Issue Date: 07/21/16 1 71114.07

NRC INSPECTION MANUAL NSIR/DPR

INSPECTION PROCEDURE 71114 ATTACHMENT 07

EXERCISE EVALUATION - HOSTILE ACTION (HA) EVENT

Effective Date: 10/01/2016

PROGRAM APPLICABILITY: 2515 A

71114.07-01 INSPECTION OBJECTIVE

To evaluate the adequacy of the licensee’s ability in a hostile action (HA) environment to; 

implement mitigative measures in response to a simulated attack on site that is sufficient to 

create the loss of a large area of the site due to physical damage and/or unknown security state;

coordinate Security, Operations, emergency response organization (ERO) and offsite response 

organization (ORO) required actions to successfully respond to and mitigate plant damage 

before local law enforcement agencies are able to declared the site secure; and its capability to 

assess performance via a formal critique process in order to identify and correct weaknesses.

Note: If the exercise is being observed or audited by Institute of Nuclear Power Operations 

(INPO) refer to the emergency preparedness appendix of the memorandum of agreement 

between INPO and the U.S. Nuclear Regulatory Commission (NRC) (ADAMS ML13129A093) 

for exercise evaluation interface expectations. 

71114.07-02 INSPECTION REQUIREMENTS

02.01 Confirm that: the licensee has submitted its biennial exercise scenario, Attachment 

71114.08, “Scenario Evaluation” has been completed, and any concerns have been provided to

the licensee.

02.02 Prepare for the HA event biennial exercise inspection. A HA event exercise is required 

for each licensee site at least once in the exercise cycle, including each licensee at a co-located 

site.

02.03 Review corrective actions identified as a result of the previous drill and exercise 

critiques, beginning with the previous biennial exercise and the previous HA event exercise 

critique to identify any unique hostile action event corrective actions. Develop a list of 

performance areas to be observed during the exercise. If applicable, 10 CFR 50.54(hh)(1) & (2) 

scenario activities should be observed and evaluated. At a minimum, all previously identified 

risk-significant planning standard (RSPS) corrective actions shall be reviewed and noted for 

observation during the exercise.
Issue Date: 07/21/16 2 71114.07

02.04 Perform independent observations of licensee’s performance in classification, 

notification, protective action recommendation (PAR) development, onsite protective actions 

and dose assessment activities and as many other aspects of performance as resources allow, 

in the HA event environment. Observe the licensee’s coordination of Security, Operations, ERO 

and ORO actions. In the case of co-located licensees, verify licensee compliance with the 

requirements of 10 CFR 50, Appendix E, paragraph IV.F.2.c concerning the continuance of 

certain activities in the period between biennial exercises.

02.05 If the exercise scenario contains demonstration of strategies, procedures, and/or

guidance developed under § 50.54(hh)(1) and or (2) observe and evaluate the implementation 

of these activities.

02.06 Note any weaknesses observed by the inspection team not appropriately identified by 

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

02.07 Identify recurring weaknesses noted in similar activities from previous evaluated 

exercise(s) for corrective action effectiveness.

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

requirement.

02.09 Determine whether the licensee has demonstrated reasonable assurance of its 

capability to effectively implement the emergency plan in a HA event environment and 

adequately protect public health and safety.

02.10 Represent the NRC at the Federal Emergency Management Agency (FEMA) public 

meeting as negotiated.

02.11 Review the proposed offsite exercise deficiencies (if any) provided by FEMA and inform 

the licensee of those deficiencies. 

71114.07-03 INSPECTION GUIDANCE

The focus of this inspection is to evaluate the adequacy of the licensee’s ability to: conduct a 

biennial exercise in a HA event environment, assess performance via a formal critique process 

and identify and correct weaknesses. Emphasis should be placed on licensee assessment of 

classification, notification, PAR development, dose assessment activities, ability to adequately 

protect employees and emergency workers, and to coordinate with offsite officials located at the 

Incident Command Post in the HA event environment. Inspectors should evaluate as many 

other aspects of performance and the critique as resources allow. The following section 

provides methods and examples of how the inspection requirements of this procedure could be 

completed. Use of the following guidance is at the discretion of the inspector. 
Issue Date: 07/21/16 3 71114.07

03.01 Biennial Exercise Scenario Submittal.

a. Confirm that: the licensee has submitted its biennial exercise scenario, Attachment 

71114.08, “Scenario Evaluation” has been completed, and any concerns have been 

provided to the licensee for resolution. 

b. Failure to submit the scenario 60 days prior to the exercise should be evaluated as an 

apparent violation of Appendix E to Part 50, §IV.f.(2)(b). Failure of the licensee to 

address the concerns prior to the exercise may be a factor in determining whether a 

remedial exercise is warranted. (See 03.09 below.)

03.02 Prepare for the Biennial Exercise Inspection.

Note: The licensee is required to submit its biennial exercise scenario for prior NRC review and 

verification. A review of the submitted scenario is performed under Attachment 71114.08, 

“Scenario Evaluation.” 

a. Review the scenario for a summary understanding. 

b. Ensure there is a consistent pre-exercise understanding of the expected decisions for 

DEP PI opportunities and extent of exercise demonstration/simulation between the 

inspection team and the licensee.

c. Develop a plan to deploy inspection resources in a manner to observe classification, 

notification, PAR development and dose assessment activities, a review Drill and 

Exercise Performance (DEP) performance indicator (PI) failures and adverse trends will 

help to inform what specific areas should be observed. If available, deploy a security 

inspector to the central alarm station/secondary alarm station or the Incident Command 

Post.

d. Review the Emergency Plan and Emergency Plan Implementing Procedures (EPIPs) 

that provide instructions for HA event environment classification, notification, PAR 

development and dose assessment activities, and other functional areas relevant to the 

exercise. Develop an understanding of the criteria for timely and accurate completion 

of these activities based on EPIPs, the scenario, NSIR/DPR-ISG-01 §IV.H, “Interim 

Staff Guidance: Emergency Planning for Nuclear Power Plants,” and NEI 99-02, 

Regulatory Assessment Performance Indicator Guideline.” Ensure that the Plan and 

EPIPs contain criteria concerning protective actions for non-essential onsite personnel, 

including evacuation for Site Area Emergencies and General Emergencies. [C2]

e. Consider the prioritization guidance provided in Attachment 1 “Prioritization of 

Additional Areas for Inspection,” to develop a plan to deploy inspection resources to 

observe other activities as practical. Selection of other areas for inspection should be

based on resource availability, past history, efforts to correct weaknesses and/or 

logistical limitations.
Issue Date: 07/21/16 4 71114.07

f. Schedule a briefing of the inspection team by licensee personnel before the exercise to 

discuss exercise content/conduct and any late scenario revisions. This is an 

opportunity to ask questions regarding the scenario, licensee expectations for judging 

timely and accurate DEP PI opportunities, logistics, mentor arrangements, shift 

changes, etc.

g. Oversight of co-located licensees introduces unique inspection requirements. See 

Section 03.03 for additional details.

03.03 Review Past Weaknesses and Corrective Actions.

a. Review previously identified weaknesses and corrective actions from licensee 

drill/exercise reports, quality assurance audits, and NRC exercise inspection reports 

since the last biennial exercise and individual DEP PI inputs below the quarterly 

reported value. This action does not replace the review of corrective actions performed 

under IP 71114.05, but rather, is to identify those weaknesses and corrective actions 

that can best be evaluated in the context of an emergency exercise as opposed to a 

program inspection, such as ERO performance weaknesses.

b. Select a sample of ERO performance and equipment-related weaknesses resolved, for 

inspection during the biennial exercise. Inspection resources should be allocated to the 

risk-significant areas first, but if there are important weaknesses in other areas, an 

attempt should be made to allocate resources in a manner that will allow inspection of 

those areas also. Use the prioritization guidance provided in Attachment 1

“Prioritization of Additional Areas for Inspection,” to identify other areas for inspection.

03.04 Perform Independent Observations of Licensee Performance.

a. Perform an evaluation of the licensee’s planned range of protective actions to protect 

onsite personnel during a hostile action and the procedural guidance for onsite 

protective action decision making. The review should include the following elements:

1. Do onsite protective actions clearly distinguish between actions taken for a 

credible threat versus active hostile action? 

2. Does the licensee have a decision making tool (e.g., procedure, logic charts, 

etc.) to aid the shift manager in rapidly determining the optimum protective action 

for onsite personnel during a hostile action? 

3. Does the range of protective actions include provisions for the following:

 Evacuation of onsite personnel from target buildings?

 Site evacuation by opening security gates while continuing to defend the 

gates?

 Dispersal of licensed operators?
Issue Date: 07/21/16 5 71114.07

 Sheltering of personnel in structures away from potential site targets?

 Arrangements for accounting for personnel after the attack?

 Is specific equipment, material, buildings or areas, readily available and in 

adequate quantity and condition to support the expected usage.

 Is access to shelter structures readily available 24/7? 

b. Observe licensee performance in classification, notification, PAR development, dose 

assessment activities, prompt dispatch of liaisons to the incident command post (ICP)

knowledgeable in plant operations, radiation protection, and plant security.

c. Observe the following as resources permit:

 Demonstration of the capabilities of site security to interface with the emergency 

operation facility (EOF), operational support center (OSC), technical support 

center (TSC) and control room.

 Support of and interface with an ICP to facilitate the transfer of plant information 

and coordination of response activities. 

 The use of the alternative emergency response facilities for activation of the

ERO.

 Actions taken to shelter personnel from armed attack or aircraft attack 

 Conduct of operations and repair activities during site conditions that prevent 

normal access due to fire, locked doors or security measures such as areas that 

have not yet been secured.

 Rescue of and medical attention for significant numbers of personnel.

 Prioritization and urgency (e.g. restore offsite power within 4 hours) of efforts to 

protect plant equipment or to secure access to plant areas for repairs.

 Response coordination and site access established between on-shift personnel 

and ORO first responders.

 Coordination and decision-making actions necessary for prompt mobilization or 

relocation of the ERO in a HA event environment.

 Protecting a minimum contingent of operations and maintenance personnel for 

recovery 
Issue Date: 07/21/16 6 71114.07

d. Gather copies of completed forms and checklists that support or document 

classification, notification and PAR development activities and the other areas selected 

for inspection. 

e. Inspector-identified weaknesses must be held confidential until after the formal licensee 

critique. Ensure the licensee critique conclusions are complete, including management 

review, before discussing inspector observations and conclusions.

1. A weakness is defined as a level of ERO performance demonstrated during an 

exercise, drill, or training (that provide performance opportunities to develop, 

maintain, or demonstrate key skills) that would preclude effective implementation 

of the plan (i.e., loss of a planning standard function) if the weakness were to 

occur during an actual emergency.

2. A mistake or a miss-step by ERO members that only detracts from the overall 

ERO performance should generally not be treated as a 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 weaknesses in the critique is generally not 

an issue of concern. 

3. Classifications, PARs, and notifications could be accurate and timely (i.e., DEP 

PI opportunity successes) and there still be a weakness (e.g., a correct 

classification based on misinformation, a correct PAR based on an incorrect dose 

assessment). Such weaknesses need to be identified and corrected since, under 

different circumstances, they could affect functions necessary for protecting the 

health and safety of the public. 

4. Prompting of exercise participants is not a finding under the assessment process 

because it represents no risk significance in itself. However, prompting related to 

a DEP PI opportunity is basis for failing a DEP PI opportunity and should be 

documented when observed. It is also possible that extensive prompting 

throughout an exercise could question the EROs ability to satisfactory execute 

the plan. This determination would be made based on the extent of the 

prompting and involve Regional management. Failure of the critique to identify 

prompting may be a finding depending on the nature of the plan commitments for 

conduct of drills and exercises and the extent of the prompting.

f. Although observations of prompting have no risk significance in of themselves, 

prompting could prevent the identification and correction of ERO performance 

weaknesses and could negate the validity of a DEP PI opportunity. Accordingly, the 

failure of the licensee to identify the weaknesses, which would have been identified if 

not for the prompting, may be a performance deficiency that should be evaluated as a 

failure to comply and assessed for significance. Prompting may also be a basis for 

failing a DEP PI opportunity.
Issue Date: 07/21/16 7 71114.07

1. Prompting is an action by a controller or evaluator that prevents an accurate 

evaluation of a player’s performance in an evaluated exercise by masking a 

performance weakness that would have otherwise become apparent had the 

prompting not occurred. This should not be confused with an exercise inject,

which is a communication between a controller and a player that provides

information regarding simulated conditions, analysis results, instrument readings, 

etc., all of which would reasonably be expected to be self-revealing or 

discoverable, during an actual event. Injects are not an issue of concern unless 

they prevent the identification and correction of ERO performance weaknesses.

2. It is also possible that prompting throughout an exercise could be so extensive as 

to bring into question whether the exercise was a satisfactory test of the plan. 

This determination would be made in consultation with Regional management, 

and would be based on the extent of the prompting and the risk-significance of 

the associated weaknesses.

3. Even if identified in the CRITIQUE, prompting during a DEP PI opportunity 

should be considered a failure. (See ROP FAQ No. 405 dated July 21, 2005).

g. Emergency response facilities and equipment, including alternate and/or backup 

facilities, to the extent feasible, should be evaluated for readiness, while observing their 

use during the exercise, such as, but not limited to:

1. Would the alternative facility (or facilities) be assessable if the site was under 

threat or experiencing hostile action?

2. Does the alternative facility (or facilities) provide a staging area for augmentation 

of emergency response staff?

3. Does the alternative facility (or facilities) collectively have the following 

characteristics:

 The capability for communication with the emergency operations facility, 

control room, and plant security. 

 The capability to perform offsite notifications, and 

 The capability for engineering assessment activities, including damage 

control team planning and preparation for use when onsite emergency 

facilities cannot be safely accessed during hostile action

h. The activation times for emergency response facilities should be noted and evaluated 

against Plan commitments.
Issue Date: 07/21/16 8 71114.07

i. Evaluation of biennial exercises at sites with co-located licensees introduces additional 

inspection requirements. These requirements are found in 10 CFR 50, Appendix E, 

Paragraph IV.F.2.c and generally involve drills, training, and activities/interactions with 

offsite authorities (Regulatory Guide 1.101, “Emergency Response Planning and 

Preparedness for Nuclear Power Reactors,” Revision 5, June, 2005, provides additional 

guidance). The inspection plan should provide for the verification that these activities 

are conducted, properly observed, and where appropriate, critiqued by licensee 

personnel. It should be noted that NRC inspectors do not evaluate offsite agency 

performance, but will rather focus on the interface of licensee personnel with offsite 

agencies. However, any observed offsite performance weaknesses that impact the 

licensee’s ability to implement the onsite Emergency Plan should be shared with the 

FEMA evaluation team for further assessment.

03.05 Exercise includes 10 CFR 50.54(hh)(1) and or (2) strategies.

a. If the exercise scenario includes a demonstration of, or the exercise inspection week 

includes an out of sequence event demonstrating, 10 CFR 50.54(hh)(1) and or (2) 

strategies, these events, to the extent possible, should be observed and evaluated.

Note: The inspector is not expected to evaluate of the adequacy or regulatory compliance of 

the licensee’s actions and/or procedures, only the licensee’s implementation of their emergency 

plan (E-plan) commitment(s) for the 50.54(hh)(1) and or (2) strategy requirement.

03.06 Evaluate Licensee’s Identification of Weaknesses.

a. The inspectors should familiarize themselves with the licensee’s critique process and 

discuss expectations with the licensee. This discussion should include the critique 

scheduling, content, participation, and when the critique process is complete. The NRC 

considers the critique process complete when all draft conclusions related to the 

identified weaknesses have been presented to licensee senior management, and 

management questions or comments have been documented. The licensee should 

understand that the critique should not be delayed in order to address every minor 

problem identified.

b. Weaknesses associated with RSPS should be given the highest priority in the critique. 

However, all weaknesses that could preclude effective implementation of the Plan in an 

actual emergency (e.g., a failure to implement), are to be identified and corrected.

c. Licensees perform critiques in many different ways and inspectors should be flexible in 

accepting different methods of weakness identification. 

1. The critical feature of a critique is all weaknesses are identified and entered into 

a corrective action system with the appropriate priority, regardless of whether the 

weakness was verbalized at a critique meeting and in a manner that will allow 

NRC review of the resolution in the future (i.e., during subsequent biennial 

exercises).
Issue Date: 07/21/16 9 71114.07

2. For the critique to be considered acceptable, the process must give the inspector 

adequate evidence that all weaknesses have been entered into a corrective 

action system. If the inspector does not have adequate evidence that a 

weakness has or will be identified and documented in the corrective action 

system, the critique is not acceptable and a critique problem exists.

d. The inspectors should conduct a pre-critique briefing with the EP staff/management 

prior to the formal critique to discuss any non-exercise-related inspection 

observations/findings, and to obtain the licensee's preliminary critique of the exercise 

results. 

1. This meeting will aid the inspector in preparation for the formal exit meeting with 

licensee senior management which is typically conducted following the formal 

critique. 

2. The inspectors cannot share the NRC exercise observations at this meeting, 

even if they are consistent with the licensee's preliminary critique. 

3. The inspectors should stress at this meeting that, for inspection purposes, while 

the formal critique should focus on weaknesses associated with the RSPS, all 

observed weaknesses must be entered into the corrective action system. The 

inspector should discuss any change in the licensee’s preliminary critique before 

the formal critique. The balance of the critique presentation is determined by the 

licensee's process.

e. Determine if the licensee critique identified the weaknesses observed by the inspection 

team. 

1. Any inspector identified weaknesses not captured by the licensee may represent 

a critique problem, or the inspectors may have misinterpreted exercise 

participants’ activities, or failed to observe a portion of those activities. It may be 

appropriate to discuss such problems with cognizant licensee staff and 

management before the formal critique. 

2. Licensee critique problems shall be documented and assessed for significance. 

Failures of the licensee evaluation should be addressed during the NRC exit 

meeting. 

3. The licensee will evaluate numerous evaluator observations, identify which 

observations rise to the level of a weakness, and prioritize resources to correct 

them. Ensure a complete understanding of the logic underlying the licensee’s 

disposition before identifying any as a critique problem. If an evaluator-identified 

weakness is improperly dispositioned and not entered into the corrective action 

system, a critique problem exists, since the licensee is required to enter identified 

weaknesses into a corrective action system.
Issue Date: 07/21/16 10 71114.07

03.07 Identify Recurring Weaknesses.

a. Using previous drill and exercise reports or assessments beginning with the previous 

biennial exercise, determine if weaknesses identified by the inspectors and/or the 

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

weakness. 

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

into the corrective action system. 

2. Identification of a failure to correct a drill or exercise weakness requires a 

detailed review of the weakness and the associated corrective actions. A single 

repeat of a weakness should not automatically be deemed a failure of the

corrective action system. Conversely, a single success in a drill or exercise (e.g., 

by one well-drilled team) should not necessarily be considered a demonstration 

of problem resolution.

b. When a previously identified weakness recurs in a subsequent drill or exercise, the 

inspector should perform an assessment of the effectiveness of the prior corrective 

actions based on a complete history of the issue. The intent of this assessment is to 

see if there is a pattern of recurring performance problems in similar activities in order 

to identify ineffective corrective actions. To obtain a reasonably complete picture of the 

current problem, the inspector should: 

1. Review specific corrective actions identified for the previous weakness. 

2. Consider the status of the DEP PI, as well as the status of the individual DEP PI

inputs.

3. Review corrective action, self-assessment, and inspection records for the 

inspection cycle with emphasis on similar performance deficiencies. 

4. Review the associated root cause and extent of condition analysis.

5. Verify completion of associated corrective actions. 

6. Look for similar occurrences during responses to prior actual events, drills, 

exercises, and training evolutions.

03.08 Identify Failures to Comply with Regulatory Requirements.

a. During an exercise (or actual event) a failure to implement a planning standard does not 

necessarily indicate a failure to meet the planning standard. However, serious failures 

may indicate a programmatic problem worthy of additional review. Performance 

problems may reflect a deterioration of the EP program element to a point that the 

applicable planning standard is no longer met.
Issue Date: 07/21/16 11 71114.07

b. The licensee’s performance during an exercise may uncover issues of concern 

regarding the effectiveness and adequacy of the program elements that comprise the 

licensee’s emergency plan. For example, the ERO may be unable to classify a 

particular emergency because the emergency action level scheme threshold was 

greater than the monitor is capable of displaying.

c. Weaknesses are defined in the context of ERO performance during an exercise. A 

program element concern related to the effectiveness and adequacy of the plan, or it’s 

implementing procedures1, observed during an exercise is not an exercise weakness. 

Instead this issue should be evaluated as an apparent failure to comply with the 

associated 10 CFR 50.47(b) planning standards and Appendix E requirements and 

assessed for significance in accordance with the EP significance determination process 

(SDP). 

1. Review the history of identified weaknesses to obtain relevant information. 

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

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

regional management for direction. 

3. The concern and the results of the additional review should be communicated to 

the licensee, documented and assessed for significance through the EP SDP.

d. If either the Plan or procedures are inadequate, it is not a drill/exercise critique issue, it 

is a failure to comply with a planning standard and the significance planning standard 

should then be assessed for significance through the EP SDP.

03.09 Evaluate Exercise against EP Cornerstone Performance Expectation.

a. The baseline inspection program is predicated on the EP Cornerstone Performance 

Expectation. The inspectors should determine that the conduct of the exercise supports 

the finding that the EP program meets the Performance Expectation: “Demonstration 

that reasonable assurance exists that the licensee can effectively implement its 

Emergency Plan to adequately protect the public health and safety in the event of a 

radiological emergency.”

b. Section IV.F.2.f of Appendix E to 10 CFR 50, provides the requirements for a remedial 

exercise, required if the Emergency Plan is not satisfactorily tested during the biennial 

exercise such that the NRC cannot find reasonable assurance that adequate protective 

measures can be taken in the event of a radiological emergency. Not invoking this 

regulation implies that the inspection team came to the conclusion that the Plan was 

satisfactorily tested. If the exercise was not a satisfactory test of the Plan or problems 

have been identified which potentially could result in a remedial exercise, the inspectors 

will obtain management review, and any subsequent action would not be decided by 

the inspection team alone.

 

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

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

implementation. 
Issue Date: 07/21/16 12 71114.07

03.10 Represent the NRC at the FEMA Public Meeting.

Note: For licensee locations that have multiple FEMA regions involved in the exercise 

evaluation, the inspector will need to determine which FEMA Public Meeting(s) can be attended 

based on inspection resources, schedules, etc.

a. The lead inspector, or alternate, should represent the NRC at the FEMA public meeting. 

A statement should be made as to the adequacy of exercise conduct from the NRC 

perspective. Potential findings against the licensee’s program (i.e., against the exercise 

critique) as a result of the inspection should not be announced at the public meeting. 

1. For a successful demonstration a statement such as:

“The preliminary observation of the inspection team is that conduct of the

exercise was adequate to demonstrate the licensee’s compliance with the EP 

Cornerstone Performance Expectation and demonstrates reasonable assurance 

exists of the licensee ability to effectively implement its Emergency Plan to 

adequately protect the public health and safety in the event of a radiological 

emergency.” 

2. For an unsuccessful demonstration, or for one that a determination has yet to be 

made (i.e. prior to the exercise, the NRC was made aware of change(s) made to 

the licensee’s emergency plan that the NRC has not had the opportunity to 

review) a statement such as:

“The NRC inspection team was not able to conclude its review of the exercise at 

this time. The NRC will continue to review the available information before 

issuing an official inspection report.” 

03.11 Review FEMA-identified Exercise Deficiencies. [C1]

a. Request NRC Headquarters to promptly inform the regional office of any potential 

deficiencies and remedial actions when notified by FEMA Headquarters per the 

“NRC/FEMA Memorandum of Understanding.”

b. Upon receipt of the letter providing official notification of offsite exercise deficiencies, 

review the proposed deficiencies and their bases for under-standing. FEMA review and 

findings are entitled to a presumption of adequacy and are to be taken at face value. If 

the basis for any deficiency is not clear or if the reviewer is aware of information to the 

contrary, obtain clarification from NRC Headquarters staff, Regional State Liaison 

Officers (RSLOs), or regional FEMA staff.

c. Inform the licensee of offsite deficiencies via formal letter.
Issue Date: 07/21/16 13 71114.07

71114-07-04 RESOURCE ESTIMATE

Direct inspection effort for this attachment is estimated to be, on average, between 54 hours 

and 74 hours, regardless of the number of reactor units at a site. If the resident inspector is 

participating as an evaluator, approximately 20 percent of the hours represent residents’ effort 

and 80 percent of the hours represent EP specialists’ effort. If the resident inspector is not 

participating as an evaluator no time is to be allotted.

When the inspection involves a co-located licensee biennial exercise, an additional 16 hours for 

an EP Specialist is estimated to be necessary, regardless of the number of reactor units at a 

site.

71114-07-05 PROCEDURE COMPLETION

The performance of this IP meets the IP 71114.01 requirement to evaluate the adequacy of the 

licensee’s conduct of the biennial exercise and its capability to assess performance via a formal 

critique process in order to identify and correct weaknesses. Routine reviews of problem 

identification and resolution activities performed in this attachment should equate to 

approximately 10 to 15 percent of the resource estimate range described above. This IP is

performed in place of IP 71114.01 at each power reactor site when a Hostile Action Based 

evaluated exercise is demonstrated. Performance of this inspection procedure is to be reported 

as sample size of one to IP 71114.07 for RPS purposes.” Regions should use note 5 in RPS, 

“not applicable – completion not required during this inspection cycle” when this inspection 

procedure is not required to be performed.

71114.07-06 REFERENCES

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

Order EA-02-026, “Order for Interim Safeguards and Security Compensatory Measures,” 

February 25, 2002

SECY-03-0165, “Evaluation of Nuclear Power Reactor Emergency Preparedness Planning 

Basis Adequacy in the Post-9/11 Threat Environment,” September 22, 2003 (ML031960020)

RG 1.214, “Response Strategies for Potential Aircraft Threats.” 

71111.05T, “Fire Protection (Triennial)” – contains 10 CFR 50.54(hh)(2) capabilities

Bulletin 2005-02, “Emergency Preparedness and Response Actions for Security-Based Events,” 

July 18, 2005 (ML051990027)

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

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

And First Responders (ML070710233)
Issue Date: 07/21/16 14 71114.07

IN 02-25, “Challenges to Licensees’ Ability to Provide Prompt Public Notification and Information 

During an Emergency Preparedness Event,” August 26, 2002

RIS 2004-15, “Emergency Preparedness Issues: Post-9/11,” October 18, 2004

NEI 06-04, “Conducting a Hostile Action-based Emergency Response Drill” Appendix A, “Drill 

and Exercise Objectives” Rev 2

NEI White Paper, “Enhancements to Emergency Preparedness Programs for Hostile Action,” 

May 2005 (Revised November 18, 2005)

Memorandum of Agreement Between the Institute of Nuclear Power Operations and the U.S. 

Nuclear Regulatory Commission dated September 11, 2013 (ML13129A093)

END
Issue Date: 07/21/16 Att1-1 71114.07 

ATTACHMENT 1

PRIORITIZATION OF ADDITIONAL AREAS FOR INSPECTION

General

In general, the U.S. Nuclear Regulatory Commission’s (NRC’s) oversight in emergency 

preparedness (EP) is focused on adherence to the emergency plan (E-Plan) with an emphasis 

on these most risk-significant areas, and inspection resources should be deployed in a manner 

to cover these areas. However, within the constraint of resources, a broad range of response 

areas should be inspected. 

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

resources accordingly. Areas, (e.g., operations support center, field monitor teams) that have 

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

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

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

observe other areas. 

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

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

performance under the DEP PI indicates reliable acceptable performance within the licensee 

response band, inspectors should reduce the inspection sampling in those areas and instead 

use a portion of available inspection resources to sample a selection of less risk significant 

areas as described below. 

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

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

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

The inspector should remain alert to the impact that the licensee’s performance in less risksignificant areas (e.g., staffing and training, etc.) may have on the licensee’s performance in the 

risk-significant areas. 

Prioritization of Additional Areas for Inspection

Guidance for deployment of inspection resources beyond the most risk-significant areas is 

provided below. These areas may generally be considered in order of importance. Selection 

for deployment of inspection resources should be based on knowledge of the program, previous 

problems and logistics.

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

authorization and thyroid protection, including actions during a hostile action 

[10 CFR 50.47(b)(10) & (11) and Sections IV.E and IV.I of Appendix E to 10 CFR 50].
Issue Date: 07/21/16 Att1-2 71114.07 

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

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

Appendix E to 10 CFR 50].

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

hostile actions, at the licensee’s site [10 CFR 50.47(b)(6) and Section IV.A.7 of 

Appendix E to 10 CFR 50].

d. Ability to formulate mitigating actions.

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

safety.

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

conditions.

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

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

addressed in the risk-significant area discussion.

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

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

j. Accuracy and completeness of licensee-approved press releases [10 CFR 50.47(b)(7)].
Issue Date: 07/21/16 Att2-1 71114.07 

ATTACHMENT 2 - Revision History for IP 71114.07

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

(Per-Decisional, NonPublic Information)

N/A

C1

C2

ML12100A229

05/29/12

CN 12-008

06/29/06

New Procedure

Completed four-year historical CN search.

Provide guidance for staff review and 

understanding of DHS deficiencies. (10/26/05, 

SRM to SECY-05-0045 (ML052990321)

Add previously deleted inspection requirement 

considered necessary for the baseline 

inspection program. (09/09/01, “Davis-Besse 

Lessons Learned Task Force” (ML101060482) 

Item No. 3.3.4.7.

Complete rewrite of document structure to 

better align it with MC 0612 and SDP 

Appendix B, additions to meet two 

commitments, change in requirements for 

co-located sites, add revision history page. 

Yes - Provided at EP 

Face to Face 

counter-part meeting 

09/09/2011

None

None

ML12100A238

N/A

ML061580338
Issue Date: 07/21/16 Att2-2 71114.07 

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

(Per-Decisional, NonPublic Information)

N/A ML15239A817

07/21/16

CN 16-017

Added “Note” to the Inspection Objective 

section describing expected actions for a 

biennial evaluated exercise at which INPO will 

be observing or auditing.

Added – inspection requirement and guidance 

to confirm the biennial exercise scenario

submission and completion of Attachment 

71114.08, “Scenario Evaluation”.

Deleted last sentence from 03.02.d “If the 

exercise scenario includes an aircraft attack 

review Fire Protection Triennial IP 71111.05T 

for additional guidance on expected licensee 

capabilities.” No requirement for demonstration 

of licensee capabilities in an aircraft attack 

scenario.

Added - guidance step 03.10.a for public 

meeting statement option for situations where

e-plan changes that may have created an RIE

have not yet been reviewed.

Changed resource estimate from 78-98 hours 

to 54-74 to align with IP 71114.01

None Comment Resolution 

– ML15239A819
Issue Date: 07/21/16 Att2-3 71114.07 

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

(Per-Decisional, NonPublic Information)

Added MOA between INPO and NRC, and IP 

71111.05T “Fire Protection (Triennial)” to the 

“References” section.

Feedback Form 71114-1925 - Align procedure 

to section numbering format in IMC-0040

Editorial change – reformatted Attachment 1 

“Prioritization Of Additional Areas For 

Inspection” and reordered additional areas for 

inspection based on branch chief comments.

Added to section 71114.07-05 “Procedure 

Completion” the IP 71152 “Problem 

Identification and Resolution” expectation for 

routine PI&R activity reviews to be 

approximately 10 to 15 percent of the baseline 

cornerstone inspection procedure resources 

estimates. The 10 to 15 percent approximation 

is based on the overall expected inspection 

effort and is a general estimate only. 

Feedback Form –

71114.07-1925 

(ML15239A861)