ML050280317

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SECY-05-0064-Attachment 1, Program Plan for Enhancing Emergency Preparedness and Response March 2005
ML050280317
Person / Time
Issue date: 04/18/2005
From:
NRC/NSIR/DPR
To:
Frant S, NSIR 415-0125
References
NRC-2017-000314, SECY-05-0064
Download: ML050280317 (19)
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OFFICIAL USE ONLY United States Nuclear Regulatory Commission Program Plan for Enhancing Emergency Preparedness and Response March 2005 Attachment 1 Plan for Enhancing Emergency OFFICIAL USE ONLY

OFFICIAL USE ONLY Preparedness and Response Executive Summary:

The plan for enhancing emergency preparedness and response (Plan) has been developed in accordance with management expectations and is aligned with the U. S. Nuclear Regulatory Commission (NRC) FY 2004 - FY 2009 Strategic Plan. The Plan guides the agency toward fulfilling the Commissions vision of achieving excellence in regulating the safe and secure use and management of radioactive materials for the public good.

The Plan includes four high level program goals that support NRCs strategic goals; 10 key initiatives to meet program goals; and staff initiatives to enhance the program and respond to Office of Inspector General (OIG) recommendations.

The initiatives are:

1. Incident Response Qualification Program
2. Program Standardization
3. Assessment of Response
4. Facilities
5. Post-9/11 Emergency Preparedness
6. Incident Response Staffing
7. Outreach
8. Staff Augmentation
9. Lessons-Learned and Corrective-Action Programs
10. Bench marking Each initiative is described, current status is noted, and actions or activities to move toward excellence are listed.
1. Purpose The purpose of this document is to provide a description of program goals and key initiatives to enhance the effectiveness of emergency preparedness and incident response.
2. Program Goals and Key Initiatives The program goals address the organizational and technical areas where enhancements can be incorporated into the current program. These goals are linked to the NRC strategic goals of Safety, Security, Effectiveness and Management, as described in the following paragraphs.

Performance measures are currently being developed to support the program goals and will tie into the NSIR Operating Plan. The organizational efficiencies achieved from implementing the program goals will help execute daily activities in the operating plan.

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OFFICIAL USE ONLY This document describes 10 key initiatives to enhance execution of program goals. The initiatives represent an agency-wide approach to address NRC incident response issues including the recommendations from the recent OIG Report on NRC incident response.

Specifically, the staff mapped and integrated OIGs recommendations into 10 key initiatives which directly support the four program goals. A cross walk to show the relationship to the program goals, initiatives, and OIG recommendations is included in Section 3.

2.1 Program Goals The Emergency Preparedness and Response program goals and corresponding actions are as follows:

1. Ensure that NRC personnel remain capable to consistently and effectively respond to incidents (supports NRC strategic goals of Safety, Security, Effectiveness)
  • Enhance the Incident Response Organization (IRO) training and qualification database
  • Effectively staff the NRC IRO
  • Effectively implement the National Response Plan (NRP) and National Incident Management System (NIMS)
2. Act as a unified response organization (supports NRC strategic goals of Effectiveness, Management)
  • More effectively align NRC headquarters, NRC regions, and Federal agency coordination processes.
3. Achieve excellence in stakeholder outreach (supports NRC strategic goals of Safety, Security, Effectiveness, Management)
  • Improve internal and external communications
  • Enhance outreach to Federal agencies, State, Local and Tribal officials, and licensees.
4. Continually improve NRC preparedness and response capabilities (supports NRC strategic goals of Safety, Effectiveness, Management)
  • Develop an assessment program for consistent performance measurement
  • Bench mark with the regions and other response organizations.

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OFFICIAL USE ONLY 2.2. Agency-Wide Incident Response Program Improvement Initiatives The 10 initiatives to support the four program goals are:

1. Incident Response Qualification Program
2. Program Standardization
3. Assessment of Response
4. Facilities
5. Post-9/11 Emergency Preparedness
6. Incident Response Staffing
7. Outreach
8. Staff Augmentation
9. Lessons-Learned and Corrective-Action Programs
10. Bench marking Table 1 in Section 3 illustrates the crosswalk of 17 OIG recommendations and the 10 initiatives in support of the high level program goals. The 17 recommendations made by OIG are listed in a November 3, 2004, memorandum from the Deputy Executive Director for Homeland Protection and Preparedness (ML042960632).

Several of the initiatives deal with process improvement and best practices implementation.

Therefore, improvements of this nature will be documented in an NRC incident response program manual chapter, providing the basis for a single, consistent, and effective program for headquarters and the regions. This will meet the Commissions requirement that NRC responders perform effectively during an incident involving an NRC licensee or with NRC licensed materials.

Base Documents Beyond the statutory requirements, the fundamental bases for the NRC agency-wide incident response program are contained in two documents. These documents are Management Directive (MD) 8.2, " NRC Incident Response Program," and NUREG 0728, "NRC Incident Response Plan." MD 8.2 describes the basic authorities and organization of the Incident Response Program. NUREG-0728 is the core document that describes NRC roles and responsibilities in response to radiological incidents and emergency events involving licensees and certificate holders. By April 14, 2005, these documents will be in conformance with the NRP, issued by the U.S. Department of Homeland Security (DHS) in January 2005.

In the following sections, each initiative is described with its current status and planned improvements. The assessment of each area included a review of data from past exercises and incidents, feedback from NRC stakeholders, OIG audit recommendations, and assessment of bench marking information from U.S. and foreign emergency response programs. For those areas, a series of activities was developed to enhance each area. The staffs goal is to achieve excellence, where excellence is defined as being among the top echelons of federal response organizations, among the most respected and emulated internationally, and one in which consistently very high quality response is achieved.

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OFFICIAL USE ONLY 2.2.1 NRC Incident Response Qualification Program Program Goal Supported:

  • Ensure that NRC personnel are capable to consistently and effectively respond to incidents

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Description:==

An agency-wide qualification program provides a consistent standard to give confidence that NRC responders will perform effectively. Qualification standards also provide consistency between headquarters and the regions. Further, a well defined, well documented program provides a mechanism to continually improve the qualification of incident responders.

The agencys incident response program was originally developed following the TMI-2 accident in 1979. Initially, NRC relied on experienced staff and did not prioritize development of a formalized responder training program. In 1995, a revised training program with minimum requirements was introduced as guidance; however, these requirements were not formally implemented.

Status:

The minimum requirements of the training program for NRC incident responders are:

For initial qualification

- General Response Training (as an introduction to the program)

- Position-specific training, (familiarization with the individuals duties), including specialized computer and technical tools training (as applicable)

- Successful participation in a drill or exercise For maintaining qualification

- (Updated) General Response Training (and refresher training)

- Periodic-specific re-training, (to maintain familiarity with the individuals duties, procedures, and to benefit from recent lessons learned experience)

- Periodic participation in drills, exercises, table tops, or walkthroughs, as appropriate to demonstrate proficiency There is no agency-wide documentation of incident response qualifications. Several training courses (such as NSIRs Response Technical Manual training and Radiological Assessment System for Consequence Analysis [RASCAL] dose assessment training courses) are presently being conducted. Exercise participation is documented and training records are maintained separately by headquarters and regional response coordinators.

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OFFICIAL USE ONLY Summary of Improvement Initiatives:

1) Develop and implement a formal qualification program to support the agencys incident response function. (OIG #16) - IN PROGRESS
2) Perform functional analyses in cooperation with response team directors and senior agency managers to ensure that the incident response training program is fully aligned with and supports the agencys safety, security and emergency preparedness missions.

(OIG #4) - IN PROGRESS

3) Develop qualification criteria based upon the knowledge, skills and abilities identified as essential for each response team position. - IN PROGRESS
4) Leverage technology to track qualification requirements, individuals delinquent in re-qualification, and response availability.
5) Convert applicable response training modules to a web-based training format.
6) Request support and expertise from NRC offices in computer based training material development and subject matter experts for training classes.
7) Develop qualification manuals or "qual cards" for each IRO position. These manuals will set a minimum prerequisite standard of training and experience for entering the incident response training program. - IN PROGRESS
8) Document completion of the qualification manuals for IRO members in the agencys learning management system maintained by the Office of Human Resources (HR).
9) Develop drill scenarios that can simulate various terrorist-initiated events, severe core damage, and severe accident mitigation strategies at reactors, fuel facilities, gaseous diffusion plants, and materials licenses. Additionally, develop intermediate phase and recovery phase drills and tabletop performance-based training scenarios to more realistically test the IRO, including response to multiple incidents and turnover practices for protracted incidents. (OIG #6, #7, #8, #9, #10, #12)
10) Perform unannounced drills (which include tabletops and walkthroughs) or exercises as necessary to test overall response readiness.

2.2.2 Program Standardization Program Goal(s) Supported:

  • Ensure that NRC personnel are capable to consistently and effectively respond to incidents
  • Act as a unified response organization OFFICIAL USE ONLY

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Description:

Standardization of incident preparedness and response programs provides fundamental elements necessary for continual improvement and the achievement of excellence. Each program benefits from appropriately detailed policies, implementing procedures, a performance based qualification program, performance evaluation methods, and agency-wide management level commitment. For continual improvement to occur, policies should direct consistent conduct of incident response actions, which are evaluated in a self-critical environment, and enhanced where necessary to address lessons learned.

Status:

Incident preparedness and response processes are not consistently maintained or standardized. Documents in some cases, contradict each other. Implementing procedures are not consistently formatted agency-wide, nor written to a level of detail to ensure consistent response actions. The qualification program for incident response organization members is not well documented, not arranged in a performance-based format (which is the standard practice of industry programs), and not consistent agency-wide. The establishment of an oversight process for the agency incident response function is not well defined or coordinated agency-wide.

Summary of Improvement Initiatives:

1) Revision of NUREG-0728 and Management Directive 8.2 to outline programmatic organization of the incident preparedness and response program, and to clarify agency policy in regard to the program. (OIG #1, #2) - COMPLETE BY APRIL 14, 2005
2) Re-alignment of other NRC documents to NUREG-0728 and Management Directive 8.2, such as NUREG-0845, and NUREG/BR-0230. Where appropriate, consolidation into other documents and/or cancellation of documents will be performed. (OIG #3)
3) Formation of an agency-wide incident preparedness and response oversight committee to ensure consistency and adherence to established policies. (OIG #2, #4, #5)
4) Establishment of an agency-wide manual chapter format for incident preparedness and response implementing procedures including:

- Implementation of a standardized procedures writers guide

- Establishment of qualification standards for incident responders,

- Instruction for performance of periodic program assessments

- Documentation of corrective actions and issue of lessons learned to incident responders as part of a continuing training process

- Implementation of standards for incident response member performance in training, performance-based drills, and exercise opportunities OFFICIAL USE ONLY

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- Establishment of procedural instructions for addressing protracted incidents, simultaneous incidents at more than one licensee or certificate holder, and incident response at regulated fuel cycle and gaseous diffusion facilities and nuclear materials holders (OIG #1, #4, #7, #8, #9, #10, #11, #13, #15)

- Development of proceduralized documents that define the policies, procedures, and programs within the agencys incident response organization.

2.2.3 Assessment of Response Program Goal Supported:

  • Continually improve NRC preparedness and response capabilities

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Description:==

The establishment and implementation of high-quality assessment processes promote continual improvement and maintenance of the agencys incident response program. Drills, exercises, and actual event response should be assessed promptly and in a consistent manner to identify areas for improvement. Determining and tracking corrective actions are important for program improvement. A method to track corrective actions to completion, including the authority to assign tasks to individuals to ensure completion, should be in place.

Status:

The OIG recommended enhancement of the incident response assessment program. An exercise assessment process was recently piloted, which developed pre-determined performance standards identified in established regulations, plans, procedures and exercise objectives, and standardized questions for the following areas: staffing, facilities, procedures, operations, essential functions, notifications and communications, transfer of responsibilities, exercise objectives, and individual observations. Region IV, also participated in the pilot program. Additional process improvements are necessary, including formalization of the post-drill, exercise, or incident critique process, and consistent documentation and tracking of lessons learned. Coincident with development of the qualification program, assessment information should be included as part of periodic IRO training.

Summary of Improvement Initiatives:

1) Revise the handbook for MD 8.2, NRC Incident Response Program to establish evaluation expectations for NRC IRO performance in drills and exercises. (OIG #2) - IN PROGRESS
2) Develop assessment procedures to ensure consistent assessment performance, including periodic reviews of headquarters and regions response capabilities, to ensure standardization and a mechanism to periodically share and implement lessons learned with regions. (OIG #5) 2.2.4 Facilities OFFICIAL USE ONLY

OFFICIAL USE ONLY Program Goal(s) Supported:

  • Ensure that NRC personnel are capable to consistently and effectively respond to incidents
  • Act as a unified response organization

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Description:==

The incident response centers (IRCs) at NRC headquarters and at each of the four NRC regional offices support IRO response functions during an incident. The headquarters IRC serves as the primary response center, with continuity of operations capability at an alternative center. Regional IRCs serve as the agencys lead facilities during the monitoring response mode and as coordinating and support facilities for the responding Site Team(s), which may report to the licensee(s) involved with an incident. The NRC operations center (NRCOC) serves a 24/7 communication and coordination function with licensees and federal stakeholders.

Information technology (IT), such as databases, software programs, hardware systems, communications, and document management applications, provides an element in the capability of the IRCs to effectively assist and assess licensee actions during an incident.

Communications hardware and software systems are tools necessary for the function of the IRCs.

Status:

While improvements to information transfer have been recently implemented in the headquarters IRC, some supporting information technology infrastructure, communication systems, facility furniture, and human factors design issues remain for the NRCOC and all IRCs.

Many of these systems date back to 1994 and have exceeded the growth capacity planned for at that time. Items that are in need of augmentation, upgrade, or replacement include:

- Power, local area network (LAN) display and fax capacity

- NRC equipment recommendations for licensee emergency operations Facilities (EOFs), including development of equipment and NRC site team resource standards for fuel facilities and material licenses

- Heating, ventilation, and air conditioning (HVAC) duct noise problems and system inadequacies

- Upgrade of regional IRC communication equipment and computer software

- System furniture and space usage

- Automatic notification system (ANS)

- Phone system (private branch exchange - PBX)

- Uninterruptible power supplies (UPS)

- Audio conferencing/bridging system

- ET briefing system

- Voice recorder

- Access to critical documentation (e.g. e-library)

Summary of Improvement Initiatives:

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1) Upgrade and replace the PBX for the headquarters IRC, NRCOC, and regions IRCs.

Address the use of greater integration of the voice conferencing system, upgrade or replacement of the ET briefing system, a networked replacement for the ANS, and a replacement for the voice recorder, and addition of caller identification features.

2) Upgrade and improve capability for LAN, display, fax, and power shortage issues in the headquarters IRC.
3) Upgrade communications equipment for regional responders and standardized/upgraded computer software.
4) Reduce elevated noise level in the headquarters IRC due to the ventilation system fan white noise and provide adequate cooling to computer systems.
5) Improve information storage, transfer, and retrieval systems. Improvements include establishing an agency-wide capability to collect store, update, and retrieve applicable licensee and certificate holder documents (such as procedures, technical specifications, drawings, design basis documents, safety analysis reports), agency incident response procedures, and other documents in a single and maintainable electronic format.
6) Ensure that the headquarters ANS is maintained and reliable to notify and augment IRO members. Include periodic performance testing and drills. (Also see Staff Augmentation) (OIG #6) - IN PROGRESS
7) Re-evaluate licensee and certificate holder emergency response facilities for NRC resource accommodations and initiate appropriate information emphasizing adherence to existing guidance or enhanced guidance. (OIG #11)
8) Remodel headquarters IRC, region IRCs, and NRCOC to support human factors related improvements.

2.2.5 Post - 9/11 Emergency Preparedness Program Goal Supported:

  • Ensure that NRC personnel are consistently and effectively ready to respond to incidents

==

Description:==

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OFFICIAL USE ONLY Commercial nuclear emergency preparedness has previously been based on the actual or potential health effects from the release of radiation that results from an escalation of events, which generally occur in a step-wise fashion based on equipment malfunctions, operator errors, or other unintentional conditions. The post-9/11 environment has resulted in program enhancement which considers acts of aggression that have the intent of inflicting the maximum damage and harm. This is sufficient reason to embrace a more proactive posture in response readiness.

Status:

A number of initiatives within the agency have raised the level of preparedness among licensees. These initiatives have been jointly undertaken by NSIR staff and include the issuance of orders and advisories to licensees, the use of Force On Force (FOF) exercises to evaluate licensee performance against upgraded design basis threats, and changes to licensee emergency action levels (EALs) associated with security related activities. In response to this program enhancement, the staff continues to assess the adequacy of existing emergency planning basis requirements and guidance. Where the staff has found weaknesses in current requirements and guidance, prompt focus to address those issues has been initiated. As an example, immediately following the events of 9/11, the staff performed an initial assessment of the existing planning basis for emergency preparedness in the commercial nuclear industry and identified five implementation issues:

1) Need for a control room contingency for notifications under duress
2) Need for review of NRC protective action guidance
3) Need to plan for the increased demand on local law enforcement agencies
4) Removal of procedural barriers to rapid notification of local law enforcement agencies
5) Development and implementation of security-event-based drill program NRC resolved issues 1, 3, and 4 through discussions with industry and issuance of Regulatory Issue Summary (RIS) 2004-15, "Emergency Preparedness Issues: Post-9/11," on October 20, 2004. To resolve issue 2, the staff has contracted Sandia National Laboratories to perform a review which is to be completed in 2006. To resolve issue 5, the staff intends to dedicate one full time employee (FTE) to develop detailed scenario standards and oversight processes to ensure nuclear power plant licensees implement a drill and exercise program that improves the emergency preparedness/operations security interface.

The staff participated in pilot and transitional FOF exercises. Several emergency preparedness program enhancements were identified through these FOF processes. Lessons learned and other observations were summarized in RIS 2004-15. For lessons learned identified after the RIS was issued, the staff transmitted lessons learned to NEI for dissemination to the industry.

Inspection procedures for the FOF are developed and the significance of any EP findings is being determined in accordance with the EP cornerstone of the Reactor Oversight Process.

Twenty FOF exercise evaluations are anticipated in 2005.

Summary of Improvement Initiatives:

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1) Develop an overall plan for emergency preparedness and response of nuclear power plant licensees in post-9/11 environment, including review of the 10 CFR 50.47 emergency preparedness planning standards guidance. This plan will assess potential improvements in the following areas for responding to security-initiated events:
  • Emergency action levels
  • Onsite protective actions
  • Offsite notifications This improvement initiative is IN PROGRESS.
2) Periodically perform inspections and emergency exercise evaluations to ensure licensees take adequate protective measures in the event of a terrorist-initiated radiological emergency. - ONGOING
3) Develop and promulgate, with appropriate stakeholder involvement, new requirements and guidance utilizing objective performance standards where appropriate. - ONGOING
4) Perform appropriate reviews of licensee-submitted changes to emergency preparedness licensing documents to ensure compliance with promulgated requirements and guidance. - ONGOING
5) Evaluate enhancements to the emergency notification process, including the potential for simultaneous notification of state/local officials and the NRC.

2.2.6 Incident Response Staffing Program Goal Supported:

  • Ensure that NRC personnel are capable to consistently and effectively respond to incidents

==

Description:==

The methodology for staffing incident response positions has remained essentially unchanged since the establishment of the incident response function. Most response positions are staffed with three or four subject matter experts. These individuals then received additional training on response team structure and agency expectations.

Status:

Response personnel are selected based upon knowledge and abilities they had demonstrated in other venues. Most individuals are in demand for other, more routine, activities, resulting in conflicting priorities and assignments. The incident response function at headquarters sometimes competes for the services of these staff members for drills or training activities.

When a scheduled response participant finds that he or she will not be available, other qualified replacement (also highly valued staff members) may not be available. In those cases, compensatory measures must be taken to reassign duties and functional responsibilities among OFFICIAL USE ONLY

OFFICIAL USE ONLY other response team members, typically resulting in delayed or absent positions in training classes and exercises. Although there is some variation among regional IRO staffing, base and site team functions parallel headquarters IRC staff functions. Regions did not express issues with IRO staff support of training activities. Discussion to more consistently staff IRO teams has been initiated among the regions.

Summary of Improvement Initiatives:

1) Establish a methodology to address prompt activation of the IRO. Include consideration for IRO member residence locations and response time, as applicable to the importance of the position held and IRC activation time expectations. Include provisions for additional staffing, as necessary, to support multiple licensee/event response and protracted staffing (greater than one shift). (OIG #8, #9, #10)
2) Establish a team approach (Red, White, and Blue) for headquarters IRO staff training and drill/exercise scheduling for headquarters IRO. Staffing practices will be established for the regions, materials, and fuel facility incident responders such that staffing arrangements are consistently applied among those organizations. These teams will be populated in such a manner that any team compliment will be prepared and capable to respond to an emergency. (OIG #10, #17) - IN PROGRESS
3) Develop strategy for identification of key minimum staffing necessary for incident response at headquarters and region IRCs. - IN PROGRESS
4) Assign individuals to NRC response positions and obtain approval by the Executive Director for Operations (EDO) for headquarters positions, and the Regional Administrators (RAs) for region positions. (OIG #16) - IN PROGRESS
5) Ensure management is aware of the commitment for assigned individuals to attend mandatory training and to participate in drills and exercises. (OIG #16) - COMPLETE
6) Identify IRO participation for each member. Participation will be recognized in the annual performance appraisal process. (OIG #16) - IN PROGRESS
7) Designate additional personnel as "in training," thereby creating a pool of trained individuals who will be available to supplement team resources or to assume the duties of a departing staff member.
8) Assign a "position lead" (or mentor) responsible for assisting NSIR team coordinators in staff training, technical tool development, peer evaluation, and procedural support.

The enhancements to response team staffing described above will be phased in to allow for development of necessary training modules and procedures.

  • Phase 1 will address the Reactor Safety Team, Protective Measures Team, Operations Support Team, and the Executive Team.

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  • Phase 2 will address the Liaison Team, Safeguards Team, Fuel Cycle Safety Team, Regional Base Team, and the Site Team.
  • Phase 3 will address response communications and other recommended enhancements.

2.2.7 Outreach Program Goal(s) Supported:

  • Achieve excellence in stakeholder outreach
  • Act as a unified response organization

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Description:==

NSIR is responsible for outreach activities regarding emergency preparedness and NRC incident response. Examples of outreach activities include: presentations with external stakeholders; participation in regional scheduling conferences; presentations at industry conferences, (such as the Nuclear Energy Institute (NEI) Communications Forum, NEI EP Forum, National Radiological Emergency Preparedness Annual Meeting, American Nuclear Society (ANS) Mid-Year Meeting Health Physics Society Annual Meeting), participation in selected public meetings to address current emergency preparedness concerns, development of written and verbal correspondence used for agency presentation, (such as Congressional hearings, public presentations by NRC officials), preparation of licensee guidance for emergency public information news centers, and continued close communication and coordination with DHS/FEMA officials on emergency preparedness issues.

Status:

The Outreach Team was recently established as a joint Emergency Preparedness Directorate/Incident Response Directorate (EPD/IRD) staff organization. The regions, who engage in outreach activities with licensees and states, are also represented on this team.

Currently, the Outreach Team is taking a primary role in coordinating various agency outreach functions, including FEMA Regional planning meetings, NRP rollout presentations, and other related activities. The staff has initiated coordination with the regions to standardize outreach activities with states and licensees. The staffs activities will correlate with the DHSs 3-phase implementation process for the NRP. Outreach Team members will assist other NRC staff in the delivery of information concerning the NRP implementation.

Summary of Improvement Initiatives:

1) Review and improve the present practices and materials used for outreach presentations related to NRC incident response activities at headquarters and the regions. The OFFICIAL USE ONLY

OFFICIAL USE ONLY Outreach Team will take a pro-active approach to providing high quality training and presentations to Licensee/State/Local/Tribal government stakeholders responsible for interacting with NRC incident responders during an incident, with a focus on providing information to applicable organizations periodically. (OIG #14) - IN PROGRESS

2) Develop a question/answer database to assist in the consistent use of prior approved NRC statements in the delivery of EP related positions. This database will be controlled by DPR and use prior developed and newly generated materials compiled in an easily accessible and searchable tool which will be available for generation of official positions for NRC public spokespersons (such as EDO staff, Office of Public Affairs, Office of Congressional Affairs. - IN PROGRESS 2.2.8 Staff Augmentation Program Goal Supported:
  • Ensure that NRC personnel are capable to consistently and effectively respond to incidents

==

Description:==

Staff augmentation is the process of notifying IRO members of an incident and to assemble at the NRC headquarters IRC and region IRCs. This process includes a standardized mechanism to call out IRO, maintenance of phone lists and/or computer databases used in the callout process, identification of available personnel to initiate IRC staffing, and periodic performance of tests and drills to ensure that the process can be consistently implemented. NRC headquarters and regions rely on staff augmentation capabilities to activate IRO members.

Status:

Staff augmentation of the NRC headquarters IRO can be performed using either a personal computer based automated notification system (ANS), a voice conferencing blast dial, or a manual callout using a published incident response call list. The databases for the ANS and manual call lists are separately maintained. The most rapid callout means is the ANS.

Maintaining multiple phone lists is not resource effective or reliable as phone lists have been found to be in disagreement. Because callout mechanisms are not routinely tested or used in drills, there are missed opportunities for training personnel to initiate call out and for detecting system database problems. Regions do not consistently implement the same staff augmentation practices from region to region but, as a whole, maintain staff augmentation capabilities more proficiently and test those capabilities more frequently than headquarters.

While the staff augmentation process as a whole may be considered functional, (i.e. capable of notifying IRO members to initiate response to the IRC), enhancements to ensure programmatic consistency, training, and testing, would improve overall assurance of performance. Additionally, methodology for addressing staff augmentation for multiple events or establishing provisions for protracted (greater than 1 shift) events is not currently considered as part of current staff augmentation practices.

Summary of Improvement Initiatives:

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1) Update the headquarters ANS responder and phone list database. Ensure that a process is in place to maintain the database accurate and current. - IN PROGRESS
2) Perform testing of the headquarters ANS callout program following completion of the database phone list review.
3) Develop and implement a schedule for periodic testing of headquarters callout mechanisms. (OIG #6)
4) Perform an evaluation for replacing the existing callout mechanisms with a single networked replacement and including access and use by the regions. If selected, this system will provide an efficient means to maintain callout databases and callout both headquarters and regional IRO members. (also see 2.2.4 Facilities)
5) Develop consistent instructions and implement staff augmentation processes to address a protracted event and staffing for multiple licensee incidents, for headquarters and region IRCs. (OIG #7, #9, #10) - IN PROGRESS 2.2.9 Lessons Learned and Corrective Action Program for Shared Learning Program Goal Supported:
  • Continually improve NRC preparedness and response capabilities

==

Description:==

A program that identifies lessons learned from assessments, drills and exercises, actual events, and occurrences elsewhere provides methods to continually improve emergency preparedness capabilities. These programs have evolved among licensees and represent a primary factor in positive improvement trends. Program excellence can be achieved when the program becomes cultural, rather than procedural. The way to achieve this is to incorporate lessons learned into training, exercises, and daily work. This can be accomplished through setting the expectations for the program, assessment and enhancement of the program, and providing incentives to use the program.

Status:

A lessons learned Microsoft Access' database exists that contains corrective actions identified during post-exercise and red event hot-wash sessions. Other than lessons learned data bases used by the regions, NSIR has not established a lessons learned program in terms of having the capability to consistently identify issues, learn from them, document corrective actions, share that information with others, and reassess progress to prevent past problems from recurring. This database is maintained by NSIR and has not been made available to the regions or headquarters personnel outside NSIR.

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OFFICIAL USE ONLY In August 2004, NRC regions compiled a list of best practices (ML042190409). The list was initially proposed for implementation by the regions, but was reviewed by the staff consideration for agency-wide improvements. Eighteen specific best practices were identified for regional implementation. Most of the region best practices list were also incorporated into the improvement initiatives, and shown below:

Initiatives Facilities Program Qualification Outreach Assessment Standardization* of Response Region List of 2 1, 3 4, 5, 6, 8, 9, 7, 13 15, 18 Best Practices 12, 14, 16, 17

  • Best practices #10 (backup resident inspector) and #11 (weekly region availability roster) were not categorized under a specific improvement initiative, but would be subject to review and agency-wide consideration under Program Standardization.

Summary of Improvement Initiatives:

1) Modify/upgrade the existing database to be usable as a corrective action tracking tool.

Some programming will be required to enable users to input new corrective action data as well as generate reports useful for management. (OIG #5)

2) Develop an agency-wide lessons learned program using established industry/government models for guidance. This will include creating a model program, management acceptance of the program, development of administrative controls for the program, and implementation of the program. Implementation will include creation of a web-based database accessible to all regions. (OIG #5)
3) Periodically review regional incident response programs for best practices and lessons learned to ensure coordinated response capabilities are maintained. (OIG #4) - IN PROGRESS
4) Provide intra-agency web-based access to the corrective action database so that outstanding regional corrective actions can be added. This will minimize duplicity and maximize use of resources. Develop procedure to standardize input and ensure consistent usage. (OIG #4) 2.2.10 Bench marking with Regions, Other Agencies, State Partners, and International Agencies Program Goal Supported:
  • Continually improve NRC preparedness and response capabilities

==

Description:==

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OFFICIAL USE ONLY Bench marking is the process of reviewing the attributes of existing programs that perform emergency response to determine if their concept of operations, policies and procedures can improve NRC incident response functions. Bench marking also allows the NRC to determine if the existing NRC response function is adequate among federal agencies and in support of licensee activities.

Bench marking is not a static, one time activity. By determining the "best practices," as they exist in the NRC regions, other federal agencies, state partners, and international regulatory agencies, the agency can implement continuous improvement to the NRC incident response function.

Status:

NRC staff and managers have visited a number of agencies to familiarize themselves with other federal agency programs, best industry examples, and private sector programs in consideration for continually improving the NRC incident response program. The list of visits include nine licensees, five federal agencies, two state agencies, one local agency, one nuclear industry advisory organization, and one international nuclear materials oversight agency. The staff has also reviewed the conduct of the emergency response functions by the Governments of Canada, United Kingdom and Japan. A recent bench marking study by the regions was incorporated into these improvement initiatives, as discussed in Section 2.2.9.

Summary of Improvement Initiatives:

1) Periodically review regional and headquarters incident response functions for best practices and lessons learned to ensure coordinated response capabilities are maintained. The reviews will be performed by peer teams. (OIG #4)
2) Periodically review other agencies incident response programs for lessons learned and to ensure coordinated response capabilities are maintained. (OIG#5) - ONGOING
3. Crosswalk of OIG Recommendations Table 1 below illustrates how the OIG report recommendations were included into the 10 emergency preparedness and response initiatives. Additionally, the program plan goals are shown in relationship to the initiatives and the OIG recommendations. All 10 initiatives and all 17 OIG recommendations are addressed under the program plan goals.

Program Goals Ensure that Act as a unified Achieve Continually NRC personnel response excellence in improve NRC are capable to organization stakeholder preparedness consistently outreach and response and effectively capabilities respond to incidents OFFICIAL USE ONLY

OFFICIAL USE ONLY Initiatives Facilities, IR Outreach, Outreach Assessment of Staffing, Staff Facilities, Response, Augmentation, Program Lessons Learned Qualification Standardization and Corrective Program, Post Actions, Bench 9/11 Emergency marking with Preparedness, Regions and other Program agencies, Post Standardization 9/11 Emergency Preparedness OIG 1, 4, 5, 6, 7, 8, 1, 3, 10, 11, 12, 14 2, 4, 5 Recommendations 9, 10, 16, 17 13, 14, 15 Table 1. How OIG recommendations support program plan goals and initiatives OFFICIAL USE ONLY

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