Issue Date: 07/21/16 1 71114.03

NRC INSPECTION MANUAL NSIR/DPR

INSPECTION PROCEDURE 71114 ATTACHMENT 03

EMERGENCY RESPONSE ORGANIZATION STAFFING AND AUGMENTATION SYSTEM

Effective Date: 10/01/2016

PROGRAM APPLICABILITY: 2515 A

71114.03-01 INSPECTION OBJECTIVE

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

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

allow meeting ERO augmentation staffing and facility activation time commitments. IMC 2515 

emphasizes performance-based inspections should observe activities and the results of 

licensee programs over reviewing procedures or records. If no changes have been made to a 

given inspection requirement area since the last performance of this attachment, observation of 

the inspection area requirement task should be given consideration.

71114.03-02 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. Review the licensee’s ERO on-shift and augmentation staffing described in the 

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

conclusions of the detailed on-shift staffing analysis (OSA) required by 

Appendix E §IV.A.9. 

c. Verify the processes for maintaining required on-shift and augmentation staffing levels 

meets E-Plan commitments.

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 the ERO augmentation activation 

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

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

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

system and process and assess their effectiveness.

71114.03-03 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 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 provides methods and examples of how the 

inspection requirements of this procedure 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. 

1. 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. 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 ERO on-shift staff of those functions.

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

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

Radiological Emergency Response Plans and Preparedness in Support of 
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Nuclear Power Plants," Table B-1 should be used to assess ERO on-shift and 

augmentation staffing levels unless an NRC-approved/acceptable alternative is 

contained within the licensee’s E-Plan.

2. Review the licensee’s ERO on-shift staffing commitments against the licensee’s 

ERO on-shift staffing analysis to verify that the ERO on-shift staffing is supported 

by the conclusions of the staffing analysis.

3. Review changes to the staffing analysis. A complete review of the analysis is not 

expected. Changes that appear to support a reduction in on-shift staffing should 

be evaluated. 

Note: Changes made to the emergency plan on-shift staffing requires a 

10 CFR 50.54(q) evaluation of the change to the emergency plan (i.e. number of 

individuals or function assignments) as well as 10 CFR 50.54(q) of the corresponding

change to the OSA. The 10 CFR 50.54(q) evaluation of the new OSA is to be 

performed against the emergency plan’s OSA being changed or replaced.

4. 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 to the ERO staffing augmentation processes against commitments 

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

implementation procedures. 

1. An 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.

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

required by the E-Plan. Qualification should include:

1) ERO position specific training.

2) Respirator qualifications and respirator spectacles where 

appropriate.

3) Training for: the proper response to ERO activations for events

such as, a radiological event, a hostile action event, as well as the 

use of alternative facilities; onsite protective measures for staff 

safety, clear reporting instructions in the event the plant is 

inaccessible.

b. 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., ERO on-shift staffing processes ensure minimum 

staffing levels are maintained, sufficient depth of qualified individuals, 

formal rotational assignment schedule).
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c. A process capable of ensuring timely augmentation of ERO on-shift

staffing in accordance with E-Plan commitments and facility activation 

goals. The augmentation staff roster may be divided into ERO teams or 

the licensee may employ an “all-call” approach. The all-call approach may 

involve all responders, reporting to the site with the first to arrive assuming 

the ERO positions.

d. An ERO augmentation staff roster review process that ensures staff in 

positions with E-Plan commitments and facility activation goals continue to 

be capable of meeting the committed time. 

2. Review the implementation of the ERO staffing augmentation process(es) as 

follows:

a. If available, the performance of an actual event or drill where personnel 

reported to their duty locations and were timed, OR

b. If available, 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

c. The performance of verifying 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.

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

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 CAP items related to ERO staffing inadequacies and verify the 

licensee has implemented adequate corrective actions. Corrective actions arising from 

the OSA are expected to have interim compensatory measures to address staffing 

shortfalls within 30 days and long-term corrective actions implemented within 

24 months. 

03.02 Review of ERO Augmentation System.

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

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

effectiveness of the process. 

1. Determine whether the system is still capable of ensuring timely augmentation of 

ERO on-shift staffing in accordance with E-Plan activation goals for primary and 

alternate facilities. Hardware systems, (e.g., pagers, cell phones, automated 
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2. 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 by conducting system tests or surveillance activities. 

3. Review the licensee’s process for keeping the ERO augmentation system (or call 

out roster) current with ERO member names and contact information. Determine 

whether system operation is periodically verified by the licensee.

b. Review all results of actual E-Plan event activations and a sample of ERO primary and 

backup augmentation activation system drills (e.g., call-in, report-in) results 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. Verify system testing frequencies meet E-Plan commitments.

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

activation system have been performed 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 aspects 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 ERO 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 primary and back-up systems have been trained.

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

tests, were entered into the licensee’s CAP 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. 
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2. Review corrective actions taken for repeat failures and assess the adequacy of 

corrective actions. 

a. Consider the disposition of personnel performance problems as well as 

equipment failures. 

b. 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. 

c. This effort may require interviews with management or other individuals 

and further review of licensee corrective action program.

3. Review all licensee self-assessments of ERO augmentation activation drills and 

system testing since the last inspection. 

a. Determine the coverage and depth of the assessments, knowledge level 

of the reviewers, and whether the disposition of problems was 

appropriate.

b. Determine whether identified problems were placed in the corrective action 

program and resolved.

71114.03-04 RESOURCE ESTIMATE

Direct inspection effort for this attachment is estimated to be, on average, between 6 hours and 

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

71114.03-05 PROCEDURE COMPLETION

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

procedure have been satisfied. 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. 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.

71114.03-06 REFERENCES

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

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

Capabilities”

END
Issue Date: 07/21/16 Att1-1 71114.03

Attachment 1 - Revision History For IP 71114.03

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 ML061790107

10/25/06

Partial re-write of document structure to add 

objective for explicit review of ERO staffing levels 

for adequacy using NUREG-0654, Table B-1 as 

the standard. Added one Inspection 

Requirement (.02.02.c) sub-section to make oneto-one correlation with Inspection Guidance. 

Added clarification on the review of ERO 

responder training and qualifications.

No

CN 07-026 ML072250458

08/24/07

Clarification in guidance section, for inspector 

verification of timeliness, on ERO staff 

augmentation 

No

N/A ML12095A279

05/29/12

CN 12-008

Revised to reflect the final EP rulemaking with 

regard to alternative facilities and on-shift 

multiple responsibilities (staffing analysis). 

Added guidance on augmentation timing start 

and stop. Editorial changes to §03.01.c and 

§03.02.c to relocate some guidance to be in the 

proper section. Editorial changes to clarify use of 

“weakness” in §03.02.d (weaknesses are 

observed only in drills and exercises). Added 

new §03.06. Other editorial changes for clarity.

Removed “Inspection Bases” in accordance with 

IMC 0040 “Preparing, Revising and Issuing 

Documents for the NRC Inspection Manual” 

formatting expectations.

Provided at 2011 

annual EP 

counterpart 

meeting.

ML12095A296
Issue Date: 07/21/16 Att1-2 71114.03

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 ML15253A855

07/21/16

CN 16-017

03.02.a.1 – Added “for primary and alternate 

facilities” to description of facility activation

Deleted 03.03 step 3 “Determine whether the 

licensee has completed the detailed on-shift 

staffing analysis required by 10 CFR 50 

Appendix E §IV.A.9 by the required 

implementation date of December 24, 2012.”

And deleted 10 CFR 50.54(q)(4) or (q)(5) 

from subsequent “Note” both based on due 

date past. 

Removed Note concerning NSIR’s review 

responsibility for initial detailed ERO on-shift 

staffing analysis

Added note to step 03.01.b.3 describing a 10 

CFR 50.54(q) is required for a change to the 

emergency plan’s OSA.

Incorporated numerous Branch Chief editorial 

comments.

Editorial change – 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)

None Comment Resolution - 

ML15253A738

Feedback Form –

71114.03-1925 

ML15253A731
Issue Date: 07/21/16 Att1-3 71114.03

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)

Added to section 71114.03-05 “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.