02.04 Requirements for Backup ANS Capability.

[10 CFR 50.47(b)(5) and Appendix E.IV.D. 4]

a. Identify the licensee’s backup means for the ANS. 

b. Perform the backup system inspection requirements if the backup ANS utilizes a 

hardware system (e.g., sirens, tone alert radios, etc.) under the licensee’s control and 

for which the licensee performs testing and maintenance activities in accordance with 

the FEMA-approved ANS Design Report. 

c. Review the licensee’s confirmation that the capability exists and determine that any 

FEMA-identified deficiencies or areas requiring corrective action have been corrected if 

the backup ANS is not under the licensee’s control (e.g., offsite response organization 

(ORO) route alerting, reverse phone dialing systems maintained by the OROs).

03.00 INSPECTION GUIDANCE

Evaluation of the primary and backup ANS testing program design need only be performed 

once. Subsequent inspections shall assess any changes implemented since the initial 

evaluation.

The following inspection guidance section and attachments provide methods and examples of 

how the inspection requirements could be completed. Use of the following guidance is at the 

discretion of the inspector.

03.01 Siren Testing System Design Evaluation [10 CFR 50.47(b)(5) and 

Appendix E.IV.D.1, 3, 4]

a. Review for understanding the FEMA-approved primary and backup ANS design report 

documents for the siren system. System documentation is available in system 

evaluation reports or may be available from licensee system descriptions.

b. Review siren system testing procedures and determine compliance with commitments. 
Issue Date: 09/04/14 Att4-3 82501

1. A typical testing procedure would include the elements of 

NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of 

Nuclear Power Plants", Appendix 3, as follows: 

 Silent test: every two weeks

 Growl test: quarterly and after maintenance is performed

 Complete cycle test: at least annually

2. Review testing commitments approved by FEMA that are deviations from the 

NUREG-0654 guidance (e.g., some systems are sounded regularly in lieu of the 

growl and/or silent tests) and structure the inspection accordingly.

c. Verify siren procedures, as performed, test the components of the system necessary for 

the system to perform its design function as described in the FEMA-approved design 

report. For example:

1. The test verifies that the siren received the activation signal?

2. The test verifies that the siren processed the activation signal?

3. The test verifies that all functions expected for the test responded to the 

activation signal?

4. The test is designed to verify the ability of the siren to process activation signals 

and perform its design function?

5. The test verifies the ability to activate the sirens from all control locations 

specified in the FEMA-design report?

6. The test credits any devices or components that may not be operable for the 

FEMA-approved configuration (e.g., components requiring AC power in an AC 

power-independent design).

Note: Actions performed in advance of a scheduled test that could mask the actual asfound condition of the siren system, such as preconditioning or pre-testing the siren 

equipment and correcting deficiencies prior to the test are not allowed. Unplanned 

corrective maintenance needed to restore siren system operability, and the postmaintenance testing associated with that maintenance, prior to a regularly scheduled 

siren test, is acceptable.
Issue Date: 09/04/14 Att4-4 82501

03.02 Program Review [10 CFR 50.47(b)(5) and Appendix E.IV.D.1, 3, 4]

a. Determine if a significant change has occurred to the primary and/or backup ANS. If 

such changes have been implemented, verify that FEMA approval was obtained. 

Examples of what constitutes a significant change to the primary or backup ANS 

include:

1. Additions to, or upgrading of, alerting devices or deletion/re-location of devices.

2. A change to maintenance methods that is not addressed in the design report.

3. A change to testing methods that is not addressed in the design report.

4. A change to administrative control of special alerting devices.

If a question arises as to whether a change is significant such that it requires prior 

FEMA approval, or that a change has altered the original primary and backup ANS 

design such that it no longer appears to meet commitments, contact the emergency 

preparedness (EP) program office and request a FEMA evaluation of the change. 

b. Review primary and backup ANS program and procedures to demonstrate the 

licensee’s compliance with commitments in the FEMA design report and emergency 

plan. The review should include:

1. Verify required tests and maintenance adequately address commitments made.

2. Verify maintenance and testing records are maintained in accordance with site 

procedures.

3. Verify post maintenance testing required by site procedures is performed.

4. Verify a protocol exists for reporting of primary and/or backup ANS equipment 

failures found during normal operation or testing and are reported in a timely 

manner. 

5. Evaluate the primary and backup ANS test program(s), maintenance program, or 

procedures for flaws or deficiencies that could result in an unintended loss of the 

offsite officials’ capability to activate the primary and backup ANS.

c. If possible, observe a primary and/or backup ANS test. Verify it is conducted in 

accordance with the approved procedure and that, as conducted, it supports the 

previous determination that the design of testing is adequate.
Issue Date: 09/04/14 Att4-5 82501

1. Review the method used for collection of test data and determine if it is timely 

such that an ANS failure would be recognized immediately. Some testing 

processes rely on a visit to the siren to determine test success and siren status. 

This may delay collection of data for a period. While this is not desirable, it is 

acceptable. 

2. Verify that data is consistently collected in a reasonable (not absolute) time 

frame, at least before the next test, but preferably within a couple of days. Verify 

that data collection actually gathers information on primary and backup ANS 

status rather than just the conduct of the test.

3. As applicable, observe the effectiveness of the interaction between the licensee 

and ORO staffs during the tests and actions taken on test failures.

d. Review the system test and maintenance records since the last inspection to identify 

problems that should have been entered into the corrective action program for 

resolution by the licensee. In addition:

1. Review any response to significant events that may have impacted the 

operability of the siren system, (e.g., high winds, ice storms, lightning strikes, 

floods, etc.). Determine the timeliness of problem resolution efforts made to 

recover from such events. 

2. Determine whether problems are recurrent in certain sirens, or siren areas, and 

review subsequent licensee corrective actions. Review records of any spurious 

siren activations and associated corrective actions.

3. Determine if siren repairs were unnecessarily delayed due to inadequate and/or 

delayed corrective actions (e.g., inappropriate priority assigned to repair efforts, 

multiple instances of apparent lack of spare parts).

e. Determine whether the licensee’s corrective actions have been effective in resolving 

primary and backup ANS problems by verifying:

1. Siren system availability is > 90 percent

2. No individual siren has been unavailable for a continuous period of > 4 months or 

for more than 30 percent of the time over a 12 month period.
Issue Date: 09/04/14 Att4-6 82501

03.03 Requirements for Non-Siren ANS Systems [10 CFR 50.47(b)(5) and 

Appendix E.IV.D.1, 3, 4]

Note: This inspection element should be implemented only when non-siren ANS systems are

used as the primary notification method in an area of the emergency planning zone

(EPZ). 

a. Review applicable design documents for understanding of features important to testing 

non-siren primary and backup ANS.

1. System documentation is available in the FEMA-approved ANS design report or 

may be available from licensee system descriptions. For example, the primary 

alerting system may consist of tone-alert radios (TARs) distributed to individual 

homes. The non-siren ANS may include reverse telephone calling systems, or

route alerting as approved by FEMA. 

2. The FEMA-approved primary and backup ANS design report should be reviewed

to understand what systems constitute the non-siren ANS, as well as the back-up 

means of alerting (e.g., route alerting as a back-up means of notifications for 

TARs). 

b. The testing and maintenance activities for non-siren systems will vary in scope and 

nature depending on the system structure and the feasibility of testing.

1. Corrective actions may differ from siren systems. The non-siren portions of the 

ANS or backup system may be beyond the licensee’s control. For example, 

tone-alert radios in private homes cannot be inspected. Accordingly, FEMA 

typically includes requirements in the ANS Design Report for certain actions 

intended to provide a modicum of assurance of availability and reliability, in lieu 

of direct testing and maintenance. The inspector should review the FEMAapproved Design Report and assess the adequacy of the licensee’s performance 

of these test and maintenance activities in accordance with the FEMA-approved 

primary and backup ANS Design Report. The FEMA-approved ANS Design 

Report will contain the commitments that should be used for criteria, but 

ineffective maintenance should be noted in any case. Typical requirements may 

include one or more of the following:

 New residences within the EPZ are offered the opportunity to obtain a 

TAR. There are many ways to accomplish this, (e.g., monitoring new 

public utility service connections and community “welcome wagon” 

initiatives). It is expected that licensees will have a method to be informed

of new housing and businesses in the regions covered by non-siren ANS.

 Residences assigned a TAR are contacted annually to determine whether 

the equipment is operable. This may be done through a letter offering new 

batteries or other methods.
Issue Date: 09/04/14 Att4-7 82501

 Telephone-based systems are updated periodically and tested periodically 

as per the approved FEMA design report. 

2. The back-up means of notification for a non-siren ANS system (e.g., route 

alerting or telephone systems) shall be evaluated to verify that populations in the 

EPZ are capable of being notified during an emergency. 

03.04 Requirements for Backup ANS Capability [10 CFR 50.47(b)(5) and Appendix E.IV.D.4]

a. Appendix E, § IV.D.3 of 10 CFR Part 50 requires that the ANS capability include 

administrative and physical means for a backup method of public alerting and 

notification. Refer to NSIR-DPR-ISG-01, “Emergency Planning for Nuclear Power 

Plants,” § IV.J, “Backup Means for Alert and Notification Systems,” for additional 

information on an acceptable method of complying with this requirement. 

ANS inspections should focus on changes made to the FEMA-approved ANS Design 

Report, relevant E-plan commitments, supporting testing and maintenance procedures; 

and the licensee’s performance on meeting the backup ANS commitments. 

The backup ANS capability is not required to meet the performance requirements of the 

primary alerting method. A backup ANS that does not meet the design objective 

established in § IV.D.3 of Appendix E for the primary ANS cannot serve as a 

compensatory action for a planned outage of the primary ANS capability.

END
Issue Date: 09/04/14 Att5-1 82501

ATTACHMENT 5

PRIORITIZATION OF ADDITIONAL AREAS FOR INSPECTION

01.00 GENERAL

Corrective action system data is used to identify response areas of concern and deploy 

inspection resources accordingly. Areas, (e.g., Operational Support Center (OSC), field monitor 

teams) that have had few critique issues or more than average as compared to the Technical 

Support Center (TSC) or Emergency Operations Facility (EOF) should be selected for 

observation. Inspection resources usually deployed in the TSC, EOF and Control Room may be 

used to observe other areas. 

If a licensee’s performance in previous inspections in classification, notification, dose 

assessment and PARs indicates reliable acceptable performance, inspectors should reduce the 

inspection sampling in these areas and instead use a portion of available inspection resources 

to sample a selection of other areas as described below.

In order to facilitate review of critique related corrective actions, the inspector should request a 

corrective action system listing sorted for drill and exercise critique issues for the previous

2-3 years. If possible, the findings should be sorted by emergency response facility.

The inspector should remain alert to the impact that the licensee’s performance in other areas 

(e.g., staffing and training) may have on the licensee’s performance of classification, notification, 

dose assessment and PARs. 

02.00 PRIORITIZATION OF ADDITIONAL AREAS FOR INSPECTION

Guidance for deployment of inspection resources beyond classification, notification, dose 

assessment and PARs areas is provided below. These areas may generally be considered in 

order of importance. Selection for deployment of inspection resources should be based on 

knowledge of the program, previous problems, and logistics.

a. Adequacy of worker protection including accountability, evacuation, exposure 

authorization and thyroid protection, including actions during a hostile action

[10 CFR 50.47(b)(10) & (11) and Sections IV.E and IV.I of Appendix E to 

10 CFR Part 50].

b. Adequacy of interface with offsite authorities (e.g., in the area of PAR communication 

and technical support). [10 CFR 50.47(b)(6) and Sections IV.A.7, IV.E.9, and IV.D of 

Appendix E to 10 CFR Part 50].

c. Adequacy of arrangements for offsite resources responding to an emergency, including 

hostile actions, at the licensee’s site.

[10 CFR 50.47(b)(6) and Section IV.A.7 of Appendix E to 10 CFR Part 50.]

d. Ability to formulate mitigating actions.
Issue Date: 09/04/14 Att5-2 82501

e. Ability to prioritize mitigation and assessment efforts to protect the public health and 

safety.

f. Ability to implement mitigating actions (e.g., damage control teams) under accident 

conditions.

g. Effectiveness of command and control [10 CFR 50.47(b)(1)].

h. Ability to diagnose plant accident conditions, other than offsite consequences 

addressed in the risk-significant area discussion.

i. Adequacy of communications between licensee facilities [10 CFR 50.47(b)(6) and 

Section IV.E.9 of Appendix E to 10 CFR Part 50].

j. Accuracy and completeness of licensee-approved press releases [10 CFR 50.47(b)(7)].

END
Issue Date: 09/04/14 Att6-1 82501

ATTACHMENT 6 - Revision History for IP 82501

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 ML14078A540

09/04/14

CN 14-020

First issuance. Completed 4 year search for 

commitments and found none.

None required ML14078A524