ML14290A199

NRR E-mail Capture - Draft RAIs for Ep/Eal LAR

ML14290A199
Person / Time
Site:	Crystal River
Issue date:	08/27/2014
From:	Michael Orenak Division of Operating Reactor Licensing
To:	Westcott D Duke Energy Corp
References
MF3415
Download: ML14290A199 (19)

Text

1 NRR-PMDAPEm Resource From:

Orenak, Michael Sent:

Wednesday, August 27, 2014 1:44 PM To:

Westcott, Daniel (Daniel.Westcott@duke-energy.com)

Subject:

Draft RAIs for EP/EAL LAR Attachments:

draft RAIs 2nd round 8-27-14.docx

Dan, Please see the attached Draft RAIs. Please let me know if you would like to set up a clarification call with the staff. I would appreciate hearing back from you by COB Tuesday Sept 2nd.

Mike Michael Orenak Crystal River and Waterford Project Manager NRR - Division of Operating Reactor Licensing Phone: 301-415-3229 e-mail: Michael.Orenak@nrc.gov

Hearing Identifier:

NRR_PMDA Email Number:

1636 Mail Envelope Properties (Michael.Orenak@nrc.gov20140827134300)

Subject:

Draft RAIs for EP/EAL LAR Sent Date:

8/27/2014 1:43:41 PM Received Date:

8/27/2014 1:43:00 PM From:

Orenak, Michael Created By:

Michael.Orenak@nrc.gov Recipients:

"Westcott, Daniel (Daniel.Westcott@duke-energy.com)" <Daniel.Westcott@duke-energy.com>

Tracking Status: None Post Office:

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Recipients Received:

CR3 LAR - Decommissioning Emergency Plan and Emergency Action Levels Page 1 of 3 DRAFT DRAFT REQUEST FOR ADDITIONAL INFORMATION (2)

CRYSTAL RIVER UNIT 3 LICENSE AMENDMENT REQUEST FOR EMERGENCY PLAN CHANGES DOCKET NUMBER 50-302 (TAC No.: MF3415)

By letter dated September 26, 2013 (Agency-Wide Documents Access and Management System (ADAMS) Accession Number (No.) ML13274A584), Duke Energy Florida, Inc. (DEF) requested a license amendment (LAR) to the Radiological Emergency Response Plan for the Crystal River Nuclear Plant, Unit 3 (CR3), heretofore identified as the Permanently Defueled Emergency Plan (PDEP). DEF requests review and approval of the CR3 PDEP to revise the emergency action level scheme and emergency plan to support the permanently defueled condition of CR3, as stated in the letter dated March 13, 2013 (ADAMS Accession No. ML13058A380).

The Office of Nuclear Security and Incident Response (NSIR), Division of Preparedness and Response (DPR), Operating Reactor Licensing and Outreach Branch (ORLOB) reviewed the license amendment request (LAR) using the guidance contained in NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (November 1980), as revised to support an emergency plan for a decommissioning power reactor facility.

Based on the staffs initial review of the submittal, a request for additional information (RAI) was sent on April 10, 2014 (ADAMS Accession No. ML14113A363) to facilitate the staffs continued technical review and DEF was informed that supplemental RAIs may be required based on the staffs concurrent technical review of CR3s requested exemptions to emergency plan requirements in Appendix E to Part 50 and the planning standards of §50.47(b), as well as other relevant issues associated with decommissioning. DEF provided a response to these RAIs via letter dated May 23, 2014 (ADAMS Accession No. ML14154A408).

Based on the review of the response to these RAIs, the staff has determined that supplemental RAIs are needed to ensure that the staff can reach a reasonable assurance finding in accordance with 10 CFR 50.47(a)(1)(i).

Note: These RAIs are numbered as a continuation of the numbering sequence presented in the previous set of RAIs related to this license amendment request. A draft of the proposed evaluation criteria for decommissioned, permanently defueled emergency plans, based on remaining applicable portions of NUREG-0654/FEMA-REP-1, is provided (Attachment 1) for your information only. The proposed evaluation criteria is based on proposed exemptions to emergency plan requirements as outlined in SECY-14-0066, and is still under review and has be finalized. However, it is provided to help inform your response to these RAIs.

CR3 LAR - Decommissioning Emergency Plan and Emergency Action Levels Page 2 of 3 DRAFT CR3-RAI-17 NRCs evaluation of the requested exemption considers the licensees ability to promptly implement mitigation measures for the spent fuel pool (SFP). In response to RAI-02, DEF indicated that it had performed an on-shift analysis for emergency response organization (ERO) functions to ensure sufficient personnel will be able to respond to a catastrophic loss of SFP water inventory using the minimum shift staffing as indicated in Section 6.0. There is no reference to this on-shift analysis in the CR3 PDEP. Please provide further justification for retaining existing language or revise Section 6.0 of the CR3 PDEP accordingly to reflect the revised licensing basis for the level of on-shift staffing.

Additionally, Table 6.1, Shift and Emergency Staffing Capabilities, does not indicate any on-shift personnel assigned to the Major Functional Area of Plant Condition Evaluation, Repair and Corrective Action. RAI-02 states that There would be three on-shift positions manning the Fire Brigade. Additionally, Table 6.1 indicates for Firefighting that the response is per the Fire Protection Plan. How does CR-3 maintain the personnel and the ability to perform mitigation actions when the number personnel assigned that function can be revised by another regulatory process other than 10 CFR 50.54(q)?

CR3-RAI-18 DEFs analysis provides reasonable assurance that in granting the requested exemption to CR3: (1) an offsite radiological release will not exceed the Environmental Protection Agencys Protective Action Guidelines at the site boundary for a design-basis accident; and (2) in the unlikely event of a severe beyond design-basis accident resulting in a loss of air cooling, there is sufficient time to initiate appropriate mitigating actions, and if a significant release is projected to occur, there is sufficient time for offsite agencies to take protective actions using a Comprehensive Emergency Management Planning (CEMP) to protect the health and safety of the public.

Historically, the staff has approved a range of ERO augmentation times of one to two hours.

These augmentation times are currently in place for all decommissioning sites except Zion, which was originally approved as one hour and was later approved to be four hours. Under Section 6.0 of the CR3 PDEP, provide further justification why a four-hour ERO augmentation time is acceptable in the event of a catastrophic loss of SFP water inventory to successfully implement required mitigation actions, and if necessary, for offsite response organizations to implement early protective measures.

CR3-RAI-19 Section 14.2 of the CR3 PDEP states, The EC [Emergency Coordinator] will initiate evacuation of the Protected Area if deemed necessary and must account for all personnel within the Protected Area and ascertain the names of missing individuals within 60-minutes. Please provide further justification for retaining existing language or revise to reflect that the 60-minutes time clock starts at event declaration. In addition, please revise to ensure that it is understood that accountability must be maintained throughout the event. (Note that this information is consistent with what is provided in CR3 Emergency Plan Implementing Procedure (EM) EM-205, Personnel Emergency Responsibilities Regarding Discovery, Assembly, Evacuation, and Accountability Within the Protected Area. Also consider revising this procedure to be consistent with the CR3 PDEP.)

CR3 LAR - Decommissioning Emergency Plan and Emergency Action Levels Page 3 of 3 DRAFT CR3-RAI-20 Section 6.3 of CR3 EM-502, Conduct of the Emergency Coordinator, states, in part: All emergency declarations should be made within 30-minutes for information becoming available to Control Room personnel that conditions have reached an EAL threshold based upon valid indications, reports, or conditions. The CR3 PDEP does not provide any information related to the timeliness of emergency classifications. Please provide further justification for retaining existing language or revise the CR3 PDEP accordingly to reflect intent to have the capability of declaring an emergency classification within 30 minutes of information becoming available.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria A

50.47(b)(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

[E.IV.1; IV.A.1, 2, 4, 7]

1.b. Each organization and sub-organization having an operational role shall specify its concept of operations, and its relationship to the total effort.

1.c. Each plan shall illustrate these interrelationships in a block diagram.

1.d. Each organization shall identify a specific individual by title who shall be in charge of the emergency response.

1.e. Each organization shall provide for 24-hour per day emergency response, including 24-hour per day manning of communications links.

4. Each principal organization shall be capable of continuous (24-hour) operations for a protracted period. The individual in the principal organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title.

B 50.47(b)(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is

1. Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement.

2. Each licensee shall designate an individual who shall be on shift at all times and who shall have the authority and responsibility to immediately and unilaterally initiate any emergency actions.

4. Each licensee shall establish the functional responsibilities assigned to the emergency coordinator.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria available and the interfaces among various onsite response activities and offsite support and response activities are specified.

available and the interfaces among various onsite response activities and offsite support and response activities are specified.

[E.IV.A.1, 2, 4, 9; A.3; C.1]

5. Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency.

9.

Each licensee shall identify the services to be provided by local agencies for handling emergencies, e.g., police, ambulance, medical, hospital, and fire-fighting organizations shall be specified. The licensee shall provide for transportation and treatment of injured personnel who may also be contaminated. Copies of the arrangements and agreements reached with contractor, private, and local support agencies shall be appended to the plan. The agreements shall delineate the authorities, responsibilities, and limits on the actions of the contractor, private organization, and local services support groups.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Minimum Staffing Requirements for NRC Licensees for Decommissioning Nuclear Power Plant Emergencies (See B.5.)

May be provided by shift personnel assigned other functions. Identify if the shift personnel assigned EP functions/tasks are from Firefighting or Security resources.

Number of additional personnel required to perform site-specific mitigation strategies required for a catastrophic loss in spent fuel pool inventory.

MAJOR FUNCTIONAL AREA MAJOR TASKS EMERGENCY POSITION, TITLE, OR EXPERTISE ON-SHIFT AUGMENTED STAFF CAPABILITY FOR RESPONSE IN 2 HOURS Plant Operations and assessment of Operational Aspects Plant Operations Shift Supervisor Shift Operator 1

1 Emergency Direction and Control Emergency Coordinator Shift Supervisor Notification/Communication Notify State and Federal personnel and maintain communications Communicator Radiological Accident Assessment and Support of Operational Accident Assessment Onsite Dose Assessment and Monitoring Heath Physics Expertise 1

Protective Actions (In-Plant)

In-Plant Surveys Radiation Protection

a. Access Control

b. HP Coverage for Repair, Corrective Actions, Search and Rescue, First Aid, and Firefighting

c. Personnel Monitoring

d. Dosimetry Health Physics Technician 1

As needed Engineering Support Technical Direction Technical Expertise 1

Plant Condition Evaluation, Repair and Corrective Action Repair, Mitigation and Corrective Action Shift Operators As needed Firefighting Firefighting Per Fire Protection Plan Rescue Operations/ First Aid Rescue and First Aid As needed Security Security Per Security Plan

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria C

(b)(3) Arrangements for requesting and effectively using assistance resources have been made and other organizations capable of augmenting the planned response have been identified.

Arrangements for requesting and effectively using assistance resources have been made and other organizations capable of augmenting the planned response have been identified.

[E.IV.A.6-7]

1. The Federal government maintains in-depth capability to assist licensees, States and local governments through the Federal Radiological Monitoring and Assessment Plan (formerly Radiological Assistance Plan (RAP) and Interagency Radiological Assistance Plan (IRAP). Each State and licensee shall make provisions for incorporating the Federal response capability into its operation plan, including the following:

a. specific persons by title authorized to request Federal assistance

b. specific Federal resources expected

4. Each organization shall identify nuclear and other facilities, organizations or individuals which can be relied upon in an emergency to provide assistance. Such assistance shall be identified and supported by appropriate letters of agreement.

D (b)(4) A standard emergency classification and action level scheme, the basis of which include facility system and effluent parameters, is in use by the nuclear facility licensee.

A standard emergency classification and action level scheme, the basis of which include facility system and effluent parameters, is in use by the nuclear facility licensee.

[E.IV.1; IV.B.1, 2; C.1, 2]

1. An emergency classification and emergency action level scheme must be established by the licensee. The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the in-plant emergency procedures.

The plan shall identify the parameter values and equipment status for each emergency class.

2. The initiating conditions shall include all postulated accidents in the Final Safety Analysis Report (FSAR) for the nuclear facility.

E (b)(5) Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow up Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow up

1. Each organization shall establish procedures which describe mutually agreeable bases for notification of response organizations consistent with the emergency classification and action level scheme. These procedures shall include means for verification of messages. The specific details of verification need not be included in the plan.

2. Each organization shall establish procedures for alerting, notifying, and mobilizing emergency response personnel.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria messages to response organizations has been established.

messages to response organizations has been established

[E.IV.1; IV.A.6, 7; C.1, 2; D.1, 3; E]

3. The licensee in conjunction with State and local organizations shall establish the contents of the initial emergency messages to be sent from the plant. These measures shall contain information about the class of emergency.

4. Each licensee shall make provisions for follow-up messages from the facility to offsite authorities which shall contain the following information if it is known and appropriate:

a. location of incident and name and telephone number (or communications channel identification) of caller;

b. date/time of incident;

c. class of emergency;

k. licensee emergency response actions underway;

m. request for any needed onsite support by offsite organizations; and

n. prognosis for worsening or termination of event based on plant information.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria F

(b)(6) Provisions exist for prompt communications among principal response organizations to emergency personnel.

Provisions exist for prompt communications among principal response organizations to emergency personnel.

[E.IV.1; IV.C.1; D.1, 3; E]

1.

Each organization shall establish reliable primary and backup means of communication for licensees, local, and State response organizations. Such systems should be selected to be compatible with one another. Each plan shall include:

a. provision for 24-hour per day notification to and activation of the State/local emergency response network; and at a minimum, a telephone link and alternate, including 24-hour per day manning of communications links that initiate emergency response actions.

b. provision for communications with contiguous State/local governments;

c. provision for communications as needed with Federal emergency response organizations;

e. provision for alerting or activating emergency personnel in each response organization; and

f. provision for communication by the licensee with NRC headquarters and NRC Regional Office Emergency Operations Centers.

2. Each organization shall ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

3. Each organization shall conduct periodic testing of the entire emergency communications system (see evaluation criteria H.10 and N.2.a.

G (b)(7) The principal points of contact with the news media The principal points of contact with the news media 3.a. Each principal organization shall designate the points of contact and physical locations for use by news media during an emergency.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria for dissemination of information during an emergency) are established in advance, and procedures for coordinated dissemination of information to the public are established.

for dissemination of information during an emergency are established in advance, and procedures for coordinated dissemination of information to the public are established.

[E.IV.A.7; D.2]

4.a. Each principal organization shall designate a spokesperson who should have access to all necessary information.

b. Each organization shall establish arrangements for timely exchange of information among designated spokespersons.

c. Each organization shall establish coordinated arrangements for dealing with rumors.

H (b)(8) Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

[E.IV.1; IV.E; G]

2. Each licensee shall establish an Emergency Facility from which evaluation and coordination of all licensee activities related to an emergency is to be carried out and from which the licensee shall provide information to Federal, State and local authorities responding to emergencies.

4. Each organization shall provide for timely activation and staffing of the facilities and centers described in the plan.

5. Each licensee shall identify and establish onsite-monitoring systems that are to be used to initiate emergency measures as well as those to be used for conducting assessment.

The equipment shall include:

a. geophysical phenomena monitors, (e.g., meteorological, hydrologic, seismic);

b. radiological monitors, (e.g., process, area, emergency, effluent, wound and portable monitors and sampling equipment);

d. fire and combustion products detectors.

6. Each licensee shall make provision to acquire data from or for emergency access to offsite monitoring and analysis equipment including:

a. geophysical phenomena monitors, (e.g., meteorological, hydrologic, seismic);

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria 10.a. Each licensee shall make provisions to inspect, inventory and operationally check emergency equipment/instruments at least once each calendar quarter and after each use. There shall be sufficient reserves of instruments/equipment to replace those which are removed from emergency kits for calibration or repair. Calibration of equipment shall be at intervals recommended by the supplier of the equipment.

10.b Communication systems shall be functionally tested as follows: State/local and NRC (ENS) communication systems shall be tested monthly This is not the same as a communication drill as stated in N.2.

11. Each plan shall, in an appendix, include identification of emergency kits by general category (protective equipment, communications equipment, radiological monitoring equipment, and emergency supplies).

I (b)(9) Adequate methods, systems, and equipment for assessing and monitoring actual or potential consequences of a radiological emergency condition are in use.

Adequate methods, systems, and equipment for assessing and monitoring actual or potential consequences of a radiological emergency condition are in use.

[E.IV.1; IV.A.4; B.1; C.2; E]

1. Each licensee shall identify plant system and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents, and shall identify the plant parameter values or other information which correspond to the example initiating conditions. Such parameter values and the corresponding emergency class shall be included in the appropriate facility emergency procedures. Facility emergency procedures shall specify the kinds of instruments being used and their capabilities.

2. Onsite capability and resources to provide initial values and continuing assessment throughout the course of an accident shall include radiation monitors.

J (b)(10) A range of protective actions has been developed for emergency workers and the public.

A range of protective actions has been developed for the emergency workers and the public.

[IV.1; IV.C.1; E; I]

1. Each licensee shall establish the means and time required to warn or advise onsite individuals and individuals who may be in areas controlled by the operator, including:

a. Employees not having emergency assignments;

b. Visitors;

c. Contractor and construction personnel; and

d. Other persons who may be in the public access areas on or passing through the site or within the owner controlled area.

2. Each licensee shall make provisions for evacuation routes and transportation for onsite individuals to some suitable offsite location, including alternatives for inclement weather, high traffic density and specific radiological conditions.

3. Each licensee shall provide for radiological monitoring of people evacuated from the site.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria

5. Each licensee shall provide for a capability to account for all individuals onsite at the time of the emergency and ascertain the names of missing individuals within 60 minutes of the start of an emergency and account for all onsite individuals continuously thereafter.

6. Each licensee shall, for individuals remaining or arriving onsite during the emergency, make provisions for:

a. Individual respiratory protection

b. Use of protective clothing.

K (b)(11) Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

[IV.E]

1. Each licensee shall establish onsite exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Actions Guides (EPA 520/1-75/001) for:

a. removal of injured persons;

b. undertaking corrective actions;

c. performing assessment actions;

d. providing first aid;

e. performing personnel decontamination;

f. providing ambulance service; and

g. providing medical treatment services.

2. Each licensee shall provide an onsite radiation protection program to be implemented during emergencies, including methods to implement exposure guidelines. The plan shall identify individual(s), by position or title, who can authorize emergency workers to receive doses in excess of 10 CFR Part 20 limits.

Procedures shall be worked out in advance for permitting onsite volunteers to receive radiation exposures in the course of carrying out lifesaving and other emergency activities. These procedures shall include expeditious decision making and a reasonable consideration of relative risks.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria 3.a. Each organization shall make provision for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers. Each organization shall make provisions for distribution of dosimeters, both self-reading and permanent record devices.

b. Each organization shall ensure that dosimeters are read at appropriate frequencies and provide for maintaining dose records for emergency workers involved in any nuclear accident.

5.a. Each organization as appropriate, shall specify action levels for determining the need for decontamination.

b. Each organization, as appropriate, shall establish the means for radiological decontamination of emergency personnel wounds, supplies, instruments and equipment, and for waste disposal.

6. Each licensee shall provide onsite contamination control measures including:

a. area access control;

b. drinking water and food supplies;

c. criteria for permitting return of areas and items to normal use.

L (b)(12) Arrangements are made for medical services for contaminated injured individuals.

Arrangements are made for medical services for contaminated injured individuals.

[E.IV.A.6, 7; E]

1. Each organization shall arrange for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.

2. Each licensee shall provide for onsite first aid capability.

4. Each organization shall arrange for transporting victims of radiological accidents to medical support facilities.

M (b)(13) General plans for recovery and reentry are developed.

General plans for recovery and reentry are developed.

[IV.1; IV.H]

1.

Each organization, as appropriate, shall develop general plans and procedures for reentry and recovery. This process should consider both existing and potential conditions.

2. Each licensee plan shall contain the position/title, authority and responsibilities of individuals who will fill key positions in the facility recovery organization. This organization shall include technical personnel with responsibilities to develop, evaluate and direct recovery and reentry operations.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria N

(b)(14) Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

[E.IV.1; E.9; F]

1.a. An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and organizations.

Exercises shall be conducted as set forth in NRC and FEMA rules.

b. The organization shall provide for a critique of the annual exercise by Federal and State observers/evaluators. The scenario should be varied from year to year such that all major elements of the plans and preparedness organizations are tested.

Some exercises should be unannounced.

2. A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular operation. A drill is often a component of an exercise. A drill shall be supervised and evaluated by a qualified drill instructor. Each organization shall conduct drills, in addition to the annual exercise at the frequencies indicated below:

a. Communication Drills: Communications with State and local governments shall be drilled annually. Communications with Federal emergency response organizations shall be drilled annually. Communication drills shall also include the aspect of understanding the content of messages.

b. Fire Drills: Fire drills shall be conducted in accordance with the plant (nuclear facility) technical specifications.

c. Medical Emergency Drills: A medical emergency drill involving a simulated contaminated individual which contains provisions for participation by the local support services agencies (i.e., ambulance and offsite medical treatment facility) shall be conducted annually. The offsite portions of the medical drill may be performed as part of the required annual exercise.

d. Radiological Monitoring Drills: Plant environs and radiological monitoring drills shall be conducted annually.

e. Health Physics Drills: (1) Health Physics drills shall be conducted semi-annually which involve response to, and analysis of, simulated elevated airborne and direct radiation measurements in the environment.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria

3. Each organization shall describe how exercises and drills are to be carried out to allow free play for decision making and to meet the following objectives. Pending the development of exercise scenarios and exercise evaluation guidance by NRC and FEMA the scenarios for use in exercises and drills shall include but not be limited to, the following:

a. The basic objective(s) of each drill and exercise and appropriate evaluation criteria;

b. The date(s), time period, place(s) and participating organizations;

c. The simulated events;

d. A time schedule of real and simulated initiating events;

e. A narrative summary describing the conduct of the exercises or drills to include such things as simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing, and

f. A description of the arrangements for and advance materials to be provided to official observers.

4. Official observers from Federal governments will observe, evaluate, and critique the required exercises. A critique shall be scheduled at the conclusion of the exercise to evaluate the ability of organizations to respond as called for in the plan. The critique shall be conducted as soon as practicable after the exercise, and a formal evaluation should result from the critique.

5. Each organization shall establish means for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for implementing corrective actions. Each organization shall establish management control used to ensure that corrective actions are implemented.

O (b)(15) Radiological emergency response training is provided to those who may be called on to assist in Radiological emergency response training is provided to those who may be called

1. Each organization shall assure the training of appropriate individuals.

a. Each facility to which the plant applies shall provide site specific emergency response training for those offsite emergency organizations who may be called upon to provide assistance in the event of an emergency.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria an emergency.

on to assist in an emergency.

[E.IV.1; IV.F]

2. The training program for members of the onsite emergency organization shall, besides classroom training, include practical drills in which each individual demonstrates ability to perform his assigned emergency function. During the practical drills, on-the-spot correction of erroneous performance shall be made and a demonstration of the proper performance offered by the instructor.

3. Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross Multi-Media.

4. Each organization shall establish a training program for instructing and qualifying personnel who will implement radiological emergency response plans. The specialized initial training and periodic retraining programs {including the scope, nature and frequency) shall be provided in the following categories:

a. Directors or coordinators of the response organizations;

b. Personnel responsible for accident assessment;

d. Police, security and fire-fighting personnel;

e. Repair and damage control/correctional action teams (onsite);

f. First aid and rescue personnel;

g. Local support services personnel;

h. Medical support personnel;

j. Personnel responsible for transmission of emergency information and instructions.

5. Each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities.

P (b)(16) Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

[IV.1; IV.G]

1. Each organization shall provide for the training of individuals responsible for the planning effort.

2. Each organization shall identify by title the individual with the overall authority and responsibility for radiological emergency response planning.

3. Each organization shall designate an Emergency Planning Coordinator with responsibility for the development and updating of emergency plans and coordination of these plans with other response organizations.

4. Each organization shall update its plan and agreements as needed, review and certify it to be current on an annual basis. The update shall take into account changes identified by drills and exercises.

DRAFT - FOR INFORMATION USE ONLY DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014 Regulations (as exempted per ISG)

NUREG-0654 (Revised -

Decommissioned)

Evaluation Criteria

5. The emergency response plans and approved changes to the plans shall be forwarded to all organizations and appropriate individuals with responsibility for implementation of the plans. Revised pages shall be dated and marked to show where changes have been made.

6. Each plan shall contain a detailed listing of supporting plans and their source.

7. Each plan shall contain as an appendix listing, by title, procedures required to implement the plan. The listing shall include the section(s) of the plan to be implemented by each procedure.

8. Each plan shall contain a specific table of contents. Plans submitted for review should be cross-referenced to these criteria.

9. Each licensee shall arrange for and conduct independent reviews of the emergency preparedness program at least every 12 months. (An independent review is one conducted by any competent organization either internal or external to the licensee's organization, but who are not immediately responsible for the emergency preparedness program). The review shall include the emergency plan, its implementing procedures and practices, training, readiness testing, equipment, and interfaces with State and local governments. Management controls shall be implemented for evaluation and correction of review findings. The result of the review, along with recommendations for improvements, shall be documented, reported to appropriate licensee corporate and plant management, and involved Federal, State and local organizations, and retained for a period of five years.

10. Each organization shall provide for updating telephone numbers in emergency procedures at least quarterly.