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

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 1

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:

Files Size Date & Time MESSAGE 457 8/27/2014 1:43:00 PM draft RAIs 2nd round 8-27-14.docx 60076 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

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 1 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 2 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.

CR3 LAR - Decommissioning Emergency Plan and Emergency Action Levels Page 3 of 3 DRAFT

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned) 50.47(b)(1) Primary Primary responsibilities for 1.b. Each organization and sub-organization having an operational role shall specify its responsibilities for emergency response by the concept of operations, and its relationship to the total effort.

emergency response by the nuclear facility licensee and nuclear facility licensee and by State and local 1.c. Each plan shall illustrate these interrelationships in a block diagram.

by State and local organizations have been 1.d. Each organization shall identify a specific individual by title who shall be in charge of organizations have been assigned, the emergency the emergency response.

assigned, the emergency responsibilities of the responsibilities of the various supporting 1.e. Each organization shall provide for 24-hour per day emergency response, including A various supporting organizations have been 24-hour per day manning of communications links.

organizations have been specifically established, and specifically established, and each principal response 4. Each principal organization shall be capable of continuous (24-hour) operations for a each principal response organization has staff to protracted period. The individual in the principal organization who will be organization has staff to respond and to augment its responsible for assuring continuity of resources (technical, administrative, and respond and to augment its initial response on a material) shall be specified by title.

initial response on a continuous basis.

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

50.47(b)(2) On-shift facility On-shift facility licensee 1. Each licensee shall specify the onsite emergency organization of plant staff personnel licensee responsibilities for responsibilities for for all shifts and its relation to the responsibilities and duties of the normal staff emergency response are emergency response are complement.

unambiguously defined, unambiguously defined, adequate staffing to provide adequate staffing to provide 2. Each licensee shall designate an individual who shall be on shift at all times and who B initial facility accident initial facility accident shall have the authority and responsibility to immediately and unilaterally initiate response in key functional response in key functional any emergency actions.

areas is maintained at all areas is maintained at all times, timely augmentation times, timely augmentation 4. Each licensee shall establish the functional responsibilities assigned to the of response capabilities is of response capabilities is emergency coordinator.

DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned) available and the interfaces available and the interfaces

5. Each licensee shall specify the positions or title and major tasks to be performed by among various onsite among various onsite the persons to be assigned to the functional areas of emergency activity. For response activities and response activities and emergency situations, specific assignments shall be made for all shifts and for plant offsite support and response offsite support and response staff members, both onsite and away from the site. The licensee must be able to activities are specified. activities are specified.

augment on-shift capabilities within a short period after declaration of an emergency.

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

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 - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Minimum Staffing Requirements for NRC Licensees for Decommissioning Nuclear Power Plant Emergencies (See B.5.)

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

• Notification/Communication Notify State and Federal personnel and Communicator

• maintain communications Radiological Accident Assessment and Onsite Dose Assessment and Monitoring Heath Physics Expertise

• 1 Support of Operational Accident Assessment Protective Actions (In-Plant) In-Plant Surveys Radiation Protection Health Physics Technician 1 As needed

a. Access Control

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

c. Personnel Monitoring

d. Dosimetry Engineering Support Technical Direction Technical Expertise 1 Plant Condition Evaluation, Repair and Repair, Mitigation and Corrective Action Shift Operators ** As needed Corrective Action Firefighting Firefighting Per Fire Protection Plan Rescue Operations/ First Aid Rescue and First Aid

• As needed Security Security Per Security Plan

• 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.

DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned)

1. The Federal government maintains in-depth capability to assist licensees, States and local governments through the Federal Radiological Monitoring and Assessment Plan Arrangements for requesting (b)(3) Arrangements for (formerly Radiological Assistance Plan (RAP) and Interagency Radiological Assistance and effectively using requesting and effectively Plan (IRAP). Each State and licensee shall make provisions for incorporating the assistance resources have using assistance resources Federal response capability into its operation plan, including the following:

been made and other have been made and other C organizations capable of organizations capable of a. specific persons by title authorized to request Federal assistance augmenting the planned augmenting the planned b. specific Federal resources expected response have been response have been identified.

identified. 4. Each organization shall identify nuclear and other facilities, organizations or

[E.IV.A.6-7]

individuals which can be relied upon in an emergency to provide assistance. Such assistance shall be identified and supported by appropriate letters of agreement.

A standard emergency 1. An emergency classification and emergency action level scheme must be established (b)(4) A standard emergency classification and action level by the licensee. The specific instruments, parameters or equipment status shall be classification and action level scheme, the basis of which shown for establishing each emergency class, in the in-plant emergency procedures.

scheme, the basis of which include facility system and The plan shall identify the parameter values and equipment status for each D include facility system and effluent parameters, is in use emergency class.

effluent parameters, is in use by the nuclear facility 2. The initiating conditions shall include all postulated accidents in the Final Safety by the nuclear facility licensee. Analysis Report (FSAR) for the nuclear facility.

licensee.

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

(b)(5) Procedures have been Procedures have been 1. Each organization shall establish procedures which describe mutually agreeable established for notification, established for notification, bases for notification of response organizations consistent with the emergency by the licensee, of State and by the licensee, of State and classification and action level scheme. These procedures shall include means for local response organizations local response organizations verification of messages. The specific details of verification need not be included in E and for notification of and for notification of the plan.

emergency personnel by all emergency personnel by all organizations; the content of organizations; the content of 2. Each organization shall establish procedures for alerting, notifying, and mobilizing initial and follow up initial and follow up emergency response personnel.

DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned) messages to response messages to response

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

[E.IV.1; IV.A.6, 7; C.1, 2; D.1, 3; E] 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 - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned)

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.

Provisions exist for prompt b. provision for communications with contiguous State/local governments; (b)(6) Provisions exist for communications among c. provision for communications as needed with Federal emergency response prompt communications principal response organizations; F among principal response organizations to emergency organizations to emergency e. provision for alerting or activating emergency personnel in each response personnel.

personnel. organization; and

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

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.

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

DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned) for dissemination of for dissemination of 4.a. Each principal organization shall designate a spokesperson who should have access information during an information during an to all necessary information.

emergency) are established emergency are established in b. Each organization shall establish arrangements for timely exchange of information in advance, and procedures advance, and procedures for among designated spokespersons.

for coordinated coordinated dissemination c. Each organization shall establish coordinated arrangements for dealing with dissemination of information of information to the public rumors.

to the public are established. are established.

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

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.

Adequate emergency (b)(8) Adequate emergency 5. Each licensee shall identify and establish onsite-monitoring systems that are to be facilities and equipment to facilities and equipment to used to initiate emergency measures as well as those to be used for conducting support the emergency H support the emergency response are provided and assessment.

response are provided and The equipment shall include:

maintained.

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

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

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 - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned) 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).

1. Each licensee shall identify plant system and effluent parameter values characteristic (b)(9) Adequate methods, Adequate methods, systems, of a spectrum of off-normal conditions and accidents, and shall identify the plant systems, and equipment for and equipment for assessing parameter values or other information which correspond to the example initiating assessing and monitoring and monitoring actual or conditions. Such parameter values and the corresponding emergency class shall be I actual or potential potential consequences of a included in the appropriate facility emergency procedures. Facility emergency consequences of a radiological emergency procedures shall specify the kinds of instruments being used and their capabilities.

radiological emergency condition are in use.

2. Onsite capability and resources to provide initial values and continuing assessment condition are in use. [E.IV.1; IV.A.4; B.1; C.2; E]

throughout the course of an accident shall include radiation monitors.

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; A range of protective actions (b)(10) A range of protective c. Contractor and construction personnel; and has been developed for the actions has been developed d. Other persons who may be in the public access areas on or passing through the J for emergency workers and emergency workers and the site or within the owner controlled area.

public.

the public. 2. Each licensee shall make provisions for evacuation routes and transportation for

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

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 - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned)

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.

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:

Means for controlling

a. removal of injured persons; (b)(11) Means for controlling radiological exposures, in an

b. undertaking corrective actions; radiological exposures, in an emergency, are established

c. performing assessment actions; emergency, are established for emergency workers. The

d. providing first aid; for emergency workers. The means for controlling

e. performing personnel decontamination; means for controlling radiological exposures shall

f. providing ambulance service; and K radiological exposures shall include exposure guidelines

g. providing medical treatment services.

include exposure guidelines consistent with EPA

2. Each licensee shall provide an onsite radiation protection program to be consistent with EPA Emergency Worker and implemented during emergencies, including methods to implement exposure Emergency Worker and Lifesaving Activity Protective guidelines. The plan shall identify individual(s), by position or title, who can Lifesaving Activity Protective Action Guides.

authorize emergency workers to receive doses in excess of 10 CFR Part 20 limits.

Action Guides.

Procedures shall be worked out in advance for permitting onsite volunteers to

[IV.E]

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 - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned) 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.

1. Each organization shall arrange for local and backup hospital and medical services Arrangements are made for having the capability for evaluation of radiation exposure and uptake, including (b)(12) Arrangements are medical services for assurance that persons providing these services are adequately prepared to handle made for medical services contaminated injured L for contaminated injured individuals.

contaminated individuals.

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

individuals.

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

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

medical support facilities.

1. Each organization, as appropriate, shall develop general plans and procedures for reentry and recovery. This process should consider both existing and potential General plans for recovery (b)(13) General plans for conditions.

and reentry are developed.

M recovery and reentry are 2. Each licensee plan shall contain the position/title, authority and responsibilities of developed. individuals who will fill key positions in the facility recovery organization. This

[IV.1; IV.H]

organization shall include technical personnel with responsibilities to develop, evaluate and direct recovery and reentry operations.

DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned) 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 Periodic exercises are (will skills in a particular operation. A drill is often a component of an exercise. A drill (b)(14) Periodic exercises are be) conducted to evaluate shall be supervised and evaluated by a qualified drill instructor. Each organization (will be) conducted to major portions of emergency shall conduct drills, in addition to the annual exercise at the frequencies indicated evaluate major portions of response capabilities, below:

emergency response periodic drills are (will be) a. Communication Drills: Communications with State and local governments shall be capabilities, periodic drills conducted to develop and drilled annually. Communications with Federal emergency response organizations N are (will be) conducted to maintain key skills, and shall be drilled annually. Communication drills shall also include the aspect of develop and maintain key deficiencies identified as a understanding the content of messages.

skills, and deficiencies result of exercises or drills b. Fire Drills: Fire drills shall be conducted in accordance with the plant (nuclear identified as a result of are (will be) corrected. facility) technical specifications.

exercises or drills are (will

c. Medical Emergency Drills: A medical emergency drill involving a simulated be) corrected.

[E.IV.1; E.9; F] 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 - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned)

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.

(b)(15) Radiological 1. Each organization shall assure the training of appropriate individuals.

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

DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned) an emergency. on to assist in an emergency. 2. The training program for members of the onsite emergency organization shall, besides classroom training, include practical drills in which each individual

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

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

(b)(16) Responsibilities for development and review and 2. Each organization shall identify by title the individual with the overall authority and plan development and for distribution of responsibility for radiological emergency response planning.

review and for distribution emergency plans are 3. Each organization shall designate an Emergency Planning Coordinator with P of emergency plans are established, and planners responsibility for the development and updating of emergency plans and established, and planners are properly trained. coordination of these plans with other response organizations.

are properly trained. 4. Each organization shall update its plan and agreements as needed, review and certify

[IV.1; IV.G] it to be current on an annual basis. The update shall take into account changes identified by drills and exercises.

DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014

DRAFT - FOR INFORMATION USE ONLY Attachment 1 Regulations (as exempted NUREG-0654 (Revised -

Evaluation Criteria per ISG) Decommissioned)

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.

DRAFT - DECOMMISSIONED REACTOR EMERGENCY PLAN REVIEW GUIDE July 2014