Issue Date: 07/21/16 1 71114.06

NRC INSPECTION MANUAL NSIR/DPR

INSPECTION PROCEDURE 71114 ATTACHMENT 06

DRILL EVALUATION

Effective Date: 10/01/2016

PROGRAM APPLICABILITY: 2515 A

71114.06-01 INSPECTION OBJECTIVE

To evaluate the adequacy and capability of the licensee’s assessment of performance, via a 

formal critique process, to identify emergency preparedness (EP) weaknesses in selected drills 

and training evolutions and use of its corrective action program (CAP) to correct EP identified 

weaknesses.

The intent of this inspection procedure is to evaluate the licensee’s ability to conduct and 

critique their own drills and or training evolutions between U.S. Nuclear Regulatory Commission 

(NRC) graded EP exercises hence performance of this inspection sample is to be completed 

independent of Inspection Procedure (IP) 71114.01 Exercise Evaluation or 71114.07 Exercise 

Evaluation - Hostile Action Event.

Note: If the last Hostile Action Base (HAB) evaluated exercise was greater than eight years

ago, request the licensee to demonstrate the emergency preparedness support during the next 

Force-on-Force drill or exercise

71114.06-02 INSPECTION REQUIREMENTS

02.01 Select a sample of EP drills and training evolutions identified as contributing to the Drill 

and Exercise Performance (DEP) and Emergency Response Organization (ERO) performance 

indicators (PI) to observe. The inspection sample should include, to the extent possible, all 

types of scenarios (e.g. 10 CFR 50.54(hh)(1) & (2), radioactive release, no release, etc.). Plan 

to inspect a sample of three drills and/or training evolutions (see note above concerning last 

HAB evaluated exercise), such that a minimum of one EP drill and some combination of two 

additional drills and/or training evolutions are observed. Drills or exercises performed by the 

licensee for the purpose of outside organization observation or audit, such as Institute of 

Nuclear Power Operations or peer audit team, should not be selected as part of this inspection 

procedure’s sample. 

02.02 Observe the licensee’s performance during the EP drill/training evolution. Emphasis 

should be on the risk-significant activities of classification, notification, dose assessment and 

protective action recommendation (PAR) development as well as other inspection areas based 

on resource availability. Review DEP PI individual inputs for degraded performance and/or 

adverse trends to ensure areas of weakness are observed.
Issue Date: 07/21/16 2 71114.06

02.03 Verify any EP weakness observed by the inspector are appropriately identified in the 

licensee’s formal critique and entered into the corrective action program.

02.04 Identify recurring weaknesses in similar activities from previous drill and/or training 

opportunities in order to evaluate the effectiveness of corrective actions.

02.05 Identify any weaknesses that may reveal a failure to comply with a regulatory 

requirement.

02.06 Determine if the licensee assessment of DEP PI opportunities are accurate.

71114.06-03 INSPECTION GUIDANCE

The primary focus of this inspection is to verify the licensee critique of the risk-significant areas 

from EP drills and training evolutions identified as DEP and ERO Drill PI opportunities. Select 

other areas for inspection based on resource availability, past history, efforts to correct 

weaknesses and/or logistical limitations. Consider the prioritization guidance in Attachment 1, 

“Prioritization of Additional Areas for Inspection” to develop a plan to deploy inspection 

resources to observe other activities as practical. 

03.01 Select Emergency Preparedness Drills and/or Training for Observation.

a. Obtain the licensee’s schedule of EP drills and training evolutions identified as DEP and 

ERO Drill PI opportunities. 

b. Inspect as a minimum one EP drill, and some combination of two EP drills and/or 

simulator-based licensed operator requalification training (LORT) evolutions involving 

shift operating crews (total of three samples). The inspection sample should include, to 

the extent possible, all types of scenarios (e.g. 10 CFR 50.54(hh)(1) & (2), radioactive 

release, no release, etc.). 

c. Observation of drill and training evolutions may be performed unannounced.

Note: The licensee is not required to include simulator-based LORT training evolutions in 

DEP PI opportunities. Additionally, the licensee may wish to collect “as found” operator 

proficiency information. There is no intent to disrupt ongoing operator qualification programs.

d. Review the selected drill/training evolution scenario to identify the timing and location of 

classification, notification, dose assessment and PAR development activities and 

licensee expectations of a successful response. If the scenario contains a potential 

aircraft threat the inspector should review the requirements of 10 CFR 50.54 (hh)(1). If 

the scenario contains a hostile action event and/or loss of large areas of the plant due 

to explosions or fire, the inspector should review the applicable requirements of 

10 CFR 50 Appendix E and 10CFR 50.54 (hh)(2). 

Note: Refer to NEI 99-02, “Regulatory Assessment Performance Indicator Guideline,”

Section 2.4, Emergency Preparedness Cornerstone, ERO Drill Participation, Clarifying Notes, to 

understand how drills and training evolutions qualify as performance enhancing experiences. 
Issue Date: 07/21/16 3 71114.06

Determine whether the drill/training evolution qualifies to be included in the DEP (and ERO) PI 

statistics.

e. Review the Emergency Plan Implementing Procedures (EPIPs) that provide instructions 

for classification, notification, dose assessment, and PAR development activities, to 

develop an understanding of the criteria for timely and accurate completion of these 

activities based on the EPIPs, the scenario, and NEI 99-02. If the licensee’s DEP PI 

indicator is in the licensee response band, the inspector should review EPIPs governing 

other ERO program areas to develop an understanding of the activity’s success criteria 

for inspection.

03.02 Drill/Training Evolution Observation.

a. Review checklists and forms used for classification, notification, dose assessment and 

PAR development activities. 

Note: The licensee has demonstrated the capability to make a notification in 15 minutes if 

offsite response organizations identified in the Emergency Plan (E-plan) receive notification of, 

at a minimum, the declared emergency classification level within 15 minutes of declaration. The 

licensee’s critique should identify any delay that occurred in making the notification to one or 

more offsite response organizations (OROs) (e.g., an ORO cannot be reached). Any 

notification delay under the control of the licensee to foresee and or prevent (e.g., telephone call 

lists not kept up-to-date) should be evaluated as a failure to comply and assessed for 

significance. 

b. Identify any weaknesses in licensee performance of classification, notification, dose 

assessment PAR development and other observed EP areas and activities. If the 

licensee’s DEP PI indicator is in the licensee response band, the inspector should 

sample DEP activities and consider other ERO program areas for inspection (See 

Attachment 1 “Prioritization of Additional Areas for Inspection”). Inspector identified 

weaknesses must be held confidential until after the licensee’s formal critique.

Note: Prompting of drill participants is not a finding under the assessment process because it 

represents no risk significance in itself. However, prompting related to a DEP PI opportunity is 

basis for failing a. DEP PI opportunity and should be documented when observed.

03.03 Licensee’s Emergency Preparedness Drill/Training Evolution Formal Critique 

Observation.

a. Determine if the licensee critique identified all weaknesses observed by the inspector. 

b. Licensee critique failures are to be documented and assessed for significance. 

c. Determine if the licensee properly identifies failures in classification, notification, dose 

assessment and PAR development activities. 

d. Verify that licensee identified weaknesses are entered into the CAP in a manner to

allow NRC review of the resolution in the future.
Issue Date: 07/21/16 4 71114.06

Note: Poor performance in a drill is not a regulatory issue if the licensee corrects the 

performance issue or enters it into its CAP. The DEP PI captures performance failures and 

unless the PI crosses the “green band” threshold then increased NRC involvement is not 

warranted.

Note: PI opportunities to be counted in the DEP PI quarterly report are at the discretion of the 

licensee and must be identified in advance and cannot be removed from the count due to poor 

performance.

03.04 Identify Recurring Weaknesses.

a. Use previous drill and training critiques to determine if previously identified weaknesses 

represent a trend or a repeat (i.e., recurring, with the same or similar cause) weakness. 

b. Review specific corrective actions identified for the previous weaknesses, as well as 

similar occurrences in response to actual events, drills, exercises and training 

evolutions.

c. Verify completion of associated corrective actions. 

d. Determine if there is a trend or repeat of a weakness. Verify the licensee identified the 

trend or repeat weakness and entered it into the corrective action system. 

e. Consider the status of the DEP PI as well as the status of the relevant risk significant 

planning standard components of the DEP PI.

03.05 Identify Failures to Comply with Regulatory Requirements.

a. Evaluate any noted program element issues related to the effectiveness and adequacy 

of the E-Plan, or it’s implementing procedures1, observed during the drill and/or training 

as an apparent failure to comply with the associated 10 CFR 50.47(b) planning 

standards and Appendix E requirements. Assess significance in accordance with the 

EP Significance Determination Program. 

For example, an ERO field monitoring team is unable to perform a survey because of 

ineffective/inadequate survey procedures or equipment. Such issues, whether 

identified by the licensee or inspector, are not treated as weaknesses, which are 

defined as deficiencies in ERO performance. The inspector should:

1. Review the history of identified issue(s) to obtain relevant information. 

2. Determine, immediately, if possible, if the program no longer meets the 

applicable planning standard. If this cannot be accomplished immediately, confer 

with regional management for direction. 

 

1 The E-plan contains the licensee’s commitments to NRC regulations. The implementing procedures are the 

licensee’s methods of implementing those commitments and may be used to judge effective, timely, and accurate 

implementation. 
Issue Date: 07/21/16 5 71114.06

03.06 Assessment of Licensee Performance Indicator Accuracy.

a. Determine if the licensee’s assessment of PI opportunity performance is accurate. 

b. Determine if the licensee is properly dispositioning failures in classification, notification, 

dose assessment and PAR development activities with regard to PI statistics. 

c. Refer any discrepancies to the regional EP inspector, regional management and 

headquarters’ Office of Nuclear Security and Incident Response/Division of 

Preparedness and Response (NSIR/DPR).

71114.06-04 RESOURCE ESTIMATE

The direct inspection effort is estimated to average, between 9 and 20 hours per year, 

regardless of the number of reactor units at a site.

71114.06-05 PROCEDURE COMPLETION

The minimum inspection sample size will constitute completion of this procedure in the Reactor 

Programs System. Routine reviews of problem identification and resolution activities performed

in this attachment should equate to approximately 10 to 15 percent of the resource estimate 

range described above. The minimum sample size is 3 samples representing observation of 

one EP drill and two additional drills and/or training evolutions. Participation in the performance 

of IP 71114.01, “Exercise Evaluation or 71114.07 Exercise Evaluation - Hostile Action (HA) 

Event,” may not be credited as one of the three samples required for this inspection procedure.

71114.06-06 REFERENCES

NSIR/DPR-ISG-01, “Emergency Planning for Nuclear Power Plants” (ML1130105230)

NEI 06-04 Rev 1, "Conducting a Hostile Action-based Emergency Response Drill"

(ML073100460)

NEI 06-04, Rev. 2, Appendix A, “Drill and Exercise Objectives” (ML112091915)

IN 07-12, Tactical Communications Interoperability between Nuclear Power Reactor Licensees 

and First Responders (ML070710233)

IN 09-19, Hostile Action-Based Emergency Preparedness Drills (ML092250360)

RIS 06-12, Endorsement of NEI Guidance “Enhancements to Emergency Preparedness 

Programs for Hostile Action” (ML061530290)

RIS 2008-08, Endorsement of Revision 1 to NEI Guidance Document NEI 06-04, “Conducting a

Hostile Action-Based Emergency Response Drill”

END
Issue Date: 07/21/16 Att1-1 71114.06

ATTACHMENT 1

PRIORITIZATION OF ADDITIONAL AREAS FOR INSPECTION

General

In general, NRC oversight in emergency preparedness is focused on adherence to the 

emergency plan with an emphasis on these most risk-significant areas, and inspection 

resources should be deployed in a manner to cover these areas. However, within the constraint 

of resources, a broad range of response areas should be inspected. 

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

inspection resources accordingly. Areas, (e.g., operational support center, field monitor teams) 

that have had few critique findings or more than average as compared to the technical support 

center (TSC) or emergency operation facility (EOF) findings should be selected for observation. 

Inspection resources usually deployed in the TSC, EOF, or control room may be used to 

observe other areas. 

If a licensee’s performance in previous baseline inspections in the risk-significant areas of 

classification, notification, dose assessment and PAR development in conjunction with its 

performance under the Drill and Exercise Performance Indicators indicates reliable acceptable 

performance within the licensee response band, inspectors should reduce the inspection 

sampling in those areas and instead use a portion of available inspection resources to sample a 

selection of less risk significant 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 findings of the 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 less risksignificant areas (e.g., staffing and training) may have on the licensee’s performance in the risksignificant areas. 

Prioritization of Additional Areas for Inspection

Guidance for deployment of inspection resources beyond the most risk-significant 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 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 50].
Issue Date: 07/21/16 Att1-2 71114.06

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 50.]

d. Ability to formulate mitigating actions.

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 50].

j. Accuracy and completeness of licensee-approved press releases [10 CFR 50.47(b)(7)].
Issue Date: 07/21/16 Att2-1 71114.06 

ATTACHMENT 2 - Revision History For IP 71114.06

Commitment 

Tracking 

Number

Accession 

Number

Issue Date

Change Notice

Description of Change Description of 

Training Required 

and Completion Date

Comment and 

Feedback Resolution 

Accession Number

(Pre-Decisional, NonPublic Information)

N/A 10/25/06 Completed four-year historical CN search. N/A N/A

CN 06-029 10/25/06 Minor wording changes to clarify that the 

Emergency Preparedness (EP) cornerstone 

licensee response band is established by the 

performance indicator system and the licensee’s 

corrective action program, the importance of the 

formal critique process to identify EP 

weaknesses, and that this inspection activity is 

associated with planning standard 

10 CFR 50.47(b)(14).

No ML061790139

N/A ML12100A225

05/29/12

CN 12-008

Added:

 “Reference” section

 To Inspection Requirement 02.01 “The 

inspection sample should include, to the extent 

possible, all types of scenarios (e.g. 10 CFR 

50.54(hh)(1) & (2), radioactive release, no 

release, etc.).”

 To Inspection Requirement 02.02 guidance to 

use the review DEP PI individual inputs for 

degraded performance and/or adverse trends 

to ensure areas of weakness are observed

Provided at EP Face 

to Face counterpart 

meeting 09/09/2011

ML12100A235
Issue Date: 07/21/16 Att2-2 71114.06 

Commitment 

Tracking 

Number

Accession 

Number

Issue Date

Change Notice

Description of Change Description of 

Training Required 

and Completion Date

Comment and 

Feedback Resolution 

Accession Number

(Pre-Decisional, NonPublic Information)

 Note If the last Hostile Action Base (HAB) 

evaluated exercise was greater than 8yrs ago, 

request the licensee demonstrate the 

emergency preparedness support for the next 

Force-on-Force drill or exercise

 Inspection Requirements 02.04 to identify 

recurring weaknesses and 02.05 to identify 

failures to comply with regulatory requirements 

and corresponding guidance sections

 To guidance section 03.01 information stating 

if the scenario is a hostile action event, the 

inspector should review the requirements of 10 

CFR 50.54 (hh)(1) and (2). 

 Attachment 1 “Prioritization of Additional Areas 

for Inspection”

Removed “Inspection Bases” in accordance with 

IMC 0040 “Preparing, Revising and Issuing 

Documents for the NRC Inspection Manual” 

formatting expectations.
Issue Date: 07/21/16 Att2-3 71114.06 

Commitment 

Tracking 

Number

Accession 

Number

Issue Date

Change Notice

Description of Change Description of 

Training Required 

and Completion Date

Comment and 

Feedback Resolution 

Accession Number

(Pre-Decisional, NonPublic Information)

N/A ML15246A245

07/21/16

CN 16-017

Added drill selection guidance to Inspection 

Requirement 02.01 regarding drills that include 

outside organization observation or audit should 

be chosen as sample for this IP

ROP Feedback Forms

 71114.06-1952 - Added detail to inspection 

objective and procedure completion sections 

stating the three inspection samples required 

by this procedure cannot be satisfied by 

participation in the performance of IP 71114.01 

or 71114.07

 71114.06-1872 - Corrected 1st note under 

03.03 to state no increase in NRC involvement 

is warranted until the PI green white threshold 

is crossed

 71114-1925 - Editorial change – Align 

procedure with standard section numbering 

format of completion section under 711XX.XX05 and the references under 711XX.XX-06

N/A Comment Resolution 

– ML15252A202

Feed Back Forms –

71114.06-1952 

(ML15252A231)

71114.06-1872 

(ML15252A364)

71114.06-1925 

(ML15252A252)
Issue Date: 07/21/16 Att2-4 71114.06 

Commitment 

Tracking 

Number

Accession 

Number

Issue Date

Change Notice

Description of Change Description of 

Training Required 

and Completion Date

Comment and 

Feedback Resolution 

Accession Number

(Pre-Decisional, NonPublic Information)

Editorial change – reformatted Attachment 1 

“Prioritization Of Additional Areas For Inspection” 

and reordered additional areas for inspection 

based on branch chief comments.

Added NSIR/DPR-ISG-01, “Emergency Planning 

for Nuclear Power Plants” (ML1130105230) to 

the “References” section.

Added to section 71114.06-05 “Procedure 

Completion” the IP 71152 “Problem Identification 

and Resolution” expectation for routine PI&R 

activity reviews to be approximately 10 to 15 

percent of the baseline cornerstone inspection 

procedure resources estimates. The 10 to 15 

percent approximation is based on the overall 

expected inspection effort and is a general 

estimate only.