ML19171A273

Energy Northwest - Emergency Preparedness Procedure 13.14.9, Rev. 20, Emergency Program Maintenance

ML19171A273
Person / Time
Site:	Columbia
Issue date:	05/23/2019
From:	Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19171A273 (17)

Text

DISTRIBUTION -VOLUME 13- EMERGENCY PREPAREDNESS PROCEDURES Page 3 of 3 Distribution Date: 05/23/19 GC Filed By:

Procedure Number Revision Procedure Number Revision Procedure Number Revision 13.14.9 030 TO: ENERGY NORTHWEST EXTERNAL CONTROLLED COPY PROCEDURE HOLDERS The following documents have been revised and are to be inserted into your controlled copy manual and the superseded revisions removed and destroyed. No receipt acknowledgement is required for the listed document(s).

Should you have questions on this distribution please contact Kim Saenz, Records and Information Supervisor at (509)377-2492 or KDSaenz@energy-northwest.com.

I EXTERNAL DISTRIBUTION I Copy# Locatiori Procedures 26 Region IV- US Nuclear Regulatory Commission All 28 Region IV - US Nuclear Regulatorv Commission All 52 State of Washington, Military Department All 55 Federal Emergency Management Agency (FEMA) All 57 Benton County - Department of Emergency Management All 75 Department of Health Radiation Protection All 87 Document Control Desk - NRC All ,.

142 Hanford EOC/SMT All 164 Oregon State Department of Energy All 223 Franklin County Emergency Management All 224 Washington State Department of Health - Office of Radiation Protection All

& PPM 13.1.1 is printed in color, single sided; on 11" x 17" paper, folded, 3-hold punched, stapled on top and distributed by Document Control.

% Contact Security- Steve English @ x 8317 or Kammi Hickman @ x 5157 for pick up and signature NOTE: Distribution of the PPM 13.1.1 wall flow charts is controlled by PPM 13.1.1 A and distribution is performed by EP . Updated 11/14/18

IVerify. Revision Information Prior* To Use I Initials Date I

Number: 13.14.9 I Use Category: REFERENCE Major Rev: 030 Minor Rev: NIA

Title:

Emergency Program Maintenance Page: 1 of 16 PCN#:

PLANT PROCEDURES MANUAL N/A Effective Date:

1111111111111111 IIIIII IIIII IIII IIIIII IIII IIII 13.14.9 05/23/19

Number: 13.14.9 \ Use Category: REFERENCE Major Rev: 030 Minor Rev: N/A

Title:

Emergency Program Maintenance Page: 2 of 16 DESCRIPTION OF CHANGES

-Justification

{required for major re~ision) - .

1) Revised section 4.3 to describe the recently adopted use of the Automated Process Workflows (APW) process for revising ERO positional checklists in response to CR 390014. (AR-CA 390014-01)

2) Revised section 2.2 to clarify applicability to align with the action described in # 1) above.

Description (in.cluding summary, reason, initiating, d6cument, *if aj)pli~able) :, *,

~age(st 4 Revised section 2.2 to clarify the types of Emergency Plan supporting documents are governed by this procedure.

6&7 Revised section 4.3 to describe the recently adopted use of the Automated Process Workflows (APW) process for revising ERO positional checklists in response to CR 3900.14. (AR-CA 390014-01) Removed references to the forms that were used to document revisions prior to the adoption of the electronic, APW process. For clarification purposes, added in discussion about the pre-existing use of the 50.54(q) process and internal department instructions associated with the revision of ERO Positional Checklists.

9 Deleted reference to revision process forms that are no longer needed. For clarification, added references to three documents governing pre-existing processes that apply to the revision of ERO Positional Checklists.

12 & 16 Updated AR references to current Model AR numbers. (Editorial}

Number: 13.14.9 I Use Category: REFERENCE Major Rev: 030 Minor Rev: N/A

Title:

Emergency Program Maintenance Page: 3 of 16 TABLE OF CONTENTS Page 1.0 PURPOSE ............................................................................................................................... 4 2.0 DISCUSSION ........................................................................................................................... 4 2.1 General Program Maintenance ................................................................................................ 4 2.2 Emergency Plan Documents .................................................................................................... 4 3.0 RESPONSIBILITIES ................................................................................................................ 4 3.1 Manager, Emergency Preparedness ........................................................................................ 4 3.2 Emergency Preparedness Staff................................................................................................ 4 3.3 Applicable Energy Northwest Managers ................................................................................... 5 4.0 PROCEDURE .......................................................................................................................... 5 4.1 Manager, Emergency Preparedness ........................................................................................ 5 4.2 Applicable Energy Northwest Managers ................................................................................... 5 4.3 Control of Emergency Preparedness ERO Positional Checklists and Forms ............................ 5 4.4 Standard Protocol for Maintaining and Completing Model AR Assignments ............................. 7

5.0 REFERENCES

........................................................................................................................ 8 \_

6.0 DOCUMENTATION ................................................................................................................. 9 7.0 ATTACHMENTS ...................................................................................................................... 9 7.1 Topics Requiring Periodic Review or Action ........................................................................... 10

Number: 13.14.9 IUse Category: REFERENCE Major Rev: 030 Minor Rev: N/A

Title:

Emergency Program Maintenance Page: 4 of 16 1.0 PURPOSE This procedure identifies the activities necessary to maintain a current emergency preparedness program in accordance with commitments made in the Columbia Generating Station Emergency Plan. {R-5.1} {R-5.3}

2.0 DISCUSSION 2.1 General Program Maintenance The Emergency Preparedness (EP) Program for Columbia Generating Station has many facets which require ongoing review and assessment to ensure that the Program is maintained. Many of these are attended to by groups outside of the Emergency Preparedness Department. For example, field survey instruments are checked and calibrated by Radiological Services, field team vehicles and emergency diesel generators are maintained by Facilities and Commercial Engineering, pagers and sirens are maintained by Information Services, etc.

If organizations that assist in the process of maintaining the EP Program are not diligent in performing their portion of the effort, the Program could be adversely affected. For this reason, the Emergency Preparedness Department will maintain an oversight role to ensure that all program maintenance requirements are being performed.

2.2 Emergency Plan Documents Documents (such as Position Checklists and record keeping) are used to provide guidance to members of the Emergency Response Organization to perform actions in support of the Emergency Plan.

This procedure provides additional guidance, beyond Document Control procedures, for the maintenance of these documents to maintain program effectiveness.

3.0 RESPONSIBILITIES 3.1 Manager, Emergency Preparedness 3.1.1 The Manager, Emergency Preparedness has the overall responsibility to maintain the CGS Emergency Plan Program.

3.1.2 The manager is responsible for overseeing maintenance activities conducted by other responsible groups.

3.2 Emergency Preparedness Staff

• Perform appropriate actions to ensure Emergency Plan documents, facilities and other program elements are ma.intpined consistent with the Emergency Plan and changes do not reduce the effectiveness of the program.

Number: 13.14.9 I Use Category: REFERENCE Major Rev: 030 Minor Rev: N/A

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Emergency Program Maintenance Page: 5 of 16 3.3 Applicable Energy Northwest Managers Directing and coordinating activities required to maintain the Emergency Plan Program.

4.0 PROCEDURE 4.1 Manager, Emergency Preparedness 4.1.1 Coordinate, as appropriate, with Energy Northwest managers to implement the ,

requirements of Attachment 7.1, Topics Requiring Periodic Review or Action.

4.1.2 Maintain, prepare, and archive records generated as a result of Emergency Preparedness program implementation in accordance with SWP-REC-01. {R-5.4}

4.1.3 Notify the Manager, Nuclear Security, of any condition which would preclude or interfere with the ability of Energy Northwest to implement the requirements of the Columbia Generating Station Emergency Plan.

4.2 Applicable Energy Northwest Managers 4.2.1 Coordinate, as appropriate, with the Manager, Emergency Preparedness to implement the requirements of Attachment 7.1, Topics Requiring Periodic Review or Action.

4.2.2 Notify the Manager, Emergency Preparedness of any condition which would preclude or interfere with the ability of Energy Northwest to respond to emergency conditions.

4.3 Control of Emergency Preparedness ERO Positional Checklists and Forms 4.3.1 Emergency Plan Implementing Procedures are supplemented by ERO Positional Checklists (for most ERO positions/ functions) and function-specific controlled forms.

a. ERO Positional Checklists and ERO-related forms are provided for use by ERO staff positions in position-specific binders, which are controlled copies and the contents of which are maintained in accordance with this procedure.

b. Position-specific binders include a "Binder Tab Index" (on the last page of the Positional Checklist) wh.ich lists the desired complement of procedures, checklists, and forms for a given position to be able to perform for two shifts without "re-charging" the binder.

1) Position-specific binders, when specified for an ERO position, are considered complete when they contain at least one, current copy of each required document listed in the Positional Checklist's "Binder Tab Index".

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c.

• Emergency Preparedness maintains a comprehensive list of Positional Binders and their contents.

4.3.2 Emergency Preparedness ERO Positional Checklist forms are revised either as major or minor revisions using the Automated Process Workflows (APW) process.

(Editorial changes are typically treated as a minor revision and appear as such in Asset Suite).

a. Use of the APW process ensures consistency with the station's current review expectations for major or minor revisions as applicable.

b. Proposed Checklist revisions receive a 50.54(q) screen in accordance with EPl-16, 50.54(q) Change Evaluation. When necessary, depending on the revision, EPl-16 guidance may indicate the need for a 50.54(q) evaluation.

c. ERO Positional Checklists are structured and formatted in accordance with EPl-32, Maintenance of ERO Positional Binders. SWP-PR0-03, Writer's Manual, guidance regarding formatting and structure does not apply to ERO Positional Checklist forms.

4.3.3 Generation of, or revisions to Emergency Preparedness controlled forms are processed using the APW process.

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Emergency Program Maintenance Page: 7 of 16 4.4 Standard Protocol for Maintaining and Completing Model AR Assignments 4.4.1 Routine periodic Emergency Preparedness activities that are required to maintain the CGS Emergency Plan are scheduled through Model Action Requests (ARs).

These Model ARs are identified in Attachment 7 .3 to PPM 13.14.4, and some are also identified in Attachment 7.1 of this procedure.

4.4.2 The periodic EP activities based on Model ARs are implemented and documented through daughter ARs and AR assignments generated from the Model ARs. For this reason, the impacts of changes to Model ARs should be clearly understood.

a. Model ARs are ARs that have Model = checked on the Asset Suite A01 O Panel.

b. Model ARs will automatically generate daughter ARs and AR assignments on the date and at the frequency specified in the Model AR (Next Date, Period and No. on the Asset Suite A010 Panel). This automatic generation is through a nightly Asset Suite batch process that looks at the Next Date of Model ARs, and backgrounds the Model when the current date = Next Date.

c. When the daughter AR and AR assignments are backgrounded from the Model, these will have a Due Date equal to the Due Date on the Model AR and Model AR assignments. For example, if the Model AR has a Due Date= 09/30/12, a Next Date= 06/01/12, Period= Mand No.= 3 (for a quarterly frequency), and Model AR Assignment 01 has a Due Date= 07/15/12, then, on 06/01/12, a daughter AR will be generated with a Due Date= 09/30/12 and an AR Assignment 01 with a Due Date= 07/15/12. On the Model AR and AR assignments, the Due Date and Next Date will automatically be reset based on the Period and No. (frequency).

d. Daughter ARs and AR assignments are automatically generated by backgrounding the Model AR and assignments. This means that all of the information in the Model (including data from related panels, such as In-Progress Notes, but not Cross-References) will be copied over to the daughter.

e. To provide a means of tracking and retrieving daughter ARs, Model ARs should have the following characteristics:

1) Model AR number should be included in the Subject line.

2) In Keywords (Panel A013), Keyword= EPLAN

3) In Attributes (Panel A015), TRACKING CODE= Model AR number 4.4.3 Daughter ARs and AR assignments are tracked and completed as follows:

a. Assignment Due bates may be rescheduled as necessary, but not beyond the end of the AR Due Date (which is the end of the frequency period; e.g.,

monthly, quarterly, etc.).

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b. Assignments should be completed as per the instructions in the Assignment Notes and In-Progress Notes, as applicable.

c. Document completion of Assignment in the Completion Notes.

d. Documents generated as a result of the Assignment should be scanned and uploaded to the EDMS of the AR.

e. Submit originals of documents generated as a result of the Assignment to the EP Records Coordinator for retention.

5.0 REFERENCES

5.1 EP-01, Emergency Plan 5.2 10 CFR 50.54(q), Condition of Licenses 5.3 10 CFR 50.54(t), Conditions of Licenses, (audits) 5.4 NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 5.5 10 CFR 50 Appendix E, IV and V 5.6 10 CFR 72.44, License Conditions 5.7 10 CFR 50.47(b), Emergency Plans 5.8 OQAPD, Appendix 111 5.9 SWP-LIC-03, Licensing Document Change Process 5.10 PPM 13.14.4, Emergency Equipment 5.11 PERA 201-1793-02 5.12 PERA 202-0098-23 5.13 PERA 202-0430-03 5.14 PERA 202-0558-03 5.15 PERA 202-0635-01 5.16 PERA 202-0684-02 5.17 PERA 202-0728-06

Number: 13.14.9 I Use Category: REFERENCE Major Rev: 030 Minor Rev: N/A

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Emergency Program Maintenance Page: 9 of 16 5.18 AR-CR 226805, Model AR process for EP routines not working as intended 5.19 Ventyx Asset Suite Action Tracking, Specifications with Revision Marks, Release 6.0.0, June 2007 5.20 SWP-LIC-02, Licensing Basis Impact Determinations 5.21 SWP-PR0-02, Preparation, Review, Approval, and Distribution of Procedures 5.22 GBP-DOC-03, Forms Control Process 5.23 SWP-PR0-03, Writer's Manual 5.24 EPl-16, 50.54(q) Change Evaluation 5.25 EPl-32, Maintenance of ERO Positional Binders 6.0 DOCUMENTATION 6.1 Positional Checklist revisions are submitted to the Permanent Plant File. At a minimum, the record should consist of the following documents:

• Copy of the revised checklist

• Procedure Revision form and associated paperwork (for major revisions)

• Marked up pages with printed name, signature, and date (for editorial changes) 7.0 ATTACHMENTS 7.1 Topics Requiring Periodic Review or Action

Number: 13.14.9 I Use Category: REFERENCE Major Rev: 030 Minor Rev: N/A

Title:

Emergency Program Maintenance Page: 10 of 16 TOPICS REQUIRING PERIODIC REVIEW OR ACTION RESPONSIBILITY FREQUENCY

1. Columbia Generating Manager, Emergency Annually A. Utilize guidance from Station Emergency Plan Preparedness {R-5.1} SWP-LJC-03, to coordinate Review (Model AR review, revision, approval, and 249408-01) issuance of the plan to incorporate changes resulting from new regulations, critiques of drills/exercises, audit findings, and comments from personnel or agencies inside and outside Energy Northwest.

B. For Emergency Plan changes that involve changes to the EAL scheme, ensure that the Washington State Emergency Management, the Benton and Franklin County Departments of Emergency Management, and the Department of Energy-Richland Operations are contacted early in the review/revision process and that their comments are solicited and considered for input into the process.

Document this portion of the review.

C. Ensure a Licensing Basis Impact review is performed as required by SWP-LIC-03.

D. Ensure the supporting documentation is submitted for POC review consistent with the proposed change.

E. Ensure a report of Emergency Plan changes is sent to the NRG per 10CFR50.4(b)(5) within 30 days of making the changes and/or per 10CFR72.44(f) within six months after the change is made.

{R-5.2, R-5.5 , R-5.6}

F. Ensure Emergency Plan is reviewed, revised, and approved per 10CFR50 Appendix E, V.

{R-5.5}

Attachment 7.1, Topics Requiring Periodic Review or Action

Number: 13.14.9 I Use Category: REFERENCE Major Rev: 030 Minor Rev: N/A

Title:

Emergency Program Maintenance Page: 11 of 16 TOPIC RESPONSIBILITY FREQUENCY SCOPE

2. Columbia Generating Manager, Emergency As Necessary A. Utilize guidance from Station Emergency Plan Preparedness SWP-PR0-02 to coordinate Implementing reviews, revisions, and Procedures (EPIPs) deviations required by revisions to the Emergency Plan or other requirements.

B. Ensure Licensing Basis Impact reviews are completed as required by SWP-LIC-02.

C. Ensure documentation is submitted for POC review, as required and approved changes are placed in locations where they are likely to be used.

{R-5.8}

D. Ensure that revisions affecting offsite response are coordinated with the appropriate agencies.

3. Columbia Generating Manager, Emergency Quarterly A. Review telephone numbers Station EPIPs Preparedness listed in the Emergency Phone Telephone Numbers Directory and EPIPs, and (Model AR 236166236166 change as required.

4. National Weather Manager, Emergency Monthly A. Check communications with the Service Preparedness NWS first order station and (Model AR 235576235576 NWS forecasting station to ensure routine meteorological observations and forecasts can be accessed. Refer to NUREG-0654, Annex 1 to Appendix 2, (3)(i).

5. Emergency Action Level Manager, Emergency Annually {R-5.5} A. Ensure officials from the State (EAL) Review (Model Preparedness of Washington, Benton and AR 249408-06) Franklin Counties, and DOE-RL are afforded the opportunity to review EAL classification scheme. {R-5.5}

6. Letters Of Agreement Manager, Emergency Annually A. Refer to Emergency Plan Preparedness Appendix 4 for the list of Letters of Agreement.

Attachment 7.1, Topics Requiring Periodic Review or Action

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Emergency Program Maintenance Page: 12 of 16 TOPIC RESPONSIBILITY FREQUENCY SCOPE

7. Plans And/Or Contracts Manager, Emergency Annually A. Refer to Emergency Plan Preparedness Appendix 1 for the list of Supporting Plans And/Or Contracts.

8. Emergency Response Manager, Emergency Quarterly (or after A. Maintain and coordinate an Organization (ERO) Preparedness substantial change) Emergency Response Assignment List Organization position (Model AR 236241-01) assignment list that meets Emergency Plan Section 2 requirements for review, revision, approval, and issuance of current list.

9. ERO Training Manager, Emergency Monthly A. Review status of Emergency (Model AR 249408-09 Preparedness Response Organization and 249408-12) personnel in the training database to ensure emergency position qualifications are being met by assigned personnel.

As Necessary B. Review and approve new or revised Emergency Training lessons.

Annually C. Ensure that a radiological training program is made available to local services personnel such as fire company and hospital personnel.

{R-5.5}

Annually D. Ensure that a radiological training program is made available to state and county agencies, and personnel involved with the emergency preparedness effort, at least annually.

Annually E. Conduct a review of GET materials and provide comments, forward to Technical Training.

Attachment 7.1, Topics Requiring Periodic Review or Action

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Emergency Program Maintenance Page: 13 of 16 TOPIC RESPONSIBILITY FREQUENCY SCOPE

10. Emergency Equipment Manager, Emergency Monthly, Quarterly, A. Ensure tasks are performed as and Supplies (Asset Preparedness Semi-Annually, or required by PPM 13.14.4.

Suite Model ARs and Annually (as required)

PMIDs)

Annually 8. Review EP maintenance and testing activities in Asset Suite.

Verify that Emergency Plan and EPIP maintenance and testing activities are effectively scheduled and tracked.

11. Emergency Facilities Manager, Emergency As Necessary A. Ensure facilities are maintained (Model AR 236207236207 Preparedness 1 and that modifications to any of Energy Northwest's Emergency Centers are documented and approved by the Manager, Emergency Preparedness.

12. Emergency Phone Manager, Emergency Quarterly A. Verify listed numbers in the Directory/ERO Phone Preparedness emergency phone directory are List/Duty Rosters (for current. Ensure Parts A & C pager carriers) phone numbers are correct.

(Model AR 236166236166 Revise as needed and make appropriate distribution. Verify phone numbers in EPIPs are accurate. If changes are made, inform sec to ensure Parts A &

C are updated.

13. EP Program Audit Manager, Emergency Biennially, or more A. Ensure an audit is conducted (AR 60285) Preparedness frequently if required that meets the OQAPD requirements and includes the Emergency Plan and Implementing Procedures, training, readiness testing, equipment, and interfaces with state and local governments.

{R-5.3, R-5.4}

8. Ensure the Audit Report is submitted to the applicable Vice President for evaluation of findings and resolutions.

1 And other Energy Northwest managers, such as Health Physics, Operations, Chemistry, Security, Records and Information Management, Telecommunications, and Maintenance.

Attachment 7.1, Topics Requiring Periodic Review or Action

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Emergency Program Maintenance Page: 14 of 16 TOPIC RESPONSIBILITY FREQUENCY SCOPE 13 EP Program Audit Manager, Emergency As Necessary C. Ensure that findings requiring (AR 60285) Preparedness Energy Northwest corrective action are tracked to completion.

D. Ensure the results of the review and recommendations are forwarded to appropriate Corporate and Plant Managers, and that portions pertinent to interface with the state and counties are made available to those jurisdictions.

Annually E. Ensure that the EP program audit includes an evaluation of the emergency evacuation notification of individuals in the Owner Controlled Area (i.e.,

IDC, et al) and their response.

14. Drill/Exercise Program Manager, Emergency Annually A. Prepare and conduct a Preparedness drill/exercise program schedule in accordance with Emergency Plan, Section 8, and 10CFR50, Appendix E, Section IV F requirements.

B. Coordinate drill/exercise controllers and evaluators to control and evaluate the ability of emergency responders to perform their Emergency Plan responsibilities.

C. Ensure that drill/exercise evaluation and critique findings are formally documented, and management controls are established to ensure that needed corrective actions are implemented.

Attachment 7.1, Topics Requiring Periodic Review or Action

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Emergency Program Maintenance Page: 15 of 16 TOPIC RESPONSIBILITY FREQUENCY SCOPE

15. Emergency Planning Manager, Emergency As Necessary A. Ensure Emergency Planning Staff qualifications Preparedness staff members maintain their professional qualifications by periodic attendance at industry seminars, training courses, and through observation of, or participation in, emergency exercises conducted at other facilities.

16. Population Study and Manager, Emergency Annually A. Review Emergency Plan Evacuation Time Preparedness Section 5, and update as Estimate necessary.

(Model AR 249408-07)

17. Media Briefing Manager, Emergency Annually A. Ensure annual media briefing is (Model AR 249408-03) Preparedness conducted in accordance with Emergency Plan, Section 9.

18. Public Information Manager, Emergency Annually or As Needed A. Ensure preparation and (Model AR 249408-02) Preparedness distribution of public information instructions on essential actions to be taken during emergencies in accordance with Emergency Plan Section 9.

19. Energy Northwest Alert Manager, Emergency Annually or As A. Schedule and conduct

& Notification System Preparedness Required operational tests of the Energy Tests Northwest Emergency Alert and (Model ARs 216342 & Notification System described 236173, AR-REG in Emergency Plan, Section 6.

61202)

B. Document and transmit reports of test results as required by FEMA Guidance Memorandum for offsite activities.

20. Severe Accident Reactor/Fuels Engineering Annually A. Review and update Technical Guidelines Manager Support Guidelines as (PPM 1.2.7) necessary.

Attachment 7.1, Topics Requiring Periodic Review or Action

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• TOPIC RESPONSIBILITY FREQUENCY SCOPE

21. IDC Implementation of Manager, Emergency Annually A. Conduct an annual assessment Columbia Generating Preparedness of the IDC implementation of Station Eplan the Columbia Generating (Model AR 273501273501 Station Emergency Plan.

Annually B. Ensure participation of IDC personnel during Columbia Generating Station emergency response drills.

Manager, IDC Monthly C. Contact entities resident in the IDC area whose personnel have neither blue nor green badges, and for whom emergency response training is appropriate, to confirm that no new or untrained personnel are employed or present.

Supervisor, Security As necessary D. Ensure SPIPs used to govern Operations security actions for IDC protective actions are reviewed by Emergency Preparedness.

END Attachment 7.1, Topics Requiring Periodic Review or Action