NRC INSPECTION MANUAL NSIR

INSPECTION MANUAL CHAPTER 0609, APPENDIX B

EMERGENCY PREPAREDNESS

SIGNIFICANCE DETERMINATION PROCESS

Note: This document is hyperlinked. Hyperlinks are underlined in blue. Ctrl click 

on the link to jump to that location. To jump back to where the hyperlink was, 

press ALT and the left arrow keys
Issue Date: 09/22/15 i 0609, Appendix B

1.0 INTRODUCTION............................................................................................................ 1

2.0 DEFINITIONS, ABBREVIATIONS, AND ACRONYMS ................................................... 1

3.0 ENTRY CONDITIONS AND GENERAL INSTRUCTIONS .............................................. 5

3.1 Entry Conditions .................................................................................................... 5

3.2 General Instructions............................................................................................... 5

4.0 ACTUAL EVENT IMPLEMENTATION ISSUE (FAILURE TO IMPLEMENT)................... 6

4.1 Background ........................................................................................................... 6

4.2 Criteria................................................................................................................... 6

4.3 Significance Determination .................................................................................... 8

5.0 FAILURE TO COMPLY .................................................................................................. 9

5.0.1 Background ........................................................................................................... 9

5.0.2 Criteria..................................................................................................................10

5.0.3 Significance Determination ...................................................................................13

5.1 10 CFR 50.47(b)(1), Emergency Response Responsibility ...................................14

5.2 10 CFR 50.47(b)(2), Onsite Emergency Organization...........................................15

5.3 10 CFR 50.47(b)(3), Emergency Response Support and Resources ....................18

5.4 10 CFR 50.47(b)(4), Emergency Classification System ........................................20

5.5 10 CFR 50.47(b)(5), Emergency Notifications.......................................................26

5.6 10 CFR 50.47(b)(6), Emergency Communications................................................30

5.7 10 CFR 50.47(b)(7), Emergency Public Information..............................................32

5.8 10 CFR 50.47(b)(8), Emergency Facilities and Equipment....................................35

5.9 10 CFR 50.47(b)(9), Emergency Assessment Capability ......................................38

5.10 10 CFR 50.47(b)(10), Emergency Protective Actions............................................40

5.11 10 CFR 50.47(b)(11), Emergency Radiological Exposure Control.........................45

5.12 10 CFR 50.47(b)(12), Emergency Medical Support ..............................................46

5.13 10 CFR 50.47(b)(13), Recovery and Reentry Planning .........................................47

5.14 10 CFR 50.47(b)(14), Drill and Exercise Program.................................................48

5.15 10 CFR 50.47(b)(15), Emergency Responder Training .........................................54

5.16 10 CFR 50.47(b)(16), Emergency Plan Maintenance............................................55

6.0 GUIDANCE ON CORRECTIVE ACTIONS .....................................................................56

6.1 Timeliness Guidelines...........................................................................................56

6.2 Considerations......................................................................................................56

6.3 Effectiveness of Corrective Actions.......................................................................57

FIGURES

Figure 5.4-1 Significance Determination for Ineffective EALs and Overclassification............25

Figure 5.14-1 Significance Determination for Critique Findings ..............................................53

Figure 5.14-2 Significance Determination for Failure to Cireect a Weakness..........................53

TABLES

Table 5.1-1 -- Significance Examples §50.47(b)(1) .................................................................15

Table 5.2-1 -- Significance Examples §50.47(b)(2) .................................................................17

Table 5.3-1 -- Significance Examples §50.47(b)(3) .................................................................19

Table 5.4-1 -- Significance Examples §50.47(b)(4) .................................................................23

Table 5.5-1 -- Significance Examples §50.47(b)(5) .................................................................28

Table 5.6-1 -- Significance Examples §50.47(b)(6) .................................................................31

Table 5.7-1 -- Significance Examples §50.47(b)(7) .................................................................33
Issue Date: 09/22/15 i 0609, Appendix B

Table 5.8-1 -- Significance Examples §50.47(b)(8) .................................................................36

Table 5.9-1 -- Significance Examples §50.47(b)(9) .................................................................39

Table 5.10-1 -- Significance Examples §50.47(b)(10)................................................................42

Table 5.11-1 -- Significance Examples §50.47(b)(11)................................................................45

Table 5.12-1 -- Significance Examples §50.47(b)(12)................................................................46

Table 5.13-1 -- Significance Examples §50.47(b)(13)................................................................47

Table 5.14-1 -- Significance Examples §50.47(b)(14)................................................................51

Table 5.15-1 -- Significance Examples §50.47(b)(15)................................................................54

Table 5.16-1 -- Significance Examples §50.47(b)(16)................................................................55

ATTACHMENTS

Attachment 1 Failure to Implement (Actual Event) Significance Logic .................................Att1-1

Attachment 2 Failure to Comply Significance Logic.............................................................Att2-1

Attachment 3 Revision History for IMC 0609 Appednix B....................................................Att3-1
Issue Date: 09/22/15 1 0609, Appendix B

1.0 INTRODUCTION

The U.S. Nuclear Regulatory Commission’s (NRC’s) Emergency Preparedness Significance 

Determination Process (EP SDP) described in this appendix utilizes risk-informed qualitative 

analyses to estimate the risk significance of inspection findings related to licensee performance 

in meeting EP Cornerstone objectives and performance expectations. Attachment 3, 

“Significance Determination Process Basis Document,” to Appendix B, “Technical Basis for 

Emergency Preparedness Significance Determination Process,” to Inspection Manual 

Chapter 0308, “Reactor Oversight Process (ROP) Basis Document,” provides the technical 

basis for the EP SDP.

2.0 DEFINITIONS, ABBREVIATIONS, AND ACRONYMS1

The following terms, which are capitalized throughout the remainder of this appendix, are 

defined for the purpose of the EP SDP only. The individual section in which each term is 

primarily used provides additional clarification and guidance. The terms are ordered such that 

each definition builds on the preceding definitions. 

a. EMERGENCY PLAN (E–plan): The document, or documents, that the licensee prepares

and maintains that identifies and describes its methods for maintaining emergency 

preparedness (EP) and responding to emergencies.

b. EMERGENCY RESPONSE ORGANIZATION (ERO): The licensee’s organization 

identified in the E–plan for responding to emergencies at the licensee’s facility. The 

ERO includes the on shift staff and the augmentation staff in the designated licensee 

emergency response facilities.

c. PLANNING STANDARD2(PS): One of the 16 EP planning standards established in 

Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b) that the E–plan must 

meet and which are supported by the corresponding sections of Appendix E, 

“Emergency Planning and Preparedness for Production and Utilization Facilities,” to 

10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities.”

d. EP REQUIREMENT: Any requirement within the purview of the EP Cornerstone, 

including the PS, Appendix E to 10 CFR Part 50, 10 CFR 50.54(q), 10 CFR 50.54(t), the 

E–plan, Commission orders, other commitments, and licensee self-imposed

requirements necessary for demonstrating compliance with the PS and Appendix E to 

10 CFR Part 50, and commitments made under 10 CFR 50.47(c) and 

10 CFR 50.54(s)(2)(ii).

 

1

In this document, acronyms may be plural or singular and are to be read in the context of the 

statement in which they appear.

2 As used in this appendix, “PLANNING STANDARD” includes RISK-SIGNIFICANT PLANNING 

STANDARDs, but “RISK-SIGNIFICANT PLANNING STANDARD” excludes non risk-significant 

PLANNING STANDARDs.
Issue Date: 09/22/15 2 0609, Appendix B

e. RISK-SIGNIFICANT PLANNING STANDARD (RSPS): A subset of the PS, which 

includes the following four PS: 10 CFR 50.47(b)(4) — emergency classification system,

(b)(5) — emergency notifications, (b)(9) — emergency assessment capability, or 

(b)(10) — emergency protective actions, and supported by the corresponding sections of 

Appendix E to 10 CFR Part 50. (Note that parts of 10 CFR 50.47(b)(10) are treated as 

not risk significant. See Section 5.10 of this appendix for more information.)

f. PLANNING STANDARD FUNCTION (PSF): One or more functions that are considered 

essential to complying with a RSPS or PS. PSF are identified for assessing the 

significance of a finding that involves noncompliance with a RSPS or PS.

g. PROGRAM ELEMENTS (PE): Items that comprise the implementation aspects of a 

PSF. Such items correspond to the evaluation criteria (e.g., contained in 

NUREG-0654/FEMA-REP-1, “Criteria for Preparation and Evaluation of Radiological 

Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,” or 

the licensee’s E–plan) that provides specific acceptable methods for complying with a 

PS. Note that the failure of a single PE does not always mean that a PSF cannot be 

accomplished.

h. FAILURE TO COMPLY (FTC): A finding that an EP program is noncompliant with a EP

REQUIREMENT. An FTC is associated with preparedness issues, whereas an FTI is 

associated with response issues. Attachment 2 illustrates the significance determination 

logic for an FTC.

i FAILURE TO IMPLEMENT (FTI): A finding of an FTC during an actual radiological 

event that precluded effective implementation of a PE. In this case, the PE complies

with the PS, and the PSF would have been accomplished had it been implemented by 

the ERO. An FTI is associated with response issues, whereas an FTC is associated 

with preparedness issues. Attachment 1 depicts the significance determination logic for 

an FTI. 

j. LOSS OF RSPS [PS] FUNCTION: An FTC finding that one or more PE is not adequate, 

not compliant with the RSPS [PS], or otherwise not functional to such an extent that the 

RSPS [PS] FUNCTION would not be accomplished if an actual radiological emergency 

were to occur. One or more of the following reasons may apply:

 Certain E–plan commitments are not met.

 The E–plan is less than adequate.

 Implementing procedures are not effective.

 ERO personnel are not capable of implementing the PE.

 The EP program design is not fully adequate.

Although licensees must comply with all EP REQUIREMENTS, a LOSS OF RSPS [PS]

FUNCTION will likely have greater significance than a noncompliance with other EP

REQUIREMENTS (e.g., 10 CFR 50.54(t)).
Issue Date: 09/22/15 3 0609, Appendix B

k. DEGRADATION OF RSPS [PS] FUNCTION: An FTC finding that one or more PE is not 

adequate or not compliant with the RSPS [PS], but reasonable assurance exists that the 

RSPS [PS] FUNCTION, although degraded, would be accomplished if an actual

radiological emergency were to occur. One or more of the following reasons may apply: 

Certain E–plan commitments are not met.

 The E–plan is less than adequate.

 Implementing procedures are not effective.

 The EP program design is not fully adequate.

However, diverse or redundant PE, or other circumstances, would allow for the RSPS 

[PS] FUNCTION to still be accomplished, albeit in a degraded manner, if an actual

radiological emergency had occurred. 

l. WEAKNESS: A level of ERO performance demonstrated during an exercise, drill, or

training that provides performance opportunities to develop, maintain, or demonstrate 

key skills that would preclude effective implementation of the E–plan if it were to occur 

during an actual radiological emergency.

1. A WEAKNESS identified by the licensee in its CRITIQUE is not a performance 

deficiency (PD) and is, therefore, neither an FTC nor an FTI.

2. A deficient PE uncovered by the exercise and identified by the licensee in its 

CRITIQUE is a licensee-identified PD and is evaluated as an FTC. If identified by the 

inspector, the deficient PE is an NRC-identified PD and is evaluated as an FTC. 

3. A licensee’s failure to identify a WEAKNESS in a CRITIQUE, or failure to take 

timely corrective actions, is a PD and is evaluated as an FTC with PS 

10 CFR 50.47(b)(14).

m. CRITIQUE: A formal or documented licensee assessment of the ERO performance 

following an exercise, drill, or training that provides performance opportunities to 

develop, maintain, or demonstrate key skills. In a CRITIQUE, which may occur in 

various venues and formats, WEAKNESSES are identified and subsequently entered 

into a corrective action system.

n. FULL-SCALE DRILL OR EXERCISE: An event that tests the integrated capability of the 

ERO to accomplish a major portion of the PSF(s). A FULL-SCALE DRILL OR 

EXERCISE is not limited to the evaluated biennial exercise, but does involve the 

following:

1. participation or simulation of multiple emergency response facilities (ERFs),

2. assessment by a team of evaluators, and,

3. a subset of a “full participation exercise,” as defined in Appendix E to 

10 CFR Part 50.
Issue Date: 09/22/15 4 0609, Appendix B

o. OFFSITE RESPONSE ORGANIZATIONS (OROs): Those entities having responsibility 

for managing the implementation of measures to protect public health and safety within 

the plume exposure pathway, ingestion pathway, and emergency planning zones (EPZs) 

in the event of an emergency. This would typically include State, county, municipal, or 

Tribal emergency management agencies, as applicable. 

p. TIME OF DISCOVERY: The point in time when the licensee “knew or should have 

known” of a condition. See Section 5.0.2.f of this appendix for further discussion.

q. MITIGATING FACTORS: Considerations that an inspector may evaluate in determining 

whether or not a noncompliant PE is a LOST RSPS [PS] FUNCTION or a DEGRADED 

RSPS [PS] FUNCTION. Such factors might include the existence of a redundant 

emergency action level (EAL), backup capabilities identified in the E–plan, or other 

capabilities that allow the inspector to conclude that the PSF could be completed despite 

the inadequate PE. Generally, these factors must have been in place before the TIME 

OF DISCOVERY. These factors are credited only in determining the significance of the 

noncompliance. See Section 5.0.2.b of this appendix for further clarification.

r. COMPENSATORY MEASURES: An interim action taken by a licensee after discovery 

of a noncompliant PE to compensate for an inadequate PE such that there is a 

reasonable expectation that the associated PSF would be accomplished, albeit in a 

degraded manner, should an actual radiological emergency occur before the completion 

of corrective actions to restore compliance. COMPENSATORY MEASURES, which 

must be viable, are credited only in determining the significance of the noncompliance. 

See Section 5.0.2.h of this appendix for further clarification.

In addition to the abbreviations and acronyms identified above, this appendix uses the following 

acronyms and abbreviations:

ANS—alert and notification system

DEP PI—drill and exercise performance (DEP) performance indicator

EAL—emergency action level

EOF—emergency operations facility

EP—emergency preparedness/emergency planning

EP SDP—emergency preparedness significance determination process

EPIP—emergency plan implementing procedure

EPZ—emergency planning zone

ERF—emergency response facility

FEMA—Federal Emergency Management Agency

IC—initiating condition

JIC—joint information center

KI—potassium iodide

OSC—onsite/operations support center

PAR—protective action recommendation

PD—performance deficiency (See IMC0612 for definition)

ROP—reactor oversight process

SDP—significance determination process

TSC—technical support center
Issue Date: 09/22/15 5 0609, Appendix B

3.0 ENTRY CONDITIONS AND GENERAL INSTRUCTIONS

3.1 Entry Conditions

a. An NRC inspector enters this EP SDP for findings related to EP REQUIREMENTS as

directed by Appendix B, “Issue Screening,” of Inspection Manual Chapter 0612, “Power 

Reactor Inspection Reports.” In performing this screening, the inspector should consider 

the guidance in Appendix G, “Emergency Planning Cornerstone-Specific Supplemental 

Guidance for Appendix B Screening Figures 1 and 2,” of IMC 0612. The EP SDP is not

used to assess the significance of a finding under the EP Cornerstone that is caused by 

a finding under a different cornerstone3if the following is true:

 the licensee’s performance would have been compliant if the finding in the other 

cornerstone had not occurred, and,

 if a finding is being issued under the other cornerstone, and the deficiency will be 

corrected. 

If either condition is not met, then the EP SDP is to be used to ensure that corrective action will be 

taken. 

3.2 General Instructions

a. Any finding related to an EP REQUIREMENT will be assessed for significance in 

accordance with this appendix, including findings associated with violations being 

treated under traditional enforcement (TE), if any.

b. If the findings are related to EP REQUIREMENTS that are not associated with a PS (i.e., 

10 CFR 50.54(t) and requirements in Appendix E to 10 CFR Part 50 that do not support 

a PS4), then assign Green significance, and return to IMC 0612.

c. Identify the PSF(s) affected by the finding and assess the significance of each finding. 

1. A finding may affect two or more PSF and each should be assessed for 

significance.

2. Include all associated issues in the inspection report to provide a complete 

record. This can be particularly important when additional information from the licensee 

causes the staff to reconsider a preliminary finding.

d. Assess the significance of each issue of concern associated with a finding (e.g., multiple 

contributing issues). 

 

3 This situation typically occurs when the E–plan relies upon equipment under the control of 

another cornerstone (e.g., an effluent radiation monitor used in the EAL scheme).

4 Sections 5.1 through 5.16 of this SDP, where applicable, identify the requirements of Appendix E 

to 10 CFR Part 50 that support the PS of 10 CFR 50.47(b).
Issue Date: 09/22/15 6 0609, Appendix B

1. If the finding involved an actual radiological emergency (i.e., FTI), go to

Section 4.3 of this appendix to assess the significance of the finding.

2. If the finding was identified during a baseline or a program inspection, or 

identified by the licensee (i.e., FTC), go to Section 5.0.3 of this appendix to assess the 

significance of the finding.

4.0 ACTUAL EVENT IMPLEMENTATION ISSUE (FAILURE TO IMPLEMENT)

4.1 Background

This branch of the EP SDP is used to assess the significance of a finding that occurs during an 

actual radiological emergency (i.e., an FTI). An FTI signifies that a licensee has failed to follow 

its E–plan, which is a noncompliance with 10 CFR 50.54(q)(2). An FTI is associated with an 

emergency response issue, rather than an emergency preparedness issue. 

4.2 Criteria

a. The significance of an FTI is assessed based on (1) the declared emergency 

classification and (2) whether the affected PSF is risk significant or not, as shown in

Attachment 1. 

b. An FTI typically results from a PD on the part of the ERO. However, it is important to 

note that a PD that occurs during an actual radiological emergency may not rise to the 

level of an FTI, particularly if the deficiency is self-identified by the ERO and corrected in 

a timely manner such that the PSF is successfully accomplished. In addition, the failure 

of the ERO to implement a single PE does not always mean that the associated PSF 

was not accomplished. Examples include the following:

 An operations support center (OSC) team was not fully briefed and had to return 

for tools but the assigned task was successfully completed.

 Engineering efforts initially misdiagnosed the accident sequence, but the 

diagnosis was corrected by peer checking.

 A notification form was not peer checked as required by emergency plan 

implementing procedures (EPIPs), but the information was found to be accurate.

c. NRC EP regulations require licensees to have the capability of making classifications, 

declarations, notifications, and initial protective action recommendations (PARs) within 

specific periods of time. Although explicit timeliness requirements are not provided in 

regulation for follow-up PARs or the notification of such PARs, the NRC expects that 

licensees will make follow-up PAR decisions as soon as possible after indications are 
Issue Date: 09/22/15 7 0609, Appendix B

available that a PAR threshold has been exceeded and will notify OROs of such PARs 

as soon as possible.5 

1. Although a failure to meet these timeliness requirements may be a failed 

opportunity under the Drill and Exercise Performance (DEP) Performance Indicator (PI), 

there may be defensible reasons for a delay during an actual radiological emergency if 

the delay has a minimal impact on the EP Cornerstone objective. Emergency 

classifications, declarations, notifications, and PARs that take longer than the specified 

time should be evaluated and a determination made as to whether the delay was 

justifiable. Generally, if the delay was caused by the licensee actively performing 

necessary safety-related actions to protect the public health and safety, and the delays 

did not deny OROs the opportunity to implement actions to protect public health and 

safety, a FINDING would not be issued. Return to IMC 0612 and reconsider the 

determination of a more than minor PD. Each event response must be evaluated on a 

case-by-case basis. 

2. Delays in classification, declaration, notification, or PARs caused by factors that 

were reasonably within the licensee’s ability to foresee and prevent likely represent an

FTC and should also be assessed in accordance with Section 5.0.3 of this appendix.

d. The NRC expects that licensees will make accurate emergency declarations, PAR 

decisions, and notifications. The inspector should evaluate the effects of inaccurate 

declarations, PAR decisions, and notifications against the affected risk-significant PSF to 

determine whether the errors rise to the level of an FTI. For example, although an error 

on a completed notification form (e.g., an erroneous time) may be a failed opportunity

under the DEP PI, a similar error during an actual radiological emergency might have 

little or no impact on ORO response efforts and a finding may not be warranted. Return 

to IMC 0612 and reconsider the determination of a more than minor PD.

e. A PD that occurs in another ROP cornerstone can cause an emergency declaration 

issue. Consider the following examples:

 Shift personnel concluded, based on an erroneous protection signal that a main 

steam line break had occurred when all other plant indications suggested 

otherwise. Given this misdiagnosis, the shift manager declared an Alert based 

on an EAL threshold of “main steam line break,” when no such declaration was 

warranted.

Because of a misinterpretation of a technical specification action statement, a 

plant was not placed in the required mode until 6 hours after the specified

 

5 Section IV.D.3 of Appendix E to 10 CFR Part 50 requires the licensee to have the capability to 

notify State and local governmental agencies within 15 minutes after declaring an emergency. 

PS 10 CFR 50.47(b)(5) requires that the content of initial and follow-up messages to the OROs 

and the public be established. Evaluation Criterion II.E.3 in NUREG-0654/FEMA-REP-1 states 

that the initial notification should contain information as to whether offsite protective measures 

may be necessary. Some licensees have included these criteria in their E–plans or implementing 

procedures.
Issue Date: 09/22/15 8 0609, Appendix B

completion time. An EAL required a Notification of Unusual Event (NOUE)

declaration (e.g., inability to reach required shutdown within technical 

specification limits). In this case, no declaration was made, as the mistaken 

interpretation was not recognized until after the plant entered the required mode. 

In both of these examples, the emergency classification would have likely been correct if 

the performance in the other cornerstone had been adequate. As such, the issue of 

concern needs to be evaluated under that cornerstone, rather than the EP Cornerstone, 

if a finding will be issued under the other cornerstone. Otherwise, the PD should be 

treated as an FTI and assessed for significance under Section 4.3 of this appendix.

f. Since the significance of a finding identified during actual radiological emergencies is 

based, in part, on the emergency classification level, an inaccurate declaration could 

affect the significance determination. The appropriate emergency classification level is 

to be used in Attachment 1 for assessing the significance of the finding, including the 

10 CFR 50.47(b)(4) finding for the misclassification itself. 

1. The missed or delayed declaration may have caused another ERO PD to occur 

(e.g., the declaration of an NOUE instead of an Alert would have prevented timely 

augmentation of the on shift staff.) In these cases, the inspection report should identify 

the associated issues, but only the 10 CFR 50.47(b)(4) finding would be identified as an

FTI and assessed for significance under Section 4.3 of this appendix.

2. However, if the additional PD was caused or exacerbated by factors other than 

the delayed or missed classification, an additional finding may be appropriate (e.g., the 

licensee failed to notify the NRC of the missed declaration within 1 hour of identification.) 

4.3 Significance Determination

a. Identify the EP REQUIREMENT affected by the finding.

b. Determine whether the finding is an FTI.

1. If the finding did not involve a failure to implement a PS or RSPS, an FTI is not 

warranted. Return to IMC 0612 and reconsider the determination of a more than minor 

PD.

2. An FTI is analogous to a LOST RSPS [PS] FUNCTION, examples of which are

provided in Section 5.0 of this appendix. Those examples, while applicable only to an

FTC, may be useful in informing the FTI determination.

3. A finding that did not rise to the level of an FTI should be identified to the 

licensee as an opportunity for improvement. Return to IMC 0612 and reconsider the 

determination of a more than minor PD.
Issue Date: 09/22/15 9 0609, Appendix B

c. Identify the emergency classification declared by the licensee and evaluate its 

appropriateness. If the classification was appropriate or under classified, proceed to 

Step 4.3.e below.

d. If the licensee over classified the actual event, then assess the significance of the 

10 CFR 50.47(b)(4) finding as follows and continue with Step 4.3.f:

1. The minimum significance level for a misclassification during an actual

radiological emergency is Green.

2. If public officials implemented protective actions other than evacuation (e.g., 

sheltering, early closure of schools) for members of the public,

6

then the significance 

level is White. 

3. If public officials implemented an evacuation of the general public,

6

then the 

significance level is Yellow.

e. Assess the significance of the FTI using Attachment 1 and the appropriate emergency 

classification level that was or should have been declared.

f. If the cause of the finding was one or more noncompliant PE (e.g., procedure or training 

shortcomings), also evaluate the finding as an FTC under Section 5.0.3 of this appendix. 

If this results in a higher significance, treat the finding as an FTC.

g. Return to IMC 0612 to document the basis for the significance determination in the 

inspection report. 

5.0 FAILURE TO COMPLY

5.0.1 Background

a. This branch of the EP SDP, illustrated in Attachment 2, is used to assess the 

significance of an FTC. An FTC signifies that an EP program is noncompliant with an

EP REQUIREMENT.

1. An FTC is generally identified during normal program inspection activities and is

related to an emergency preparedness issue, rather than an emergency response issue. 

2. However, a finding of an FTI during an actual emergency event may uncover an 

inadequate or noncompliant PE (e.g., procedure or training shortcomings), the 

significance of which should also be assessed under this branch of the EP SDP, with the 

higher significance finding cited.

 

6

If the ORO response was clearly inappropriate for the conditions present (e.g., ordering an 

evacuation of the EPZ upon receiving notification of an Alert emergency), assign Green 

significance.
Issue Date: 09/22/15 10 0609, Appendix B

b. Sections 5.1 through 5.16 of the appendix correspond respectively to PS 

10 CFR 50.47(b)(1) through (b)(16). Each section does the following:

 Identifies the PS and the associated PSF(s).Identifies references to supporting 

requirements in Appendix E to 10 CFR Part 50 and the informing criteria of 

NUREG-0654/FEMA-REP-1.

 Provides examples of finding(s) corresponding to, as appropriate, LOSS OF 

RSPS [PS] FUNCTION, DEGRADED RSPS [PS] FUNCTION, and Green finding.

c. The significance examples are neither all inclusive nor exclusive; instead, the examples 

are intended to inform significance determinations. These examples may or may not 

fully envelop the finding being considered. If no significance example envelops the 

finding being considered, it will be necessary to compare the finding against the 

definitions of LOSS OF RSPS [PS] FUNCTION, or DEGRADED RSPS [PS] FUNCTION

in conjunction with Attachment 2.

5.0.2 Criteria

a. Multiple PE may comprise the implementation aspects of each PS. These PE are 

developed from the PS, the supporting requirements in Appendix E to 10 CFR Part 50, 

the evaluation criteria guidance in NUREG-0654/FEMA-REP-1, and commitments made 

in the approved E–plan. PS functionality does not require compliance with every PE. 

An FTC with one or even a few inadequate PE is not necessarily a LOSS OF RSPS [PS] 

FUNCTION. Consequently, the inspector must determine whether the PSF could be 

accomplished in spite of the inadequate PE. 

b. There may be circumstances in which the PE is found to be noncompliant but, because 

of mitigating factors, the inspector is able to determine that reasonable assurance exists 

that the PSF would be accomplished, albeit in a degraded manner, if an actual

radiological emergency were to occur. In such cases, the PSF would be degraded 

rather than lost.

1. For example, an initiating condition that addresses a radioactive release contains 

two EALs: an indication on an effluent radiation monitor or a certain result from an 

analysis on a sample obtained from the effluent release stream. The licensee 

determined that the radiation monitor indication was in error — a noncompliance. 

Although the sample analysis results could provide a basis for an emergency 

declaration, there would be a delay in identifying and classifying an abnormal release. In 

this case, the PSF may be found to be degraded rather than lost.

2. To be considered in significance determinations, mitigating factors must have 

already been in place before the TIME OF DISCOVERY. Section 5.0.2.h. of this 

appendix addresses measures implemented by the licensee to compensate after 

identification of the noncompliance.

c. Several significance examples address unavailability issues related to equipment and 

facilities. These examples are intended to encompass equipment, systems, and 
Issue Date: 09/22/15 11 0609, Appendix B

facilities specifically identified in the E–plan, or relied upon by the E–plan, as PE. Some

of these resources may serve other functions in the plant design or operations. 

However, only the functions specifically identified in the E–plan should be considered 

when assessing the significance of the finding. For example, an effluent radiation 

monitor skid may include several monitor channels of which only one is used in an EAL

threshold. Only a finding with that channel would be assessed significance under this 

EP SDP.

d. Time limits and percentages are provided to inject objectivity and thus consistency to the 

assessment process. These values should be used for any applicable finding in the 

absence of extenuating circumstances for which the predetermined criteria need to be 

reconsidered. In those rare cases, a different characterization of the finding could be 

appropriate so long as the basis for the deviation is justified and agreed to by the SDP 

and Enforcement Review Panel.

e. NRC EP regulations require licensees to have the capability of making classifications, 

declarations, notifications, and initial PARs within specific periods of time. Licensees 

establish these capabilities by providing sufficient personnel, procedures, equipment, 

training, instrumentation, and other resources necessary to perform the functions in a 

timely and accurate manner. A finding may exist if there is an issue of concern

regarding the licensee’s capability to make timely declarations, notifications, or PARs, 

should an actual radiological emergency occur. Consider the following examples:

 The licensee no longer has the personnel on shift to evaluate a seismic reading 

used in the EAL scheme.

 The licensee’s dose assessment capability no longer supports PAR 

development.

 The licensee’s EAL scheme allows an indeterminate delay in classifying a fire to 

await verification of a fire alarm.

Although explicit timeliness requirements are not provided in regulation for follow-up

PARs or the notification of such PARs, the NRC expects that licensees will make followup PAR decisions as soon as possible after indications are available that a PAR 

threshold has been exceeded and will notify OROs of such PARs as soon as possible.7

f. Many of the significance examples incorporate the concept of TIME OF DISCOVERY. It 

should be assumed that the condition occurred at this time including, as necessary, 

timely confirmation or analysis of raw indications (i.e., when the licensee “knew”).

 

7 Section IV.D.3 of Appendix E to 10 CFR Part 50 requires the licensee to have the capability to 

notify State and local governmental agencies within 15 minutes after declaring an emergency. 

PS 10 CFR 50.47(b)(5) requires that the content of initial and follow up messages to the public be 

established. Evaluation Criterion II.E.3 in NUREG-0654/FEMA-REP-1 provides that the initial 

notification contain information as to whether offsite protective measures may be necessary. 

Some licensees have included these criteria in their E–plans or implementing procedures.
Issue Date: 09/22/15 12 0609, Appendix B

1. If a condition existed before it was discovered and it can be shown that the 

licensee missed an earlier opportunity to recognize the condition, the TIME OF 

DISCOVERY is the first missed opportunity (i.e., when the licensee “should have 

known”). A missed opportunity occurs when the activity failed to identify a condition or 

when corrective actions were not implemented upon identification.

2. Opportunities to identify conditions and initiate corrective actions may include 

normal surveillances, log reviews, self-assessments, audits, quality assurance activities, 

NRC generic communications, industry operating experience reports, condition reports, 

and inspection reports.

3. Consideration should be given to the opportunities for identification; the ease of 

discovery; specificity, relevance, and timing of a prior notification; and action(s) taken by 

the licensee.

g. A finding related to licensee identification of a PD that occurred in the past (normally 

older than 3 years) in engineering, design, or installation that is not reasonably linked to

the licensee’s present performance may be a candidate for enforcement discretion. See 

IMC0305 11.05 for complete details. Examples of such findings for the EP Cornerstone 

could be miscalculated EAL thresholds for installed radiation monitors or deficiencies in 

emergency response facility design.

h. Some of the significance examples explicitly provide credit for viable measures that 

compensate for the inadequate PE. Many of these significance examples also specify 

duration for the condition, for example “...longer than 7 days from TIME OF DISCOVERY 

and no COMPENSATORY MEASURES were implemented.”8 The following criteria 

should be considered before crediting a COMPENSATORY MEASURE in a significance 

determination:

1. The measure must be capable of accomplishing the affected PSF in a 

reasonably comparable manner. For example, a company microwave link may be a 

viable COMPENSATORY MEASURE for a failure of a private telephone bridge if all 

OROs can still be notified without significant delay. However, “comparable” does not 

require the COMPENSATORY MEASURES to meet the same performance 

requirements as the primary method.

2. The measure must be in place before the end of the specified duration. If no 

duration is specified, the measure must have been implemented in a timely manner 

following discovery.

3. The specified duration is measured from the TIME OF DISCOVERY. If the 

condition is first identified by the inspector, it will be necessary to assess when the 

licensee should have known of the condition in determining the COMPENSATORY 

MEASURE credit.

 

8

If the licensee did implement COMPENSATORY MEASURES that met the guidance of this 

section, within the specified duration, the example threshold has not been exceeded.
Issue Date: 09/22/15 13 0609, Appendix B

4. The inspector should determine the following:

 The measure was addressed in procedures, night orders, or the like, and 

ERO members were made aware of the measure.

 ERO personnel expected to implement the measure have received 

training (unless the measure reasonably falls within the definition of “skill 

of the craft”).

 The necessary equipment and personnel were readily available to 

implement the measure.

 The licensee is placing an appropriate priority on completing corrective 

actions.

5. A COMPENSATORY MEASURE is used only in assessing significance; as such,

a measure generally cannot be used to show compliance.

6. See Section 5.5 of this appendix for additional criteria for COMPENSATORY 

MEASURES for ANS outages.

7. The EP SDP allows COMPENSATORY MEASURES to continue to be used in 

certain situations in which the noncompliant PE was caused by major disruptive events 

(e.g., hurricanes, fires, explosions, loss of offsite power) or are the result of a planned 

outage of certain systems or facilities. The EP SDP recognizes that there may be delays 

in implementing corrective actions that are not completely under the control of the 

licensee. In these situations, such measures continue to be acceptable as long as the 

licensee implements the corrective actions with appropriate priority. The significance 

examples to which this provision applies are annotated to this effect.

5.0.3 Significance Determination

a. If the finding is related to EP REQUIREMENTS that are not associated with a PSF (e.g., 

10 CFR 50.54(q),10 CFR 50.54(t), and requirements in Appendix E to 10 CFR Part 50

that do not support a PSF), assign Green significance. Return to IMC 0612.

b. Identify the PSF(s) 9 affected by the finding. A finding may affect two or more PSF and 

each should be assessed for significance.

c. Compare the identified finding to the examples tabulated in the appropriate section, and 

if needed, Attachment 2, to identify the significance. The language of the PSF is 

generally broad and the determination of the significance of a finding may not always be 

obvious.

 

9 Sections 5.1 through 5.16, as applicable, of this EP SDP identify the requirements of Appendix E 

to 10 CFR Part 50 that support the PS of 10 CFR 50.47(b).
Issue Date: 09/22/15 14 0609, Appendix B

1. The examples provided for each PSF are not intended to be all-inclusive or all

exclusive.

2. More than one PE may be associated with the PSF, and varied facility-specific 

methods of implementation and a particular finding may not correspond directly to any 

particular example provided.

3. Extenuating circumstances may need to be considered.

4. In making the significance determination, the analyst will need to use judgment, 

informed by the examples that are provided. The cited supporting requirements and 

informing criteria should be considered as necessary. Reviewing previous inspection 

reports for a similar finding, where available, can provide additional insight. 

d. Return to IMC 0612 to document the basis for the significance determination in the 

inspection report.

5.1 10 CFR 50.47(b)(1), Emergency Response Responsibility

PLANNING STANDARD: Primary responsibilities for emergency response by the nuclear 

facility licensee and by State and local organizations within the 

Emergency Planning Zones have been assigned, the emergency 

responsibilities of the various supporting organizations have been 

specifically established, and each principal response organization 

has staff to respond and to augment its initial response on a 

continuous basis.

PS FUNCTIONS: 1. Responsibility for emergency response is assigned.

2. The response organization has the staff to respond and 

augment on a continuing basis (24/7 staffing) in accordance 

with the E–plan.

Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.A.1 through IV.A.8
Issue Date: 09/22/15 15 0609, Appendix B

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.A, and the licensee’s 

approved E–plan

Table 5.1-1

Significance Examples for 

10 CFR 50.47(b)(1)

LOSS OF PS FUNCTION:

White Finding

The ERO assigned responsibilities in the E–plan no longer 

has the authority or resources to respond on a continuing 

(24/7) basis.

DEGRAD. OF PS FUNC.

Green Finding:

An individual plant staffing change created an inability to 

assign responsibility on a continuous basis.

Additional Guidance: None

5.2 10 CFR 50.47(b)(2), Onsite Emergency Organization

PLANNING STANDARD: On-shift facility licensee responsibilities for emergency response 

are unambiguously defined, adequate staffing to provide initial 

facility accident response in key functional areas is maintained at 

all times, timely augmentation of response capabilities is available,

and the interfaces among various onsite response activities and 

offsite support and response activities are specified.

PS FUNCTIONS: 1. Process ensures that on shift emergency response 

responsibilities are staffed and assigned.

2. Process for timely augmentation of on shift staff is established 

and maintained.

Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.A.2.a, b, c; IV.A.3; 

IV.A.9; and IV.C

Informing Criteria: NUREG-0654, Section II.B and the licensee’s approved E–plan

Significance Examples

See Table 5.2.1

Additional Guidance:

EPPOS-3, “Emergency Preparedness Position (EPPOS) on Requirement for Onshift Dose 

Assessment Capability,” dated November 8, 1995 [ML023040473]
Issue Date: 09/22/15 16 0609, Appendix B

Nuclear Energy Institute (NEI) 99-02, “Regulatory Assessment Performance Indicator 

Guideline,” Revision 6, [ML092931123], identifies key ERO members.

NSIR/DPR-ISG-001, “Emergency Planning for Nuclear Power Plants” [ML113010523]

Information Notice (IN) 93-81, “Implementation of Engineering Expertise on Shift,” dated 

October 12, 1993, http://www.nrc.gov/reading-rm/doc-collections/#gen 
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS OF PS FUNCTIONWhite Finding

DEGRADED PS FUNCTION

Green Finding

(b)(2)

Process ensures that on shift

emergency response responsibilities are 

staffed and assigned.

Process for timely augmentation of on 

shift staff is established and maintained.

N/A

 

An EP responsibility for any key ERO 

member function is not assigned.

ERO staffing levels are less than the 

staffing levels provided for by the 

licensee’s on shift staffing analysis to 

the extent that more than one required 

ERO functional area (in accordance with 

E–plan commitments) would not be 

staffed.

Scheduling and/or processes (not 

personnel error) for on shift staffing 

would allow two or more shifts to go 

below E–plan minimum staffing 

requirements within 30 days (e.g., 2 of 4 

weekends in a month, 2 or more 

backshifts over a 30-day period).

–––

Staffing augmentation processes are 

routinely not capable of ensuring timely 

augmentation of the on shift emergency 

response staff to the extent that more 

than one required ERO functional area 

(in accordance with E–plan 

commitments) would not be filled (e.g., 

repetitive activation test failures or 

augmentation process design 

inadequacies).

 

Failure to recognize loss of minimum 

ERO staffing for more than a short 

duration (e.g., 2 hours) on two or more 

shifts in a 30-day period. 

Staffing processes would permit a shift 

to go below E–plan minimum staffing 

requirements, but there were no actual 

instances in which such shortages 

occurred.

(b)(2)

Table 5.2-1 -- Significance Examples §50.47(b)(2)

Issue Date: 09/22/15 17 0609, Appendix B 
Issue Date: 09/22/15 18 0609, Appendix. B

5.3 10 CFR 50.47(b)(3), Emergency Response Support and Resources

PLANNING STANDARD: Arrangements for requesting and effectively using assistance 

resources have been made, arrangements to accommodate State 

and local staff at the licensee's Emergency Operations Facility 

have been made, and other organizations capable of augmenting 

the planned response have been identified.

PS FUNCTIONS: 1. Arrangements for requesting and using offsite assistance have 

been made. 

2. State and local staff can be accommodated at the EOF in 

accordance with the E–plan. 

Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.A.6 and IV.A.7

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.C, and the licensee’s 

approved E–plan

Significance Examples

See Table 5.3-1

Additional Guidance: None
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS OF PS FUNCTIONWhite Finding

DEGRADED PS FUNCTION

Green Finding

(b)(3)

Arrangements for requesting and using 

offsite assistance have been made. 

State and local staff can be 

accommodated at the EOF in 

accordance with the E–plan. 

N/A

 

E–plan commitments for offsite 

assistance would no longer be met for 

medical, fire, or law enforcement 

support, including assistance for 

response to hostile actions.

–––

The EOF has been changed in such a 

manner that it would no longer 

accommodate OROs in accordance with 

the E–plan.*

* Some E–plans accommodate OROs 

through means other than the physical 

presence of personnel in the EOF (e.g., 

video teleconferencing).

 

E–plan elements have degraded to the 

point that E–plan commitments for offsite 

assistance would no longer be met for 

support other than medical, fire, or law 

enforcement support, including 

assistance for response to hostile 

actions.

Agreements with organizations 

committed in the E–plan as supporting 

the response effort have been allowed to 

lapse and are currently not being sought, 

but the agency remains willing to support 

the E–plan. 

(b)(3)

Table 5.3-1 -- Significance Examples §50.47(b)(3)

Issue Date: 09/22/15 19 0609, Appendix B
Issue Date: 09/22/15 20 0609, Appendix B

5.4 10 CFR 50.47(b)(4), Emergency Classification System

PLANNING STANDARD: A standard emergency classification and action level scheme, the 

bases of which include facility system and effluent parameters, is 

in use by the nuclear facility licensee, and State and local 

response plans call for reliance on information provided by facility 

licensees for determinations of minimum initial offsite response 

measures.

RSPS FUNCTION: A standard scheme of emergency classification and action levels 

is in use. 

Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.B and IV.C

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.D, and the licensee’s 

approved E–plan

The NRC has endorsed standard emergency classifications and 

action level schemes in Regulatory Guide 1.101, “Emergency 

Planning and Preparedness for Nuclear Reactors,” as being 

acceptable alternatives for demonstrating compliance with this 

RSPS FUNCTION. Additionally, the NRC has allowed certain 

modifications to the classification schemes as outlined in 

EPPOS-1, “Acceptable Deviations from Appendix 1 of NUREG0654 Based Upon the Staff's Regulatory Analysis of 

NUMARC/NESP-007, ‘Methodology for Development of 

Emergency Action Levels’” dated June 1, 1995.

Significance Examples

See Table 5.4-1 and

Figure 5.4-1

Additional Guidance:

NSIR/DPR-ISG-001, “Emergency Planning for Nuclear Power Plants” [ML113010523]

IN 1989-72, “Failure of Licensed Senior Operators to Classify Emergency Events Properly,” 

dated October 24, 1989, http://www.nrc.gov/reading-rm/doc-collections/#gen

IN 2005-19, “Effect of Plant Configuration Changes on the Emergency Plan,” dated July 18, 

2005, http://www.nrc.gov/reading-rm/doc-collections/#gen

Regulatory Issue Summary (RIS) 2003-18, “Use of NEI 99-01, ‘Methodology for Development of 

Emergency Action Levels,’ Revision 4, Dated January 2003,” dated October 8, 2003, 

http://www.nrc.gov/reading-rm/doc-collections/#gen
Issue Date: 09/22/15 21 0609, Appendix B

RIS 2003-18, Supplement 1, “Use of NEI 99-01, ‘Methodology for Development of Emergency 

Action Levels,’ Revision 4, Dated January 2003,” dated July 13, 2003, 

http://www.nrc.gov/reading-rm/doc-collections/#gen

EAL schemes typically have a series of initiating conditions (IC), which represent the condition 

being classified and, for each IC, one or more EALs, which represent indications that the IC may 

be exceeded. As used herein, an EAL is ineffective when it no longer results in a timely and 

accurate declaration for the IC. A particular EAL may be a single indication or may include a list 

of redundant instrument channels. In either case, it is treated as a single EAL for significance 

purposes.

The significance examples differ by the licensee’s ability to make the proper emergency 

declaration even with the ineffective EAL. An EAL may be rendered ineffective by changes to 

facility procedures, systems, or equipment; errors in numeric thresholds; or any other cause that 

could result in an IC, which should be declared, not being declared in a timely and accurate 

manner following the change(s). These ineffective EAL examples do not apply to instruments 

that are temporarily out of service if timely corrective actions are being taken to restore the 

instrument(s).

EAL schemes often have either redundant or diverse indications for the same IC. Credit is to be 

given to these alternative EALs as MITIGATING FACTORS if they were part of the licensee’s 

approved emergency classification scheme before the ineffective EAL was identified. Other ICs 

generally may not be credited as MITIGATING FACTORS. One of the following two 

significance situations may exist:

(1) If the alternative EALs are such that an accurate declaration of the IC would still be 

made, but delayed beyond the 15-minute timeliness capability requirement, the 

classification function is degraded. An example would be waiting on an analysis of a 

grab sample in lieu of observing a reading on a direct-indicating instrument.

(2) If the alternative EALs are such that an accurate and timely declaration of the IC would 

still be made, the classification function is neither lost nor degraded. In this context, 

timely means within the 15-minute timeliness capability requirement. For example, loss 

or potential loss of the fuel barrier IC may include EALs such as reactor pressure vessel 

(RPV) level and drywell radiation monitor. A decreased RPV level is a precursor to core 

damage and can adequately compensate for an ineffective drywell radiation monitor 

threshold because the declaration will still be timely and accurate. However, a 

classification based on drywell radiation monitor threshold rather than an ineffective RPV 

level would likely be delayed (as the core damage must first occur for the radiation 

monitor to indicate).

The NRC expects declarations to be timely and accurate (See Section 5.0.2 of this EP SDP). 

Unnecessary public protective actions caused by an overclassification are a concern since the 

public could be placed at increased health risks without realizing the dose avoidance benefit of 

a necessary protective action. The NRC encourages conservative decisionmaking in uncertain 

events. However, the licensee’s emergency classification process should, to the extent 

possible, support timely and accurate declarations should an emergency occur. A deficient 

emergency classification process that would result in an overclassification and cause the 
Issue Date: 09/22/15 22 0609, Appendix B

licensee to make a protective action recommendation, or cause OROs to implement protective 

actions (e.g., a nondiscretionary precautionary evacuation of schools on a Site Area 

Emergency) by procedure, should be identified as a DEGRADATION OF RSPS FUNCTION. A 

deficient emergency classification process that would result in an overclassification, but would 

not result in unnecessary public protective measures, should be identified as a Green finding.

See NSIR/DPR-ISG-001 for guidance on the timeliness criteria, including when the “clock” starts 

and stops for classification and declaration.
PLANNING STANDARD

FUNCTION(s)

LOSS of RSPS FUNCTION 

Yellow Finding

Yellow Finding

DEGRADED RSPS FUNCTION

White Finding Green Finding

(b)(4)

A standard scheme of emergency 

classification and action levels is in use. 

Continued

 

An EAL has been rendered ineffective 

such that any General Emergency would 

not be declared for a particular 

off-normal event.

 

An EAL has been rendered ineffective 

such that any General Emergency would 

not be declared for a particular 

off-normal event, but because of other 

EALs, an appropriate declaration could 

be made in a degraded manner (e.g., 

delayed).

An EAL has been rendered ineffective 

such that any Site Area Emergency 

would not be declared for a particular 

off-normal event.

The EAL classification process* is not 

capable of classifying a General 

Emergency or a Site Area Emergency 

within 15 minutes or declaring the 

emergency promptly once the 

appropriate classification level is 

determined.

 

An EAL has been rendered ineffective 

such that any General Emergency would 

not be declared for a particular 

off-normal event, but because of other 

EALs, an appropriate declaration could 

be made in an accurate and timely 

manner.

An EAL has been rendered ineffective 

such that any Site Area Emergency 

would not be declared for a particular 

off-normal event, but because of other 

EALs, an appropriate declaration could 

be made in a degraded manner (e.g., 

delayed).

An EAL has been rendered ineffective 

such that any Alert or NOUE would not 

be declared, or declared in a degraded 

manner for a particular off-normal event.

The EAL classification process* is not 

capable of classifying an Alert or NOUE 

within 15 minutes or declaring the 

emergency promptly once the 

appropriate classification level is 

determined.

*EAL classification process includes 

facility procedures; training; ERO 

staffing; system, instrumentation, or 

equipment; or other resources or 

capabilities necessary to complete a 

classification or declaration.

(b)(4)

Table 5.4-1 -- Significance Examples §50.47(b)(4)

Issue Date: 09/22/15 23 0609, Appendix B
PLANNING STANDARD

FUNCTION(s)

LOSS of RSPS FUNCTION 

Yellow Finding

Yellow Finding 

DEGRADED RSPS FUNCTION

White Finding Green Finding

(b)(4) Continued

A standard scheme of emergency 

classification and action levels is in use. 

 

The EAL classification process* would 

result in an over classification that would 

lead to OROs implementing, by 

procedure (i.e., a non-discretionary 

action), unnecessary protective actions 

for the public. (In making this 

determination, consider only those 

public protective actions that would be 

triggered by an ORO receiving 

notification of a particular emergency 

classification (e.g., “when the plant 

reports this then do this”). This condition 

should also be considered met if the 

licensee would make a PAR to the 

OROs because of the 

overclassification.)

*EAL classification process includes 

facility procedures; training; ERO 

staffing; system, instrumentation, or 

equipment; or other resources or 

capabilities necessary to complete a 

classification or declaration.

 

The EAL classification process* would 

result in an over-classification causing 

an unnecessary emergency declaration.

Annual EAL review is not conducted with 

State and local governmental authorities.

 

(b)(4) 

Table 5.4-1 (Continued) -- Significance Examples §50.47(b)(4)

Issue Date: 09/22/15 24 0609, Appendix B
Issue Date: 09/22/15 25 0609, Appendix. B

Figure 5.4-1

Significance Determination for Ineffective EALs and Overclassification

EAL Deficiency Classification Level Impact of Deficient EAL

Yellow Event would not be declared

White Event would be declared in a degraded manner 1

Green Event would be declared in a timely and accurate manner 1

White Event would not be declared

Green Event would be declared in a degraded manner 1

No Finding Event would be declared in a timely and accurate manner 4

1

General Emergency

Site Area Emergency

Green Event would not be declared

Green Event would be declared in a degraded manner 1

No Finding Event would be declared in a timely and accurate manner 4

1

NOUE or Alert

Ineffective EAL 2

Would result in unnecessary PARs for the public White

3

Would result in unnecessary classification Green EAL Overclassification

EAL Issue

Finding

1 Emergency condition would be declared because of unaffected redundant or diverse EAL thresholds.

2 An EAL is ineffective when it, in of itself, no longer results in a timely and accurate declaration for the initiating condition.

3

In making this determination, consider only those public protective actions that would be triggered by an ORO receiving notification of 

a particular emergency classification (e.g., an invalid General Emergency declaration). This significance logic does not apply to over 

classifications during an actual event.

4. Return to IMC 0612 and reconsider the more-than-minor determination.
Issue Date: 09/22/15 26 0609, Appendix. B

Significance Examples

See Table 5.5-1

Additional Guidance:

The significance examples provide for COMPENSATORY MEASURES as means of mitigating 

the significance of certain finding(s). See Section 5.0.2.h. of this appendix for additional 

guidance.

IN 2002-25, “Challenges to Licensee’s Ability to Provide Prompt Public Notification and 

Information During an Emergency Preparedness Event,” dated August 26, 2002, 

http://www.nrc.gov/reading-rm/doc-collections/#gen

5.5 10 CFR 50.47(b)(5), Emergency Notifications

PLANNING STANDARD: Procedures have been established for notification, by the licensee, 

of State and local response organizations and for notification of 

emergency personnel by all organizations; the content of initial 

and follow-up messages to response organizations and the public 

has been established; and means to provide early notification and 

clear instruction to the populace within the plume exposure 

pathway Emergency Planning Zone have been established.

RSPS FUNCTIONS: 1. Procedures for notification of State and local governmental 

agencies are capable of alerting them of the declared 

emergency within 15 minutes after declaration of an 

emergency and providing subsequent follow-up notifications.

2. Administrative and physical means have been established for 

alerting and providing prompt instructions to the public within 

the plume exposure pathway.

3. The public alert and notification system meets the design 

requirements of FEMA-REP-10, “Guide for Evaluation of Alert 

and Notification Systems for Nuclear Power Plants,” or 

complies with the FEMA approved ANS design report and 

supporting FEMA approval letter.

Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.D.1 and IV.D.3

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.E and Appendix 3, and the 

licensee’s approved E–plan

Additional criteria integral to this RSPS FUNCTION is found in 

FEMA REP-10.
Issue Date: 09/22/15 27 0609, Appendix. B

IN 2005-06, “Failure to Maintain Alert and Notification System Tone Alert Radio Capability,” 

dated March 30, 2005, http://www.nrc.gov/reading-rm/doc-collections/#gen

In the notification significance examples, the scope of OROs is limited to those agencies that 

the licensee must directly notify of an emergency as described in the E–plan. This would

typically include State, county, municipal, and Tribal emergency management agencies, but 

may include others that are notified by the licensee within 15-minutes of an emergency 

declaration.

Section IV.D.3 of Appendix E to 10 CFR Part 50 requires the licensee to demonstrate that the 

primary and backup ANS administrative and physical means of alerting the public have been 

established. The NRC uses the FEMA-approved final ANS design report as evidence that the 

means have been established. The following applies:

 Since the final ANS design report is approved by FEMA, licensee-proposed measures to 

compensate for ANS outages or failures must meet the criteria in Section 5.0.2.h, and be 

reviewed by FEMA for acceptability, before being credited in determining significance. 

The Office of Nuclear Security and Incident Response/Division of Preparedness and 

Response (NSIR/DPR) staff will refer the issue to FEMA Headquarters for additional 

input. 

 FEMA must approve substantive changes to the ANS, hardware, testing, and 

maintenance under 44 CFR 350, “Review and Approval of State and Local Radiological 

Emergency Plans and Preparedness.” A review under 10 CFR 50.54(q)(3) is not 

sufficient.

 FEMA evaluation of licensee deviations from the FEMA-approved final ANS design 

report (e.g., licensee fails to perform maintenance described in the design report) will be 

obtained before citing a finding related to these deviations. The NSIR/DPR staff will 

refer the issue to FEMA Headquarters for its input. Subsequent enforcement will 

depend on the input received from FEMA.

An approved prearranged backup method of notification, described in the FEMA approved ANS 

design report that meets the performance requirements described in Section IV.D.3 of Appendix 

E to 10 CFR Part 50 for the primary notification means may be credited for determining 

compliance. Otherwise, the prearranged backup method can serve as a COMPENSATORY 

MEASURE only for determining significance. Primary ANS outages caused by planned 

maintenance and testing as identified in the FEMA-approved ANS Design Report are generally 

not FTCs.

There is an extensive record of case law related to intervener contentions regarding the 

requirements in 10 CFR 50.47(b)(5) or Section IV.D of Appendix E to 10 CFR Part 50 

particularly, the “...about 15-minute...” performance criteria. In general, such rulings have 

precedence only for the contested docket, but may be useful in informing staff decisions. 

Assistance should be sought from NRC counsel. Some significant rulings include the following: 

Generic CLI-80-40, 12 NRC 636; Indian Point 18 NRC 811, 18 NRC 939 San Onofre 15 NRC 

1163, 17 NRC 346, 17 NRC 528; Seabrook 29 NRC 527, 31 NRC 213, 32 NRC 57; Shearon 

Harris 23 NRC 294, 24 NRC 532; Shoreham 21 NRC 644, 27 NRC 85, 28 NRC 275, 28 NRC 

603; Vermont Yankee CLI-74-40, 8 AEC 809
PLANNING STANDARD

FUNCTION(s)

LOSS of RSPS FUNCTION 

Yellow Finding

Yellow Finding

DEGRADED RSPS FUNCTION

White Finding Green Finding

(b)(5)

Procedures for notification of State and 

local governmental agencies are 

capable of alerting them of the declared 

emergency within 15 minutes after 

declaration of an emergency and 

providing subsequent follow-up 

notifications.

Administrative and physical means have 

been established for alerting and 

providing prompt instructions to the 

public within the plume exposure 

pathway

The public ANS meets the design 

requirements of FEMA-REP-10 or 

complies with the FEMA approved ANS 

design report and supporting FEMA 

approval letter.

Continued

 

The notification process (e.g., 

procedures, systems, and resources) is 

not capable of alerting ANY responsible 

ORO of the declared emergency within 

15 minutes after declaring an 

emergency.

–––

Loss of both the primary and backup 

methods of alerting the populations 

within 0–5 miles of the plant.

–––

Deficiencies in the licensee’s program for 

performing ANS testing and 

maintenance results in a major loss of 

the system for a significant period from 

the TIME OF DISCOVERY (e.g., 100% 

over 35 days, greater than 80% over 45 

days, greater than 40% over 90 days, 

greater than 20% over 6 months). 

 

The notification process (e.g., 

procedures, systems, and resources) is 

not capable of alerting ALL responsible 

OROs of the declared emergency within 

15 minutes after declaring an 

emergency.

–––

Loss of both the primary and backup 

methods of alerting the population within 

5–10 miles of the plant. 

Loss of the primary method of alerting 

100% of the population within 0–5 miles 

of the plant with the prearranged backup 

capability still available. (See Additional 

Guidance section regarding a planned 

ANS outage.)

–––

Deficiencies in the licensee’s program for 

performing ANS testing and 

maintenance degrade a portion of the 

system for a significant period from the 

TIME OF DISCOVERY (e.g., 100% over 

25 days, greater than 48% over 45 days, 

greater than 24% over 90 days, greater 

than 12% over 6 months).

 

The notification process (e.g., 

procedures, systems, and resources) is 

not capable of providing follow-up 

notifications to ANY responsible OROs 

during an emergency.

–––

Loss of the approved backup method of 

alerting the population within the plume 

exposure EPZ with the primary capability 

still available.

–––

An individual siren has been available 

less than 70% of the time over a period 

of 12 months as a result of inadequate or 

delayed corrective actions.

An individual siren has not been 

available for a continuous period of 

greater than 4 months with inadequate or 

delayed corrective actions.

(b)(5)

Table 5.5-1 -- Significance Examples §50.47(b)(5)

Issue Date: 09/22/15 28 0609, Appendix. B
PLANNING STANDARD

FUNCTION(s)

LOSS of RSPS FUNCTION

Yellow Finding

DEGRADED RSPS FUNCTION

White Finding Green Finding

(b)(5) Continued

The public ANS meets the design 

requirements of FEMA-REP-10 or 

complies with the FEMA approved ANS 

design report and supporting FEMA 

approval letter.

Licensee ANS test and maintenance 

programs do not comply with requirements 

in the ANS design report.

Licensee made changes to the ANS or the 

testing and maintenance program, 

described in the ANS design report, 

without prior FEMA approval.

Loss of an ANS design feature (e.g., 

feedback system, battery backup, loud 

hailing features) identified in the ANS 

design report.

NOTE: See text on Page B-25 of this 

appendix with regard to obtaining FEMA 

evaluation of deviations from the ANS 

design report before citing a finding 

against one of these three examples.

(b)(5)

Table 5.5-1 (Continued)-- Significance Examples §50.47(b)(2)

Issue Date: 09/22/15 29 0609, Appendix. B
Issue Date: 09/22/15 30 0609, Appendix B

Significance Examples

See Table 5.6-1

Additional Guidance:

The significance examples provide for COMPENSATORY MEASURES as means of mitigating 

the significance of certain finding(s). See Section 5.0.2.h. of this appendix for additional 

guidance.

NEI 99-02, “Regulatory Assessment Performance Indicator Guideline,” [ML092931123], 

identifies key ERO members.

5.6 10 CFR 50.47(b)(6), Emergency Communications

PLANNING STANDARD: Provisions exist for prompt communications among principal 

response organizations to emergency personnel and to the public.

PS FUNCTIONS: 1. Systems are established for prompt communication among 

principal emergency response organizations.

2. Systems are established for prompt communication to 

emergency response personnel.

Supporting Requirements: 10 CFR Part 50, Appendix E, Section IV.E.9

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.F, and the licensee’s 

approved E–plan
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS OF PS FUNCTIONWhite Finding

DEGRADED PS FUNCTION

Green Finding

(b)(6)

Systems are established for prompt 

communication among principal 

emergency response organizations.

Systems are established for prompt 

communication to emergency response 

personnel.

N/A

 

Communications systems have 

degraded such that no communications 

channel between any two key ERO 

members is available in the TSC, EOF, 

or control room, including alternate 

facilities, or no communication channel 

between the ERO and OROs is available 

for longer than 24 hours from the TIME 

OF DISCOVERY and no COMPENSATORY MEASURES were implemented.* 

Loss of communications capability, for 

longer than 7 days from the TIME OF 

DISCOVERY such that no 

communications channel between any 

key ERO member and any individual, 

group, or organization with whom that 

key ERO member is expected to 

interface (e.g., field teams, OROs) and 

no COMPENSATORY MEASURES

were implemented.* 

Backup power supplies for at least one 

onsite and one offsite communications 

systems are not functional for more than 

30 days from the TIME OF DISCOVERY

and no COMPENSATORY MEASURES

were implemented. 

*In the event of major disruptive events (e.g., 

hurricane, fire, explosion, loss of power) or 

planned outages, COMPENSATORY

MEASURES are acceptable while repair 

activities proceed with high priority. 

 

Communications equipment for key ERO 

members in an emergency facility is 

degraded (e.g., many phones) at the 

TIME OF DISCOVERY and no COMPENSATORY MEASURES were 

implemented.*

Backup power supplies for at least one 

onsite and one offsite communications 

systems, as required by Appendix E to 

10 CFR Part 50, are not functional for 

more than 3 days from the TIME OF 

DISCOVERY and no COMPENSATORY 

MEASURES were implemented.*

(b)(6)

 

Table 5.6-1 -- Significance Examples §50.47(b)(6)

Issue Date: 09/22/15 31 0609, Appendix B
Issue Date: 09/22/15 32 0609, Appendix B

Significance Examples

See Table 5.7-1

Additional Guidance:

The significance examples provide for COMPENSATORY MEASURES as means of mitigating 

the significance of certain finding(s). See Section 5.0.2.h. of this appendix for additional 

guidance.

EPPOS-5, “Emergency Preparedness Position (EPPOS) on Emergency Planning Information 

Provided to the Public,” dated December 4, 2002, [ML023040492]

5.7 10 CFR 50.47(b)(7), Emergency Public Information

PLANNING STANDARD: Information is made available to the public on a periodic basis on 

how they will be notified and what their initial actions should be in 

an emergency (e.g., listening to a local broadcast station and 

remaining indoors), the principal points of contact with the news 

media for dissemination of information during an emergency 

(including the physical location or locations) are established in 

advance, and procedures for coordinated dissemination of 

information to the public are established.

PS FUNCTIONS: 1. EP information is made available to the public on a periodic 

basis within the plume exposure pathway EPZ.

2. Coordinated dissemination of public information during 

emergencies is established.

Supporting Requirements: 10 CFR Part 50, Appendix E, Section IV.D.2

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.G; NUREG-0696; and the 

licensee’s approved E–plan
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS OF PS FUNCTIONWhite Finding

DEGRADED PS FUNCTION

Green Finding

(b)(7)

EP information is made available to the 

public on a periodic basis within the 

plume exposure pathway EPZ.

Continued

N/A

 

Processes do not provide for the 

complete dissemination of EP-related 

public information such that the licensee 

does not provide information to all 

transient areas, EPZ segments, or other 

specialized/localized groups (e.g., hotels, 

recreational parks, select phone books, 

zip codes).

EP-related public information documents 

do not contain the required information 

(e.g., how the public will be notified, what 

their actions should be, and principal 

points of contact for information during 

an emergency).

Locations within the licensee’s owner 

controlled area, accessible by individuals 

who have not completed appropriate 

access training, are not provided

appropriate EP-related public information 

to which the licensee committed in the 

E–plan or, in the absence of E–plan

commitment, Federal regulation.*

*For some locations, signs and the like 

may be appropriate for disseminating 

public information.

 

Processes or procedures for 

disseminating information to the public 

are not maintained, such that significant 

elements of the public information 

process are degraded (e.g., contact lists 

are not effective, approval process 

cannot be implemented because of 

organizational changes, news releases 

are untimely, licensee news briefings are 

not coordinated with OROs).

EP-related public information has not 

been disseminated for a period longer 

than that to which the licensee 

committed in the E–plan or, in the 

absence of E–plan commitment, Federal 

regulation. 

Locations within the licensee’s owner 

controlled area, accessible by individuals 

who have not completed appropriate 

access training, are not provided

EP-related public information for a period 

longer than that to which the licensee 

committed in the E–plan or, in the 

absence of E–plan commitment, Federal 

regulation.*

(b)(7)

Table 5.7-1 -- Significance Examples §50.47(b)(7)

Issue Date: 09/22/15 33 0609, Appendix B
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS OF PS FUNCTIONWhite Finding

DEGRADED PS FUNCTION

Green Finding

(b)(7) Continued

Coordinated dissemination of public 

information during emergencies is 

established.

N/A

 

Licensee processes would not provide

for timely and accurate information 

releases to such an extent that the health 

and safety of the public would be 

compromised during emergencies (e.g., 

the ERO members are not knowledgeable with regard to emergency news 

center operations, procedures for 

disseminating information are not 

established, augmentation (call-out) 

processes would not ensure timely 

activation of the emergency news center, 

or untimely methods for information 

approval).

Licensee processes would not

coordinate news briefings to such an 

extent that the health and safety of the 

public would be compromised during 

emergencies (e.g., information is 

inaccurate, contradictory, or delayed).

 

Licensee processes at the joint 

information center would not provide for 

the issuance of a news release during an 

NOUE or Alert declaration in accordance 

with E–plan commitments.

Familiarization programs for news media 

are not conducted as the licensee 

committed in the E–plan or, in the 

absence of E–plan commitment, Federal 

regulation.

(b)(7)

Table 5.7-1 (Continued)-- Significance Examples §50.47(b)(7)

Issue Date: 09/22/15 34 0609, Appendix B
Issue Date: 09/22/15 35 0609, Appendix. B

Significance Examples

See Table 5.8-1

Additional Guidance:

The significance examples provide for COMPENSATORY MEASURES as means of mitigating 

the significance of certain finding(s). See Section 5.0.2.h. of this appendix for additional 

guidance.

The principal functional areas of emergency response are, as established in 10 CFR Part 50, 

Appendix E, §IV.F.2.b: management and coordination of emergency response, accident 

assessment, event classification, notification of offsite authorities, assessment of the onsite and 

offsite impact of radiological releases, protective action recommendation development, 

protective action decision making, plant system repair, and mitigative action implementation.

IN 2004-19, “Problems Associated with Back-up Power Supplies to Emergency Response 

Facilities and Equipment,” dated November 4, 2004,

http://www.nrc.gov/reading-rm/doc-collections/#gen

The TSC, and the EOF in certain cases, have habitability requirements in NUREG-0696 that 

derive in part from the habitability requirements for the main control room. Although neither 

document is explicitly applicable to TSCs or EOFs, the following additional guidance may be 

useful in informing issues related to TSC and EOF habitability. 

GL 2003-01, “Control Room Habitability,” dated June 12, 2003. http://www.nrc.gov/readingrm/doc-collections/gen-letters/2003/gl03001.pdf

RIS 2006-04, “Experience With Implementation of Alternative Source Terms,” dated March 7, 

2006, http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2006/ri200604.pdf

5.8 10 CFR 50.47(b)(8), Emergency Facilities and Equipment

PLANNING STANDARD: Adequate emergency facilities and equipment to support the 

emergency response are provided and maintained.

PS FUNCTIONS: 1. Adequate facilities are maintained to support emergency 

response.

2. Adequate equipment is maintained to support emergency 

response.

Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.E1–4, IV.E.8, IV.G

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.G; NUREG-0696; and the 

licensee’s approved E–plan
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS OF PS FUNCTION

White Finding

DEGRADED PS FUNCTION

Green Finding

(b)(8)

Adequate facilities are maintained to 

support emergency response.

Continued

N/A

 

The OSC, TSC, or EOF is not functional, 

to the extent that any principal functional 

area of emergency response assigned to 

the facility could not be performed, for a 

period of longer than 7 days from the 

TIME OF DISCOVERY and no

COMPENSATORY MEASURES were 

implemented.* 

A backup or alternative emergency 

response facility is no longer capable of 

being activated in accordance with the 

E–plan for a period of longer than 30 

days from the TIME OF DISCOVERY, 

and no COMPENSATORY MEASURES

were implemented.*

*In the event of major disruptive events 

(e.g., hurricane, fire, explosion, loss of 

power) or planned outages, COMPENSATORY MEASURES are acceptable 

while repair activities proceed with high 

priority.

 

The OSC, TSC, or EOF is not functional 

to the extent that any principal functional 

area of emergency response assigned to 

the facility could not be performed, for a 

period of longer than 24 hours from the 

TIME OF DISCOVERY, and no COMPENSATORY MEASURES were 

implemented.*

A backup or alternative emergency 

response facility is no longer capable of 

being activated in accordance with the 

E–plan for a period of longer than 7 days 

from the TIME OF DISCOVERY, and no

COMPENSATORY MEASURES were 

implemented.*

Changes have been made to the OSC, 

TSC, or EOF that do not comply with the 

E–plan, but the facilities remain 

functional. 

A licensee having a primary EOF greater 

than 25 miles from a reactor site has not 

maintained adequate provisions for 

locating the NRC and offsite responders 

closer to the site (e.g., inadequate 

space, communication links with other 

licensee ERFs and with OROs, 

computer links with internet access, or 

copying equipment and office supplies.

(b)(8)

Table 5.8-1 -- Significance Examples §50.47(b)(8)

Issue Date: 09/22/15 36 0609, Appendix B
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS OF PS FUNCTIONWhite Finding

DEGRADED PS FUNCTION

Green Finding

(b)(8) Continued

Adequate equipment is maintained to 

support emergency response. 

N/A

 

–––

Equipment necessary to implement the 

E–plan is not available or not functional, 

to the extent that any principal functional 

area of emergency response could not 

be performed, for a period of longer than 

7 days from the TIME OF DISCOVERY, 

and no COMPENSATORY MEASURES 

were implemented. (e.g., lack of 

engineering documents would prevent 

TSC technical support from performing 

function). The availability of additional 

onsite equipment, in a reasonably timely 

manner, is considered to be a 

COMPENSATORY MEASURE for this 

PSF.

 

–––

A significant amount of equipment 

necessary to implement the E–plan is 

not available or functional to the extent 

that any principal functional area or 

emergency response could not be 

performed, and no COMPENSATORY 

MEASURES were implemented.

(b)(8)

 

Table 5.8-1 (Continued)-- Significance Examples §50.47(b)(8)

Issue Date: 09/22/15 37 0609, Appendix B
Issue Date: 09/22/15 38 0609, Appendix. B

5.9 10 CFR 50.47(b)(9), Emergency Assessment Capability

PLANNING STANDARD: Adequate methods, systems, and equipment for assessing and 

monitoring actual or potential offsite consequences of a 

radiological emergency condition are in use.

RSPS FUNCTION: Methods, systems, and equipment for assessment of radioactive 

releases are in use.

Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.B and IV.E.2

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.I, and the licensee’s 

approved E–plan

Significance Examples

See Table 5.9-1

Additional Guidance:

The significance examples provide for COMPENSATORY MEASURES as means of mitigating the 

significance of certain finding(s). See Section 5.0.2.h of this appendix for additional guidance.

EPPOS-3, “Emergency Preparedness Position (EPPOS) on Requirement for Onshift Dose Assessment 

Capability,” dated November 8, 1995. [ML023040473]

Some significance examples refer to an incapability of providing technically adequate estimates of 

projected releases and doses. As with all significance examples, the focus is on a PD that is reasonably 

under the licensee’s control to identify and prevent. Quantification of the magnitude of the error is not 

required. These errors may be identified during exercise when licensee results are compared to those 

performed by other entities. The following conditions are generally under the licensee’s control:

 Inadequate procedures and training may cause users to select processing options or make data 

entries that are not appropriate for the particular projections being performed. 

 Use of a dose projection model that does not account for site-specific and plant-specific 

meteorological regimes, terrain characteristics, release pathway configuration (e.g., elevated 

versus ground, building wake)

 Site- and unit-specific data files that adapt the modeling to a particular site (e.g., monitor 

efficiencies, terrain heights, stack heights, etc.) are inconsistent with the site configuration.

Conversely, the inherent uncertainties in the components of a dose projection — source term, 

meteorology, and dose calculation — are generally not under the control of the licensee, and therefore 

are not PDs. 
PLANNING STANDARD

FUNCTION(s)

LOSS of RSPS FUNCTION 

Yellow Finding 

DEGRADED RSPS FUNCTION

White Finding Green Finding

(b)(9)

Methods, systems, and equipment for 

assessment of radioactive releases are 

in use.

 

The dose projection process is 

incapable* of providing technically 

adequate estimates of radioactive 

material releases to the environment or 

projected offsite doses in any case.

Equipment or systems necessary for 

dose projection are not functional for 

longer than 24 hours from the TIME OF 

DISCOVERY, to the extent that the 

licensee has no capability for immediate 

dose projection.

 

The field monitoring function (at least 

dose rate measurement and iodine 

presence determination) is unavailable 

for more than 72 hours from the TIME 

OF DISCOVERY and no COMPENSATORY MEASURES were implemented**. 

The dose projection process is 

incapable* of providing technically 

adequate estimates of radioactive 

material releases to the environment or 

projected offsite doses in some cases.

Equipment or systems necessary for 

dose projection are not functional for 

longer than 24 hours from the TIME OF 

DISCOVERY, to the extent that the 

licensee has no capability for immediate 

dose projection in facility emergency 

response centers as committed to in the 

E–plan.

*Because of a systematic deficiency in 

input data, calculational methodology 

and assumptions, user procedures, user 

training, etc. Systematic deficiencies do 

not include normal uncertainties inherent 

to the dose assessment process or end 

user errors.

**In the event of major disruptive events 

(e.g., hurricane, fire, explosion, loss of 

power) or planned outage, 

COMPENSATORY MEASURES are 

acceptable while repair activities 

proceed with high priority.

 

The field monitoring function in 

accordance with the E–plan is 

unavailable for more than 72 hours from 

the TIME OF DISCOVERY, and no

COMPENSATORY MEASURES were 

implemented**. 

The dose projection process is 

incapable* of providing technically 

adequate estimates of radioactive 

material releases to the environment or 

projected offsite doses beyond 10 miles 

but less than 50 miles

Equipment or systems necessary for 

dose projection are not functional for 

longer than 24 hours from the TIME OF 

DISCOVERY and no COMPENSATORY 

MEASURES were implemented or 

corrective actions are inadequate or 

delayed.

(b)(9)

. 

Table 5.9-1 -- Significance Examples §50.47(b)(9)

Issue Date: 09/22/15 39 0609, Appendix B
Issue Date: 09/22/15 40 0609, Appendix B

Significance Examples

See Table 5.10-1

Additional Guidance:

The significance examples provide for COMPENSATORY MEASURES as means of mitigating 

the significance of certain finding(s). See Section 5.0.2.h of this appendix for additional 

guidance.

5.10 10 CFR 50.47(b)(10), Emergency Protective Actions

PLANNING STANDARD: A range of protective actions has been developed for the plume 

exposure pathway EPZ for emergency workers and the public. In 

developing this range of actions, consideration has been given to 

evacuation, sheltering, and, as a supplement to these, the 

prophylactic use of potassium iodide (KI), as appropriate. 

Evacuation time estimates have been developed by applicants 

and licensees. Licensees shall update the evacuation time 

estimates on a periodic basis. Guidelines for the choice of 

protective actions during an emergency, consistent with Federal 

guidance, are developed and in place, and protective actions for 

the ingestion exposure pathway EPZ appropriate to the locale 

have been developed.

RSPS FUNCTIONS:

PS FUNCTIONS:

1. A range of public PARs (excluding KI) is available for 

implementation during emergencies.

2. ETEs for the population located in the plume exposure 

pathway EPZ are available to support formulation of PARs and 

have been provided to State and local governmental 

authorities.

1. A range of protective actions is available for emergency 

workers during emergencies, including hostile action events.

2. KI is available for implementation as a protective action 

recommendation in those jurisdictions that chose to provide KI 

to the public.

Supporting Requirements: Appendix E, Section IV.I

Informing Criteria: NUREG-0654/FEMA-REP-1, Sections II.J.1–8, II.J.2–6, and

II.J.10; Supplement 3 to NUREG-0654; and the licensee’s 

approved E–plan
Issue Date: 09/22/15 41 0609, Appendix B

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

[ML113010515]

NUREG-0654/FEMA-REP-1, Supplement 3, “Guidance for Protective Action Strategies” 

[ML113010596]

NSIR/DPR-ISG-001, “Emergency Planning for Nuclear Power Plants” [ML113010523]

(Remaining documents can be found at http://www.nrc.gov/reading-rm/doc-collections/#gen )

IN 1998-20, “Problems with Emergency Preparedness Respiratory Programs,” dated

June 3, 1998

RIS 2002-14, “Ensuring a Capability to Evacuate Individuals, Including Members of the Public, 

From the Owner-Controlled Area,” dated April 8, 2002

RIS 2002-21, “National Guard and Other Emergency Responders Located in Licensee’s 

Controlled Area,” dated November 8, 2002

RIS 2003-12, “Clarification of NRC Guidance for Modifying Protective Actions,” dated 

June 24, 2003

RIS-2004-13, “Consideration of Sheltering in Licensee's Range of Protective Action 

Recommendations,” dated August 2, 2004, and Supplement 1, dated March 10, 2005

RIS-2005-08, “Endorsement of Nuclear Energy Institute (NEI) Guidance ‘Range of Protective 

Actions for Nuclear Power Plant Incidents,’” dated June 6, 2005

IN 2002-14, “Ensuring a Capability to Evacuate Individuals, Including Members of the Public, 

from the Owner-Controlled Area” dated April 8, 2002
PLANNING STANDARD

FUNCTION(s)

LOSS of RSPS FUNCTION 

Yellow Finding

DEGRADED RSPS FUNCTION

White Finding Green Finding

(b)(10)

A range of public PARs (excluding KI) is 

available for implementation during 

emergencies.

Approved ETEs for the population in the 

plume exposure pathway EPZ are 

available to support formulation of PARs 

and have been provided to State and 

local governmental authorities.

Continued

 

The PAR process* does not provide for 

timely initial and subsequent PARs that 

are in accordance with E–plan 

commitments or Federal guidance to the 

extent that necessary evacuation or

sheltering PARs would not be issued to 

cover affected areas** within 5 miles of 

the site. 

The capability to implement protective 

actions within the owner controlled area 

(refer to IN 2002-14) is deficient to the 

extent that procedures, equipment, or 

personnel would not be capable of timely 

evacuation and processing of members 

of the public who might be present.

–––

 

The PAR process* does not provide for 

timely initial and subsequent PARs that 

are in accordance with E–plan 

commitments or Federal guidance to the 

extent that necessary evacuation or

sheltering PARs would not be issued to 

cover affected areas** within 5 to 10 

miles of the site.

The capability to implement protective 

actions within the owner controlled area 

(refer to IN 2002-14) is deficient to the 

extent that procedures, equipment, or 

personnel would not consistently provide 

assurance of timely evacuation and 

processing of members of the public who 

might be present.

–––

The ETE analysis has not been updated 

as required.

 

The PAR process* does not provide for 

timely initial and subsequent PARs that 

are in accordance E–plan commitments 

or Federal guidance to the extent that

necessary evacuation or sheltering

PARs would not be issued to cover 

affected areas** beyond the plume 

exposure pathway EPZ.

The PAR process* provides an initial or 

subsequent PAR that recommends 

members of the public be evacuated 

unnecessarily from areas where the 

PAGs are not predicted to be exceeded 

based upon the existing or projected 

plant conditions, meteorological 

conditions, or dose assessments.

–––

ETEs and updates to the ETEs were not 

provided to responsible OROs.

The current public protective action 

strategies documented in EPIPs are not 

consistent with the current ETE.

(b)(10) 

Table 5.10-1 -- Significance Examples §50.47(b)(10)

Issue Date: 09/22/15 42 0609, Appendix B
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS of PS FUNCTIONWhite Finding

DEGRADED PS FUNCTION

Green Finding

(b)(10) (Continued) 

A range of protective actions is available 

for emergency workers during 

emergencies, including hostile action 

events.

Continued

 

N/A

 

–––

A significant fraction (e.g., greater than 

25%) of the onsite notification system 

(e.g., plant page speakers) is out of 

service in occupied areas that would 

need to be evacuated during an 

emergency for longer than 7 days from 

the TIME OF DISCOVERY, and no 

COMPENSATORY MEASURES were 

implemented.

The site evacuation process is deficient 

to the extent that it cannot be 

accomplished during an emergency.

The accountability process is deficient to 

the extent that it cannot ensure that 

onsite accountability is achieved and 

maintained during an emergency.

The site process for implementing 

protective actions during hostile action 

events is deficient to the extent that the 

site’s capability to safely shut down the 

reactor or perform the RSPS functions of 

the E–plan is lost.

Onsite respiratory protective equipment 

is degraded, or personnel are not 

qualified to use it, to the extent that the 

minimum complement of control room 

operators could not be protected for at 

least 4 hours (if needed) from the TIME 

OF DISCOVERY, and no COMPENSATORY MEASURES were 

implemented.

 

–––

A fraction (e.g., greater than 10%) of the 

onsite notification system (e.g., plant 

page speakers) is out of service in 

occupied areas that would need to be 

evacuated during an emergency for 

longer than 24 hours from the TIME OF 

DISCOVERY, and no COMPENSATORY MEASURES were implemented.

The site process for implementing 

protective actions during hostile action 

events is deficient to the extent that the 

site’s capability to perform the functions 

of the E–plan is lost.

Onsite respiratory protective equipment 

is not maintained in accordance with 

regulations or E–plan commitments.

Emergency workers who would be 

required to use respiratory protective 

equipment are not qualified or trained to 

use that equipment.

The KI program is not maintained in 

accordance with regulations or E–plan

commitments.

(b)(10)

 

Table 5.10-1 (Continued)-- Significance Examples §50.47(b)(10)

Issue Date: 09/22/15 43 0609, Appendix B
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS of PS FUNCTION

White Finding 

DEGRADED PS FUNCTION

Green Finding 

(b)(10) (Continued) 

KI is available for implementation as a 

PAR in those jurisdictions that choose to 

provide KI to the public.

 

N/A

 

–––

The PAR process* does not provide for 

timely initial and subsequent KI PARs 

that are in accordance with E–plan 

commitments or Federal guidance to the 

extent that necessary KI PARs would not 

be issued to cover affected populated 

areas** within the plume exposure 

pathway EPZ in those jurisdictions that 

opt to provide KI to the public.

*Process” includes the licensee’s PAR 

strategy, procedures, equipment, 

training, and ERO staffing necessary to 

develop a PAR.

**Includes any area where the public 

may be present including areas over 

water.

(b)(10)

Table 5.10-1 (Continued)-- Significance Examples §50.47(b)(10)

Issue Date: 09/22/15 44 0609, Appendix B
Issue Date: 09/22/15 45 0609, Appendix. B

5.11 10 CFR 50.47(b)(11), Emergency Radiological Exposure Control

PLANNING STANDARD: Means for controlling radiological exposures, in an emergency, 

are established for emergency workers. The means for controlling 

radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity 

Protective Action Guides.

PS FUNCTION: The resources for controlling radiological exposures for 

emergency workers are established.

Supporting Requirements: 10 CFR Part 50, Appendix E, Section IV.E.1

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.K, and the licensee’s 

approved E–plan

Table 5.11-1

Significance Examples for 

10 CFR 50.47(b)(11)

LOSS OF PS FUNCTION:

White Finding

Radiological control equipment, instrumentation, processes 

and/or personnel necessary to control emergency workers’

exposure is not available (e.g., out of service or calibration) to 

the extent that emergency work necessary to protect the 

health and safety of the public could not be performed during 

emergencies. The availability of additional equipment, on

site, in a reasonably timely manner is considered a 

COMPENSATORY MEASURE for the PS.

Resources for controlling exposures during emergencies will 

not ensure that exposures are maintained in accordance with

E–plan commitments.

DEGRAD. OF PS FUNC.

Green Finding:

Radiological control equipment, instrumentation, processes, 

and/or personnel necessary to control emergency workers’

exposure is not available to the extent that emergency work 

necessary to protect the health and safety of the public would 

be impaired during emergencies. The availability of additional 

equipment, on site, in a reasonably timely manner is 

considered a COMPENSATORY MEASURE for the PSF.

Additional Guidance: None
Issue Date: 09/22/15 46 0609, Appendix. B

5.12 10 CFR 50.47(b)(12), Emergency Medical Support

PLANNING STANDARD: Arrangements are made for medical services for contaminated 

injured individuals.

PS FUNCTION: Arrangements are made for medical services for contaminated, 

injured individuals.

Supporting Requirements: 10 CFR Part 50, Appendix E, Section IV.E.5-7

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.L, and the licensee’s 

approved E–plan

Table 5.12-1

Significance Examples for 

10 CFR 50.47(b)(12)

LOSS OF PS FUNCTION:

White Finding

No agreement exists with any qualified and properly equipped 

hospital or ambulance service for the care of contaminated, 

injured individuals.

DEGRAD. OF PS FUNC.

Green Finding:

An agreement for medical support with an organization has 

been allowed to lapse, but the organization remains willing to 

support the E–plan.

Additional Guidance: None
Issue Date: 09/22/15 47 0609, Appendix. B

Table 5.13-1

Significance Examples for 

10 CFR 50.47(b)(13)

LOSS OF PS FUNCTION:

White Finding

None

DEGRAD. OF PS FUNC.

Green Finding:

Recovery efforts are not preplanned.

The recovery process is not exercised within an 8-year

period.

Additional Guidance:

Because of the nonemergency nature of recovery efforts, no LOSS OF PS FUNCTION would 

be assigned for failures in this area (i.e., any FTC would not exceed a Green finding).

5.13 10 CFR 50.47(b)(13), Recovery and Reentry Planning

PLANNING STANDARD: General plans for recovery and reentry are developed.

PS FUNCTIONS: Plans for recovery and reentry are developed.

Supporting Requirements: None

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.M, and the licensee’s 

approved E–plan
Issue Date: 09/22/15 48 0609, Appendix. B

Significance Examples

See Table 5.14-1 and

Figures 5.14-1 and 5.14-2

Additional Guidance:

See guidance in Section 6.0 regarding correction of WEAKNESSES.

Identification of WEAKNESSES

A WEAKNESS is defined as a level of ERO performance demonstrated during an exercise, drill, 

or training that provides performance opportunities to develop, maintain, or demonstrate key 

skills that would preclude effective implementation of the E–plan, if the weakness were to occur 

during an actual emergency.

A failure of a CRITIQUE to identify a WEAKNESS observed by NRC inspectors is a CRITIQUE 

finding and should be processed against 10 CFR 50.47(b)(14) and Section IV.F.2.g of 

Appendix E, if the WEAKNESS could preclude effective implementation of the E–plan in an 

actual emergency (i.e., FTI). 

5.14 10 CFR 50.47(b)(14), Drill and Exercise Program

PLANNING STANDARD: Periodic exercises are (will be) conducted to evaluate major 

portions of emergency response capabilities, periodic drills are 

(will be) conducted to develop and maintain key skills, and 

deficiencies identified as a result of exercises or drills are (will be) 

corrected.

PS FUNCTIONS: 1. A drill and exercise program (including, for example, 

radiological, medical, health physics) is established.

2. All exercises, drills, and training that provide performance 

opportunities to develop, maintain, and demonstrate key skills

are assessed via a CRITIQUE process to identify 

WEAKNESSES.

3. Identified WEAKNESSES are corrected.

Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.F.1–2

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.N, and the licensee’s 

approved E–plan
Issue Date: 09/22/15 49 0609, Appendix. B

Since a WEAKNESS is defined in the context of ERO performance, a PROGRAM ELEMENT

issue related to the effectiveness and adequacy of the E–plan or its implementing procedures10

is not a WEAKNESS. Accordingly:

 A deficient PE uncovered by the exercise and identified by the licensee in its critique is a 

licensee-identified PD and is evaluated as a FTC. 

 If identified by the inspector, the deficient PE is an NRC-identified PD and is evaluated 

as a FTC. 

 Because of this dichotomy, inspectors will need to remain alert to the possibility that a 

WEAKNESS may have uncovered one or more inadequate PE.

A mistake or a misstep by ERO members that only detracts from the overall ERO performance 

should not be treated as a de facto WEAKNESS. Mistakes are likely to happen in the course of 

an exercise and many are corrected by the ERO (e.g., peer-checking), which should be viewed 

as an organizational strength. Failure to identify these mistakes as a WEAKNESS in the 

CRITIQUE is generally not a PD. 

Inspectors must remain alert to exercise controller actions (e.g., coaching, prompting) that have 

the effect of masking an ERO WEAKNESS such that corrective actions might not be 

implemented. Failure of the licensee’s CRITIQUE to identify the ERO performance 

WEAKNESS masked by the controller action is a CRITIQUE finding. (Even if identified in the 

CRITIQUE, the controller’s action could result in a DEP PI opportunity being considered as a 

failure. See ROP FAQ No. 405 dated July 21, 2005.)

Classifications, PARs, and notifications could be accurate and timely (DEP PI opportunity 

successes) and there still be a WEAKNESS. Such a WEAKNESS needs to be identified and 

corrected since, under different circumstances, it could affect activities necessary for protecting 

the health and safety of the public. A failure to identify such a WEAKNESS in a CRITIQUE 

should be classified as a Green finding because of its lesser significance. Examples include the 

following:

 An emergency classification is made as anticipated by the scenario, but the classification 

was based on misinformation, lack of information, invalid indicators, or reliance on 

emergency director judgment EALs when explicit EALs were applicable.

 A PAR is developed as anticipated by the scenario, but the PAR was based on a dose 

assessment performed using erroneous input parameters (e.g., improper release 

duration, credit for filtration when none available).

Licensees perform CRITIQUES in many different ways and the inspectors should be flexible in 

accepting mechanisms for WEAKNESS identification. The critical feature of any CRITIQUE is 

 

10 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: 09/22/15 50 0609, Appendix. B

that a WEAKNESS is captured and entered into a corrective action system with appropriate 

priority, regardless of whether the WEAKNESS was verbalized at a CRITIQUE meeting. 

If the inspector can be assured that all WEAKNESSES will be entered into a corrective action 

system, before disclosing the identified issues, the CRITIQUE should be considered acceptable. 

However, if the inspector does not have assurance that a WEAKNESS has or will be captured 

and entered into the corrective action system, the CRITIQUE was not acceptable and a 

CRITIQUE finding exists. 

The disposition of CRITIQUE observations also varies among sites. In any given exercise, the 

licensee will evaluate numerous evaluator observations, identify which observations rise to the 

level of a WEAKNESS, and prioritize resources for correction. Care should be taken to 

understand the logic underlying the suggested disposition before identifying it as a CRITIQUE 

finding. If the inspector identifies that a well-founded, evaluator-identified WEAKNESS was 

improperly dispositioned and was not entered into the corrective action system, a CRITIQUE 

finding exists since the NRC expects the licensee to enter identified WEAKNESSES and enter 

them into a corrective action system.

If the ERO performance during a biennial exercise is degraded to the extent that the inspector

cannot find that reasonable assurance exists that adequate protective measures can be taken in 

the event of an actual radiological emergency or cannot find that the ERO has maintained key 

skills specific to emergency response, the NRC may require the conduct of a remedial exercise 

under Section IV.F.2.f of Appendix E to 10 CFR Part 50.
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS of PS FUNCTIONWhite Finding

DEGRADED PS FUNCTION

Green Finding

(b)(14) 

A drill and exercise program (including, 

for example, radiological, medical, health 

physics) is established.

Continued

 

N/A

 

More than two drills or exercises (e.g., 

radiological, medical, health physics) 

(excluding the biennial exercise) during a 

2-year (calendar) period have not been 

conducted in accordance with the E–

plan.

A biennial exercise is not conducted 

during a 2-year (calendar) period without 

receiving an exemption.

Exercises and drills are not sufficiently 

varied to ensure that all RSPS PE are 

tested within the exercise planning cycle

ERO performance is such that a 

remedial exercise is required because 

the NRC cannot find reasonable 

assurance that adequate protective 

measures can be taken in the event of a 

radiological emergency or the ERO 

failed to maintain and demonstrate key 

skills.

 

A drill has not been conducted during a 

2–year (calendar) period in accordance 

with the E–plan.

Exercises and drills are not sufficiently 

varied to ensure that all PS PE are 

tested within the exercise planning cycle.

A biennial exercise does not provide 

opportunities for the ERO to 

demonstrate key emergency response 

skills identified in Appendix E 

Section IV.F.2.b in the control room, 

TSC, OSC, EOF, or JIC.

Biennial exercises are not sufficiently 

varied to ensure ERO proficiency in 

responding to scenario elements 

identified in Appendix E Section IV.F.2.j 

and to minimize anticipatory responses 

caused by preconditioning of 

participants.

A biennial exercise is not sufficiently 

technically accurate or challenging to 

adequately test the plans, procedures, 

equipment, and implementation of the 

licensee’s emergency response 

capabilities. 

(b)(14)

Table 5.14-1 -- Significance Examples §50.47(b)(14)

Issue Date: 09/22/15 51 0609, Appendix B
PLANNING STANDARD

FUNCTION(s) Yellow Finding LOSS of PS FUNCTIONWhite Finding

DEGRADED PS FUNCTION

Green Finding

(b)(14) Continued

All exercises, drills, and training that 

provide performance opportunities to 

develop, maintain, and demonstrate key 

skills, are assessed via a formal 

CRITIQUE process to identify 

WEAKNESSES.

Identified WEAKNESSES are corrected.

 

N/A

 

–––

Formal CRITIQUES are not conducted 

for more than two scheduled drills or 

exercises.

The CRITIQUE process does not 

properly identify a WEAKNESS 

associated with an RSPS that is 

determined (by the NRC) to be a DEP PI 

opportunity failure during a FULL-SCALE 

DRILL OR EXERCISE. 

–––

The licensee failed to correct an RSPS 

WEAKNESS. (See Section 6.0, 

“Corrective Actions.”)

 

–––

Formal CRITIQUES are not conducted 

for more than two scheduled training 

evolutions. 

The CRITIQUE process does not identify 

a WEAKNESS associated with a RSPS 

that is determined (by the NRC) as a 

DEP PI successful opportunity during a 

FULL-SCALE DRILL OR EXERCISE. 

The CRITIQUE process does not identify 

a WEAKNESS associated with a nonRSPS during a FULL-SCALE DRILL OR 

EXERCISE or any PS WEAKNESS 

during a limited facility interaction drill in 

which there is a limited team of 

evaluators (e.g., facility tabletop training 

drill, operator training simulator drill, 

individual facility training drill).

The CRITIQUE process does not 

properly identify a WEAKNESS 

associated with RSPS 

10 CFR 50.47(b)(9).

–––

The licensee failed to correct a nonRSPS WEAKNESS. (See Section 6.0,

“Corrective Actions.”)

(b)(14)

 

Table 5.14-1 (Continued)-- Significance Examples §50.47(b)(14)

Issue Date: 09/22/15 52 0609, Appendix B
Issue Date: 09/22/15 53 0609, Appendix B

Figure 5.14-1

Significance Determination for CRITIQUE Findings

Scope of Drill or Exercise Weakness PS PI Opportunity Status* Finding Significance

Failure White

Success

RSPS

Non-RSPS

CRITIQUE FULL-SCALE

Finding

Green

Green

 Limited Participation Green

. *As determined by the NRC inspector.

With regard to the PI opportunity status branch, if the licensee fails to identify a RSPS 

WEAKNESS observed during a FULL-SCALE DRILL OR EXERCISE that is determined by the 

inspector to be a PI opportunity failure, the significance is White. All other CRITIQUE findings

are assigned Green significance.

Figure 5.14-2

Significance Determination for Failure to Correct a WEAKNESS

Planning Standard Repetition Current DEP PI Status Finding Significance

Green White

White

RSPS b(4), b(5), b(10)

RSPS b(9)

No Finding** Failure

To

Correct

>10% failure* White

<10% failure*

non-RSPS

**

>10% failure* Green

<10% failure* **

*Including all observed WEAKNESSES having a common uncorrected root cause (e.g., 

inadequate ERO training). See Section 6.0.

**Return to IMC 0612 and reconsider the more-than-minor determination.
Issue Date: 09/22/15 54 0609, Appendix B

Table 5.15-1

Significance Examples for 

10 CFR 50.47(b)(15)

LOSS OF PS FUNCTION:

White Finding

ERO personnel would not be available (e.g., lapsed training) 

to provide continuous coverage (24 hours) for a key ERO 

function (as defined by NEI 99-02). NOTE: If the DEP and 

ERO PIs have been Green for the previous eight quarters, the 

significance should be Green.

DEGRAD. OF PS FUNC.

Green Finding:

ERO personnel would not be available (e.g., lapsed training) 

to provide continuous coverage (24 hours) for any ERO 

position listed in the licensee’s E–plan. Unqualified personnel 

(e.g., lapsed training) are maintained on the ERO duty roster 

and are relied upon to respond during an emergency.11

Additional Guidance:

NEI 99-02, “Regulatory Assessment Performance Indicator Guideline,” Revision 6,

[ML092931123], identifies key ERO members.

 

11 Since the PS applies only to personnel relied upon to respond during an emergency, a PD does 

not exist if personnel were removed from the ERO duty roster when their training qualification 

lapsed. Return to IMC 0612 and reconsider the more-than-minor determination.

5.15 10 CFR 50.47(b)(15), Emergency Responder Training

PLANNING STANDARD: Radiological emergency response training is provided to those 

who may be called on to assist in an emergency.

PS FUNCTION: Training is provided to ERO personnel.

Supporting Requirements: 10 CFR Part 50, Appendix E, Sections IV.F.1–2

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.O, and the licensee’s 

approved E–plan
Issue Date: 09/22/15 55 0609, Appendix B

5.16 10 CFR 50.47(b)(16), Emergency Plan Maintenance

PLANNING STANDARD: Responsibilities for plan development and review and for 

distribution of emergency plans are established, and planners are 

properly trained.

PS FUNCTION: 1. Responsibility for E–plan development and review is 

established.

2. Planners responsible for E–plan development and 

maintenance are properly trained.

Supporting Requirements: None

Informing Criteria: NUREG-0654/FEMA-REP-1, Section II.P, and the licensee’s 

approved E–plan

Table 5.16-1

Significance Examples for 

10 CFR 50.47(b)(16)

LOSS OF PS FUNCTION:

White Finding

None.

DEGRAD. OF PS FUNC.

Green Finding:

Responsibilities for E–plan development are not established.

Planners did not receive initial and/or continuing training.

Additional Guidance:

Because of the nonemergency nature of E–plan development efforts, no LOSS OF PS 

FUNCTION would be assigned for failures in this area (i.e., any FTC would not exceed a Green 

finding).
Issue Date: 09/22/15 56 0609, Appendix B

6.0 GUIDANCE ON CORRECTIVE ACTIONS

6.1 Timeliness Guidelines

a. The NRC expects that licensees will resolve an identified WEAKNESS in a timely 

manner consistent with its risk significance. That said, it is important to note that the 

time it takes to correct a WEAKNESS may depend on various factors, not all of which 

may be under the licensee’s direct control. The licensee determines the risk significance 

of a WEAKNESS and sets resolution priorities in accordance with its corrective action 

programs and other commitments. Root cause and extent of cause analyses may take 

60 days or longer to complete. While immediate corrective actions, such as procedure 

changes, briefings, lessons-learned summaries, or COMPENSATORY MEASURES may 

be implemented rapidly, multiple longer term corrective actions may be necessary to 

fully resolve the WEAKNESS and prevent its reoccurrence. 

b. This guidance, which should be interpreted as flexible guidelines, is intended to inform 

an inspector’s evaluation of the timeliness of the corrective actions for an identified 

WEAKNESS. The following guidance is to be used when assessing timeliness of 

corrective actions:

1. An RSPS-related WEAKNESS is typically corrected within 90 days of 

identification.

2. A PS-related WEAKNESS is typically corrected within 180 days of identification.

3. Resolution of other WEAKNESSES is expected within the next evaluated 

biennial exercise cycle because of the lower risk significance of these efforts and 

expected lower priority of such efforts.

4. EP-related corrective action systems may track enhancement suggestions that 

result from the drill program. These enhancement suggestions often add value to the 

EP program, but are not required and do not address WEAKNESSES. There is no NRC 

timeliness expectation for resolution of enhancement suggestions.

6.2 Considerations

a. If a WEAKNESS is corrected in less time than that suggested in Section 6.1.(b), above, 

further review of the timeliness of the corrective actions by the inspector is probably not 

necessary. If a WEAKNESS is not corrected within the time periods suggested in 

Section 6.1.(b), the inspector should review:

1. the licensee’s schedule and prioritization rationale

2. reasons for the delay

3. any actions being taken to accelerate completion (if any)
Issue Date: 09/22/15 57 0609, Appendix B

4. the effect of any immediate corrective actions that may have already been taken

b. If the inspector finds that the licensee is not making a best effort to complete the 

corrective actions, or that the delay could potentially impact the effectiveness of the 

E–plan to protect public health and safety, an FTC with PS 10 CFR 50.47(b)(14) finding

should be pursued.

6.3 Effectiveness of Corrective Actions

a. Although a licensee may have properly identified a WEAKNESS, entered it into the 

licensee’s corrective action program, and implemented necessary corrective actions to 

prevent reoccurrence, the associated ERO performance may recur in subsequent drills 

and exercises. It is important to note that a single repetition of a WEAKNESS in a 

subsequent drill or exercise may not indicate a failure to correct a WEAKNESS. 

Conversely, success in a drill or exercise (e.g., by one well-drilled team) might not be a 

valid demonstration that a WEAKNESS has been corrected. 

b. When a previously identified WEAKNESS in a particular PS recurs in a subsequent drill 

or exercise, the inspector should do the following:

1. Review the specific corrective actions identified.

2. Verify that the corrective actions are complete.

3. Review associated root cause and extent of condition analyses, if performed.

4. Consider similar occurrences during responses to actual events, drills, exercises,

and training evolutions.

5. Consider the status of relevant PIs; for the DEP PI, review the performance for 

the individual RSPS as well as that for the overall PI (good performance in two RSPS 

can mask poor performance in the third).

6. Review corrective actions, self-assessment, and inspection records for an entire 

inspection cycle with emphasis on similar performance deficiencies.

c. Assessment of the effectiveness of the corrective actions should be based on the 

complete history of the issue. The intent of the reviews suggested above is to uncover a 

pattern of recurring performance deficiencies in similar activities as a means to identify 

ineffective corrective actions.

d. A specific root cause of a WEAKNESS in a particular RSPS may have been corrected, 

and yet another WEAKNESS in the same RSPS but with a different root cause may be 

observed in a subsequent drill or exercise. A trend in such repetitive WEAKNESSES, 

even though each may have a different root cause, could indicate that the root cause 

and extent of cause analyses may have been ineffective such that an unidentified (and 

uncorrected) root cause still exists. Accordingly, the WEAKNESS is uncorrected and a
Issue Date: 09/22/15 58 0609, Appendix B

failure to correct a WEAKNESS needs to be considered as provided for in this section. 

In addition, a trend of repetitive WEAKNESSES may indicate the need to perform a root 

cause analysis of the trend. 

e. If corrective actions are aggressive and appear to be complete but not yet fully effective, 

consideration may be given to allow more time for performance improvement (future 

drills should show such improvement). 
Issue Date: 09/22/15 Att1-1 0609, Appendix B

Attachment 1

FAILURE TO IMPLEMENT (ACTUAL EVENT) SIGNIFICANCE LOGIC

FAILURE TO IMPLEMENT

General Emergency RED

YELLOW RSPS

FAILURE TO IMPLEMENT: FAILURE TO COMPLY with a REGULATORY REQUIREMENT during an actual event in which the failure precluded effective implementation of PROGRAM ELEMENTs. RSPS: Risk Significant Planning Standard; PS: Planning Standard

PS GREEN

Yes

Yes

No

Yes

No

Site Area Emergency YELLOW

WHITE RSPS

PS GREEN

Yes

Yes

No

Yes

No

No

Alert Emergency WHITE

GREEN RSPS

GREEN

Yes Yes No

No

No
Issue Date: 09/22/15 Att2-1 0609, Appendix B

Attachment 2

FAILURE TO COMPLY SIGNIFICANCE LOGIC

FAILURE TO COMPLY

Loss of RSPS Function

RSPS Degraded Function

Loss of PS* Function

No

No

Yes

Yes

Yes No

YELLOW

WHITE

WHITE

GREEN FAILURE TO COMPLY: A program is noncompliant with a REGULATORY FUNCTION. LOSS OF RSPS FUNCTION: PROGRAM ELEMENTs are not adequate, not compliant with the PLANNING STANDARDS, or otherwise not functional to such an extent that the RISK SIGNIFICANT PLANNING STANDARD FUNCTION is not available for emergency response. DEGRADATION OF THE RSPS FUNCTION: PROGRAM ELEMENTs are not adequate or not compliant, but the RISK SIGNIFICANT PLANNING STANDARD FUNCTION, although degraded is available for emergency response. LOSS OF PLANNING STANDARD FUNCTION: PROGRAM ELEMENTs are not adequate, not compliant with the PLANNING STANDARDS, or otherwise not functional to such an extent that the PLANNING STANDARD FUNCTION is not available for emergency response. *RSPS functions are a subset of the PS functions. Thus, a RSPS function that is not loss or degraded would be Green.
Issue Date: 09/22/15 Att3-1 0609, Appendix B

Attachment 3

Revision History for IMC 0609, App B

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)

n/a 04/21/00

CN-00-07

Initial Issue n/a n/a

n/a 12/29/00

CN-00-30

EP SDP has been revised to include guidance for 

implementing EP SDP, which was not included in the 

initial issuance of this appendix. Revisions to the 

guidance was made based on regional comments.

n/a n/a

n/a 03/06/03

CN-03-07

EP SDP has been revised to incorporate lessonslearned and to provide a white path for the risk 

significant planning standards. This revision also 

more closely aligns the EP Cornerstone with the 

other cornerstones. 

n/a n/a

n/a ML120090270

02/24/12

CN 12-003

A complete re-write of the EP SDP initiated to 

address (1) new EP rule-making, (2) incorporate 

lessons-learned, (3) address use of EP SDP for 

assessing significance for traditional enforcement 

violations, (4) incorporate regional comments, (5) 

implement a new assessment protocol for 

§50.47(b)(4) findings, and (6) editorial reformatting to 

improve usability.

November 8, 2011 

via VTC. All regional 

EP inspectors 

participated
Issue Date: 09/22/15 Att3-2 0609, Appendix B

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)

ML13270A478

09/23/14

CN 14-021

Note: this revision to the EP SDP was issued for 

regional review three times due to the identification 

of additional needed changes from review 

comments. Some of the proposed changes have 

since been rendered moot by other revisions. The 

comments were combined in a single resolution: The 

change listing below is a delta from the 2/24/2012 

version.

Several changes were made to the EP SDP address 

experience in implementing the 2/24/2012 revision: 

(1) References to §50.72 in the definition of 

REGULATORY REQUIRE-MENT were omitted as 

the failure to make a required report is not a PD 

under the EP Cornerstone and is treated under TE; 

(2) conforming changes for (1); (3) changed “EAL IC” 

in §5.4 to read “EAL” to remove confusion; (4) 

additional guidance was added to §5.8 regarding 

TSC/EOF habitability and examples were revised;

The changes to the 

EP SDP have been 

discussed with 

regional personnel 

through 

presentations at the 

annual EP 

counterpart meetings 

(most recent: May 

2013)

ML14209B024
Issue Date: 09/22/15 Att3-3 0609, Appendix B

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)

(5) In §§5.6, 5.8, 5.9, and 5.10 changed “in absence of 

COMPENSATORY MEASURES” to read “and no 

COMPENSATORY MEASURES were implemented,” to 

address mistaken interpretation of the original 

language; (6) revised several examples in §5.8 to 

replace the emphasis on the ability of one key ERO 

member with an emphasis instead on the facilities’ 

ability to perform principal functional areas of 

emergency response; (7) added guidance on principal 

functional areas to §5.8. In response to comments that 

the EP SDP repeated guidance already in IMC 0612, 

made several changes: (8) omitted definitions of 

PERFORMANCE DEFICIENCY, FINDING, an 

VIOLATION, and made instances of those terms lower 

case in the text; (9) changed definition of 

REGULATORY REQUIREMENT to read EP 

REQUIREMENT to address mistaken interpretation that 

the EP SDP didn’t address findings that were not 

violations; (10) Clarified definition of WEAKNESS; 

(11) made several changes to section 3.1 and 3.2; (12) 

Section 7.0 was deleted (See IMC0612 App G); (13) 

omitted the “no finding” column from the significance 

example tables; (14) other references to “no finding” 

were modified (in footnotes) to direct the user to IMC 

0612 Appendix B and to reconsider the more-thanminor determination. Clarified “populated area” in Table 

5.10-1. 
Issue Date: 09/22/15 Att3-4 0609, Appendix B

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)

ML15128A462

09/22/15

CN 15-017

Changes made to significance examples in Table 5.10-

1 to provide an example for an over-conservative PAR. 

Conforming changes made to other examples in this 

table. Addresses issues that arose in processing 

Enforcement Action EA 15-072. Editorial changes 

made to other examples in this table for clarity

Regional EP 

specialists were 

made aware of this 

changes during the 

development of the 

change and during 

the comment 

period. Changes 

were also 

discussed during 

monthly

counterpart calls. 

07/09/2015

ML15190A137