ML040280345
ML040280345 | |
Person / Time | |
---|---|
Site: | Nine Mile Point |
Issue date: | 01/12/2004 |
From: | Detter G Constellation Energy Group |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
References | |
NIP-EPP-01, Rev 15 | |
Download: ML040280345 (19) | |
Text
{{#Wiki_filter:P.O. Box 63 Lycoming, New York 13093 Constellation Energy Group Nine Mile Point Nuclear Station January 12, 2004 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE: Nine Mile Point Unit 1 Nine Mile Point Unit 2 Docket No. 50-220 Docket No. 50-410 DPR-63 NPF-69 Gentlemen: Enclosed please find a copy of the following procedure revision for Nine Mile Point Nuclear Station: NIP-EPP-01 Rev 15 Emergency Response Organization Expectations and Responsibilities This procedure revision is being submitted as required by Section V to Appendix E of 10 CFR Part 50. Should you have any questions, please feel free to contact Mr. James D. Jones, Director of Emergency Preparedness at (315) 3494486. Very truly yours, G L. Detter Manager Security & Emergency Preparedness GLD/cr Enclosure Pc: Mr. H.J. Miller, Regional Administrator, Region I (1 copy) Mr. G.K. Hunegs, Senior Resident Inspector (1 copy) Mr. P.S. Tam, Senior Project Manager, NRR (2 copies) 04S
NINE MILE POINT NUCLEAR STATION NUCLEAR INTERFACE PROCEDURE NIP-EPP-01 REVISION 15 EMERGENCY RESPONSE ORGANIZATION EXPECTATIONS AND RESPONSIBILITIES I TECHNICAL SPECIFICATION REQUIRED I 01
- Approved by: .204 :::?hS-103 G.L Detter Date -1 Effective Date: i2/19/2003 K> PERIODIC REVIEW DUE DATE: JUNE 2004
NINE MILE POINT NUCLEAR STATION NUCLEAR INTERFACE PROCEDURE
/i NIP-EPP-01 REVISION 15 EMERGENCY RESPONSE ORGANIZATION EXPECTATIONS AND RESPONSIBILITIES
[TECHNICAL SPECIFICATION REQUIRED 0, Approved by: 42Zz Z/ - 03 G.L.Detter Date -f Effective Date- f 2/19/2003 PERIODIC REVIEW DUE DATE: JUNE 2004
, TABLE OF. CONTENTS SECTION / PAGE 1.0 PURPOSE .. I.......
2.0 PRIMARY RESPONSIBILITIES ................. .1 3.0 PROCEDURE ...... .... .. 1 3.1 ERO Composition, Structure, and Maintenance ........................... 1 3.2 ERO Qualification and Expectations ........................... 2 3.3 ERO Maintenance ........................... 3 3.4 ERO Response Time .4 3.5 ERO Continuous Improvement Program ....................... 5 4.0 DEFINITIONS ... ;;6
5.0 REFERENCES
AND COMMITMENTS ....................... 7 -6.0 RECORDS REVIEW AND DISPOSITION ........................ 7 ATTACHMENT 1: EMERGENCY RESPONSE ORGANIZATION .. 8 ATTACHMENT 2: ERO CHANGE REQUEST .. 12 ATTACHMENT 3: ERO POSITION PREREQUISITE MATRIX .. 13 ATTACHMENT 4: ERO PERSONNEL PERFORMANCE STANDARDS . ........................................ 15 5.................. Page i NIP-EPP-01 Rev 15
I
.1.0 PURPOSE To describe the composition, structure, expectations and maintenance of the Emergency J Response Organization (ERO).
2.0 PRIMARY RESPONSIBILITIES 2.1 Nuclear Division Managers and Supervision
. assign qualified individuals to the ERO,
- assign personnel to perform emergency equipment surveillances and inventories,
- support the training, drill and emergency response functions required to maintain emergency preparedness,
- assist Emergency Preparedness with the oversight and resolution of ERO Performance issues.
2.2 Directors Emergency Preparedness
- maintain the ERO with qualified individuals insufficient quantity to meet the requirements of the Site Emergency Plan (SEP),
- assure adequate resources to effectively implement the SEP.
2.3 ERO Initial Responders maintain qualifications and meet expectations associated with the position being filled. 2.4 ERO Secondary Responders maintain qualifications and meet expectations associated with the position being filled. 2.5 Other ERO Members respond to the emergency as directed by supervision. 2.6 ERO Selection Committee consists of the Director of Emergency Planning (DEP) and Senior Managers. Committee purpose isto assist the DEP in reviewing ERO composition and selecting replacement personnel. 3.0 PROCEDURE 3.1 ERO Composition, Structure, and Maintenance 3.1.1 The Director of Emergency Preparedness:
- a. Shall ensure that personnel are assigned to staff the ERO in accordance with Attachment 1, 'Emergency Response Organization."
- b. Shall maintain the staffing of positions inAttachment 1using NUREG-0654 Table B-1 as a guide.
Page 1 NIP-EPP-01 Rev 15
3.1.1 (Cont)
- c. Shall, on at least aquarterly basis, generate a training due report, and provide this to Emergency Directors/Recovery Managers, and for secondary responders, the /
appropriate Managers. The training due report should contain:
- When each responder isdue for training.
- A summary of any responders currently delinquent.
- Any responders that will be delinquent prior to the next revision of the training list.
- d. Shall maintain a notification system for all responders.
3.2 ERO Qualification and Expectations 3.2.1 ERO Responders shall become qualified and maintain qualifications in accordance with NTP-TQS-202, Emergency Preparedness Training. 3.2.2 During drills, exercises and actual events, ERO responders shall demonstrate the ERO Personal Performance Standards (as appropriate) detailed in Attachment 4. 3.2.3 ERO Initial and Secondary Responders should:
- a. Comply with Fitness for Duty requirements when responding to emergencies, in accordance with NIP-FFD-01. This shall be accomplished by:
- 1. Persons in on-call ERO positions shall limit consumption of alcohol during their duty week, such that they maintain a blood alcohol level of less than 0.04% BAC.
- 2. All responders shall report consumption of alcohol to Security personnel or their emergency facility lead, if consumed within five hours of the emergency call-out.
- 3. Responders who are not fit for duty should not respond.
- b. Report to their designated emergency response facility when notified of an emergency, in accordance with Step .4.
NOTE: ERO Responders should respond to.an emergency, if notified, regardless of what team is on duty.
- c. Report for all training, drills, and associated activities (such as briefings or critiques) when noti ed to do so, unless other arrangements have been made in accordance with 3.2.4
- d. Respond to notification drills by completing Attachment 3, Notification Drill Response Form, from EPMP-VPP-06.
- e. Report any changes in home telephone numbers to Emergency Preparedness.
Page 2 NIP-EPP-01 Rev 15
3.2.3 (Cont)
- f. Observe ard evaluate during their 'on-decy$weekfor the duty team during scheduled drills and exercises as designated, unless other arrangements have been made in accordance with 3.2.4.
- 9. Clerical personnel shall report to the EOF upon notification of an emergency.
3.2.4 Initial and secondary responders shall arrange for qualified relief if they are not available for any reason during their duty week, or as required in Steps 3.2.3.c and 3.2.3.d of this procedure.
- a. Personnel who arrange for relief should inform the appropriate facility leader:
- EOF: Emergency Director/Recovery Manager
- TSC: TSC Manager
- OSC: OSC Coordinator
- JNC: JNC Director 3.2.5 ERO Initial Responders should inform their supervisor or facility lead of the inability to perform their ERO duty due to long-term absence or job change.
3.2.6 ERO Secondary Responders should inform their immediate supervisor of the inability to perform their ERO duties due to absence or job change. 3.3 ERO Maintenance 3.3.1 Managers and Supervisors should complete "Attachment 2' for any changes to initial and secondary responders and forward to Emergency Preparedness. This includes telephone number changes, qualification lapses, job change or termination. 3.3.2 ERO Selection Committee
- a. The DEP should maintain the ERO selection committee to consist of:
- DEP (chairperson)
- Operations Managers (for TSC staff)
- Engineering Manager (for TSC staff)
- Maintenance Manager (for OSC staff)
- Work Control/Outage Management Manager (for OSC staff)
- Training Manager (for EOF staff)
- Director of Communication/Public Relations (for JNC staff)
Page 3 NIP-EPP-01 Rev 15
2 . . - 3.3.2 (Cont)
/ DEP should:
- 1. Assess the organization for qualified ERO replacements using Attachment 3 as a guide.
- 2. Provide ERO selection committee with suggested replacements
- 3. When committee finalizes recommendation for replacements, communicate decision to candidates supervisorlmanager.
- c. The DEP should ensure:
- 1. the committee meets a minimum of once per year and
- a. reviews the ERO against Attachment 3'ERO Position Prerequisite Matrix'
- b. removes or assigns personnel as needed to maintain a fully staffed ERO that iscompliant with Attachment 3
- 2. ERO vacancies are
- a. assessed by the Committee
- b. replacements are designated in accordance with Attachment 3
- c. designees are placed on the duty roster within
* .60 days after the creation of the vacancy
- 10 days after satisfactory completion of the most recent site drill
-- d. The ERO Selection Committee shall participate inthe above activities 3.3.3 Nuclear Division supervisors and managers should assess impact of the loss of any ERO member due to illness, leaving the company, etc., and inform the Director of Emergency Preparedness as necessary.
3.3.4 Managers and Supervisors shall assist EP in maintaining the notification database when requested. 3.4 ERO Response Time 3.4.1 ERO Initial and Secondary Responders should report to their designated emergency response facility:
- a. Within 30 minutes of being notified during normal work hours for the TSC and oSC.
- b. Within 60 minutes of being notified during normal work hours for the EOF and JNC.
- c. Within 60 minutes of being notified during off-hours for all emergency response facilities.
Page 4 NIP-EPP-01 Rev 15
3.5 ERO Continuous Improvement Program 3.5.1 Ownership of the ERO composition and performance isas follows:
-{Fl' ERFLead t~raA' sibleEO soo BMis IF' Owner JNC JNC Director JNC Directors, JNC staff, DEP Director-Communications . and Public Affairs EOF Emergency Director Emergency Directors, EOF Director Emergency staff, DEP Preparedness OSC OSC Coordinator OSC Directors, OSC staff, DEP Maintenance Manager TSC TSC Manager TSC Directors, TSC staff, DEP Operations and Engineering Managers 3.5.2 Continuous improvement actions should be implemented as follows:
- a. EP shall initiate and provide guidance for all activities associated with the initiatives detailed below.
- b. Emergency Preparedness (EP) shall:
- 1. Develop summaries of drills/exercises, actual events and Operating Experience issues that contain strengths, opportunities, good practices and applicable ERO wSitions/Emergency Response Facility (ERF). These will be referred to an EP event Reports.
- 2. Distribute EP Event Reports to the ERO
- 3. Initiate and facilitate to completion, the activities inSteps 3.5.2.b-d.
- c. Performance issues should be handled as follows:
Prior to drill/exercise
- 1. ERF. leads who will be playing inthe evolution should, when prompted by EP:
- a. Assemble their teams two or three weeks prior to the drill
*b. Review expectations and performance standards
- c. Review pertinent drill/exercise and event performance issues, corrective actions and good practices, as provided by EP.
After a drill/exercise or actual event
- 1. All ERO members should review the EP Event Reports for applicable issues
- 2. ERF Facility leads who participated inthe evolution should, when prompted by EP:
- a. Participate inthe development and execution of corrective actions
- b. As needed, relate useful findings to the ERO -
- c. Initiate requests to EP for additional proficiency enhancing evolutions, as needed
- d. Seek assistance from ERF mission owners and EP for major performance issues Page 5 NIP-EPP-01 Rev 15
3.5.2 (Cont)
- d. ERF Leads and ERF Mission owners shall: /
- 1. Review EP Event Reports for applicable issues.
- 2. Assist ERO Performance owners in the resolution of issues and the maintenance of good practices, when requested.
- e. Managers and supervisors should:
- 1. Maintain awareness of their responsible ERO performance through review of EP Event Reports.
- 2. Support resolution of ERO performance issues as needed and requested.
4.0 DEFINITIONS 4.1 Emergency Response Organization (ERO) Member Any person having designated emergency response duties in one of the Emergency Response Facilities. This may include, but is not limited to: ERO Initial and Secondary Responders
- Operators/Operations Department Personnel
-, Mechanical Maintenance Personnel *~a; Electrical Maintenance Personnel
- Instrument and Calibration Technicians Radiation Protection Technicians Staff as assigned by individual supervisors
* . Security Personnel actively assigned shift functions Staff assigned to each of the above departments may not be considered ERO members unless they are specifically assigned. Other personnel are considered Non-Essential.
4.2 Initial Responder. An individual assigned to fill a key position designated inthe ERO per Attachment 1. 4.3 Secondary Responder. An individual who supports an initial responder in the emergency preparedness program per Attachment 1. 4.4 Facility Lead. The functional leader of an emergency response facility. Page 6 NIP-EPP-01 Rev 15
5.0 REFERENCES
AND COMMITMENTS 5.1 Licensee Documentation None 5.2 Standards, Regulations, and Codes 5.2.1 10CFR50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities 5.2.2 NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency. Response Plans and Preparedness in Support of Nuclear Power Plants 5.2.3 . NUREG-0696, Functional Criteria for Emergency Response Facilities 5.3 Policies, Programs, and Procedures 5.3.1 Site Emergency Plan 5.3.2 NDD-EPP, Emergency Preparedness 5.4 Commitments None 6.0 RECORDS REVIEW AND DISPOSITION 6.1 The following records generated by this procedure shall be maintained by Records Management for the Permanent Plant File in accordance with NIP-RMG-01, Records Management: None 6.2 The following records generated by this procedure are not required for retention in the Permanent Plant File: Attachment 2,ERO Change Form LAST PAGE Page 7 NIP-EPP-01 Rev 15
ATTACHMENT 1: EMERGENCY RESPONSE ORGANIZATION Sheet 1 of 4 CON TROL ROOM OGA ZATd'I. uri~pc~~J N ~1)- Title/Position Secondary Responder Station Shift Supervisor (SSS) who is the NONE Emergency Director (ED) inthe Control Room Assistant SSS (ASSS)' Shift Technical Advisor (STA) Chief Shift Operator (CSO) Nuclear Operator 'E' Nuclear Auxiliary Operator 'B" or (rninimum mC of 2)2 Chemistry Technician Fire Brigade (minimum of 2) Radiation Protection Tech.3 Communications Aide
' ASSS may also fulfill STA function if qualified.
2 Can perform basic mechanical and electrical maintenance functions. 3Additional RP Tech available from unaffected unit. 4 Operating Shift complement iscontained in GAP-OPS-01. ) Page 8 NIP-EPP-01 Rev 15
I I.. . - w', i *t - ATTACHMENT I (Cont) o Sheet 2 of 4 [EMERGENCY OPERATIONS FACILITY (EOF) ,::Nr,- .,-:. -- .; .. ' :.:..: InitialResponder Secondary Responder Emergency Director (1) None Off-Site Dose Assessment Manager Environmental Survey Sample Team (ODAM) (1) Coordinator (1) Dose Assessment Staff (1) Rad Pro Tech (1) Administrative Logistics Manager (1) Clerical Staff (14) (for all facilities) Technical Liaison Advisory Manager (1) None EOF Administrator (1) Tech Staff (1/Unit) EOF Communicator (1/Unit) Plant Information Coordinator (1) County Liaison (1) State Liaison (1)(Staffed by unaffected Unit EOF Communicator) Communications Coordinator (1) None EOF/JNC Liaison (1) None Minimum number of responders are noted in parenthesis. Page 9 NIP-EPP-01 Rev 15
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ATTACHMENT 1 (Cont)
/ Sheet 3 of 4 1TECHNICALSUPPORT CENTER(TSC) ORGANIZATION, ,;.'. I, .,:",:-.' , :,-' 'l Initial Responder Secondary Responder TSC Manager (TSCM) (1) None Technical Data Coordinator (min 2) Technical Staff (minimum of 4)
Emergency Notification System (ENS) Communicator (min of 1) TSC Communicator (min of 1 per Unit) Control Room Communicator (min 1 per Unit) Reactor Analyst (1) None Maintenance Coordinator (1) None Radiological Assessment Manager (RAM) (1) Rad Support Staff (as needed) Health Physics Network (HPN) Communicator (min of 1) Chemistry Technician or On-Call Chemistry Supervisor (minimum of 1) Security Liaison (1) None Nuclear Engineering & Design (NED) (NED) Engineering Staff: Coordinator (1) Mechanical (min of 1) Electrical (min of 1) Nuclear Fuel (min of 1) Minimum number of responders are noted in parenthesis Page 10 NIP-EPP-01 Rev 15
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ATTACHMENT I (Cont) Sheet 4 of 4 / -OPERATIONSSUPPORT:CENTER(OSC) ORGANIZATION .- '..%:- -;:.. l InitialResponder SecondaryResponder OSC Coordinator (1) None OSC Communicator (1) None Radiation Protection Team Radiation Protection Technician: Coordinator (1) Downwind Survey Teams ( minimum of 6 technicians) In-Plant Survey Teams (minimum of 3 technicians) Damage Control Team Support (minimum of 3technicians) Damage Control Team Coordinator Damage Control Teams Mechanical (minimum of 3) Electrical (minimum of 3) Instrument & Control (minimum of 3) Fire Brigade (per Site requirements) 4Personnel Accountability Coordinator None Minimum number of responders as noted in parenthesis. 4May report to the Security Tactical Operations Center ( STOC) l JOINT NEWS CENTER (JNC) ORGANIZATION j '>.- .' Initial Responder Secondary Responder JNC Director (1) JNC Radiological Briefer (minimum 1) JNC Technical Briefer (minimum 1)
.JNC Admin Manager (1)
JNC Writer (1) Rumor Control Coordinator (1) Rumor Control/Media Response (minimum 2) Media Monitoring (minimum 1) JNC Spokesperson (1) None Minimum number of responders as noted in parenthesis. Page 11 NIP-EPP-01 Rev 15
I I . .
, I . . .: , Z . .. . I ATTACHMENT 2: ERO CHANGE REQUEST Name of affected person: Work ext:
Affected ERO Position: El Unit I O Unit 20C N/A Description of Change: (O Add O Delete 0 Change) Description/Reason: Ifaddition: Home Phone: Pager #: or al doesn't have one yet or El N/A This form completed by: Name (print/initial/date): _ Work ext_ Approved (Branch Manager or above): (print/initial/date): Fax completed form to EP at # 4874 Emergency Preparedness use only O Approve O Reject Reason: C.,ompletea Dy: Name iprinuinitialidate) Initiate ERO changes in accordance with EPMP-EPP.06 ) Page 12 NIP-EPP-01 Rev 15
( C.. ATTACHMENT 3: ERO POSITION PREREQUISITE MATRIX
- '.....ERO Positi6nf TitI: 'qWuPrbilsit sikill, irtiraepat ment EOF Emergency Director General plant knowledge, command/control skills Senior manager Offsite Dose Assessment Mgr Health physics or chemistry background Chemistry Mgrs, Analysis Engineers Environmental Survey Sample Team Technical background Environmental, Chemistry Coord ._.
Dose Assessment Staff Health physics or chemistry background Chemistry, Analysis Engineers Rad Protection Tech RP Tech qualification RP Admin Logistics Manager . Admin or Technical background Any Clerical Staff Plant Operating Clerk, Admin Personnel Any Technical Liaison Advisory Manager Engineering Management Engineering General Mgr or Principle Engineer EOF Administrator General plant knowledge Training EOF Tech Staff SRO Cert or license (past or current) Training (Ops) EOF Communicator General plant knowledge Training (Ops) Plant Info Coordinator Technical or Admin background Training -
-t__ . o.
County Liaison General plant knowledge Training Communications Coordinator Technical or Admin background Q& PA - - -T EOF/JNC Liaison . Admin background Any . w- , . -1
. I ..1. .
TSC TSC Manager Detailed plant-specific knowledge and Ops Mgr and Ops GSO I command/control skills Technical Data Coordinator Detailed plant-specific knowledge Ops or System Engineering TSC Technical Staff SRO Cert or license (past or current), or detailed Ops or System Engineering i plant specific knowledge ENS Communicator Technical background System Engineering TSC Communicator General plant knowledge Ops or System Engineering Control Room Communicator Detailed plant-specific knowledge, SRO Cert or Ops Support (Super and Specialists) License (past or current) . Reactor Analyst Reactor Engineer Reactor Engineering Page 13 NIP-EPP-01 Rev 15
K- C Q .. ATTACHMENT 3 (Cont) X-t ERF' - "EROPstio W rerequis l e ions : , TSC Maintenance Coordinator Maintenance Management Maintenance General Supervisors (Cont) Radiological Assessment Mgr Rad. Prot. Managdment RP Manager, Supers Rad Support Staff Rad. Prot. background Rad. Prot. HPN Communicator Technical background Rad Pro Chemistry Dept Tech or Supervisor Chemistry background NA Security Liaison Security Management Security Dept Mgrs/Supers NED Coordinator Engineering Management Engineering Engineering staff Engineering staff Engineering OSC OSC Coordinator Maintenance Management Maintenance OSC Communicator Maintenance or WC/OM Management Maintenance or WC/OM Rad Protection Team Coord Rad. Prot. Management Rad Pro RP Techs NA NA Damage Control Team Coord Maintenance or WC/OM Management Maintenance or WCIOM Personnel Accountability Coord Security Management Security ,- -7Y Fire Brigade Fire Prot. background Fire Protection JNC JNC Director Department Manager, Comm & Public Affairs Any Rad Briefer RP background Any Tech Briefer Detailed plant-specific knowledge Ops Training Admin Manager Management Any Writer Management Licensing Rumor Control Coord Management. Any Media Response Management Any Rumor Control Management Any Spokesperson Technical background Any Page 14 NIP-EPP-01 Rev 15
C- C ( ATTACHMENT 4: ERO PERSONNEL PERFORMANCE STANDARDS KI M - e.. EN-EVT Timely and Accurate Event Recognizes normal and off normal parameter values, trends. Collects relevant data using multiple indications to validate plausible Recognition events. Solicits input from crew and station workforce. Compares plant conditions with staff knowledge and experience and develops correct diagnosis of event. MON Critical Parameters and events Demonstrates understanding of system status during transients and emergency conditions. Demonstrates recognition of expected Monitored and Trended and unexpected system changes. Demonstrates understanding of system operation including setpoints, interlocks and automatic actions. Demonstrates understanding of how systems and components interact. Demonstrates understanding of how actions should affect system operation PRO Appropriate Procedures Referenced Refers to correct procedures as required and without delay. Follows procedure steps in correct sequence. Abides by cautions and and Utilized limitations. Procedure steps are completed as written. Utilizes approved methods of place keeping. Reviews procedures (as individual and with crew when crew participation required) prior to use when possible. Procedure changes are identified and supported when required. Activities are stopped, the plant is stabilized and supervision is contacted when problems arise. SAP Applies safety principles to all Use and enforces site safety procedures and practices when planning and performing work. Adheres to ALARA. Stops unsafe activities work practices. Utilizes the Hazardous Energy Control Program effectively. Maintains and enforces housekeeping standards. MIT Develops timely and appropriate Assesses and actively seeks all available information to understand plant and radiological conditions. Determine need for action mitigate and corrective action strategies. Considers all inputs for possible solutions, including innovation as required. Requests or plans for devised actions strategies without delay. Assesses effectiveness of these plans and actions and adjusts strategies as needed. COM Communications Comply with the Communications and the phonetic alphabet are strictly practiced. All communications are clear and concise. Listens actively and Established Standard checks for understanding. Requests for clarification are made when necessary. Log keeping practices allow for accurate event recreation. CNC Command and control behaviors Makes conservative decisions. Sets priorities consistent with plant and offsite conditions, and available resources. Delegates consistently used responsibilities considering roles, levels of experience and workload. Provides updates when ERF staff needs timely information to carry out responsibilities. Conducts briefs when needed to ensure that staff remains aware of and focused on their goals. Evaluates plant response to crew's actions. Reinforces good behavior. INF Communicate Vital Information Provides relevant and timely information; both solicited and unsolicited. Provides relevant and timely notification and recommendations when parameters, parameter trends and system availability require action or change significantly. Advocates conservative decision making. Questions priorities inconsistent with ERF goals and provides solutions. Informs ERF leadership if assigned tasks are beyond current capabilities and provides solutions. Provides unsolicited feedback on status of actions being taken. Holds self and crewinembers accountable to established standards of performance. Provides coaching when needed. CAL Calculations and engineering Performs calculation and analysis tasks methodically and accurately. Performs appropriate verification of inputs and results. analysis are accurate and timely OFF Recognition and action towards the Advocates ofsite agency needs and priorities within the ERO. Incorporates offsite agency requirements and requests into actions. needs of offsite agencies Resolves issues related to offsite agency needs without delay. Page 15 NIP-EPP-01 Rev 15}}