Issue Date: 07/21/16 1 71114.02

NRC INSPECTION MANUAL NSIR/DPR

INSPECTION PROCEDURE 71114 ATTACHMENT 02

ALERT AND NOTIFICATION SYSTEM EVALUATION

Effective Date: 10/01/2016

PROGRAM APPLICABILITY: 2515 A

71114.02-01 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.

71114.02-02 INSPECTION REQUIREMENTS

02.01 Primary and Backup ANS Testing System Design Evaluation.

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.

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
Issue Date: 07/21/16 2 71114.02

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.

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

backup ANS problems.

02.03 Requirements for Non-Siren ANS systems.

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.

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., off-site response organization 

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

71114.02-03 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.

03.01 Siren Testing System Design Evaluation.

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. 

1. A typical testing procedure would include the elements of NUREG-0654 "Criteria 

for Preparation and Evaluation of Radiological Emergency Response Plans and 

Preparedness in Support of Nuclear Power Plants," Appendix 3, as follows: 
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 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 do not mask the actual asfound condition of the siren system when the scheduled test is performed (i.e., 

preconditioning). Pre-testing the siren equipment and correcting identified deficiencies 

prior to a regularly scheduled test is incompatible with the ANS performance indicator 

(PI) as a uniform and valid indicator of the siren system reliability to perform its safety 

function. Unplanned corrective maintenance needed to restore siren system 

operability, and the post-maintenance testing associated with that maintenance, prior to 

a regularly scheduled siren test, is acceptable.

03.02 Program Review.

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:
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1. Addition to or upgrading of alerting 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/or backup ANS 

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

1. Verify required tests and maintenance adequately addresses 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 to the licensee. 

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/or backup ANS.

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

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

determination that the design of testing is adequate. 

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.
Issue Date: 07/21/16 5 71114.02

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’ corrective actions have been effective in resolving 

primary and backup ANS problems. 

Note: The ANS PI measures reliability of the offsite ANS. Performance above the 

green/white band threshold (94 percent) is in the licensee response band. For systems 

operating in the licensee response band, with a validated testing program (i.e., validated 

through this inspection procedure) corrective actions should be assumed to be effective. 

Because a licensee’s ANS PI is in the “Green Band” does not mean the system operability is 

meeting its design reliability. For example, an ANS with 100 sirens could have an ANS PI of 

95 percent reliability (in the licensee response band) and have some sirens that never work. 

An individual siren not being available for a continuous period of 4 months or for more than 

30 percent over a period of 12 months may indicate inadequate and/or delayed corrective 

actions.

03.03 Requirements for Non-Siren ANS Systems.

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. 
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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, 

TARs 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 FEMA-approved 

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.

 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.

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. 
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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 inspector should review the licensee’s progress on complying with the backup ANS 

requirement until full compliance is reached.

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.

71114.02-04 RESOURCE ESTIMATE

Direct inspection effort for this attachment is estimated to be, on average, between 4 hours and 

8 hours biennially regardless of the number of reactor units at a site.

71114.02-05 PROCEDURE COMPLETION

This procedure is considered complete when all the 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.

71114.02-06 REFERENCES

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

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

Plants” (ML102510343)

END
Issue Date: 07/21/16 Att1-1 71114.02

ATTACHMENT 1 - Revision History for IP 71114.02

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 06/29/06 Completed four-year historical CN search None N/A

N/A ML061580344

06/29/06

Rewrite to include evaluation of siren 

maintenance program in addition to the testing 

program, clarify what constitutes a significant 

system change, and align the procedure with the 

EP SDP. Also, change agency reference from 

FEMA to DHS. .

Provided training at 

last national EP 

counterpart meeting. 

January, 2006

CN 09-031 12/07/09

ML092990272

Changes in inspection requirements and 

guidance, pertaining to FEMA-approved siren 

system design report and evaluation of back-up 

means of notifications for non-siren ANS 

systems. Also revised number of hours allowed 

for inspection, per ROP Re-alignment review, 

2009. Also, change agency reference from DHS 

to FEMA.

None
Issue Date: 07/21/16 Att1-2 71114.02

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, 

Non-Public Information)

N/A ML12095A256

05/29/12

CN 12-008

Added:

 Inspection Requirement 02.04 and guidance 

section 03.04 to address the new EP rule 

requirements for backup ANS capability

 Section 71114.02-05 “References”

Removed “Inspection Bases” in accordance with 

IMC 0040 “Preparing, Revising and Issuing 

Documents for the NRC Inspection Manual” 

formatting expectations.

Provided at EP 

Face-to-Face 

counterpart 

meeting

09/09/2011

ML12095A266
Issue Date: 07/21/16 Att1-3 71114.02

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, 

Non-Public Information)

N/A ML15253A596

07/21/16

CN 16-017

Editorial changes:

– Align procedure with standard section 

numbering format of completion section under 

711xx.xx-05 and the references under 

711xx.xx-06 (see ROP Feedback Form 71114-

1925)

- Various branch chief editorial changes such 

as changing inspection guidance step 03.01.c 

from questions to statements.

- Removed past one time requirements to:

 For sites with an existing FEMA approved 

backup method verify it is implement in its 

E-plan by December 24th 2012

 For sites without an existing FEMA 

approved backup method, verify the 

licensee submitted a revised ANS Design 

Report to FEMA no later than June 24, 

2013 and install/implement the approved 

backup ANS capability with 365 days of 

FEMA’s approval of the updated ANS 

Design Report, or no later than June 22, 

2015, whichever occurs first.

Technical change – removed detail discussing 

expected FEMA actions.

None Comment Resolution -

ML 15253A596

Feedback Form –

71114.02-1925

ML15253A606
Issue Date: 07/21/16 Att1-4 71114.02

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, 

Non-Public Information)

Added to section 71114.02-05 “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.