Issue Date: 08/24/04 APP C6-1 1245

Appendix C-6

Emergency Preparedness Inspector 

Technical Proficiency 

Training and Qualification Journal
1245 C6-2 Issue Date: 08/24/04

PAGE INTENTIONALLY BLANK
Issue Date: 08/24/04 APP C6-3 1245

Table of Contents

Introduction ......................................................... 5

Required Emergency Preparedness Inspector Training Courses ............. 5

Supplemental Post Qualification Emergency Preparedness Inspector Training

Courses: ...................................................... 5

Required Emergency Preparedness Inspector Refresher Training ............ 5

Emergency Preparedness Inspector Continuing Training ...................... 5

Emergency Preparedness Individual Study Activities .......................... 7

(ISA-EP-1) Code of Federal Regulations for Emergency Preparedness

Inspectors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

(ISA-EP-2) Licensee Emergency Plan Documents . . . . . . . . . . . . . . . . . . . . . 11

(ISA-EP-3) Preparation and Evaluation of Radiological Emergency Response

Plans and Preparedness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

(ISA-EP-4) Functional Criteria for Emergency Response Facilities . . . . . . . . 17

(ISA-EP-5) TMI Action Plan Requirements

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

(ISA-EP-6) Manual of Protective Action Guides and Protective Actions for

Nuclear Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

(ISA-EP-7) RTM-96, Response Technical Manual . . . . . . . . . . . . . . . . . . . . . 23

(ISA-EP-8) NUMARC/NESP-007, Methodology for Development of Emergency

Action Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

(ISA-EP-9) NUREG 0396, Planning Basis for the Development of State and

Local Government Radiological Emergency Response Plans in Support of

Light Water Nuclear Power Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

(ISA-EP-10) NUREG/CR-5247, RASCAL User’s Guide . . . . . . . . . . . . . . . . . 29

(ISA-EP-11) Emergency Preparedness Position (EPPOS) Papers . . . . . . . . . 31

(ISA-EP-12) Emergency Preparedness Significance Determination Process

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

Emergency Preparedness On-the-Job Activities . . . . . . . . . . . . . . . . . . . . . . . . . . 37

(OJT-EP-1) Alert and Notification System Testing . . . . . . . . . . . . . . . . . . . . . 39

(OJT-EP-2) Emergency Response Organization Augmentation . . . . . . . . . . . 43

(OJT-EP-3) Emergency Action Level and Emergency Plan Changes . . . . . . . 47

(OJT-EP-4) Correction of Emergency Preparedness Weaknesses and

Deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

(OJT-EP-5) Performance Indicator Verification . . . . . . . . . . . . . . . . . . . . . . . 57

(OJT-EP-6) Performance Indicator Verification: Drill and Exercise Performance

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

(OJT-EP-7) Performance Indicator Verification: Emergency Response

Organization Drill Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

(OJT-EP-8) Performance Indicator Verification: Alert and Notification System

Reliability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69
1245 C6-4 Issue Date: 08/24/04

(OJT-EP-9) Emergency Drill/Exercise Evaluation . . . . . . . . . . . . . . . . . . . . . . 73

Emergency Preparedness Inspector Technical Proficiency Level Signature Card

and Certification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79

Form 1: Emergency Preparedness Inspector Technical Proficiency Level Equivalency

Justification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81
Issue Date: 08/24/04 APP C6-5 1245

Introduction

Do not begin the activities or complete the courses in this qualification journal until you

have completed the Basic Inspector Certification Journal. You may complete the General

Proficiency requirements contained in Appendix B together with the Technical Proficiency

requirements outlined in this journal.

Before signing up for any course, be sure that you have checked and have met any

prerequisites.

Required Emergency Preparedness Inspector Training Courses:

(Require the completion of Appendix A)

(R-104B) - GE Technology |

(R-104P) - Westinghouse Technology |

(H-203) - Emergency Preparedness Technology 

Additional Emergency Preparedness Inspector Training Courses:

(This course DOES NOT require the completion of Appendix A but you must meet any

course prerequisites.)

(E-110S) - Power Plant Engineering (self-study of selected chapters)

Supplemental Post Qualification Emergency Preparedness Inspector Training

Courses:

These courses ARE NOT required for initial qualification. Attendance at courses will be

determined by your supervisor and is dependent on your previous work experience and

planned inspection activities (e.g., lead EP inspector, RAC member). Registration for

these courses must be requested through the NRR Program Branch responsible for

Emergency Preparedness.

(H-303) - Radiological Emergency Response and Operations

(H-306) - Radiological Emergency Planning

Required Emergency Preparedness Inspector Refresher Training

None identified

Emergency Preparedness Inspector Continuing Training

(H-402) - Emergency Preparedness Special Topics
1245 APP C6-6 Issue Date: 08/24/04

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Issue Date: 08/24/04 APP C6-7 1245

Emergency Preparedness Individual Study Activities
1245 APP C6-8 Issue Date: 08/24/04

PAGE INTENTIONALLY BLANK
Issue Date: 08/24/04 APP C6-9 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-1) Code of Federal Regulations for Emergency

Preparedness Inspectors

PURPOSE: The purpose of this activity is to familiarize you with the regulations

having direct application to emergency preparedness inspections.

By ensuring that the facility licensee is in compliance with the

provisions delineated in the Code of Federal Regulations we

determine whether a licensee is meeting the Emergency

Preparedness Cornerstone Objectives. 

COMPETENCY

AREA: REGULATORY FRAMEWORK

TECHNICAL AREA EXPERTISE

LEVEL OF

EFFORT: 16 hours

REFERENCES: 1. 10 CFR 50.47

2. 10 CFR 50.54(q-u)

3. 10 CFR 50 Appendix E

4. 10 CFR 100

5. 44 CFR Parts 2, 350-352

EVALUATION

CRITERIA: At the completion of this activity you should be able to:

1. Describe each of the (16) Planning Standards for an

emergency response plan.

2. Discuss which Planning Standards are risk significant. 

3. Contrast the responsibilities of the facility licensee for

emergency preparedness with those of the State and local

organization.

4. Describe the significance of Section IV.F.4.g. of Appendix E

to 10 CFR 50 as it relates to the correction of EP

weaknesses and deficiencies.

5. Describe the requirements of making changes to the

licensee’s emergency plans as provided for in 10 CFR

50.54(q).

6. Describe the audit requirements of 10 CFR 50.54(t).

7. Describe the 10 CFR 100 limits for exposure to the general

public during an event.
1245 APP C6-10 Issue Date: 08/24/04

8. Give an overview of the FEMA’s responsibilities for offsite

planning and response for nuclear power plants.

TASKS: 1. Review pertinent sections of 10 CFR 50 to familiarize

yourself with the standards for emergency planning.

2. Review 10 CFR 100, Reactor Site Criteria, to become

familiar with the definitions and requirements for the

exclusion area, low population area, and populations center

distance.

3. Review 44 CFR Parts 2, 350-352 to gain an understanding

of FEMA’s responsibilities for off site planning. 

4. Meet with your supervisor or qualified EP inspectors to

discuss any questions you might have.

DOCUMENTATION: Emergency Preparedness Proficiency Level Qualification

Signature Card Item ISA-EP-1
Issue Date: 08/24/04 APP C6-11 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-2) Licensee Emergency Plan Documents

PURPOSE: The purpose of this activity is to become familiar with examples of

an Emergency Plan and supporting licensee documents. 

Supporting documents are used to either implement the Plan

during a drill/exercise/actual emergency event; to maintain

emergency response facilities and equipment in an acceptable

state of operational readiness; or, to gather and assess

performance indicator information.

COMPETENCY

AREA: TECHNICAL AREA EXPERTISE 

LEVEL OF

EFFORT: 40 hours

REFERENCES: Emergency Plan

Emergency Plan Implementing Procedures (EPIP)

Site-specific Emergency Action Levels (EAL) technical bases

document

Emergency Plan equipment inventory and surveillance procedures

Emergency Response Organization (ERO) training program

procedures

Procedures for compiling and self-assessing records of emergency

preparedness Performance indicators (PI)

Plume exposure pathway Emergency Planning Zone (EPZ)

evacuation time estimates study

Relevant Technical Specifications

Relevant sections of the USAR

EVALUATION

CRITERIA: At the completion of this activity, you should be able to:

1. Discuss how a designated licensee’s Emergency Plan was

organized and designed to satisfy emergency preparedness

regulatory requirements and guidance.

2. Discuss how this licensee’s Emergency Plan commitments

would be implemented and fulfilled through its use of EPIPs.
1245 APP C6-12 Issue Date: 08/24/04

3. Discuss how this licensee developed and maintains sitespecific EALs consistent with regulatory requirements and

applicable regulatory guidance.

4. Discuss how this licensee has proceduralized equipment

inventory and surveillance tests to ensure that its emergency

response facilities and equipment would be maintained in an

acceptable state of operational readiness per Emergency

Plan commitments. 

5. Discuss how this licensee has established an ERO training

program to meet regulatory requirements and to fulfill

Emergency Plan commitments. 

6. Discuss the licensee procedures for gathering and selfassessing its records for emergency preparedness PI

submittals to NRC.

7. Discuss a licensee’s evacuation time estimates study for its

site’s plume exposure pathway EPZ.

8. Identify and discuss a designated licensee’s Technical

Specifications that are related to maintaining its Emergency

Plan commitments.

9. Identify and discuss sections of the USAR that are related to

Emergency Plan commitments. 

TASKS: 1. Review copies of an operating power reactor licensee’s

Emergency Plan designated by your supervisor.

2. Review copies of the same licensee’s EPIPs.

3. Review the same licensee’s technical bases document for its

site-specific EALs.

4. Review the same licensee’s procedures for inventories and

surveillance tests that would be done to maintain its

emergency response facilities and equipment in an

acceptable state of operational readiness.

5. Review the same licensee’s procedures for training its

personnel on their assigned emergency response duties.

6. Review a designated licensee’s procedures for compiling

and self-assessing records related to its periodic emergency

preparedness PI submittals to NRC.

7. Review a designated licensee’s evacuation time estimates

study for its site’s plume exposure pathway EPZ.
Issue Date: 08/24/04 APP C6-13 1245

8. Review a designated licensee’s Technical Specifications for

statements on its emergency plan commitments.

9. Review a designated licensee’s USAR for sections on its

emergency plan commitments.

DOCUMENTATION: Emergency Preparedness Proficiency Level

Qualification Signature Card Item ISA-EP-2
1245 APP C6-14 Issue Date: 08/24/04

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Issue Date: 08/24/04 APP C6-15 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-3) Preparation and Evaluation of Radiological Emergency

Response Plans and Preparedness

PURPOSE: The purpose of this activity is to acquaint you with the criteria used

by NRC licensees, State and local governments to develop

radiological emergency plans and improve emergency

preparedness. A major portion of NUREG-0654 parallels and

amplifies the 16 planning standards listed in 10 CFR 50.47(2)(b). It

also provides guidance for an acceptable emergency action level

scheme, the alert and notification system, and evacuation time

estimates.

COMPETENCY 

AREA: INSPECTION

TECHNICAL AREA EXPERTISE

LEVEL 

OF EFFORT:16 hours

REFERENCES: NUREG-0654/FEMA-Rep-1, Revision 1, “Criteria for Preparation and

Evaluation of Radiological Emergency Response Plans and

Preparedness in Support of Nuclear Power Plants”

Licensee Emergency Plans

EVALUATION 

CRITERIA: At the completion of reviewing this document, you should be able

to:

1. Discuss key elements of the planning basis

2. Discuss the general topics of the planning standards

3. Discuss the difference between the four emergency

classification levels in terms of safety significance to the

public

4. Discuss the key functions performed by the licensee and

offsite agencies at the various classification levels

5. Discuss purpose, acceptance criteria, design and operation

of the notification system

TASKS: 1. Obtain copy of NUREG-0654

2. Read Section I, and Appendices 1,3, and 4. Review Section

II
1245 APP C6-16 Issue Date: 08/24/04

3. Meet with supervisor or qualified EP inspector to discuss any

questions and review the evaluation criteria.

DOCUMENTATION: Emergency Preparedness Proficiency Level Qualification

Signature Card Item ISA-EP-3
Issue Date: 08/24/04 APP C6-17 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-4) Functional Criteria for Emergency Response Facilities

PURPOSE: The purpose of this activity is to review the facilities and systems to

be used by nuclear power plant licensees to improve responses to

emergency situations. This activity will also review the established

the criteria that the NRC staff used to evaluate whether licensees

met the requirements of 10 CFR 50 Appendix E, Section IV.E.8

and Appendix A, GDC 19.

COMPETENCY 

AREA: INSPECTION

TECHNICAL AREA EXPERTISE

LEVEL 

OF EFFORT:8 hours

REFERENCES: NUREG-0696, “Functional Criteria for Emergency Response Facilities”

10 CFR 50 Appendix E, Section IV.E.8

10 CFR 50 Appendix A, GDC 19.

EVALUATION

CRITERIA: At the completion of reviewing this document, you should be able

to:

1. Discuss general functions of the OSC, TSC, and EOF. 

2. Discuss the facility design objectives (i.e., location, size,

structure, staffing)

3. Discuss the data systems and their design criteria

TASKS: 1. Obtain copy of NUREG-0696

2. Read entire document with emphasis on OSC, TSC, and

EOF

3. Meet with supervisor or qualified EP inspector to discuss any

questions and review the evaluation criteria.

DOCUMENTATION: Emergency Preparedness Proficiency Level Qualification

Signature Card Item ISA-EP-4.
1245 APP C6-18 Issue Date: 08/24/04

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Issue Date: 08/24/04 APP C6-19 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-5) TMI Action Plan Requirements

PURPOSE: This purpose of this activity is to acquaint you with the NRC

requirements that resulted from the Three Mile Island Accident

lessons learned and identifies any changes from previous

requirements and guidance. There are some requirements specific

to emergency planning (e.g. shift manning, control-room design

reviews, improving licensee emergency preparedness, controlroom habitability requirements and plant systems that contribute to

offsite dose calculations). 

This activity will acquaint you with the reference source for the

operation of certain plant systems/instrumentation during a

radiological emergency. Supplement No. 1 to 0737, was specific to

emergency preparedness and provided additional clarification

regarding safety parameter display systems, detailed control room

design reviews, Regulatory Guide 1.97, upgrade emergency

operating procedure, emergency response facilities and minimum

staffing requirements. 

COMPETENCY

AREA: INSPECTION

LEVEL 

OF EFFORT:16 hours

REFERENCES: 10 CFR 50.47(b) and Appendix E

NUREG-75/087

Regulatory Guide 1.23

NUREG-0654/FEMA-Rep-1, Revision 1, Criteria for Preparation

and Evaluation of Radiological Emergency Response Plans and

Preparedness in Support of Nuclear Power Plants.

NUREG-0696, Functional Criteria for Emergency Response

Facilities

NUREG-0737, Clarification of TMI Action Plan Requirements and

NUREG- 0737 Supplement 1, Requirements for Emergency

Response Capability
1245 APP C6-20 Issue Date: 08/24/04

EVALUATION 

CRITERIA: At the completion of reviewing this document, you should be able

to:

1. Discuss the various radiological information, both in-plant

and environmental, needed for evaluating the offsite

consequences (evacuation, sheltering) of a radiological

emergency condition.

2. Generally discuss the various plant systems/instrumentation

at the various emergency facilities which display critical plant

variables to aid the licensee in rapidly and reliably

determining the safety status of the plant.

3. Discuss the importance for control room habitability

requirements and what measures licensees have taken to

ensure compliance.

4. Generally discuss the use of emergency operating

procedures and the purpose of the emergency response

facilities.

TASKS: 1. Review the reference materials described above.

2. Scan all sections of NUREG 0737. Read, in depth, sections

I.A.1.3, I.D.1, II.B.3, II.F.1, and attachments 1-6, III.A.2,

III.D.3.4. 

3. Meet with supervisor or qualified EP inspector to discuss any

questions and review the evaluation criteria.

DOCUMENTATION: Emergency Preparedness Proficiency Level Qualification

Signature Card Item ISA-EP-5.
Issue Date: 08/24/04 APP C6-21 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-6) Manual of Protective Action Guides and Protective

Actions for Nuclear Incidents

PURPOSE: The purpose of this activity is to have you become familiar with the

guidance used by decision makers regarding the appropriate

protective actions to take in the event of a radiological emergency.

COMPETENCY

AREA: INSPECTION

TECHNICAL AREA EXPERTISE

LEVEL 

OF EFFORT:8 hours

REFERENCES: EPA 400-R-92-001, “ Manual of Protective Action Guides and

Protective Actions for Nuclear Incidents

EVALUATION 

CRITERIA: At the completion of reviewing this document, you should be able

to:

1. Discuss the different phases of an accident. 

2. Discuss the protective action guidelines for the early phase

3. Discuss the range of possible protective action

recommendations

4. Discuss possible exceptions to implementing the protective

actions

5. Discuss the protective action guidelines for the late phase

6. Discuss the various exposure pathways

TASKS: 1. Obtain copy of EPA 400-R-92-001

2. Read chapters 1 through 5

3. Meet with supervisor or qualified EP inspector to discuss any

questions and review the evaluation criteria.

DOCUMENTATION: Emergency Preparedness Proficiency Level Qualification

Signature Card Item ISA-EP-6.
1245 APP C6-22 Issue Date: 08/24/04

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Issue Date: 08/24/04 APP C6-23 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-7) RTM-96, Response Technical Manual

PURPOSE: The purpose of this activity is to provide a review of the simple

methods used for estimating possible consequences of different

kinds of radiological accidents.

COMPETENCY 

AREA: INSPECTION

TECHNICAL AREA EXPERTISE

LEVEL 

OF EFFORT: 4 hours

REFERENCES: RTM-96, Response Technical Manual

EVALUATION

CRITERIA: At the completion of reviewing this document, you should be able

to:

1. Discuss the steps used when conducting a Reactor Core

Damage Assessment.

2. Discuss the steps used in each methodology when

conducting a Classification Assessment.

3. Discuss the steps used when conducting a Reactor Accident

Consequence Assessment. 

4. Discuss the steps used when conducting an Early Phase

Protective Action Assessment.

TASKS: 1. Obtain copy of RTM-96

2. Read topics stated above (Sections A, B, C, and G)

3. Meet with supervisor or qualified EP inspector to discuss any

questions and review the evaluation criteria.

DOCUMENTATION: Emergency Preparedness Proficiency Level Qualification

Signature Card Item ISA-EP-7
1245 APP C6-24 Issue Date: 08/24/04

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Issue Date: 08/24/04 APP C6-25 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-8) NUMARC/NESP-007, Methodology for Development of

Emergency Action Levels

PURPOSE: The purpose of activity is to familiarize you with an alternate

emergency action level scheme to NUREG-0654. The

implementation of this alternate methodology provided a consistent

standard of making emergency classifications within the industry.

COMPETENCY

AREA: INSPECTION

TECHNICAL AREA EXPERTISE

LEVEL 

OF EFFORT: 8 hours

REFERENCES: NUMARC/NESP-007, “Methodology for Development of

Emergency Action Levels”

10 CFR 50.47(b)(4)

10 CFR 50 Appendix E.IV.B

Regulatory Guide 1.101, “Emergency Planning and Preparedness

for Nuclear Power Reactors”

EVALUATION 

CRITERIA: At the completion of reviewing this document, you should be able

to:

1. Discuss the different Initiating Condition Matrices: Abnormal

Rad Levels/Radiological Effluent; Fission Product Barrier

Degradation; Hazards and Other Conditions Affecting Plant

Safety; and, System Malfunction. Include in the discussion,

their relationship to symptom-, event-, and barrier-based

grouping of Initiating Conditions and Emergency Action

Levels.

2. Discuss format of the Emergency Action Levels. Include an

explanation of the different sections (i.e., Initiating Condition,

Mode Applicability, EAL & Basis), and their use/relationship

when classifying an event.

TASKS: 1. Obtain copy of NUMARC/NESP-007

2. Read Executive Summary and Section 3.0

3. Become familiar with content and format of Section 5.0 
1245 APP C6-26 Issue Date: 08/24/04

4. Meet with supervisor or qualified EP inspector to discuss any

questions and review the evaluation criteria.

DOCUMENTATION: Emergency Preparedness Proficiency Level Qualification

Signature Card Item ISA-EP-8
Issue Date: 08/24/04 APP C6-27 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-9) NUREG 0396, Planning Basis for the Development of

State and Local Government Radiological Emergency Response

Plans in Support of Light Water Nuclear Power Plants

PURPOSE: The purpose of this activity is to acquaint you with the basis for

Federal, State and local government emergency preparedness

organizations to determine the appropriate degree of emergency

response planning efforts in the environs of nuclear power plants. 

You will become familiar with the concept of generic Emergency

Planning Zones as a basis for the planning of response actions and

determining the radiological consequences offsite. This activity will

be helpful in understanding the licensee’s responsibilities to the

offsite agencies and its role in the plume phase of a radiological

event.

COMPETENCY

AREAS: INSPECTION

TECHNICAL AREA EXPERTISE

LEVEL 

OF EFFORT: 4 hours

REFERENCES 10 CFR 50.47(b)(5)

10 CFR 50.47(b)(10)

10 CFR Part 50, Appendix E, Section F.2.c.

EPA 400-R-92-001, “Manual of Protective Action Guides and

Protective Actions for Nuclear Incidents

NUREG 0396, “Planning Basis for the Development of State and

Local Government Radiological Emergency Response Plans in

Support of Light Water Nuclear Power Plants”

EVALUATION 

CRITERIA: At the completion of reviewing this document, you should be able

to:

1. Define the emergency planning zone and its purpose.

2. Discuss how different meteorological scenarios (e.g. wind,

rain, sun) can effect the dose assessment estimates.

3. Discuss the difference between the plume exposure phase

and the ingestion phase of a radiological event.

TASKS: 1. Read NUREG 0396 
1245 APP C6-28 Issue Date: 08/24/04

2. Meet with the Regional Government Liaison to discuss

offsite emergency response and the roles of FEMA, state

and counties.

3. Meet with supervisor or qualified EP inspector to discuss any

questions. 

DOCUMENTATION: Emergency Preparedness Proficiency Level Qualification

Signature Card Item ISA-EP-9
Issue Date: 08/24/04 APP C6-29 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-10) NUREG/CR-5247, RASCAL User’s Guide

PURPOSE: The Radiological Assessment System for Consequence Analysis

(RASCAL) was developed for use during response to radiological

emergencies. RASCAL is a software program used as the NRC’s

dose assessment model and is designed to perform dose

assessment calculations and used as a comparison with EPA

Protective Action Guidance, licensee dose assessment calculations

and other health effects thresholds. Calculations generated from

RASCAL will assist the NRC in evaluating the adequacy of the

licensee’s protective action recommendations to the State.

COMPETENCY

AREAS: INSPECTION

TECHNICAL AREA EXPERTISE

LEVEL 

OF EFFORT 4 hours

REFERENCES: NUREG/CR-5247, RASCAL User’s Guide

10 CFR 50.47(b)(10)

NUREG-0396, “Planning Basis for the Development of State and

Local Government Radiological Emergency Response Plans in

Support of Light Water Nuclear Power Plants”

RTM-96, Response Technical Manual

EVALUATION

CRITERIA: At the completion of reviewing this document, you should be able

to:

1. Discuss the purpose of the RASCAL dose assessment

model 

2. Operate the model using various accident scenarios.

3. Interpret the data.

TASKS: 1. Receive hands-on instruction on how to operate the NRC

dose assessment model (RASCAL). 

2. Attend a training class for operating the NRC dose

assessment model (RASCAL). 

3. Meet with a qualified user to discuss any questions
1245 APP C6-30 Issue Date: 08/24/04

4. Meet with supervisor or qualified EP inspector to discuss any

questions. 

DOCUMENTATION: Emergency Preparedness Proficiency Level Qualification

Signature Card Item ISA-EP-10
Issue Date: 08/24/04 APP C6-31 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-11) Emergency Preparedness Position (EPPOS) Papers

PURPOSE: To familiarize you with the context and purpose of each of the

EPPOS.

COMPETENCY

AREAS: INSPECTION

TECHNICAL AREA EXPERTISE

LEVEL 

OF EFFORT: 2 hours

REFERENCES:

1. EPPOS No. 1, Applicable Deviations from App. 1 of

NUREG-0654, Methodology for the Development of

Emergency Action Levels (EALs)

2. EPPOS No. 2, Timeliness of Classification of Emergency

Conditions

3. EPPOS No. 3, Requirement for Onshift Dose Assessment

Capability

4. 4. EPPOS No. 5, Emergency Planning Information Provided

to the Public

5. 10 CFR 50.47(b)(4)

6. 10 CFR 50.47(b)(10)

7. 10 CFR 50.47(b)(5)

EVALUATION

CRITERIA: At the completion of reviewing these papers, you should be able to:

1. Generally describe the context and purpose of the four

papers.
1245 APP C6-32 Issue Date: 08/24/04

TASKS: 1. Read EPPOS 1, 2, 3, and 5

2. Meet with supervisor or qualified EP inspector to discuss any

questions. 

DOCUMENTATION: Emergency Preparedness Proficiency Level Qualification

Signature Card Item ISA-EP-11
Issue Date: 08/24/04 APP C6-33 1245

Emergency Preparedness Inspector Individual Study Activity

TOPIC: (ISA-EP-12) Emergency Preparedness Significance Determination

Process

PURPOSE: The Significance Determination Process (SDP), as described in

Manual Chapter 0609, aids NRC inspectors and staff in

determining the safety significance of inspection findings, using risk

insights when appropriate. The SDP determinations for inspection

findings and the Performance Indicator information are combined

for use in assessing licensee performance. Upon completion of

this activity, you will be able to use the Significance Determination

Process to determine the safety significance of an EP inspection

finding.

COMPETENCY

AREAS: TECHNICAL AREA EXPERTISE 

INSPECTION

LEVEL OF

EFFORT: 8 hours

REFERENCES: 1. NRC Inspection Manual Chapter IMC-0609, “Significance

Determination Process”

2. NRC Inspection Manual Chapter IMC-0612 “Power Reactor

Inspection Reports”, Appendix B, “Thresholds for

Documentation”

3. NEI 99-02, “Regulatory Assessment Performance Indicator

Guidelines”, Section 2.4, “EP Cornerstone”

4. 10CFR50.47(b)

5. 10CFR50 Appendix E

EVALUATION

CRITERIA: At the completion of this activity, you should be able to:

1. Identify the most risk significant Emergency Preparedness

planning standards (RSPS) contained in 10CFR50.47(b) and

Appendix E.

2. Classify an inspection finding as an Actual Event

Implementation Problem or a Failure to Meet Regulatory

Requirement.
1245 APP C6-34 Issue Date: 08/24/04

3. Verify the efficacy of the licensee efforts to correct

weaknesses and deficiencies to ensure the EP Cornerstone

Objective is met.

4. Disposition an inspection finding, using the EP SDP flow

chart logic, into one of the following categories: green;

white; yellow; or, red. Also, discuss the differences between

the categories.

5. Discuss your role during the “Significance and Enforcement

Review Process” as described in IMC-0609, Attachment 1.

6. Discuss the “Process for Appealing NRC Characterization of

Inspection Findings (SDP appeal process)” as described in

IMC-0609, Attachment 2.

TASKS: 1. Obtain a copy of NEI 99-02, Section 2.4, EP Cornerstone

and familiarize yourself with the EP performance indicators

and their thresholds.

2. Obtain a copy of 10CFR50.47(b) and Appendix E. Read all

sections. In particular, become well-acquainted with the risk

significant planning standards (RSPS): 10CFR50.47(b)(4),

(5), (9) and (10) and Appendix E, section IV B, C, D(1) and

D(3).

3. Obtain a copy of IMC-0609 and read introduction and

Appendix B. Become well-versed in the use of the EP SDP

flow chart logic diagrams in Appendix B.

4. Obtain a copy of IMC-0612 Appendix B and read for

understanding the process to determine if an EP issue is

suited for SDP analysis.

5. Obtain from your supervisor or a qualified senior emergency

preparedness inspector three (3) actual EP inspection

findings that have undergone the Significant Determination

Process or three (3) EP SDP case studies and perform the

following:

(a) Utilizing IMC-0612 Appendix B, determine whether

each of the issues has sufficient significance to

warrant SDP analysis and/or documentation.

(b) If you determine the issue warrants an SDP analysis,

classify each as an Actual Event Implementation

Problem or a Failure to Meet Regulatory Requirement

per IMC-0609 Attachment B.
Issue Date: 08/24/04 APP C6-35 1245

(c) Identify if the issue is a repeat weakness and/or

deficiency and determine the efficacy of the

licensee’s corrective action efforts.

(d) Utilizing IMC-0609, Attachment B, EP SDP flow chart

logic, formulate an outcome as to the risk significance

category (green, white, yellow or red) for each.

(e) Compare your conclusions with those provided by the

actual findings or case studies.

(f) Discuss your results with your supervisor or a

qualified senior emergency preparedness inspector.

1. Obtain a copy of IMC-0609 Attachment 1 and read for

understanding your role during the “Significance and

Enforcement Review Process”.

2. Obtain a copy of IMC-0609 Attachment 2 and read for

understanding the “Process for Appealing NRC

Characterization of Inspection Findings (SDP Appeal

Process)”.

3. Whenever possible, attend a significance determination and

enforcement review panel (SERP) related to this SDP.

Discuss the rationale for the outcome/resolution of the panel

with a qualified senior emergency preparedness inspector.

4. Meet with your supervisor or a qualified senior emergency

preparedness inspector to discuss any questions that you

may have as a result of this activity and demonstrate that

you can meet the evaluation criteria listed above. 

DOCUMENTATION: Emergency Preparedness Inspector Qualification Signature

Card, Item ISA-EP-12
1245 APP C6-36 Issue Date: 08/24/04

PAGE INTENTIONALLY BLANK
Issue Date: 08/24/04 APP C6-37 1245

Emergency Preparedness On-the-Job Activities
1245 APP C6-38 Issue Date: 08/24/04

PAGE INTENTIONALLY BLANK
Issue Date: 08/24/04 APP C6-39 1245

Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-1) Alert and Notification System Testing

PURPOSE: The offsite alert and notification system, generally consisting of

outdoor sirens and/or tone alert radios, is risk significant because it

is the primary means for notification of the general public to monitor

emergency instructions. The reliability of the siren portion of these

systems is routinely determined and reported to the Federal

Emergency Management Agency (FEMA) and NRC as a

performance indicator. Inspection Procedure (IP) 71114.02

provides guidance for ensuring that testing methods used by a

licensee are sufficiently robust to provide consistently valid data. 

Upon completion of this activity, you will be able to use NRC and

licensee information to evaluate the adequacy of licensee siren

testing programs.

COMPETENCY

AREAS: TECHNICAL AREA EXPERTISE 

INSPECTION

LEVEL OF

EFFORT: 60 hours

REFERENCES: 1. IP 71114.02, “Alert and Notification System Testing”

2. Appendix 3, “Means for Providing Prompt Alerting and

Notification of Response Organizations and the Population,”

to NUREG-0654/FEMA-REP-1, Revision 1, “Criteria for

Preparation and Evaluation of Radiological Emergency

Response Plans and Preparedness in Support of Nuclear

Power Plants,” dated November 1980

3. FEMA REP-10, “Guide for the Evaluation of Alert and

Notification Systems for Nuclear Power Plants,” dated

November 1985

4. Licensee emergency plan

5. Licensee procedures for the conduct of siren tests 

6. Licensee alert and notification system design reports

7. Licensee system manuals for system components 

8. Licensee, offsite official, and FEMA correspondence

pertaining to the initial installation and acceptance of the

offsite siren system
1245 APP C6-40 Issue Date: 08/24/04

9. FEMA acceptance tests and reports for the initial

acceptance of the offsite siren system

10. Licensee corrective action documentation related to siren

functionality

EVALUATION

CRITERIA: At the completion of this activity, you should be able to:

1. Describe Federal guidance for siren performance and

testing

2. Describe typical configurations of licensee siren systems

3. Describe the systems that can be used as alternatives to

outdoor sirens, with the circumstances in which their use

may be appropriate

4. Determine whether a licensee’s siren testing program is

effective in testing important elements of the system

5. Determine whether a licensee’s siren testing program is

conducted in accordance with Federal guidance

6. Determine whether a licensee is appropriately identifying

and correcting siren system problems, and whether siren

problems are included in the licensee’s corrective action

program

TASKS: 1. Review IP 71114.02 to identify the attributes used to

determine if a siren testing program is satisfactory.

2. Review NUREG-0654, Appendix 3, to become acquainted

with the acceptable means of providing alert notifications to

the general public

3. Review FEMA REP-10, Chapter 1, Appendixes 2 and 4, to

become acquainted with the methods available for verifying

the testing methods for sirens

4. At 3 sites determined by your supervisor, perform the

following tasks under the guidance of a senior emergency

preparedness inspector:

(a) Determine the overall characteristics and function of

the [public] alert and notification system from the

licensee’s emergency plan. Determine the current

testing periodicity and any related requirements.
Issue Date: 08/24/04 APP C6-41 1245

(b) Review any current licensee commitments related to

the: (a) notification system design, (b) notification

system maintenance, (c) design of the testing

methodology, (d) test frequency, and/or (e) reporting

or archiving of test results. These commitments could

be to the FEMA, NRC, or offsite Agencies.

(c) Obtain and briefly review vendor manuals describing

the alert and notification system configuration. For

sirens, obtain an understanding of the siren sounding

mechanism, control system, feedback system, and

report outputs.

(d) Obtain and review the original FEMA acceptance

report for the alert and notification system. Obtain an

understanding of the system configuration at the time

of acceptance.

(e) Determine whether significant hardware, software, or

testing changes have been made to the alert and

notification system since its installation. If changes

have been made, determine whether commitments

continue to be met. Note that some commitments

may have existed at the time of system installation

(15-20 years ago) and may not be currently tracked

by the licensee. Determine whether the alert and

notification system, as currently implemented, is

correctly described in the emergency plan.

(f) Obtain and review licensee procedures for testing the

alert and notification system. Review results from a

recent system test and from the most recent annual

full-cycle test. For each type of test performed (silent,

poll, growl, partial cycle, full cycle, or other, as

appropriate), determine whether the tests are

designed to provide positive indication of the reliability

of the system. Discuss your conclusions with a senior

emergency preparedness inspector.

(g) Review licensee procedures for preventive

maintenance, work orders, maintenance records, and

failures revealed through the testing program to

determine the frequency of failures in the alert and

notification system. Determine whether any common

failure trends exist or whether components [sirens] fail

at an unusual rate. Determine whether problems with

the alert and notification system are captured in the

licensee’s corrective action program.
1245 APP C6-42 Issue Date: 08/24/04

(h) From the overall data, form a conclusion about

whether the licensee’s alert and notification system,

as currently implemented, continues to meet planning

standard provided in 10 CFR 50.47(b)(5) [refer to MC

0609, Appendix B, §5.5]. Discuss any concerns with

a senior emergency preparedness inspector.

(i) Observe 1 complete alert and notification system

[siren] test conducted by means of computer

telemetry and polling. Observe the actual activation

and sounding of at least 1 siren.

(j) Review an NRC inspection report that describes a

finding and/or violation related to the design, testing,

or implementation of the alert and notification system.

5. Meet with your supervisor or a qualified senior emergency

preparedness inspector to discuss any questions that you

may have as a result of this activity and demonstrate that

you can meet the evaluation criteria listed above. 

DOCUMENTATION: Emergency Preparedness Inspector Qualification Signature

Card, Item OJT-EP-1.
Issue Date: 08/24/04 APP C6-43 1245

Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-2) Emergency Response Organization Augmentation

PURPOSE: The licensee’s emergency response organization augmentation

system is an vital part of overall event response because of the

critical need to relieve the control room of the emergency response

functions unrelated to combating a plant event. The additional

personnel and capabilities available in emergency response

facilities (i.e., technical support center and emergency operations

facility) may be needed for classified events or in other unusual

circumstances. Augmentation systems typically consist of a

combination of public address systems, pagers, automated phone

dialing systems, and manual call trees. Inspection Procedure (IP)

71114.03 provides guidance for ensuring that the emergency

response organization can be mobilized, as required, and that

emergency plan goals for activating emergency response facilities

can be achieved. Upon completion of this activity, you will be able

to determine whether licensee augmentation goals can be

achieved as described by the licensee’s emergency plan.

COMPETENCY

AREAS: TECHNICAL AREA EXPERTISE 

 INSPECTION

LEVEL OF

EFFORT: 40 hours

REFERENCES: 1. IP 71114.03, “Emergency Response Organization

Augmentation”

2. Licensee emergency plan

3. Licensee emergency plan implementing procedures for

performing emergency response organization notification

and emergency response facility activation (may include

control room response procedures); primary and back-up

methods may be addressed in separate procedures

4. Design or bid specifications for automated telephone system

or other automatic notification systems

5. Vendor manuals for telephone auto-dial or other automatic

notification systems

6. Licensee drill records (including drill critiques) for pager

tests, emergency response organization call-in drills, and/or

drive-in drills
1245 APP C6-44 Issue Date: 08/24/04

7. Licensee corrective action system documentation related to

activation of the emergency response augmentation staff

EVALUATION

CRITERIA: At the completion of this activity, you should be able to:

1. Describe the functions or capabilities that the on-shift

emergency response organization is required to implement

2. Describe the functions or capabilities for augmenting the onshift organization, including the basis in regulation or

guidance

3. Describe regulatory requirements for conducting

augmentation drills

4. Describe the components or methods that are used in onsite and off-site augmentation systems

5. Describe the attributes that you used to conclude that a

licensee’s system for augmentation will support

augmentation of the emergency response organization in

accordance with the licensee’s activation goals

TASKS: 1. Review IP 71114.03 to identify the attributes for determining

the various methods available for determining if an

emergency response augmentation plan is acceptable.

2. At 3 sites determined by your supervisor, perform the

following tasks under the guidance of a senior emergency

preparedness inspector:

(a) Determine the licensee’s staffing commitments from

the emergency plan and implementing procedures. 

This should include the positions to be staffed and

related emergency response facility activation goals.

(b) Review licensee procedures for implementing primary

and backup methods for augmenting the on-shift

emergency response organization.

(c) Obtain a current licensee emergency response roster. 

Compare the roster against the positions listed in the

emergency plan. Determine whether the licensee has

sufficient depth in all key positions (as tracked for the

emergency preparedness performance indicators) to

ensure an adequate response. Discuss your

conclusions with a senior emergency preparedness

inspector.
Issue Date: 08/24/04 APP C6-45 1245

(d) Obtain vendor manuals describing an automated

augmentation system. Briefly review the system

overview and description.

(e) Select a sample of approximately 10 percent of the

licensee’s key positions. Review licensee data on the

expected off-hours response times for these key

positions. Determine whether the selected key

individuals could reasonably be expected to respond

to their assigned emergency response facilities within

the activation time goals for those facilities. 

For each selected key individual consider: (1) the

time necessary to activate the augmentation method

(including any delay in the control room to perform

other higher-priority functions), (2) the time used in

implementing the augmentation method, (3) the

distance required to be traveled by the individual, (4)

the average travel speed, (5) the time required to

report to the facility after arrival on-site (including time

spent at the security gate), and (6) other relevant

factors. Discuss your conclusions with a senior

emergency preparedness inspector.

(f) Review the staffing of emergency response facilities

during any declared emergency classifications during

the current inspection period. Obtain the following

items: (1) shift and responder logs (especially from

the control room), (2) off-site and on-site notification

worksheets, (3) completed procedures and/or

attachments, and (4) communication logs or other

relevant material. 

Determine whether emergency response facility

staffing goal times were met. Determine whether the

data suggests that problems in implementation

occurred. If concerns are noted, determine whether

problems were appropriately captured in the

licensee’s corrective action program. Discuss your

concerns with a senior emergency preparedness

inspector.

(g) Review the licensee’s procedure for conducting drills

or surveillances of the augmentation system. Obtain

and review the results of 2 call-in or drive-in drills

conducted by the licensee. In addition, if the licensee

performs surveillances of their backup augmentation

method, obtain the results of 1 such surveillance. 
1245 APP C6-46 Issue Date: 08/24/04

Determine if: (a) the design of the surveillance

method reasonably tests the augmentation system,

(b) the surveillance results indicate that staffing goal

times can reliably be met, and (c) implementation

problems occurred. If concerns are noted, determine

whether problems were appropriately captured in the

licensee’s corrective action program. Discuss your

conclusions with a senior emergency preparedness

inspector.

(h) Determine whether the integrated augmentation

system, including provision for backup methods, is

adequate to meet emergency response facility

staffing goals [times]. Discuss your conclusions with

a senior emergency preparedness inspector.

3. Meet with your supervisor or a qualified senior emergency

preparedness inspector to discuss any questions that you

may have as a result of this activity and demonstrate that

you can meet the evaluation criteria listed above. 

DOCUMENTATION: Emergency Preparedness Inspector Qualification

Signature Card, Item OJT-EP-2.
Issue Date: 08/24/04 APP C6-47 1245

Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-3) Emergency Action Level and Emergency Plan

Changes

PURPOSE: Licensee emergency plans provide a description of the personnel,

facilities, activities, and methods used to respond to an emergency

condition at the licensee’s facility. They also describe the

regulatory commitments made by the licensee to the NRC. 

Emergency action levels provide entry criteria for classifying

emergency conditions based on measurable or observable

conditions. Standards for contents of emergency plans and

emergency action levels are found in NRC regulations and other

documents. Licensees are permitted to make changes to their

emergency plan and emergency action levels as described by 10

CFR 50.54(q). Upon completion of this activity, you will be able to

determine whether licensee emergency plan changes are in

accordance with the requirements of 10 CFR 50.54(q).

COMPETENCY

AREAS: TECHNICAL AREA EXPERTISE 

INSPECTION 

LEVEL OF

EFFORT: 50 hours

REFERENCES: 1. Inspection Procedure (IP) 71114.04, “Emergency Action

Level and Emergency Plan Changes”

2. NUREG-0654/FEMA-REP-1, Revision 1, “Criteria for

Preparation and Evaluation of Radiological Emergency

Response Plans and Preparedness in Support of Nuclear

Power Plants,” (I) Introduction; (II) Planning Standards and

Evaluation Criteria; and Appendix 1: “Emergency Action

Level Guidelines for Nuclear Power Plants”

3. EPA 400-R-92-001, “Manual of Protective Action Guides

and Protective Actions for Nuclear Incidents,” dated May

1992

4. Information Notice 83-28, “Criteria for Protective Action

Recommendations for General Emergencies”

5. Supplement 3, “Criteria for Protective Action

Recommendations for Severe Accidents,” to NUREG0654/FEMA-REP-1, Revision 1, “Criteria for Preparation and

Evaluation of Radiological Emergency Response Plans and

Preparedness in Support of Nuclear Power Plants,” dated

July 1996
1245 APP C6-48 Issue Date: 08/24/04

6. NUMARC/NESP-007, Revision 2, “Methodology for

Development of Emergency Action Levels,” dated January

1992

7. NEI 99-01, Revision 4, “Methodology for Development of

Emergency Action Levels,” dated May 1999

8. EPPOS No. 1, “Emergency Preparedness Position on

Acceptable Deviations from Appendix 1 of NUREG-0654"

based upon the staff’s regulatory analysis of

NUMARC/NESP-007, “Methodology for Development of

Emergency Action Levels”

9. EPPOS No. 4, “Emergency Preparedness Position on

Emergency Plan and Implementing Procedure Changes,”

dated November 1998

10. Licensee emergency plan

11. Licensee procedures for evaluating and making changes to

the emergency action levels and the emergency plan,

including methods for making determinations of compliance

with 50.54(q) and for evaluating potential decreases of

effectiveness of the emergency plan and implementing

procedures

12. 10 CFR Part 50, Appendix E

13. 10 CFR 50.54(q)

EVALUATION

CRITERIA: At the completion of this activity, you should be able to:

1. Describe the inspection requirements for an in-depth review

of emergency action level and emergency plan changes that

have been submitted to the NRC

2. Describe what is meant by a “decrease in effectiveness” of

the emergency plan, emergency action levels, and

emergency plan implementing procedures

3. Describe the regulatory requirements for licensees to make

and implement changes to their emergency plan and/or

emergency action levels

4. Describe where to find regulatory requirements for the

contents of emergency plans and procedures and where to

find regulatory guidance
Issue Date: 08/24/04 APP C6-49 1245

5. Review a submitted emergency plan change and determine

whether the change requires an in-depth review

6. Review a submitted emergency plan or emergency action

level change to determine if the change results in a

decrease in effectiveness of the emergency plan

TASKS: 1. Review IP 71114.04 to identify the attributes used to

determine if a change to an emergency plan or emergency

action level constitutes a decrease in effectiveness

2. Become familiar with the content of the following emergency

action level basis documents: (a) NUREG-0654, Sections

(I), (II), and Appendix 1; (b) NUMARC/NESP-007; (c) NEI

99-01, Revision 4; and (d) EPPOS No. 1.

3. Become familiar with the content of the following guidance

documents for the development of protective action

recommendations: (a) EPA 400-R-92-001, Chapters 1, 2,

and 5; (b) Information Notice 83-28; and (c) NUREG-0654,

Supplement 3.

4. Become familiar with the contents of EPPOS No. 4.

5. Review 5 significant licensee submissions of changes to

licensee emergency action levels that have been

implemented under the provisions of 10 CFR 50.54(q) [see

EPPOS 4]. The selected submissions should represent at

least 3 different licensee sites. The licensee sites should

represent both pressurized water and boiling water reactor

sites, and 2 of the selected submissions should be

previously unreviewed by the NRC. 

For each submission, perform the following tasks under the

guidance of a senior emergency preparedness inspector:

(a) Determine whether the submission was made within

30 days of implementation of the emergency action

level change as required by 10 CFR Part 50,

Appendix E, V.

(b) Determine whether the basis for licensee emergency

action levels is NUREG-0654 or NUMARC/NESP-007

(as revised).

(c) Determine whether the changes eliminated or

changed any licensee commitments.
1245 APP C6-50 Issue Date: 08/24/04

(d) Determine whether the changes continue to meet the

requirements of the applicable basis document

(NUREG-0654 or NUMARC/NESP-007).

(e) Determine whether the changes constitute a

decrease in the effectiveness of the emergency plan. 

Discuss your conclusions with a senior emergency

preparedness inspector.

(f) Discuss with a senior emergency preparedness

inspector, the differences between a significant

change to a licensee’s emergency plan (which is

required to be reviewed) and one which is not

significant. List the circumstances under which an

emergency plan change might not be reviewed by the

NRC.

6. Obtain 5 licensee submissions of changes to the emergency

plan that have been implemented under the provisions of 10

CFR 50.54(q). The selected submissions should represent

at least 3 different licensee sites; at least 2 of the selected

submissions should be currently unreviewed. 

For each submission perform the following tasks at each

under the guidance of a senior emergency preparedness

inspector:

(a) Determine whether the submission was made within

30 days of implementation of the emergency plan

change as required by 10 CFR Part 50, Appendix E,

V.

(b) Determine whether the change eliminated or changed

any licensee commitments.

(c) Determine whether the change continues to meet the

requirements of 10 CFR 50.54(q), 10 CFR 50.47(b),

and 10 CFR Part 50, Appendix E.

(d) Determine whether the change constitutes a

decrease in effectiveness of the emergency plan. 

Discuss your conclusions with a senior emergency

preparedness inspector.

7. Obtain and review one NRC inspection report that identifies

licensee changes to emergency action levels and/or the

emergency plans that were determined to be a decrease in

the effectiveness of the emergency plan. Review any

associated notices of violation and the licensee’s corrective

action.
Issue Date: 08/24/04 APP C6-51 1245

8. Obtain and review one NRC inspection report that

documents the inspection of changes to a licensee’s

emergency action levels or emergency plan.

9. Meet with your supervisor or a senior emergency

preparedness inspector to discuss any questions that you

may have as a result of this activity and demonstrate that

you can meet the evaluation criteria listed above. 

DOCUMENTATION: Emergency Preparedness Inspector Qualification Signature

Card, Item OJT-EP-3.
1245 APP C6-52 Issue Date: 08/24/04

PAGE INTENTIONALLY BLANK
Issue Date: 08/24/04 APP C6-53 1245

Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-4) Correction of Emergency Preparedness Weaknesses

and Deficiencies

PURPOSE: Licensees are required to identify and correct weaknesses and

deficiencies discovered through their emergency drill and exercise

program. They are also required to conduct formal critiques in

conjunction with all training activities and to correct any identified

deficiencies. In a broader context, the licensee’s ability to identify

and resolve programmatic, procedural, training, and facility

problems is a key component of the emergency preparedness

cornerstone of the reactor oversight program. Upon completion of

this activity, you should be able to evaluate the overall ability of a

licensee to identify and correct problems related to their emergency

preparedness program.

COMPETENCY

AREA: TECHNICAL AREA EXPERTISE

INSPECTION

LEVEL OF

EFFORT: 40 hours

REFERENCES: 1. Inspection Procedure (IP) 71114.05, “Correction of

Emergency Preparedness Weaknesses and Deficiencies”

2. NUREG-0696, “Functional Criteria for Emergency Response

Facilities”

3. NUREG-0737, Supplement 1, “Clarification of TMI Action

Plan Requirements for Emergency Response Capability,”

dated January 1983

4. NUREG-0814, (Draft) “Methodology for Evaluation of

Emergency Response Facilities,” dated August 1981

5. Licensee procedure for the corrective action program

6. Summaries of corrective action program activity and

individual records of corrective action entries

EVALUATION

CRITERIA: At the completion of this activity, you should be able to:

1. Describe the licensee documents that may contain

information about problems that have been identified

emergency preparedness weaknesses and deficiencies
1245 APP C6-54 Issue Date: 08/24/04

2. Describe emergency preparedness regulatory requirements

for the identification and resolution of problems,

weaknesses, and deficiencies

3. Identify trends in licensee performance regarding its

corrective action documentation

4. Identify instances, or give examples, where a licensee failed

to appropriately capture an issue in its corrective action

program

5. Describe the method(s) for verifying the effectiveness of

corrective actions taken by the licensee

6. Summarize for your supervisor, the overall effectiveness of a

licensee’s corrective action program as it pertains to

emergency preparedness following a review of corrective

action program documentation

TASKS: 1. Read IP 71114.05 to identify the attributes provided for

inspection of a corrective action program for emergency

preparedness weaknesses and deficiencies.

2. Become familiar with the following NRC guidance

documents: (a) NUREG-0696, (b) NUREG-0737, and (c)

NUREG-0814.

3. For 3 licensee sites determined by your supervisor, perform

the following tasks under the guidance of a senior

emergency preparedness inspector:

(a) Obtain and review the licensee’s site-wide or overall

procedure for the corrective action program. 

Determine how (whether) emergency preparedness is

included in the corrective action program. Review

how emergency preparedness issues are prioritized

by the procedure.

(b) Obtain and review a summary list of issues related to

emergency preparedness that have been entered into

the licensee’s corrective action program since the

previous inspection. Determine whether the data

contains trends in any of the areas listed in IP

71114.05, Sections 3.04 and 3.05. Discuss your

conclusions with a senior emergency preparedness

inspector.

(c) Review documentation associated with an actual

emergency classification (Notice of Unusual Event or

greater) made at a licensee site. Determine whether
Issue Date: 08/24/04 APP C6-55 1245

documentation was sufficiently detailed to support

independent conclusions concerning the following: 

(a) whether the classifications and offsite notifications

were correctly performed, and (b) whether problems

were associated with implementation of the

emergency plan during the events. Determine

whether negative performance or program issues

identified in the documentation, which meet the

appropriate threshold, were captured in the corrective

action program. Discuss your conclusions with a

senior emergency preparedness inspector.

(d) Obtain and review the most recent 10 CFR 50.54(t)

audit. Determine whether it was conducted in

accordance with emergency plan requirements and

commitments. Determine whether off-site agencies

were provided the results and conclusions. 

Determine whether performance or program issues

identified in the audit, which meet the appropriate

threshold, were captured in the corrective action

program.

(e) Obtain and review 1 additional audit or

self-assessment of the emergency preparedness

program. Determine whether performance or

program issues identified in the audit, which meet the

appropriate threshold, were captured in the corrective

action program.

(f) Obtain and review the final report for an emergency

drill conducted during the inspection cycle in which

the emergency response facilities were activated. 

Review all of the following that are available for the

same emergency drill: (a) drill scenario, (b)

participant and evaluator logs, (c) offsite notification

forms or worksheets, (d) dose projections, (e)

environmental monitoring team records, (f) significant

event logs, (g) participant worksheets, and (h) postdrill critique notes and comment forms. Determine

whether all performance or program issues that were

revealed in the documentation were appropriately

captured in the licensee’s report and corrective action

program. Discuss your conclusions with a senior

emergency preparedness inspector.

(g) At each site, select 3 corrective actions associated

with a declared emergency and obtain the detailed

corrective action descriptions. Use IP 71114.05,

Sections 3.04 and 3.05, as a guide for selection of the

corrective action documents to review. Verify the
1245 APP C6-56 Issue Date: 08/24/04

completion of each corrective action through direct

observation. Not more than 1 of the selected

corrective actions should be verified solely through

documentation review.

(h) Select at least 5 additional completed corrective

actions from the summary list provided in IP

71114.05, Sections 3.04 and 3.05. Obtain the

detailed corrective action description and verify the

completion of each corrective action through direct

observation. Not more than 2 of the selected

corrective actions should be verified solely through a

documentation review.

4. Meet with your supervisor or a senior emergency

preparedness inspector to discuss any questions that you

may have as a result of this activity and demonstrate that

you can meet the evaluation criteria listed above. 

DOCUMENTATION: Emergency Preparedness Inspector Qualification Signature

Card, Item OJT-EP-4.
Issue Date: 08/24/04 APP C6-57 1245

Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-5) Performance Indicator Verification

PURPOSE: The performance indicators (PI) collectively measure aspects of

emergency preparedness performance. These indicators are

significant in evaluating the overall quality of the program and are

measurable without introducing an unreasonable administrative

burden on the licensee. The administration of the PI program is

completely within the licensee’s responsibility as a major

component of the reactor oversight program. To protect the

integrity of the program, provide consistency in the process, and

provide assurance to management that data is accurate, NRC

inspectors periodically verify the data reported by licensees.

COMPETENCY

AREA: TECHNICAL AREA EXPERTISE

INSPECTION

LEVEL OF

EFFORT: 24 hours

REFERENCES: 1. NEI 99-02, “Regulatory Assessment Performance Indicator

Guidelines” 

2. Regulatory Issue Summary 2001-11

3. Emergency Preparedness Performance Indicator

“Frequently Asked Questions” (FAQ)

4. Manual Chapter (MC) 0608, “Performance Indicator

Program”

5. MC 0801, “Program Feedback”

6. Inspection Procedure (IP) 71150, “Discrepant or Unreported

PI Data”

7. IP 71151, “Performance Indicator Verification”

8. 10 CFR 50.9

EVALUATION

NOTE: This OJT activity must be completed before completing the following OJT

activities: (1) Performance Indicator Verification: Drill and Exercise Performance, 

(2) Performance Indicator Verification: Emergency Response Organization Drill Participation,

and (3) Performance Indicator Verification: Alert and Notification System Reliability
1245 APP C6-58 Issue Date: 08/24/04

CRITERIA: The following evaluation criteria apply to the verification of all

emergency preparedness PIs. At the completion of this activity,

you should be able to:

1. Describe where to find guidance related to the

implementation of the each PI.

2. Describe the frequently asked question process, including its

relationship to published guidance and circumstances and

where it would be appropriate for an inspector to use the

process.

3. Demonstrate how to locate frequently asked questions using

the internal NRC web page and/or other means.

4. View and print emergency preparedness PI data submitted

to the NRC.

5. Describe the criteria for identifying a finding with respect to

errors in a licensee’s reported PI data.

TASKS: 1. Become familiar with MC 0608, “Performance Indicator

Program” and MC 0801, “Program Feedback.”

2. Review IPs 71151 and 71150 to identify the inspection

attributes provided for verification of PIs. Discuss any

questions with a senior emergency preparedness inspector.

3. Become familiar with NEI 99-02, Section 2.4 “Emergency

Preparedness Cornerstone.” Discuss any questions with a

senior emergency preparedness inspector.

4. Access the “Plant Assessment Results” web page on the

ROP Digital City web page.

a. Review for information, the status of plants in your

Region as listed in the Action Matrix Summary

b. For 2 reactor sites located in your region, as

designated by your supervisor, obtain the current

emergency preparedness PI status through each of

the following methods:

(i) Using the “PI Summary” link at the top of the

web page, double-click on one of the PI

windows for the selected site (EP1-DEP, EP2-

ERO, or EP3-ANS).
Issue Date: 08/24/04 APP C6-59 1245

(ii) Using the “PI Summary” link at the top of the

web page, follow the plant name link (in the

left-side column). From the plant performance

summary, scroll down to the PI status. Click

on one of the emergency preparedness

windows to display the associated PI data.

(iii) From the ROP Plant Assessment Results

Page, open the plant performance summary

page by selecting the alphabetical listing

followed by the plant name and selecting the

appropriate regional plant listing followed by

the plant name.

(iv) Print from the web page, the emergency

preparedness PIs for 1 reactor site located

within your region, as designated by your

supervisor.

c. For 1 plant in your region designated by your

supervisor, compare the PI data tables displayed with

each of the 3 emergency preparedness PIs for the

number of calendar quarters used to compute the

statistic per NEI 99-02. Note any differences.

d. From the Plant Assessment Results web page,

page-down to the section on “Frequently Asked

Questions (FAQ).” View the current emergency

preparedness FAQs by clicking on the link labeled

“cornerstone/PI.” Scroll to locate and view the

appropriate questions. View current draft

(incomplete) emergency preparedness FAQs by

clicking on the link labeled “Draft FAQs.”

5. From the ROP Digital City web page, scroll to the block

labeled “ROP Feedback Process.” Follow the link “Open

Feedback Forms by Region.” Review the topics which are

currently open. [Since this section is not organized by

procedure or PI, a review of feedback from all regions is

required to identify all emergency preparedness issues].

6. Discuss with your supervisor or a senior emergency

preparedness inspector, the current NRC enforcement

guidelines with respect to applying 10 CFR 50.9 (inaccurate

information) to the reporting of PI data.

7. Meet with your supervisor or a senior emergency

preparedness inspector to discuss any questions that you

may have as a result of this activity and demonstrate that

you can meet the evaluation criteria listed above. 
1245 APP C6-60 Issue Date: 08/24/04

DOCUMENTATION: Emergency Preparedness Inspector Qualification

Signature Card, Item OJT-EP-5.
Issue Date: 08/24/04 APP C6-61 1245

Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-6) Performance Indicator Verification: Drill and Exercise

Performance

PURPOSE: The drill and exercise performance indicator (PI) measures the

ability of the licensee’s emergency response organization to

perform the risk significant tasks of emergency classification,

protective action recommendations, and the associated

notifications to off-site authorities. These activities are critical

because they have a direct impact on the protection of the public

during an emergency. Licensees perform self-assessments of their

performance and the NRC annually verifies the adequacy of the

licensee’s assessment. Upon completion of this activity, you

should be able to evaluate licensee performance documentation

and determine whether available documentation is sufficient to

validate licensee conclusions.

COMPETENCY

AREA: TECHNICAL AREA EXPERTISE

INSPECTION

LEVEL OF

EFFORT: 24 hours

REFERENCES: 1. IP 71151, “Performance Indicator Verification”

2. NEI 99-02, “Regulatory Assessment Performance Indicator

Guidelines”

3. Regulatory Issue Summary 2001-11

4. Emergency Preparedness Performance Indicator

“Frequently Asked Questions” (FAQ)

5. Licensee Emergency Action Levels and procedures for

classifying an emergency condition for the facility designated

by your supervisor

6. Licensee procedures for developing protective action

recommendations for the facility designated by your

supervisor

NOTE: Completion of OJT-EP-5, Performance Indicator Verification, is a

prerequisite for this activity.
1245 APP C6-62 Issue Date: 08/24/04

7. NUREG-0654/FEMA-REP-1, Revision 1, “Criteria for

Preparation and Evaluation of Radiological Emergency

Response Plans and Preparedness in Support of Nuclear

Power Plants,” Supplement 3, “Criteria for Protective Action

Recommendations for Severe Accidents,” dated July 1996

8. EPA 400-R-92-001, “Manual of Protective Action Guides

and Protective Actions for Nuclear Incidents,” dated May

1992

9. Licensee procedures for performing offsite notifications of an

emergency condition (including protective action

recommendations) for the facility designated by your

supervisor

10. Licensee procedures for the collection, processing, analysis,

reporting, and archiving performance indicator information

for the facility designated by your supervisor

11. Licensee performance indicator reports to the NRC for the

facility designated by your supervisor

EVALUATION

CRITERIA: At the completion of this activity, you should be able to:

1. Define an “opportunity” as it relates to drill and exercise

performance

2. Define the timeliness goals applied to the following: (a)

classifying an emergency condition, (b) determining a

protective action, and (c) notifying offsite authorities of a

change in either emergency classification or protective

action recommendations

3. Define “accurate” as applied to the following: (a) classifying

an emergency condition, (b) determining a protective action,

and (c) notifying offsite authorities of a change in either

emergency classification or protective action

recommendations

4. Describe where the “as expected” or “as designed” outcome

of each opportunity can be located

5. Describe the type of documentation that is necessary to

validate a licensee’s determination of success or failure for

each of the following: (a) classifying an emergency

condition, (b) determining a protective action, and (c)

notifying offsite authorities of a change in either emergency

classification or protective action recommendations
Issue Date: 08/24/04 APP C6-63 1245

6. Determine whether a licensee’s evaluation of the timeliness

and accuracy of an opportunity was correctly decided

7. Perform the drill and exercise performance indicator

calculation

TASKS: For 3 sites within your region, as designated by your supervisor,

perform the following tasks under the guidance of a senior

emergency preparedness inspector:

1. Review licensee procedures for collecting and reporting

performance indicators. (These procedures may include

separate site-wide and departmental procedures.)

2. Select 5 emergency drills conducted during the current

inspection cycle that were evaluated for drill and exercise

performance and perform a detailed review. At least 2 of the

selected emergency drills must involve activation of licensee

emergency response facilities.

3. Obtain and review the scenarios used to conduct the

emergency drills. Identify the intended opportunities for

emergency classification and for development of protective

action recommendations (PAR). Identify the intended

results including the emergency action levels (EAL) to be

used to classify and the PAR(s) expected to be transmitted. 

Evaluate whether the scenario contained sufficient

information to clearly establish expectations in these areas. 

(Some discussion with licensee staff may be required to

understand prior expectations.) Discuss your conclusions

with a senior emergency preparedness inspector.

4. Review the documentation associated with each emergency

drill.

(a) Determine for each classification that was actually

made whether: (a) the classifications were made in a

timely manner, (b) the classifications were made in an

accurate manner [at the correct emergency

classification level, with EALs that were correct for the

data available], and (c) the classifications were

accurately communicated to off-site agencies. Apply

the definition of “accurate” that was in effect during

the calendar quarter in which the emergency drill

occurred and evaluate all aspects of “accurate.” Note

instances where the data did not permit a definite

determination. Discuss your conclusions with a

senior emergency preparedness inspector.

(b) Determine for each PAR action that was actually

transmitted whether the PARs were: (a) timely, (b) 
1245 APP C6-64 Issue Date: 08/24/04

accurate (according to licensee procedures), and (c)

accurately communicated to offsite agencies. Apply

the definition of “accurate” that was in effect during

the calendar quarter in which the emergency drill

occurred and evaluate all aspects of “accurate.” Note

instances where the data did not permit a definite

determination. Discuss your conclusions with a

senior emergency preparedness inspector.

(c) Determine whether the scenario and/or

documentation suggested any opportunities which

were not recognized by the emergency drill

participants.

(d) For each classification or PAR that was not intended

by the scenario, determine whether the licensee’s

documentation was sufficiently detailed to evaluate

whether the licensee correctly assigned a success or

failure to the opportunity. Discuss your conclusions

with a senior emergency preparedness inspector.

5. After reviewing the scenario and associated documentation,

independently score the number of opportunities,

successes, and failures for each emergency drill. Compare

your score with that reported to the NRC by the licensee and

note any differences. Discuss your conclusions with a

senior emergency preparedness inspector.

6. Meet with your supervisor or a senior emergency

preparedness inspector to discuss any questions that you

may have as a result of this activity and demonstrate that

you can meet the evaluation criteria listed above. 

DOCUMENTATION: Emergency Preparedness Inspector Qualification Signature

Card, Item OJT-EP-6.
Issue Date: 08/24/04 APP C6-65 1245

Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-7) Performance Indicator Verification: Emergency

Response Organization Drill Participation

PURPOSE: The emergency response organization participation performance

indicator measures whether persons holding key response

positions maintain a minimum drill participation frequency of 2

years. Regular drill and exercise participation by key members of

the emergency response organization maintains their proficiency in

the risk significant functions of emergency classification, protective

action recommendations development, and their associated

notifications to offsite authorities. The regular conduct of

emergency drills and exercises also supports the continuous

identification and resolution of problems. Inspectors annually verify

the reported participation frequency of key responders. Upon

completion of this activity, you will be able to evaluate licensee

participation documentation and determine whether the

documentation is sufficient to validate reported licensee data.

COMPETENCY

AREA: TECHNICAL AREA EXPERTISE

INSPECTION 

LEVEL OF

EFFORT: 24 hours

REFERENCES: 1. Inspection Procedure (IP) 71151, “Performance Indicator

Verification”

2. NEI 99-02, “Regulatory Assessment Performance Indicator

Guidelines”

3. Regulatory Issue Summary 2001-11

4. Emergency Preparedness Performance Indicator

“Frequently Asked Questions” (FAQ)

5. List of key emergency response organization positions

identified by the licensee for a facility designated by your

supervisor

Note: OJT-EP-5, Performance Indicator Verification and OJT-EP-6, Performance

Indicator Verification: Drill and Exercise Performance must be completed before this

OJT activity.
1245 APP C6-66 Issue Date: 08/24/04

6. Licensee rosters for identified key emergency response

organization positions for a facility designated by your

supervisor

7. Licensee procedures for the collection, processing, analysis,

reporting, and archiving performance indicator information 

for a facility designated by your supervisor

8. Licensee performance indicator reports to the NRC for a

facility designated by your supervisor

EVALUATION

CRITERIA: At the completion of this activity, you should be able to:

1. Describe the linkage between the drill and exercise

performance indicator and emergency response

organization participation performance indicator (PI)

2. Describe the key positions in a licensee’s emergency

response organization

3. Describe the type of licensee documents that are required to

validate emergency response organization participation for

key individuals

4. Determine whether a licensee’s evaluation of drill

participation for an individual in a key emergency response

organization position was correctly decided

5. Perform the emergency response organization participation

performance indicator calculation

TASKS: For 3 reactor sites within your region, as designated by your

supervisor, perform the following activities for each site under the

guidance of a senior emergency preparedness inspector:

1. Review licensee procedures for collecting and reporting PIs. 

(These procedures may include separate site-wide and

departmental procedures.)

2. Determine from licensee procedures the list of “key”

emergency response positions that are tracked for PI

purposes.

3. Select 2 calender quarters within the inspection cycle. For

each selected calender quarter:

a. Obtain the end-of-quarter roster used to prepare PI

data for the calender quarter.
Issue Date: 08/24/04 APP C6-67 1245

b. Determine the most recent emergency drill

participation date for each key participant on the

roster [as reflected in the licensee’s computer data

bases or other records]. If the licensee maintains a

listing of key individuals and their participation dates

separate from the overall roster, determine whether

all key individuals appearing on the roster also appear

on the separate list.

c. Flag each individual who does not have a

participation date within the previous 8 calender

quarters. Sum the number of such individuals and

calculate a ratio of the sum to the total number of key

personnel.

d. Compare the ratio you have calculated to the ratio the

licensee reported to the NRC. Note any differences

and discuss them with a senior emergency

preparedness inspector.

e. Select a sample of about 5 percent of the key

individuals or a sample of not less than 3 persons,

whichever is larger. Obtain original signature

documents or accurate copies of such originals to

verify the drill participation of the selected individuals

on the dates listed in the licensee’s data base. Only

the most recent date is required to be verified.

4. Meet with your supervisor or a senior emergency

preparedness inspector to discuss any questions that you

may have as a result of this activity and demonstrate that

you can meet the evaluation criteria listed above. 

DOCUMENTATION: Emergency Preparedness Inspector Qualification Signature

Card, Item OJT-EP-7.
1245 APP C6-68 Issue Date: 08/24/04

PAGE INTENTIONALLY BLANK
Issue Date: 08/24/04 APP C6-69 1245

Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-8) Performance Indicator Verification: Alert and

Notification System Reliability

PURPOSE: The offsite alert and notification system is considered risk

significant because it is the primary means by which the population

becomes aware of a need to monitor emergency instructions. The

reliability of the siren portion of these systems is routinely

determined by the licensee and is reported to the NRC as a

performance indicator. Inspectors annually verify the accuracy of

the reported siren reliability. Upon completion of this activity, you

will be able to evaluate licensee siren test documentation and

determine whether the documentation is sufficient to validate

reported licensee data.

COMPETENCY

AREA: TECHNICAL AREA EXPERTISE 

INSPECTION

LEVEL OF

EFFORT: 24 hours

REFERENCES: 1. Inspection Procedure 71151, “Performance Indicator

Verification”

2. NEI 99-02, “Regulatory Assessment Performance Indicator

Guidelines”

3. Regulatory Issue Summary 2001-11

4. Emergency Preparedness Performance Indicator

“Frequently Asked Questions” (FAQ)

5. Licensee procedures for siren testing at the facility

designated by your supervisor

6. Direct data collected during licensee siren tests may include

some or all of the following: (a) computer tables or lists, (b)

summary computer reports, (c) individual siren reports, or (d)

individual evaluator worksheets, at the facility designated by

your supervisor

Note: OJT-EP-5, Performance Indicator Verification and OJT-EP-6, Performance

Indicator Verification: Drill and Exercise Performance must be completed before

beginning this OJT activity.
1245 APP C6-70 Issue Date: 08/24/04

7. Licensee out-of-service and maintenance records for sirens

at the facility designated by your supervisor

8. Licensee procedures for the collection, processing, analysis,

reporting, and archiving performance indicator information at

the facility designated by your supervisor

9. Licensee performance indicator (PI) reports to the NRC at

the facility designated by your supervisor

EVALUATION

CRITERIA: At the completion of this activity, you should be able to:

1. Describe the siren tests or activation opportunities that are

included in the siren reliability performance indicator

2. Describe the type of licensee documents that are required to

validate siren reliability

3. Determine whether a licensee’s evaluation of reliability for an

individual siren was correctly decided

4. Perform the siren reliability performance indicator calculation

TASKS: For 3 reactor sites within your region designated by your

supervisor, perform the following for each site under the guidance

of a senior emergency preparedness inspector:

1. Review licensee procedures for collecting and reporting PIs. 

(The procedures may include separate site-wide and

departmental procedures.)

2. Review licensee commitments related to the frequency of

alert and notification testing contained in the emergency

plan. Determine the expected frequency of tests which are

counted towards the PI.

3. Review licensee procedures for conducting alert and

notification system (siren) tests. Determine from the

procedures, discussions with licensee staff, and/or other

documentation, how successes and failures are indicated on

the testing documentation.

4. Select 2 calender quarters within the inspection cycle. For

each calender quarter:

a. For each scheduled testing date during the calender

quarter, obtain the original data that was collected or

created by the test (or accurate copies of this data).
Issue Date: 08/24/04 APP C6-71 1245

b. For each scheduled testing date, review the raw data

for each individual siren. Determine whether

according to licensee procedures the data indicates a

success, a failure, or is indeterminate.

c. Flag each indicated failure or indeterminate test

result. Total the number of indicated successes for

each testing date. Total the number of indicated

successes for the calender quarter.

d. Calculate the ratio of successes to the total number of

sirens tested according to your review of the data. 

Compare this ratio to the ratio reported by the

licensee to the NRC. Discuss any differences with a

senior emergency preparedness inspector.

5. Meet with your supervisor or a senior emergency

preparedness inspector to discuss any questions that you

may have as a result of this activity and demonstrate that

you can meet the evaluation criteria listed above. 

DOCUMENTATION: Emergency Preparedness Inspector Qualification Signature

Card, Item OJT-EP-8.
1245 APP C6-72 Issue Date: 08/24/04

PAGE INTENTIONALLY BLANK
Issue Date: 08/24/04 APP C6-73 1245

Emergency Preparedness Inspector On-the-Job Activity

TOPIC: (OJT-EP-9) Emergency Drill/Exercise Evaluation

PURPOSE: The conduct of an emergency drill/exercise allows the licensee to

test and assess its emergency responders’ performances and to

identify and correct identified concerns. Root causes of identified

performance concerns may involve factors such as: emergency

response training, emergency plan implementing procedures,

response facility and equipment readiness, personnel performance,

organizational and management changes, or equipment operability. 

Upon completion of this activity, you will be able to evaluate the

adequacy of a licensee’s capability to conduct an emergency

drill/exercise and adequately critique its participants’ performances.

COMPETENCY

AREAS: INSPECTION

LEVEL OF

EFFORT: 40 hours

REFERENCES: IP 71114.01, “Exercise Evaluation 

IP 71114.06, “Drill Evaluation”

10CFR50, Appendix E, Section IV.F

10CFR50.47(b)

Licensee’s drill/exercise objectives

Licensee’s drill/exercise scenario manual

NEI 99-02, Section 2.4, “Emergency Preparedness Cornerstone”

IP 71151-03.01.h, “Performance Indicator Verification, Emergency

Response Organization Drill/Exercise Performance (DEP)

EVALUATION

CRITERIA: At the completion of this activity, you should be able to:

1. Review a designated licensee’s drill/exercise objectives and

scenario manual to determine if the drill/exercise will be an

acceptable test of the licensee’s Plan in accordance with

10CFR50, Appendix E Section IV.F.2

2. Discuss NRC inspection procedures for drill/exercise

observation and assessment of the licensee’s critique

process.
1245 APP C6-74 Issue Date: 08/24/04

3. Independently assess drill/exercise participants’

performances in areas such as: emergency classification;

offsite agency notification; Protective Action

Recommendation (PAR) development and notification;

command and control; development and implementation of

a prioritized accident mitigation strategy; and other areas

observed during the drill/exercise. Licensee drill/exercise

performance should be evaluated during several exercises

by an inspector in training in at least these locations: Control

Room; Technical Support Center (TSC); Operations Support

Center (OSC); and Emergency Operations Facility (EOF). 

4. Determine if the planning standards of 10CFR50.47(b)

would be met as a result of independent observation of

emergency drill/exercise performance.

5. Compare your independently identified performance

concerns against the licensee’s identified concerns to

determine whether the licensee is properly identifying

performance weaknesses and deficiencies, particularly with

respect to the risk significant topics of emergency

classification, notification, PAR development, and PAR

notification.

6. Determine if the licensee’s critique of drill/exercise

performance is effective in identifying drill/exercise

performance weaknesses and deficiencies, as well as

concerns of lesser significance, for inclusion in its corrective

action tracking system.

7. Compare the biennial exercise scenario’s narrative summary

and time line to those scenarios used by the licensee since

the previous biennial exercise to determine if the biennial

exercise is unacceptably similar to those previously used

scenarios.

8. Identify trends in poor performance during an emergency

drill/exercise that may represent failures to correct

weaknesses and deficiencies identified during the time

period beginning with the previous biennial exercise.

9. Determine if licensee has demonstrated the capability of

providing reasonable assurance that adequate on-site and

off-site protective measures can be taken in the event of a

radiological emergency, or if a recommendation to NRC

management should be made that the licensee conduct a

remedial drill.
Issue Date: 08/24/04 APP C6-75 1245

TASKS: 1. Review IP 71114.01, “Exercise Evaluation” and IP 71115.06,

“Drill Evaluation” to identify the inspection attributes provided

for drill/exercise performance evaluations. Discuss any

questions with your supervisor or a designee, such as an

emergency preparedness inspector.

2. Review NEI 99-02, Section 2.4, “Emergency Preparedness

Cornerstone” to become familiar with the Drill/Exercise

Performance (DEP) Indicator. Discuss any questions with

your supervisor or designee.

3. Review the regulatory requirements with regard to an

emergency drill/exercise contained within

10CFR50.47(b)(14) and 10CFR50, Appendix E, Section

IV.F.

4. Become familiar with the content of IP 71151-03.01.h,

“Performance Indicator Verification, Emergency Response

Organization Drill/Exercise Performance (DEP).

5. Obtain the emergency preparedness drill/exercise schedule

for the region or site. Coordinate your observation of

upcoming emergency drills/exercises with your supervisor,

regional emergency preparedness inspectors, and senior

resident inspectors. Observe drill/exercise performances

within at least these locations: Control Room, TSC, OSC,

and EOF in order to obtain multiple perspectives of

licensees’ emergency response capabilities.

6. Become familiar with relevant portions of the licensee’s

Emergency Plan and Implementing Procedures. In

particular, review those implementing procedures that

provide instructions for classification, notification and PAR

development to develop an understanding of successful

implementation.

7. Review copies of the chosen emergency drill/exercise

objectives and scenarios. Identify opportunities for

classification, notification, and PAR development, and the

licensee’s criteria for determining performance success

versus failure. Determine if each drill/exercise is a sufficient

test of the Plan per 10CFR50 Appendix E, Section IV.F.2. f. 

(If you suspect it is not a sufficient test, notify your

supervisor or designee). Refer to IP 71114.01-03.01

Inspection Guidance.

8. Obtain and review a sample of identified weaknesses and

deficiencies from the previously conducted biennial

emergency exercise and become familiar with corrective

actions taken. Identify opportunities for observation of
1245 APP C6-76 Issue Date: 08/24/04

repeat weaknesses and deficiencies. Refer to IP 71114.01-

03.02 Inspection Guidance.

9. Perform an independent observation of licensee

performance during the emergency drill/exercise. Refer to

previously identified opportunities for classification,

notification, PAR development, corrective actions, and other

areas selected to aid in prioritizing observations. Do not

interfere with the licensee’s drill/exercise participants. Do

not “prompt” licensee participants or evaluators, or voice

your opinions of participants’ performances during the

drill/exercise. The NRC assessments must be held

confidential until after the licensee’s critique presentation to

the inspectors.

10. Document instances when licensee controllers or evaluators

“prompt” participants during the drill/exercise. Refer to IP

71114.01-03.03.

11. Obtain copies of checklists and forms used during

drill/exercise performance with regard to classification,

notification, PAR development, and PAR notification. 

Identify any failures. 

12. Obtain records of other observed areas which you suspect

to be weak or deficient. Identify if area indicates a

programmatic problem to the point that a planning standard

of 10CFR50.47(b) may not be met.

13. Attend licensee evaluator meetings and critiques where

exercise weaknesses and deficiencies are identified. 

Determine if the licensee’s critique identified your observed

performance concerns. In particular, identify if licensee

correctly assessed classification, notification, PAR

development and notification, corrective action failures, and

other observed weak or deficient areas.

14. Verify that the licensee properly dispositions weaknesses

and deficiencies with regards to performance indicator

statistics and the site’s corrective action program.

15. Provide your emergency drill/exercise observations and

critique results to the lead inspector. Discuss your

emergency drill/exercise observations with lead inspector

and provide a recommendation on whether licensee

demonstrated the capability of providing reasonable

assurance that adequate protective measures can be taken

in the event of a radiological emergency, or if a remedial

drill should be recommended to NRC management.
Issue Date: 08/24/04 APP C6-77 1245

16. Meet with your supervisor or a qualified senior emergency

preparedness inspector to discuss any questions that you

may have as a result of this activity. 

DOCUMENTATION: Emergency Preparedness Inspector Proficiency Level

Qualification Signature Card Item OJT-EP-9.
1245 APP C6-78 Issue Date: 08/24/04

PAGE INTENTIONALLY BLANK
Issue Date: 08/24/04 APP C6-79 1245

Emergency Preparedness Inspector Technical

Proficiency Level Signature Card and Certification

Inspector Name: ___________________________

Employee

Initials/ Date

Supervisor’s

Signature/Date

A. Required Training Courses

Power Plant Engineering (Self Study of selected chapters)

(R-104B) GE Technology |

(R-104P) Westinghouse Technology |

(H-203) Emergency Preparedness Technology

B. Individual Study Activities

(ISA-EP-1) Code of Federal Regulations for Emergency Preparedness

 Inspectors

(ISA-EP-2) Licensee Emergency Plan Documents

(ISA-EP-3) Preparation and Evaluation of Radiological

Emergency Response Plans and Preparedness

(ISA-EP-4) Functional Criteria for Emergency Response Facilities

(ISA-EP-5) TMI Action Plan Requirements

(ISA-EP-6) Manual of Protective Action Guides and Protective Actions

 for Nuclear Incidents

(ISA-EP-7) RTM-96, Response Technical Manual

(ISA-EP-8) NUMARC/NESP-007, Methodology for Development of 

Emergency Action Levels

(ISA-EP-9) NUREG 0396, Planning Basis for the Development of

State and Local Government Radiological Emergency

Response Plans in Support of Light Water Nuclear 

Power Plants

(ISA-EP-10) NUREG/CR-5247, RASCAL User’s Guide

(ISA-EP-11) Emergency Preparedness Position (EPPOS) Papers

(ISA-EP-12) Emergency Preparedness Significance Determination

 Process

C. On-the-Job Training Activities

(OJT-EP-1) Alert and Notification System Testing

(OJT-EP-2) Emergency Response Organization Augmentation

(OJT-EP-3) Emergency Action Level and Emergency Plan Changes

(OJT-EP-4) Correction of Emergency Preparedness Weaknesses 

and Deficiencies

(OJT-EP-5) Performance Indicator Verification
1245 APP C6-80 Issue Date: 08/24/04

(OJT-EP-6) Performance Indicator Verification: Drill and Exercise

 Performance

(OJT-EP-7) Performance Indicator Verification: Emergency 

Response Organization Drill Participation

(OJT-EP-8) Performance Indicator Verification: Alert and

 Notification System Reliability

(OJT-EP-9) Emergency Drill/Exercise Evaluation

Supervisor’s Signature indicates successful completion of all required courses and activities listed in this journal and

readiness to appear before the Oral Board.

Supervisor’s Signature ____________________________ Date: ___________

This signature and certification must be accompanied by the appropriate Form 1, Emergency Preparedness

Inspector Technical Proficiency Level Equivalency Justification, if applicable.
Issue Date: 08/24/04 APP C6-81 1245

Form 1: Emergency Preparedness Inspector Technical

Proficiency Level Equivalency Justification

Inspector Name: __________________________

Identify equivalent training and

experience for which the inspector is to

be given credit

A. Training Courses

Power Plant Engineering (Self Study of selected chapters)

GE Technology (R-104B) |

Westinghouse Technology (R-104P) |

Emergency Preparedness Technology

B. Individual Study Activities

(ISA-EP-1) Code of Federal Regulations for Emergency Preparedness

 Inspectors

(ISA-EP-2) Licensee Emergency Plan Documents

(ISA-EP-3) Preparation and Evaluation of Radiological

Emergency Response Plans and Preparedness

(ISA-EP-4) Functional Criteria for Emergency Response Facilities

(ISA-EP-5) TMI Action Plan Requirements

(ISA-EP-6) Manual of Protective Action Guides and Protective Actions

 for Nuclear Incidents

(ISA-EP-7) RTM-96, Response Technical Manual

(ISA-EP-8) NUMARC/NESP-007, Methodology for Development of 

Emergency Action Levels

(ISA-EP-9) NUREG 0396, Planning Basis for the Development of

State and Local Government Radiological Emergency

Response Plans in Support of Light Water Nuclear 

Power Plants
1245 APP C6-82 Issue Date: 08/24/04

(ISA-EP-10) NUREG/CR-5247, RASCAL User’s Guide

(ISA-EP-11) Emergency Preparedness Position (EPPOS) Papers

(ISA-EP-12) Emergency Preparedness Significance Determination

 Process

C. On-the-Job Training Activities

(OJT-EP-1) Alert and Notification System Testing

(OJT-EP-2) Emergency Response Organization Augmentation

(OJT-EP-3) Emergency Action Level and Emergency Plan Changes

(OJT-EP-4) Correction of Emergency Preparedness Weaknesses 

and Deficiencies

(OJT-EP-5) Performance Indicator Verification

(OJT-EP-6) Performance Indicator Verification: Drill and Exercise

 Performance

(OJT-EP-7) Performance Indicator Verification: Emergency 

Response Organization Drill Participation

(OJT-EP-8) Performance Indicator Verification: Alert and

 Notification System Reliability

(OJT-EP-9) Emergency Drill/Exercise Evaluation

Supervisor’s Recommendation: Signature / Date: ___________________________

Division Director’s Approval: Signature / Date: ___________________________

Copies to: Inspector 

HR Office

Supervisor