ML20138J663
| ML20138J663 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/30/1985 |
| From: | Battelle Memorial Institute, PACIFIC NORTHWEST NATION |
| To: | NRC |
| Shared Package | |
| ML20138J646 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8510290431 | |
| Download: ML20138J663 (17) | |
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REPORT ON THE f
V0GTLE EMERGENCY CLASSIFICATION SYSTEM ii l
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PREPARED BY l
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BATTELLE PACIFIC NORTHWEST LABORATORIES FOR THE I
i U.S. NUCLEAR REGULATORY COMMISSION
'l t-i SEPTEMBER 1985 l
8510290431 851022 PDR ADOCK 05000424 F
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V0GTLE EMERGENCY CLASSIFICATION SYSTEM i
BACKGROUND i
Battelle, PNL requested COMEX Corporation to review that portion of the VEGP Emergency Plan dealing with the emergency classification system and Emergency Action Level (EAL) set. PNL forwarded to COMEX Corporation Section D of the
' Emergency Plan, Rev. O dated November 30, 1984, and Rev. 1, dated May 1985.
Symptomatic Emergency Operating Procedures (E0P's), and the Emergency Plan Implementing Procedures'(EPIP's) were not available for review.
GENERAL COMMENT
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Based on information provided in the Emergency Plan, VEGP is developing a symptomatic based emergency resp ~onse set of E0P's based on the Westinghouse Owner's Grot'9 guidelines.
Event diagnosis is accomplished by evaluation of Critical Safety Function Status Trees (CSFST's); this methodology provides the basis for emergency classification.
To understand the basis for the classification scheme and the supporting EAL's, an understanding of the basis for the E0P's is required. The symptomatic approach is based on maintenance of critical safety functions that assure integrity of the three fission product barriers:
the Fuel Matrix / Clad ~,'
reactor coolant system, and containment. A breach, or challenge to the j
integrity of the barrier, is analyzed during the evaluation of the CSFST's.
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t At the same time analysis of fission product barrier integrity is occurring, the appropriate functional restorative procedures for the plant are also identified. Emergency Response and Classification are therefore proceeding hand-in-hand.
Plant-specific parameters are used to evaluate branch points in the CSFST's of
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subcriticality, coolant system integrity, core cooling, reactor coolant inventory, heat sink, and containment integrity.
Passage through the status tree by answers of yes/no yield the evaluation of which fission product barriers are breached / challenged. One should note that the parameters listed in the CSFST's are, in many cases, the EAL's for emergency classification.
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Barrier status is then checked against a table to yield declaration of the I
i classification.
L Table D-1 of the Emergency han provides an event-oriented list of plant conditions to lead the Emergency Response Manager to Declaration of Notification of Unusual Event. Table D-2 lists the equivalency of 1/3 barriers breached or challenged as alert, 2/3 - Site Area Emergency, and 3/3 -
General Emergency. Also included in Table D-2 are a few event-oriented plant conditions, such as " Loss of All (onsite and offsite) AC Power", that do not readily lend themselves to fission product barrier analysis unless consideration of the end result is evaluated. Once comparison of fission prcduct barrier integrity with Table D-1, 2 'is completed, classification may be made. VEGP procedures define Emergency Classifications, provide class descriptions, and establish responses that are consistent with 10 CFR 50 and NUREG-0654.
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1-l EVALUATION Evaluation of the applicant's Emergency Plan was based on NUREG-0654 and 10 CFR 50 as follows:
Evaluation Criteria, NUREG-0654 Planning Standard - Section D.
Emergency Classification System "A Standard f
Emergency Classification and Action Level Scheme, The basis of which include Facility System Effluent Parameters, is in use by the Nuclear Facility Licensee, and state and local Facility Licensees for determinations of minimal initial off-site response measures."
CRITERIA i
1.
An Emergency Classification and Emergency Action Level Scheme as set forth
. in Appendix 1 must be established by the licensee. The specific instruments, parameters, or equipment status shall be shown for 1
establishing each emergency class, in the in-plant procedures. The plan shall identify the parameter values and equipment status for each emergency class.
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"The initiating conditions shall include the example conditions found in,,
j Appendix 1 and all postulated accidents in the Final Safety Analysis Report (FSAR) for the nuclear facility."
It should be noted that for the
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alert, site area emergency, and general emergency classifications that a 3
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direct correlation between the VEGP EAL's and the example EAL's of Appendix 1 is not possible. Without the E0P's/EPIP's, only the intent (as derived from the Emergency Pian) of correlating the VEGP EAL's to Appendix i
i 1 could be evaluated.
I Additionally, the regulatory requirements of 10 CFR 50, Appendix E - IV., B.
f and C.. were considered in the evaluation:
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"... The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring..."
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... Emergency Action Levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that I
indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described..."
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SYNOPSIS OF REVIEW F
Emergency Classification and Emergency Action Level Schemes consistent with the intent of NUREG-0654, Appendix 1, and 10 CFR 50, Appendix E have been i
established by VEGP in their emergency plan. Several example initieting i.
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conditions of NUREG-0654 have been omitted from the VEGP procedures.
Some NUREG-0654 alert classification conditions are included as Notification of
.j Unusual Event Classifications in the VEGP Procedures.
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f I-REVIEW COMMENTS Specific coments concerning the content of the Emergency Plan as a result of l'
conducting the review and evaluation against the above stated criteria are 5
contained in enclosure (1).
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ENCLOSURE 1 REVIEW COMMENTS VEGP EMERGENCY PLAN, CLASSIFICATION AND EAL SCHEME 1.
NUREG-0654, Appendix 1, p.1-8, Licensee Actions, Item 5. states " Provide periodic plant status updates to offsite authorities (at least every 15 minutes)."
4 Paragraph D.2.2 Alert, Item 2.e., p. D-3 states for Georgia Power Company (GPC) actions " Provide periodic plant status u,ndates to offsite authorities."
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The applicant should consider including specific guidance on the periodicity of plant status updates, and should ensure that such guidance is also included in the appropriate EPIP's.
2.
NUREG-0654,Section II.E.3. states "The licensee... shall establish the i
contents of the initial emergency messages to be sent from the plant.
These messages shall contain information about... whether protective messages shall contain information about... whether protective measures may be necessary."
Paragraph D.2.3 Site Area Emergency, Item 2.b. of GPC Actions, p.0-3 states "if necessary, provide protective action recommendations to state and local authorities."
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f The applicant should consider adding the requirement to make a protective action recommendation, even if the recommendation is "none" to the list of GPC Actions for the Notification of Unusual Event and Alert, and consider modifying the words of Item 2.b. to read " provide protective action recommendation...".
3.
NUREG-0654, Appendix 1,-Examn' Initiating Conditions: Notification of Unusual Event, lists Item 3.c.
" Failed Fuel Monitor (PWR) indicates increase greater than 0.1% equivalent fuel failures within 30 minutes.
Y VEGP procedures provide no equivalent EAL to this NUREG-0654 EAL as a preliminary indicator of failed fuel not requiring coolant activity analysis.
4.
NUREG-0654, Appendix 1, Notification of Unusual Event, lists Item 4.
As
" Abnormal fuel temperatures outside of technical specification limits."
VEGP Procedures provide for declaration of an alert (or higher if more than one barrier challenged) if evaluation of the CSFST shows the reactor coolant system boundary under " challenge", i.e., high enough pressure for low enough temperature. However, there are circumstances where the CSFST would lead the operator to an evaluation that the reactor coolant system was "off-normal" (i.e., outside of technical specification limits), but the operator would not._
be led to a classification since the boundary was not under " challenge". VEGP Procedures do not provide for the equivalent of the NUREG-0654 Unusual Event EAL concerning coolant temperature / pressure relationships.
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NUREG-0654, Appendix 1, Alert lists Item 1. as " Severe loss of cladding."
References to Figure D-8 of the VEGP Procedure that determines the status of.
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.the fuel cladding integrity, Item 4. shows " post-accident sampling verifies the existence of failed fuel and provides an indication of coolant activity greater than ten times technical specification limits."
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1 As written, the implication of the analysis chart is that post-accident sampling must have detected the condition, when in fact, if any coolant sampling detects the condition of high activity, fuel cladding integrity is breached. The applicant should modify the words to reflect " coolant activity f
sampling...".
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NUREG-0654, Appendix'1, Alert Item 5. states " Primary coolant leak rate greater than 50 GPM."
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As written, VEGP Procedures currently would tolerate a LOCA leak rate considerably in excess of 50 GPM, with no procedural necessity to declare an j
emergency. This occurs because the inventory CSFST (Figure D-7) leads the operator to only an "off-normal" condition, even if the pressurizer level is less than 17%. Consider the case of the leak rate equal to charging pump capacity; the pressurizer level is maintained, but the leak could be as much,,
as 150 GPM. As stated above, even if pressurizer level is less than 17%, the operator is led to evaluation of the situation as an "off-normal" condition, not a " challenge" to RCS integrity. By procedure, a challenge to integrity is 8
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i required for the classification. Reference to the reactor coolant system integrity flow chart, Figure D-9, shows that ultimately the proper classification would be made after activity released to containment or the steam generators. built up to alarm levels. The applicant should revise the j
EAL to be consistent with the intent of NUREG-0654 that a breach of the RCS is i
considered to have occurred for a leak of 50 GPM.
7.
NUREG-0654, Alert, Item 8. states " Loss of all onsite DC power...".
No equivalent EAL exists in the VEGP Procedures. Until fission product barrier status is impacted, a declaration for this serious condition is not made' procedurally. The applicant should consider including this EAL as a discrete condition for alert.
8.
NUREG-0654, Alert, Item 10.
" Complete loss of any function needed for plant cold shutdown."
i This EAL is included in VEGP Procedures as an unusual event (Table D-1 Item 14.).
The applicant should consider including this discrete condition as an Alert Classification.
9.
NUREG-0654, Alert, Item 14.
"Most or all alarms (annunciators) lost."
The equivalent EAL in VEGP Procedures (Table D-1, Item 16) is listed as an unusual event. The applicant should consider listing this as a discrete EAL for an Alert due to the severity.
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- 10. NUREG-0654, Alert, Item 16.
" Ongoing security compromise."
No equivalent EAL exists in the VEGP Procedures. Ultimately, such a situation could result.in a challenge to fission product barriers, and thus a declaration would be made. However, one of the intents of the classification f
scheme is to previde early notification. Waiting for a degradation of a
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barrier to occur before declaring an Alert does not fulfill the timeliness intent. The applicant should consider including this as a discrete EAL for the Alert Classification.
- 11. NUREG-0654, Alert, Item 17.
" Severe natural phenomena being experienced or projected."
No equivalent EAL exists in the VEGP procedures (see discussion in #10 above).
The applicant should consider the inclusion of this example EAL as a discrete EAL in the Alert Classification.
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- 12. NUREG-0654, Alert, Item 18.
"Other hazards being experienced or projected."
No equivalent EAL exists in the VEGP Procedures (see discussion in #10 above).
The applicant should include this as a discrete EAL in the Alert Classification.
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- 13. NUREG-0654, Alert, Item 19.
"Other plant conditions exist that warrant precautionary activation of the TSC and placing near-site EOF and other key emergency personnel on standby."
No equivalent EAL to this example initiating condition is included in the VEGP Procedures. There does not appear to be any discretionary authority in the procedures that would mandate the emergency manager to exercise the equivalent of this EAL, therefore the applicant should consider including this EAL as a discrete item in the Alert Classification.
- 14. NUREG-0654, Alert, Item 20.
" Evacuation of control room anticipated or required with control of shutdown systems establi'shed from local station." is included as Item #7, Table D-1, Notification of Unusual Event in the VEGP Procedures. Due to the potential for severe, adverse problems from this condition, the applicant should consider the inclusion of such a discrete EAL in the Alert-Classification category.
- 15. NUREG-0654, Site Area Emergency, Item 1.
"Known LOCA greater than makeup pump capacity."
See discussion in #6 above concerning the shortcoming of Figure D-7, Inventory, leading the operator only to the Critical Safety Function (CSF) being off-normal, not " challenged" as is required for classification entry.
Referring to the CSF of core cooling, Figure D-3, the operator is eventuelly led to a challenge to the fuel cladding if the condition continues.
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if the CSFST's are strictly interpreted, degradation of the plant conditions to reactor vessel level low, and/or core exit thermocouple high is required before the CSF of core cooling is considered " challenged", and thus the elevated classification made.
In sumary, the 0654 EAL is simplistic in nature; the VEGP methodology is cumbersome to arrive at the desired result; in fact, VEGP procedures will probably not give the desired result since the inventory CSFST never results in a " challenge", even for the worst case.
The applicant should consider modification of the EAL to assure that the intent of the NUREG-0654 EAL is fulfilled, i.e., if the LOCA exceeds pump capacity, it is a Site Area Emergency.
- 16. NUREG-0654, Site Area Emergency, Item 6.
" Loss of offsite power and loss of onsite AC power for more than 15 minutes. "
No equivalent, discretc EAL exists ir, the VEGP Procedures. Degradation of plant systems with the loss of power would ultimately result in the classification utilizing the CSFST's. However, the deterioration in the early l
stages of the emergancy would not cause a declaration in 15 minutes. The applicant should considcr a discrete EAL in the Site Area Emergency Scheme (similaptothediscreteEALfortheAlertClassification)forthiscondition.
- 17. NUREG-0654, Site Area Emergency, Item 7.
Loss of all vital DC power for more than 15 minutes."
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r-To equivalent, discrete EAL exists in the VEGP Procedures. The applicant should consider the addition of such a discrete EAL.
- 18. -NUREG-0654, Site Area Emergency, Item 8.
" Complete loss of any function needed for plant hot shutdown."
No equivalent, discrete EAL exists in the VEGP Procedures.
In the absence of a plant transient, current procedures would not lead to a classification of such an EAL. The applicant should consider the inclesion of such an anticipatory EAL.
- 19. NUREG_0654, Site Area Emergency, Item 10
" Major damage to spent fuel in containment or fuel handling building...".
No equivalent, discrete EAL exists in the VEGP Procedures.
Unlike the EAL listed for the alert classification dealing with high radiation levels or high airborne contamination levels that would occur for such an accident, no EAL's are provided to provide classification guidance for such accidents as expended fuel element damage, or radwaste treatment system failures.
Source term studies show the potential magnitude of such an accident to have the radiological impact of site area or general emergencies. Thus the applicant should consider including a readily determined EAL set dealing with this acciderit.
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- 20. NUREG-0654, Site Area Emergency, Item 11.
" Fire compromising the functions of safety systems."
No equivalent EAL is included in the VEGP Procedures. As written, until a plant (emergency) transient occurs, evaluation of CSFST's leading to a d
classification would not occur, even though the example initiating condition could have been exceeded. Therefore, the applicant should consider including guidance concerning extensive fire degradation to safety systems.
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- 21. NUREG-0654, Site Area Emergency, Item 13.b.
"These dose rates...are measured in the environs."
A discrete EAL appears in the Table D-2 Emergency Classifications for Site Area Emergency that reads " Site boundary whole body dose rate reasonably expected to be greater than 50 mr/hr or thyroid dose rate greater than 250 mr/hr."
The applicant should modify the words of Table 0-2 to reflect the words of NUREG-0654 that "The dose rates are projected to exceed 50 mr/hr whole body..., or are measured in the environs" to assure that the intent of 2
NUREG-0654 is fulfilled.
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- 22. NUREG_0654, Site Area Emergency, Items 14., 15., 16., 17., and 18 are not included in the VEGP Procedures.
Ultimately, the results of such disasters would result in classification through the use of the CSFST's, 14
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i but as written, there exists no direct EAL. set that states "This condition is a Site Area Emergency" to fulfill the intent of NUREG_0654.
l The appifcant should consider adding discrete plant conditions to cover these suggested EALs of NUREG_0654.
- 23. NUREG-0654, General Emergency, Item 1.a.
" Effluent monitors dete :t levels corresponding to I rem /hr W.B. or 5 rem /hr thyroid at the site boundary under actual meteorological conditions.
b.
These dose rates are projected based on other plant parameters (e.g.,
radiation levels in containment with leak rate appropriate for existing i
containment pressure with some confirmation from effluent monitors) or are measured in the environs."
TheVEGPEALequivalentstates"offsitedosereasonablyexpectedtoexceedEPk PAG Levels at site boundary."
The applicant should consider modifying the words of the EAL to reflect a) actual meteorology, b) measurements from the environs as well as projections, and c) actual values for dose / dose rates rather than forcing reliance on melnory for " EPA PAG Levels.".
24.
NUREG-0654, General Emergency, Item 3.
" Loss of physical control of the i
facility."
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'o No equivalent EAL exists in the VEGP Procedures for this NUREG condition. The applicant should consider including the EAL in the:r procedures for the same reasons discussed in #10 above.
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- 25. Figure D-8, fuel cladding integrity determination flow chart Item 5.
j states " Gross failed fuel detector high", as one of the determining factors for evalu~ating failed fuel.
J The applicant should consider modifying the words of the EAL to be more specific, such as "off-scale high", "100 times normal", or "in alarm high".
Each EAL should be, where possible, a discrete instrument reading or plant
-condition.
26.
Figure D-9, Reactor-coolant system integrity determination flow chart Items B.1. and 2. use adjectives of "... indicates abnormal radiation intensity.", and "... increase significantly.". The applicant should consider modifying the words of these EAL's to quantify the adjectives to 2
readable, objective values.
- 27. No determination could be made as to whether "other" VEGP Procedures such as abnormal operating procedures, chemistry, and health physics procedures contain references leading to the EAL/ classification scheme.,,
t Based on the content of the emergency plan, not direct observation of the E0P's, it appears that such reference is included in the E0P's.
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U.S.NUCLEARREGUL$TORYCOMMISSION OFFICE OF INSPECTION AND ENFORCEMENT INSPECTION AND ENFORCEMENT MANUAL TEMPORARY INSTRUCTION 2515/55
SUBJECT:
EMERGENCY PREPAREDNESS IMPLEMENTATION APPRAISAL
- PROGRAM l
A.
OBJECTIVES The purpose of this TI is to describe the scope of the Emergency Preparedness Implementation Appraisal Program and to provide '
guidance for its implementation. This TI modifies the require-ments of scheduliq of certain inspections of emergency prepared-I ness activities cc power reactors in consideration of special team inspection efforts to be condacted during 1981 and 1982.
Emergency preparedness inspections under TI 2515/44 are superseded by this TI.
B.
BACKGROUND AND PROGRAM DESCRIPTION The background and program description for this effort is given in Reference 1 " Emergency Preparedness Appraisal Program".
C.
PROGRAM DESIGN 1.
General Special team appraisals of emergency preparedness programs will be conducted at each of the sites which have power reactors in operation or which are classified as NTOLs. The schedule for completion of these inspections is April 1982, with the first appraisal being conducted in April 1981. Review teams will be composed of four members, with the team leader being a senior NRC Office of Inspection and Enforcement individual. Other members of the team will be professionals provided by PNL and c
the NRC headquarters and regional staffs.
l Each member of the appraisal teams will be under the direction of the NRC team leader.
Individual team members are not expected to have thorough knowledge of all areas, but are to be assigned to selected areas for appraisal based, in part, on their expertise. Although there are inspection outlines and guidance provided, reasonable flexibility will be allowed each member in the conduct of these inspections / evaluations to account for the individual character of each plan. A more indepth review than is defined by the scope of the questions may be pursued at the discretion of the i
team leader for areas in which weaknesses have been identified.
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- T'he tenn appraisal is used in this document as a description of a particular inspection technique. The tenn appraisal is used to indicate an inspection focused on identification and correction of underlying causes of deficiencies i
rather than on identification of non-ccmpliance itens.
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Each onsite appraisal will be preceded by about two weeks of i
advanced preparation of appraisal details and familiarization i
of site specifics such as plant layouts, technical specifications, the HP Appraisal Findings, the Emergency Plan and Implementing Procedures. During this two week period, all or a major portion of the procedure review portions of the appraisal (Section 5.0)
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should be perfonned.
If this preparation phase requires a meeting of team nenbers, the meeting should be scheduled insnediately before 1
the onsite appraisal to minimize travel costs and time.
Appraisals will be performed during a 2-week period at the licensee's nuclear power reactor site and are to involve review of records, discussions with plant personnel, observation of work practices and conduct of independent measurements by team members.
Upon completion of the onsite appraisal, a fonnal appraisal j
report is required. Discussions and coordination of report j
findings may necessitate conferring with team members.
t Some accumulation of radiation dose is expected during the conduct of the appraisal program, however, individual team 1
members are expected to apply ALARA principles. Under no j
circumstances shall team members exceed 1 1/4 rems per quarter.
2.
Philosophy NUREG-0654, Rev.1 does not give specific guidance for imple-mentation of emergency plans other than to say they must be i
effectively implemented.
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The purpose of developing the Emergency Preparedness Appraisal Program was to institute a standard means for perfonning a o
comprehensive evaluation of the overall adequacy and effective-ness of power reactor licensees' total emergency preparedness program. The appraisal mst result in a finding that there is or is not reasonable assurance that appropriate assessment and protective measures can and will be taken in the event of a radiological emergency. Any deficiencies preventing a positive finding mst be identified.
To make this finding, the licensee must demonstrate that proper equipment, trained personnel and adequate procedures are in place to detect and assess the course of an accident and its potential severity, that the licensee's emergency organization, appropriate authorities and the public will be notifed promptly, and that adequate protective 8
actions can and will be taken in response to the emergency.
O Current emergency planning inspections are compliance oriented j
and lead to the inspection of emergency planning programs by ij discrete subject areas. The appraisal program was structured i
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to facilitate an integrated look at the total program. Also, by the very nature of the goal, which is to evaluate the over-all adequacy and effectiveness of emergency plan implementation, the appraisal program may be directed into areas for which explicit regulatory requirements may not currently exist. This appraisal program is geared toward evaluating the total program i
in terms of capabilities and performance and identifying major inadequacies, not towards identification of noncompliance.
An emergency response consists of the performance of a sequence of crucial tasks under a wide range of conditions. The effective-ness of the response is dependent upon the establishment and meintenance of an effective response capability. The fact that a site has an emergency plan that meets all guidance of NUREG-0654 Rev.1 does not mean that plan can or will be implemented effectively under emergency conditions. Therefore, the appraisal is designed to assess the ability of licensee response personnel to complete the sequence of crucial tasks under emergency conditions using the resources available at the site to meet the fundamental objective of an emergency response. The findings in relation to the licensee's ability to meet the objective will be based on evaluations of:
the administrative elements essential to the establishment l
and continued maintenance of the response capability; the structure and definition of the emergency organization; l
the training of response personnel; the-facilities, equipment and decisional aids essential to the performance of the crucial emergency response tasks; the fonn, scope and content of the procedures which will guide the performance of the crucial tasks; the coordination of the licensee's response tasks with those of supporting groups; and performance demonstrations of critical tasks by key emer-gency response personnel.
The ultimate benefits to be gained from the appraisal program are in terms of adequate emergency planning and preparedness for the workers and the general public. However, in order for these i
benefits to be achieved, licensees must take specific actions to strengthen areas that are weak and correct areas that are inade-quate or which do not meet regulations and guidance. To provide 3
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that assurance, licensees will be directed to respond in writing within 25 days of the date of the transmittal letter to all nejor findings of weakness or inadequacy and to correct j
such weaknesses or inadequacies within four months of the date of the letter. To assure that lasting corrective efforts are implemented as part of the appraisal, the team will also recommend improvements to the Emergency Plan where identified weaknesses appear to have thei cause in incomplete planning.
h The team leader (and appropriate team members) should meet l
with plant management during the appraisal to discuss any significant findings such that prompt corrective actions can i
be formulated prior to the exit meeting. Following the appraisal, there will be an exit interview. If major concerns were identified during the appraisal, appropriate corrective actions and possible enforcement actions will be discussed.
Licensee commitments will be obtained where needed.
For the remainder of the appraisal findings, the licensee will be allowed the opportunity to review the report details and i
coortlinate an integrated corrective action, j
3.
Program Implementation Headquarters (DEP) is responsible for overall management of l
the program and for setting rey'ew schedules, after consultation l
with the Regions. Headquarters and Regional Offices are responsible for implementing the program, b
A draft letter for " Licensee Notification of Emergency Pre-
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paredness Program Appraisal" is provided as Reference 2, and l
Reference 3 is a sample letter for transmitting the appraisal report to the licensees.
I D.
ROUTINE INSPECTION PROGRAM CHANGES l
Considering that regional manpower is required for the special team appraisal effort and that team appraisal efforts will achieve the objectives of the routine IE emergency preparedness inspection program, the routine program of inspection will not be implemented for the duration of this appraisal effort.
In addition, because of the need for manpower on the appraisal program, the routine emergency
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preparedness inspection program for nonpower reactors will be postponed until after the completion of the appraisal program
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unless otherwise determined by the appropriate Regional Director.
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Reactors in Construction Phase aj
- No emergency preparedness inspections 4
2.
Reactors in NTOL Phase L
- This TI shall be used as the preoperational inspection
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Reactors in Operation
- This TI shall be used
- Procedures 828208 (Fire Prevention / Protection) shall continue in effect.
- Emergency Preparedness Inspections under the following pro-cedures shall be delayed:
TI 2515/44 71713, Review of Plant Operations, Resident Semi-Annual Review (only those aspects that pertain to emergency preparedness,Section II.6) 823308, Bnergency Planning / Coordination with Offsite Agencies 823318 Emergency Planning / Facilities. Equipment, Procedures 82331C, Bnergency Planning / Preop Tests and Training 823328, Emergency Planning / Tests and Drills 82'7108, Omergency Planning / Coordination with Offsite Agencies (Operations) 82710C, Emergency Planning Operations, Resident Inspection Procedure Supplement 827118, &nergency Planning / Facilities, Equipment, Procedures (Operations) 827128, &nergency Planning / Tests and Drills (Operations) 82745B, Research Reactor Emergency Plan
- Reactivity efforts shall continue in accordance with current requirements and policy (e.g., response to incidents).
- Observation of exercises conducted in accordance with the Commission regulations shall continue.
E.
MANPOWER SYSTEM AND 766 DATA Tracking Number is 0255558 F.
OVERTIME In general, overtime (or compensatory time) will be paid only for work done in the field during site visits for the emergency pre-i
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6 paredness implementation appraisal program or during exercise ob serva tions. The team leaders in the field will be responsible for the time of the team members during the visits and will provide to the members supervisor the required Fom 145, " Request i
and Authorization for Irregular and Occasional Overtime." One fom is required for each individual and shall be completed by the team leader immediately upon return to his duty station following r
i the visit.
In addition, the fom shall indicate whether overtime or compensatory time is desired by the team member. Because of the extremely tight schedule during this next year, in general, compen-satory time will not be authorized. As the time and attendance (T&A) cards must ce consistent with Fom 145, it is imperative I
l that T&A clerks receive these forms in time to be submitted with the l
T8A ca rds.
In those instances where this is not possib'e because the team is onsite, the team leader will call the respective I
members supervisor with the applicable infomation. The super-visor will then submit the appropriate Fom 145.
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During the site visits, the teams will be working irregular and occasional overtime, which will be documented on NRC Form 145
" Request and Authorization for Irregular and Occasional Overtime.."
Normally, no overtime will be granted for work perfomed at the r
nomal duty station; however, when it is mandatory, it must be j
approved in advance by the respective Branch Chiefs.
f You are reminded that any authorized compensatory time for use in subsequent workweeks shall be used no later than 12 pay periods af ter the pay period it is earned. Compensatory time not used by the end of the 12 pay periods will be paid for at the overtime rate at which earned.
G.
IE HEADQUARTERS CONTACT l
Questions should be addrased to Frank G. Pagano, 492-9647.
l Alternate contact: Richard Van Niel, 492-9732.
H.
REFERENCES (Reference 1 distributed only to a limited distribution list) 1.
Emergency Preparedness Appraisal Program 2.
Draf t Letter to Licensee from Regional Director notifying 4
them of impending team visit.
3.
Sample Letter for transmitting appraisal report to Licensee from Regional Director.
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'I REFERENCE 1 1
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EMERGENCY PREPAREDNESS APPRAISAL PROGRAM s
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t TABLE OF CONTENTS 1
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Introduction..................................................
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II. Reg u l a to ry Ba c kg rou nd........................................
1 I
III. Emergency Prepa redness Appraisal Program......................
2 A.
Objectives...............................................
2 B.
Methodology..............................................
2 A
C.
Design...................................................
2 1.
General.............................................
4 2.
Philosophy..........................................
5 IV. Appraisal Program Procedure...................................
6 I
j A.
Prepa ra tion for Ons i te Appra i sal.........................
6 B.
Onsite Plan Implementation and Emergency Preparedness Appraisal..............................................
8 C.
Documentation.'...........................................
9 V.
Fol low-up of Apprai sal Findi ng s............................... 11 VI. Exe rc i s es a n d D r i l l s..........................................
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V I I. R e fe re n c e s....................................................
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VIII. Appendices....................................................
A.
Basic Appraisal Program..................................
3 B.
Appraisal Matrix..........................................
I C.
NUREG-0654/Apprai sal Cross Refe rence.....................
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Introduction The U.S. Nuclear Regulatory Commission has recently upgraded its emergencv planning regulations to assure that protective measures can and will be taken to protect the health and safety of the public in the event of an emergency at a nuclear power plant. Pursuant to these upgraded regulations, nuclear power l
plant licensees were required to submit upgraded emergency plans, together with the upgraded emergency response plans of state and local governments, to the Commission by January 2,1981.
In addition, the licensees were required to:
- 1) submit to the Commission by March 1,1981 the procedures which will be used by the licensees to implement their upgraded emergency plans, and 2) implement i,
those plans by April 1, 1981. Further, more extensive guidance has been issued by the Commission in the fom of NUREGs for use by licensees in meeting the requirements of the upgraded emergency planning regulations. Of specific inter-est in this regard is NUREG-0654, Rev.1, and its supporting documents.
l The program described in this document was developed to clearly define the i
methods which will be used by NRC to review and evaluate the licensees' emergency planning and preparedness. The appraisal procedures cover three major aspects:
j Preparation for Onsite Appraisal; Onsite Emergency Preparedness Appraisal; Doctanentation i
The methods described in this report are predominantly aimed at the onsite implementation review stage and the overall review and evaluation process.
This document addresses only the NRC portions of the review and evaluation process related to a licensee overall emergency preparedness. The Federal Emergency Management Agency (FEMA) is responsible for the detemination as to whether state and local emergency plans are adequate and capable of being imple-mented. The NRC'will review the FEMA findings and deteminations in addition to the results of its own. review of the licensee's preparedness to arrive at l
an overall detemination of adequacy of emergency preparedness.
II. Regulatory Background Pursuant to the provisions of the Atomic Energy Act of 1954, as amended. P.L.83-703 and Title II of the Energy Reorganization Act of 1974, as amended, P.L.93-438, the U.S. Nuclear Regulatory Commission is vested with the authority and respo,nsibility to regulate the processing and utilization of source, by-product, and spe~ ial nuclear material in the national interest and in order to c
provide for the common defense and security and to protect the health and safety of the public.
Further, pursuant to the provisions of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended and the President's Statement i
of December 7,1979 (with the accompanying fact sheet) the U.S. Nuclear Regula-tory Comission is specifically charged with responsibility for the development and promulgation of guidance to nuclear facilities operators, States and local t.
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3 goverranents, in coordination with other Federal agencies, for the preparation of radiological emergency response plans and assessing the adequacy of such l
plans.
In June 1979, the Nuclear Regulatory Commission began a fomal reconsideration of the role of emergency planning to ensure the continued protection of the i
public health ar.d safety in areas around nuclear power facilities. The Commis-sion began this reconsideration in recognition of the need for more effective j
emergency planning and in response to the TMI accident and to reports issued j
by responsible offices of government and the NRC's Congressional oversight committees.
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j In response to and guided by the various reports and public comments, as well as its own detemination on the significance of emergency preparedness, the 4
Commission has therefore concluded that adequate emergency preparedness is an i
essential aspect in the protection of the public health and safety. Therefore, j
on August 19, 1980, the USNRC published in the Federal Register (45 FR 55402) its final rule regarding emergency planning for nuclear power facilities j
licensed under 10 CFR Parts 50 and 70. The Commission's final rules are based on the significance of adequate emergency planning and preparedness to ensure 1
adequate protection of the public health and safety. It is clear, that onsite and offsite emergency preparedness as well as proper siting and engineered design features are needed to protect the health and safety of the public.
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In order to discharge effectively its statutory responsibilities, the Consnis-sion must know that proper means and procedures will be in place to assess the course of an accident and its potential severity, that NRC and other appro-priate authorities and the public will be notified promptly, and that adequate 4
protective actions in response to actual or anticipated conditions can and will i
be taken. The Commission nust also detennine that the means and procedures will be in place by which this state of emergency preparedness will be main-i tained.
l III. Emergency Preparedness Appraisal Program A.
Objectives To detennine the adequacy of emergency preparedness at licensed nuclear power 4
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plants.
I B.
Method The guidance necessary to accomplish this objective (Appendix A) was developed l
to satisfy the need for a clearly defined method for appraising the licensee's i
emergency preparedness progran, and to provide guidance to the appraisal teams
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in both scope and implementation of the review and evaluation process. This i
program is designed to be dynamic. The content will be subjected to further i
i scrutiny and subsequent improvement.
It is anticipated that this program will I
evolve in such a manner that it will serve as the basis for the emergency 1'
planning inspection program when the implementation review phase has been comple ted.
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The program is described using analytic trees, written guidance and a series of questions. The analytic trees provide a graphical depiction which aids in the deductive analysis of the system. The guidance sections provide the user with the objectives to be met, a discussion of the basis for the questions and need to review a given area ar,d suggests review methods. The questions are intended to lead the reviewer into the major areas pertinent to a comprehensive evaluation of the various aspects of emergency preparedness.
The analytic trees and worksheets are provided as tools to evaluate the informa-tion gathered to reach findings. Use of these tools will aid in identifying interrelationships of findings, thereby pemitting an assessment of the total impact of findings in a logical way. They can also be helpful in communicat-ing the findings to the licensee.
This method will be used by all teams. The team leaders, however, are permitted some flexibility in application. Whether the analytic trees are presented and discussed with the licensee is strongly encouraged but not man-datory. Also, the questions are not on all inclusive listing of significant i tems. They are intended as an aid in providing an overview of the areas of interest and as directive guidance in conducting the appraisal to prevent team oversights in critical areas. Thus while each and every question need not necessarily be answered, all of the major areas must be explored and a suf-ficient number of questions must be answered to assure acceptability.
The analytic trees provide a clear picture of the basic elements of the pro-gram and provide ~a logic display of interrelationships. The trees start with a single desirable condition and systematically proceed through lower levels or tiers until all important factors which produce the major condition are specified. The trees presented in this document provide a description of the elements of a fully implemented emergency plan which meets the planning stan-dards in 10 CFR Part 50.47(b) and the specific criteria in NUREG-0654, Rev.1, (NUREG-0654 Plan). Use of these trees can help in the detection and correction of licensee oversights and omissions.
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Each of the trees has some degree of interface with the other.
Important
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interfaces are highlighted by transfer functions (triangles with arrows and a letter or number). The questions accompanying each tree are carefully struc-tured to avoid duplicative effort in the interface areas.
The interfaces between areas are important in the evaluation process. To properly evaluate areas where transfers are noted, data collected from one area mst be " transferred" to another %d considered in the evaluation of buu.
areas. The end result is that the impact of a particular finding can be assessed in a systematic way and assurance provided that a given area is adequate or inadequate, with a minimum amount of time and effort.
No method or program can or should eliminate the need for professional judge-ment.
In this sense, the program is not an attempt to preclude the reviewer's application of judgement factors, but rather seeks to clarify where such judg-ment is needed and to aid the reviewer in making judgements by bounding the area requiring such professional judgments. The " Acceptance Criteria" column reflects e
both those areas where the reviewer's professional judgement is the sole acceptance 3
criterion and areas where the NRC Staff has determined that existing regulations, guides or standards should be used as the acceptance criteria. Even in those areas where finn acceptance criteria exist, the reviewer still must exercise judgement in evaluating the degree to which a particular area meets criterit.
In those areas where no finn criteria exist, the question itself may be con-sidered the criterion to be met.
In this case, the reviewer uses his judgement to determine the degree to which the licensee's system meets the objective intent of the question. Reviewers should keep in mind that the licensee's Emergency Plan itself constitutes criteria that must be met.
In total, the reviewers should have adequate " criteria" upon which to base their evaluations.
C.
Design 1.
General Special team appraisals of energency preparedness programs will be con-ducted at each of the sites which have power reactors in operation or which are classified as NTOLs. The schedule for completion of these inspections is April 1982, with the first appraical being conducted in April 1981.
Review teams will be composed of four members, with the team leader being a senior NRC Office of Inspection and Enforcement individual.
Other members of the team will be professionals provided by PNL and the NRC headquarters and regional staffs.
Each member of the appraisal teams will be under the direction of the NRC team leader.
Individual team members are not expected to have thorough knowledge of all areas, but are to be assigned to selected areas for appraisal based, in part, on their expertise. Although there are inspec-tion outlines and guidance provided, reasonable flexibility will be allowed each member in the conduct of these inspections / evaluations to account for the individual character of each plan.
A more indepth review than is defined by the scope of the questions may be pursued at the discretion
.of the team leader for areas in which weaknesses have been identified.
Each onsite appraisal will be preceded by about two weeks of advanced prepara-tion of appraisal details and familiarization of site specifics such as plant layouts, technical specifications, the HP Appraisal Findings, the Emergency Plan and Implementing Procedures. During this two week period, all or a major portion of the procedure review portions of the appraisal (Section 5.0) should be performed.
If this preparation phase requires a meeting of team members, the meeting should be scheduleo immediately before the onsite appraisal to minimize travel costs and time.
Appraisals will he performed during a 2-week ceriod at the licensee's nuclear power reactor site and are to involve review of records, discus-sions with plant personnel, observation of work practices and conduct of independent measurements by team members.
Upon completion of the onsite appraisal, a formal appraisal report is requi red. Discussions and coordination of report, findings may neces-sitate conferring with team members.
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3 Some accumulation of radiation dose is expected during the conduct of the appraisal program, however, individual team members are expected to apply ALARA principles. Under no circumstances shall team members exceed 1%
rems per quarter.
2.
Philosophy NUREG-0654 Rev. I does not give specific guidance for implementation of emergency plans other than to say they must be effectively implemented.
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The purpose of developing the Emergency Preparedness Appraisal Program was to institute a standard means for performing a comprehensive evalua-tion of the overall adequacy and effectiveness of power reactor licensees' total emergency preparedness program. The app'raisal must result in a find-ing that there is or is not reasonable assurance that appropriate assessment and protective measures can and will be taken in the event of a radiological eme rgency. Any deficiencies preventing a positive finding must be identi-fied. To make this finding, the licensee must demonstrate that proper equipment, trained personnel and adequate procedures are in the place to detect and assess the course of an accident and its potential severity, that the licensee's energency organization, appropriate authorities and the public will be notified promptly, and that adequate protective actions can and will be taken in response to the energency. Current energency planning inspections are compliance oriented and lead to the inspection of energency planning programs by discrete subject areas. The appraisal program was structured to facilitate an integrated look at the total pro-gram. Also, by the very nature of the goal, which is to evaluate the overall adequacy and effectiveness of emegency plan implementation, the appraisal program may be directed into areas for which explicit regula-tory requirements may not currently exist. This appraisal program is geared toward evaluating the total program in terms of capabilities and performance and identifying major inadeqaucies, not towards identifica-tion of noncompliance.
An emergency response consists of the performance of a sequence of crucial tasks under a wide range of conditions. The effectiveness of the response is dependent upon the establishment and maintenance of an effective response capability. The fact that a site has an emergency plan that meets all guidance of NUREG-0654, Rev.1, does not mean that plan can or will be implemented effectively under emergency conditions.
Therefore, the appraisal is designed to assess the ability of licensee response person-nel to complete the sequence of crucial tasks under emergency conditions using the resources available at the site to meet the fundamental objec-tive of an emergency response.
The findings in relation to the licensee's ability to meet the objective will be based on evaluations of:
the administrative elements essential to the establishment and con-tinued maintenance of the response capability; the structure and definition of the energency organization; 5
the training of response personnel; e
the facilities, equipment and decisional aids essential to the per-formance of the crucial emergency response tasks; the form, scope and content of the procedures which will guide the i
performance of the crucial tasks; the coordination of the licensee's response tasks with those of j
supporting groups; and i
performance demonstrations of critical tasks by key emergency response personnel.
The ultimate benefits to be gained from the appraisal program are in terms of adequate emergency planning and preparedness for the workers and the general public. However, in order for these benefits to be achieved,
. licensees must take specific actions to strengthen areas that are weak i
and correct areas that are inadequate or which do not meet regulations To provide that assurance, licensees will be directed to and guidance.
respond in writing within 25 days of the date of the letter transmitting f
the report to all major findings of weakness or inadequacy and to correct 1
such weaknesses or inadequacies within four months of the date of the letter.
To assure that lasting corrective efforts are implemented as part of the l
appraisal,- the team will also recommend improvements to the Emergency Plan where identified weaknesses appear to have their cause in incomplete 1
planning.
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The team leader (and appropriate team members) should meet with plant i
management during the appraisal to discuss any significant findings such that prompt corrective actions can be formulated prior to the exit meeting.
l If major concerns Following the appraisal, there will be an exit intertiew.
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were identified during the appriasal, appropriate corrective actions and l
Licensee commitments will
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possible enforcement actions will be discussed.For the remainder of tne appraisal findings, be obtained where needed.
the licensee will be allowed the opportunity to review the report details l
i and coordinate an integrated corrective action.
i IV. Appraisal Program Procedures A.
Preparation for onsite appraisal i
1.
Document Acquisition and Distribution Before beginning the 2-week preparation period, the Team Leader will obtain copies of the following documents for the facilitiy to be appraised:
Emergency Plan (EP) i-Emergency Plan Implementing Procedures (EPIP)
'Other procedures referenced in the EP or EPIP (Emergency Operating F
l Procedures, Erergency Alarm Procedures, Health. Physics Procedures, Chemistry Procedures, etc...)
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s Technical Specifications (may only need a limited portion, e.g.,
Section 6.0)
Current FSAR (Appropriate sections - e.g. those dealing with analyzed accidents; effluent radiation monitoring instruments; other area or process instruments; etc.
Health Physics Appraisal Report (at least the emergency planning por-tions).
Complete case file relative to emergency preparedness (e.g. inspec-tion reports and resulting outstanding items list; correspondence on exceptions to NRC policy; NUREG-0578, 0737; etc.)
The Team Leader will assure that the documents are distributed to the appropriate team members, and should assign team members their areas of review. An appraisal matrix has been provided in Appendix B to simplify the task of assignment.
2.
Document Review During the 2-week preparation period the team members will; Review the documents distributed by the Team Leader in their assigned areas to identify the tasks crucial to detection, assessment, notifica-tion, and protective action implementation and the conditions that can influence performance of these tasks paying particular attention to areas that would cause under-reaction or over-reaction to the emergency.
Identify the response. individuals who perfom the crucial tasks, Identify the minimum equipment, procedures and decisional aids required to perfom the crucial tasks, Identify any deficiencies in the. emergency plans and procedures (The existence of deficiencies in the emergency plan will not preclude or postpone the onsite appraisal),
Identify any other procedures or documents needed during the site visit and transmit the listing to the Team Leader, and Review the questions in light of this infomation to highlight gaps, thereby identifying "high priority questions."
3.
Logistics At least two weeks prior to the projected onsite appraisal, the Team Leader will assure that plant management has been contacted to arrange for team access, workspace and training for access. This will be confimed by a standard letter sent from the Regonal Director, detailing the schedule for the appraisal, team comparition (by name and affiliation) and other appropriate logistical details.
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'o The Team Leaders must coordinate lodging for the team. The team shall stay at the same location to facilitate coordination and availability for daily meetings.
B.
Onsite Plan Implementation & Bnergency Preparedness Appraisal 1.
Entrance Onsite Upon arrival at the site for the start of the appraisal, an entrance meet-ing should be held with the plant manager and other appropriate onsite and corporate management personnel. The resident inspector, though not a member of the team, should be invited to the meeting. Other than this meeting and the exit, the resident inspector will not be required to partici-pate in the appraisal. The Team Leader must, however, keep him informed of the appraisal findings. During the meeting, licensee personnel should be informed of the overall scope and schedule for the appraisal, the team members should be introduced, and the method of appraisal discussed. The intent is to coordinate the appraisal teams activities with those of the licensee, thereby avoiding unnecessary conflicts or delays. Other areas to be discussed during the entrance include:
Records, procedures and other documents to be reviewed and made avail-able; the need to interview personnel; any special plant considerations that may impact on the appraisal.
A situation ray occur where a licensee will conduct a drill during the appraisal. The Team, Leader should determine, during the entrance, if such will occur.
If so, the licensee should be informed that selected portions of the drill may be observed at the discretion of the Team Leader in partial fulfillment of the walk through portion of the Appraisal Pro-gram 'Section 7.0).
It should be noted that the appraisal team will not observe a full scale joint exercise as part of the onsite appraisal process. This exercise will be evaluated and documented as a separate activity.
2.
Conduct of Appraisal' The Team Leader has the overall lead for this activity and apportions the workload to his team members as he deems necessary. An " Appraisal Matrix" is provided to assist the Team Leader in this task (Appendix B).
Individ-ual team members are not expected to have thorough knowledge of all areas and should be assigned to areas suitable to their expertise. Guidance is provided for tne conduct of each of the seven phases of appraisal, how-ever, reasonable flexibility will be allowed each member in the conduct of the appraisal. Offsite agencies and groups and all shifts of licensee personnel should be contacted. The team should meet daily to review cur-rent status and progress toward meeting the appraisal objective.
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During the onsite portion of the appraisal, infomation relating to identi-fied "high priority" questions (see Section IV.A.2 of this document) must All renaining questions may be be sought to provide a complete picture.
asked to the extent necessary to verify that the information gathered during the review is actually representative of the "as irplemented" condition.
The detailed questions, therefore, should not be viewed as an all inclusive listing of significant items that, if answered, will provide a totally The questions are intended to aid the appraiser in pro of the specific areas of interest and in providing specific questions to serve as directional guidance in conducting the appraisal.
3.
Exit Interview At the conclusion of the appraisal, an exit meeting should be held with Appropriate cor-the most senicr licensee representative for the site.
porate representatives should also be present as should key members of A member or members of the NRC's Regional Office Management, commensurate with the significance of the appraisal f the station staff.
will also attend this meeting.
Except as provided in Section C, the team will prepare a draft appraisal report prior to this exit interview along with the trans-to attend.
mittal letter Appendix A. "Significant Appraisal Deficiency Findings."
During the exit interview, the licensee should be made aware of theCo preliminary appraisal findings.
significant ' deficiencies requiring immediate attention where the level o concern would be equivalent to that necessitating an immediate action Other commitments to Appendix A, "Significant Appraisal Deficiency Findings," will be requested in writing in response to the appraisal packaga letter.
C.
Documentation The following steps are sugges:ed to assure prompt documentation of the res i
of the onsite appraisal.
When the team leader is not from the Regional office which will review the product, an effort should be made by the team to confer with the appropriate regional supervisors on the report.
The report should be completed in first draft fonn while the team is The team leader should assure that team member assignments The drafts are to onsite.
allow time'for writing during the onsite phase.
i be typed with a System 6 typing ball so that the draft can be read 4
Overnight delivery onto System 6 at Headquarters without retyping. service s At the team leader's request, authorization may be given by the Chief. EPLB, to relocate the team to the Regional office durin quarters.
g the second week for the report writing phase, providing a commitment from Regional management is obtained to assure that the team is not diverted to other tasks.
Af ter entry on System 6,^ the draft report will be transmitted to the review will A parallel concurrence Region for review and issuance.
be perfomed in headquarters.
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Transmittal Letter Reference 3 of TI-2515/55 contains a sample transmittal letter. The basic content and structure of this letter are to be used to maintain consistency.
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Briefly summarize the most significant findings in tems of the overall program and explain the importance of these findings.
It is important that these major findings be discussed from the broadest perspective as opposed to individual items which, when combined, lead to the conclusion that a significant weakness or inadequacy exists. Likewise, if no e 4
significant weakness is found, this should be stated.
a.
Appendix A. "Significant Appraisal Deficiency Findings" Identify the major deficiencies in the state of emergency pre-paredness. Generally, this will be a discussion of those major topic headings contained in the appraisal program which were found to exhibit significant weaknesses or inadequacies. These deficiencies are those which, in accordance with 50.54(s)(2),
cause the NRC to find "that the state of emergency preparedness does not provide reasonable assurance that appropriate protective measures can and will be taken in the event.of a radiological i
emergency." It is not intended nor is it necessary to discuss all of the major headings.
Examples of the individual items which fonned the basis for the broader conclusions should be included in the discussion of the significant weaknesses.
Inclusion of all examples is not necessary.
Note: Significant items will be identified with the appropriate sec-tion of the appraisal report and the appropriate regulation (items (1) through (16) of 50.47(b) which are also the A through P standards
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of NUREG-0654, Rev.1). Regulation sections 50.54(s)(2), and 50.47(b) will form the basis for enforcement action for any items not corrected within four months, b.
Appendix B " Notice of Violations" While this is not a compliance inspection, Appendix B, " Notice of Violations" will be used to transmit to the licensee glaring items of non-compliance identified during the appraisal, similar in use to that in the Health Physics Appraisal Program.
c.
Appendix C, "Other Emergency Preparedness Deficiencies" This appendix will contain deficiencies identified in the licensee's emergency plan, which are of lesser significance than Appendix A "Significant Appraisal Findings;" but still require corrective actions.
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Appraisal Report The appraisal report shall consist of at least the three headings listed below.
It shall be given a docket number and transmitted to the PDR and to the licen-i see with the transmittal letter.
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a.
Summa ry: This will briefly list the findings of the appraisal.
It should include the status of any outstanding emergency planning items identified during the Health Physics Appraisal or other inspection.
3 b.
Details Section: This part of the report should be subdivided into the major topic headings which correspond to the numbered sections of the ques-tions in Appendix A of this document, " Basic Program." It is similar to the format used in the documentation of the Health Physics Appraisal program and should include:
Strengths as well as weaknesses A conclusion for each section (major topic heading) as to the ade-quacy or inadequacy of the li'censee's program. One of the following statements may be used to conclude each major report section:
1.
If this portion of the licensee's program is implemented in accordance with the plan and the implementation meets the implementation objective use the following:
Based on the above findings, this portion of the licensee's pro-gram appears to be acceptable.
2.
If weaknesses are found which warrant identification as Appendix A items, use the following:
e Based on the above findings, the following deficiencies must be if corrected to achieve an acceptable program: (summarize specific areas).
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A listing of key persons contacted during the appraisal should be included as an appendix to the report, including individuals from l
outside support agencies. Other plant personnel contacted should be grouped by job tunction (i.e. operators, technicians, security person-E I
nel, etc.) and total numbers in each group should be indicated.
Contractor members of the appraisal team need not sign the report
[i but should be provided a copy of the final draft at the same time it is undergoing management review in the region.
All significant appraisal findings, items of non-compliance, emer-gency plan deficiencies, and any unresolved items, if any, will. be tracked with a unique identifying number in the body of the report using the Regional Outstanding Items List (OIL) System.
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8 c.
Emergency Plan Evaluation If the results of the emergency plan evaluation have not previously I
been transmitted to the licensee, it should be done in this section.
The section should be subdivided into majo.' topic headings which correspond to the planning standards A through P identified in L
NUREG-0654 Revision 1.
The fonnat will be similar to that previously used in previous Safety Evaluation Reports.
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Follow-up of Appraisal Findings Followup will be performed on identified appraisal deficiencies by the Regional Office (or in conjunction with appraisal team members where numerous serious itens were identified). The time frame for followup will be based on the level of significance of the items, the completion dates for corrective action and available resources.
VI. Drills and Exercises
- The full scale joint exercises are not evaluated as part of this Appraisal Program. The excercise observation and evaluation will be documented in a separate report along with FEMA's evaluation of offsite energency response.
VII. References ANSI 3.1 American National Standard for Selection and Training of Nuclear Power Plant Personnel. January 17, 1978.
ANSI 3.7.1 Facilities and Medical Core for On-site Nuclear Power Plant Radiological Emergencies, April 1979.
ANSI 3.7.2 Emergency Core Centers for Nuclear Power Plants, April 1979.
ANSI 3.7.3 Radiological Emergency Preparedness Exercises for Nu' clear Power Plants, April 1979.
ANSI 13.12 Control of Radioactive Surface Contamination on Materials, Equipment, and Facilities to be Released From Uncontrolled Use (0 RAFT) August 1978.
NUREG-0041 Manual of Respiratory Protection Against Airborne Radioactive Materials.
NUREG 0396 State and Local Emergency Plans.
NUREG 0578 TMI-2 Lessons Learned Task Force Status Report and Short-Term Recanmendations, July 1979.
NUREG 0585 TMI-2 Lessons Learned Task Force Final Report, October 1979.
NUREG 0600 Investigation Into the Pfarch 28, 1979 Three Mile sland Accident by Office of Inspection and Enforcement, July 1979.
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1 NUREG 0616 Report to the Director, Office of Inspection and Enforcement on Lessons Learned from Three Mile Island December 1979.
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Pev.1, November 1980.
NUREG,0660 NRC Action Plan Developed as a Result of the THI-2 Accident.
Volunes 1 and 2 Rev. 1. July 1980.
NUREG 0696 Functional Criteria for Emergency Response Facilities.
February 1981.
NUREG 0728 Report to Congress: NRC Incident Response Plan, September 1980.
NUREC 0729 Report to Congress on NRC Emergency Communication, September 1980.
NUREG 0730 Report to Congress on the Acquisition of Reactor Data for the NRC Operations Center, September 1980.
t NUREG 0731 Guidelines for Utility Management Structure and Technical Resources (DRAFT), September 1980.
NUREG 0737 Clarification of TMI Action Plan Requirements, November 1980.
NUREG 75/087 Standard Review Plan for the Review of SAR.
NUREG/CR 0314 An Air Samplin9 System for Evaluating the Thyroid Dose Commitment Due to Fission Products Released from Reactor Containment.
i NUREG/CR 0315 1
Environmental Radiciodine Monitoring to Control Exposure Expected fran containment Release Accidents April 1979.
NUREG/CR 1368 Development of a Checklist for evaluating Maintenance, Test and Calibration Procedures Used in Nuclear Power Plants, May 1980.
i NUREG/CR 1745 Analysis of Techniques for Estimating Evacuation Times for 1
Emergency Planning Zones, November 1980.
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10 CFR 20 Standards for Protection Against Radiation.
10 CFR 50 Domestic Licensing of Production and Utilization Facilities.
10 CFR 73 Physical Protection of Plants and Materials.
1' 10 CFR 1090 DN 76N-0050 Accidental Radioactive Contamination of Human Food and Animal Feeds.
21 CFR 1090 DN 780-0343 Potassium Icdide as a Thyroid Blocking Agent in a Radiation Emergency.
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t id EPA 520/
Manual of Protective Action Guides for Protective Actions 4
1-75-001 for Nuclear Incidents.
f EPA 520/
Evacuation Risks-An Evaluation.
6-74-002
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Reg. Guide 1.8 Personnel Selection and Training (under revision).
I Reg. Guide Onsite Meteorological Programs, February 1972.
l 1.23 Quality Assurance Program Requirements (Operation Rev. 2, l
Reg. Guide 1.33 March 1978.
Instrumentation for Light-Water-Cooled Nuclear Power Plants Reg. Guide to Assess Plant Conditions During and Following an Accident, 1.97 Rev. 2, December 1980.
u Assumptions Used for Evaluating the Potential Radiological Reg. Guide Consequences of a Radioactive Offgas System Failure in a f
Boiling Water Reactor, March 1976.
1.98 Calculation of Annual Doses to Man from Routine Releases Reg. Guide of Reactor Effluents for the Purpose of Evaluating Com-i 1.109 pliance with 10 CFR Part 50, App. I. Rev.1, October 1977.
i Reg. Guide 4.1 Program Monitoring Radioactivity in the Environs of Nuclear Plants, Rev.1. April 1975.
SECY 79-497 Thyroid Protection.
a.
Radiation Protection - Thyroid Blocking.
SECY 80-257 NCRP 29 Exposure to Radiation in an Emergency.
Protection of Thyroid Gland in the Event of Release of NCRP 55 Radioiodine.
l Application of Meteorology to Nuclear Power Plants.
IAEA 29 Management of Persons Accidently Contaminated with Radio-NCRP 65 nuclides.
]
I AEA-CN-39/95 Accident Assessment: Role of the Containment Radiation Monitor.
1 HASL-300 EM Procedures Manual.
ICRP-23 Report of the Task Group on Reference Manual.
Kemeny Commission Report.
i Rogovin Report.
Red Cross Multimedia Standard First Aid - Revision 1978.
14 J
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N-716 Proposed Standard Criteria for Dosimetry.
Meteorology and Atomic Energy, 1968 AEC Fublication.
BNL-21541 High Efficiency Mixed Species Radiofodine Air Sampling Readout j
and Dose Assessment Systen.
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RA8 Technical Position on an Acceptable Radiological Environment !
Monitoring Program. Rcy. 1 November 1979.
4 i
CPG 1-17 Outdoor Warning Systems Guide, March 1980.
Respiratory Protection Devices Manual, American Industrial Hygiene Associa-tion, 1963.
Nuclear Power Plant Emergency Response Plan, AIF, October 1979.
)j.
Letter from H. R. Denton, NRC, to All Operating Plants, "Discussiori of Lessons Learned Short-Tenn Recuirements," dated October 30, 1979.
6
?
Letter from D. G. Eisenhut, NRC, to All Licensees, " Clarification of NRC Requirements for Emergency Response Facilities at Each Site," dated i
April 25, 1980.
i Letter from D. G. Eisenhut, NRC, to All Licensees. " Post-TMI Requirements for the Emergency Operations Facility (Generic Letter 81-10), February 18, 1981.
2 Letter from D. G. Eisenhut, NRC, to All Licensees, No Title, November 13, 1980.
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APPENDIX A BASIC PROGRAM 40 t
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ADEOUAIE SEASE OF EMEHGENCY PREPAREDNESS
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[ GUIDANCE Of PLAN MLETS NUREG 06b4
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EMERGENCY EMERGLNCY 3
AllklNIS IH AllON 1 RAINING &
f ACilalltS &
PROCEDURES ORGAN ZA) ON g
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9 3.0 EMERGENCY PLAN TRAINING / RETRAINING Objective (s)
To verify that the licensee has developed and implement'ed an emergincy plan training program.
To verify that all personnel (even if only a backup) have been trained in accordance with the program.
To evaluate the adequacy of the scope and content of the established program.
Basis Emergency situations precipitate changes in renorting chains, scope and nature of duties, and the perceptions of individuals. When under stress, individuals may revert to established behavior patterns.
These behavioral patterns may be productive or counter productive and random in purpose depending upon the way in which the behavior patterns were. established.
Proper training partially serves to establish acceptable behavior patterns and eliminate randomness of
/
Once desired behavior patterns are established, they must be rein-purpose.
forced and then tested and evaluated under stress to ensure that the desirable beh'avior is sufficiently ingrained ~. A " test" (whether written or a practical j
exercise) will help in making a determination that the individual understands the information he has been presented and is capable of performing in the desired manner. This testing should be against student performance cbjectives j
which comorise a portion of the lesson plan. These performance objectives should define the task to be performed, give the conditions under which it is to be performed, and briefly describe the standards by which performance is to be judged. Testing which addresses only general knowledge when specific 4
knowledge is expected is inadequate. All personnel who may perform a task must be trained and tested even though they may only be a backup. Training should also be provided for those personnel who have no role to play in emerg-i ency response so they will know what they are to do in an emergency.
(
t An adequate training program should not consist solely of classroom instruc-tion, demonstrations of equipment to the group, or using maps or plant drawings l
to point out emergency response duty stations. Rather, the training program should also include hands-on use of equipment and tours of areas since the l
individual may be required to use equipment or go to locations with which he t
is unfamiliar. Historically, emergency plan training has been conducted using a broad range of methods, from simple self-administered reading assignments to lecture / practical exercise combinations. The latter method has proven to be the most effective.
l Licensee training programs must also contain provisions for training the various offsite agencies. Normally these agencies will include the State agency responsible for the planning effort and for protective action decision-making, local -ambulance / rescue services, the offsite medical treatment facility, local fire companies and local emergency planning personnei. The purpose of j
the training should be to ensure mutual understanding of roles, procedures, and interfaces. The licensee should offer the training at times convenient to l
the offsite agency to ensure maximum participation. AlthoJgh licensees can A-3.1
.j not control or require offsite groups to participate in the training, appraisers must assess the capabilities of these groups to provide the degree of support to the licensee that is relied upon and the extent to which they participate i
in the training.
Much of this information should be available from FEMA.If j
not, the appraiser should discuss the topic during contacts with the offsite 1
groups.,
i l
Guidance Obtain a copy of the emergency organization chart and the listing of personnel assigned to the functional areas of emergency activities and the agencies forming a part of the response scheme.
Review the training procedure / training manual description of the training program and compare the content for consistency with the Emergency Plan.
Review lesson plans to verify adequacy of scope and content and consistency with the duties as reflected.in the implementing procedures.
1 Interview instructors to ascertain their background and experience in the 3
areas which they teach.
t l
Review training records and compare attencance listing witn the procedures and list of persons assigned to the emergency organization to verify that all 3
~
required sessions were conducted and all required personnel have been trained.
Review a sampling of tests and test results from each training class to verify that tests were adequate, that they were actually given, and that they measured student performance against the training objectives. Verify that individuals who failed to meet performance objectives have been retrained and passed, or were removed from the emergency organization.
i Interview several individuals assigned to each functional area (onsite and j
corporate) to verify that. training was actually conducted and was of the scope required.
Conta'ct individuais on all shifts. Question individuals in relation to their duties and the procedures and equipment which they would be required.
to use.
Do not have them demonstrate their ability to perform at this time.
This will be accomplished during the last phn e of the appraisal in accordance with Section 7.0.
If a training session is to be conducted, attend a session.
I
(
During interviews with offsite agencies perfomed as part of section 6.0, L
discuss the scope and nature of the training provided and verify that it was presented from their perspective and met the needs of the agencies and persons I
involved.
(Before interviewing offsite agencies the FEMA RAC chairman should be contacted to detennine what information he has relative to training of offsite agencies.
The RAC chairman should be told of the intentions to inter-view offsite agencies and the information provided by him should be used to judge the depth and scope of the interviews).
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TRAINING /
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'ROGR AM IS PROGRAM IMPLEMENTED ADEOUATELY I
ESTABLISHED OCUMENTE A
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3.2.1 l 3.1.1 3.1.2 l 3.1.3 TR AINING.
R ORMED ADEOUATE APPROPRIATE 3 2.2 DOCUMENTED SCOPE &
PERSONS CONTENT INCLUDED INDIVIDU AL S UNDERSTAND AND INCLUSION OF CAN PElIFORM A
FREQUENCY e
i e
tESSON PLANS /
INFORMATION ON DUTIES
/a P 7.2 I
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.I OUTLINES UNUSUAL PLANT 3.1.3.1
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e INSTRUCIORS CONDITIONS IICENSEE ASSIGNED e SURVEILL ANCE PL P SONNE L ATTENDANCE UNDER SIMULATED e STATE DOCUMENTED ACCIDENT ifi7352 e 10 CAL STUDENT PEflFOR-CONDillONS NON-LICENSEE
'e LOCAL SEftVICES SUPPORT e
e DuilES &
SUPPORT PERS f
M ANCE OBJECilVE CONTRACTOOS/ VENDORS 6.1 e
DEFINED RESPONS181LITIES OTHER UTILITIES l
e RED CROSS MULTI-3.1.3.3 STUDENT PERFOR-e MANCE EVALUATED MEDIA FOR FIRST POPULATION A
AfD TEAMS IN EP2
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PROCEDURES FOR e
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i EXPECTED ROLES e
e SIIE ACCESS PilOCEDURE e ONSITE INDIVID.
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e Sul'I ACilVITIES I
I i
NUREG-0654 PLAll/
f REV. 1 PROCE00RE ACCEPT.
IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA CON 4LNIS I
EMERGENCY PLAN TRAINING / RETRAINING G.S ANSI /ANS O.1 3.7.3 i
3.1 Program Established 0.1.a Section 3 0.1.b Does the licensee have a formally 0.2 a.
documented and approved emergency 0.3 plan training / retraining program 0.4.a description (procedure or train-0.4.b ing manual)?
0.4.c 0.4.d b.
Does it include qualification 0.4.e criteria for the individuals 0.4.f selected for assignment to 0.4.g the various functional areas 0.4.h of emergency activity?
0.4.1 0.4.j c.
Are training and retraining 0.5 required at least annually (1 3 months) for licensee personnel assigned to all func-tional areas applicable to the licensee's plans?
4.
i d.
Are the number and designation of the training categories consistent l
with the number and designation of the functional areas of emergency activity in the emergency organization? for example:
Emergency response coordination; Plant systems operation; I
Radiological environmental survey and monitoring; f
l A-3. 4 l
I
i NUREG-0654 PLAN /
~
REV. 1 PROCEDURE ACCEPl.
IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA COMENTS First ald/ rescue; Personnel monitoring; Decontamination; Security and site access control; Repair / corrective actions; Personnel accountability; I
Radiological accident assessment; Communications; i
Radiation protection and in plant
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radiological survey and monitoring; j
Plant chemistry; Radwaste operations; and Technical stpport.
e.
Are training and retraining required 10 CFR 19 at least annually (1 3 months) for general employees (note, the training referred to here is in addition to annual drills and exercises; general employees are those that normally do not have a function assigned by the emergency plan)?
A-1.5 t
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l NUREG-0654 PLAN /
REV. 1 PROCEDURE ACCEPT.
lHPLEMENTATION AREA ELEMENT REFERENCE CRITERIA COMENTS i
l f.
Are training and retraining required at least annually (1 3 months) for licensee augmentation personnel (e.g., corporate)?
g.
Are training and retraining offered to state and local services support organizations and the news medi4 at least annually (1 3 months)?
h.
Where autual aid agreements exist between local agencies such as fire, police, ambulance / rescue.
units, is the training also offered to the other departments who are members of the mutual aid pact?
i.
Is there an approved, formal lesson plan for each category of training?
j.
Do lesson plans have clearly stated student performance objectives.
k.
Do the performance objectives provide a basis for a valid test of the indi-l viduals' ability to perform their assigned emergency tasks?
1.
Are the instructors selected and qualified in accordance with established criteria?
I A-3.6 j
F
O 1
NUREG-0654 PLAN /
REV. 1 PROCEDURE ACCEPT.
lHPLEMENTATION AREA ELEMENT REFERENCE CRITERIA COMENTS Are there provisions for documenting:
m.
the name of individual attendees; the date; lesson title; instructor n.
Do training programs consist of lecture-type classroom instruction and hands-on use of all equipment (including respiratory protection etc.) and procedures which attendees may be expected to,use in responding, to eniergencies.
1 o
Do the training program provide that individuals are walked-through or talked-through their emergency duties, with erroneous performance s
corrected, on-the-spot and additional i
training given and a demonstration of the proper performance provided by the instructor (Note, this " walk-through" is in addition to the drills and exercises required by section 7)?
p.
Does the train'.ig include:
j information on what might be
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expected under unusual plant conditions, e.g., components l
and areas with high radiation levels magnitudes of radiation increases, changed nuclide l
composition, etc.?
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1 NUREG-0654 PLAN /
REV. 1 PROCEDURE ACCEPT.
IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA CON 4ENTS I
discussion of the procedures i
applicable to the functional area a description of the emergency i
organization and the relationship of the functional area to the entire organization; communication; limits of authorities and responsibilities; I
protective action decision making?
q.
Does training of personnel in sur-veillance under accident conditions s
include:
use of equipment; interpretation of results; I
i personnel access control; protective action decision making; special precautions (protective actions) to be implemented?
r.
Does training for individuals assigned to licensee first aid teams include Red Cross Standard First Aid-Multimedia?
A-3.8
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NUREG-0654 PLAN /
I REV. 1 PROCEDURE ACCEPT.
l IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA CCM?EHf5 i.
Does training for hospital personnel',,
s.
j ambulance / rescue, police and fire departments include the procedures for notification, basic radiation l
protection, and their expected roles?
I t.
For those local services support organizations who will enter the site, (fire / ambulance and rescue) does the g
training also include site access procedures and identifica*.lon of the individual in-the onsite emergency organization who will control the organization's support activities?
t u.
Does the training of Ilcensee per-sonnel assigned to the emergency j
organization include pratical exercises and/or tests, without i
coaching, in which each individual 6
demonstrates his ability to perform e
his assigned emergency function under accident conditions (e.g. -
l take readings while wearing a mask or meeting the student performance
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objective set forth in the lesson plan)?
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v.
Does the training of offsite pro-A tective action. decision makers 3
i include the relationship between i
plant conditions and protective measures?
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A-3.9 o
k NUREG-0654.
PLAN /
REV. 1 P?.CCEDURE ACCEPT.
IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA COMMENTS w.
Are there provisions to train members of the emergency organiza-tion in changes to procedures and equipment which occur in the* period between the scheduled training sessions?
x.
Is the method for training personnel in changes to procedures and equip-ment similar to the method used for the basic qualification training prograe (e.g. lesson plans, hands on use of equipment, tests, etc.)?
y.
Are there provisions to train non-licensee augmentation personnel (e.g.,
contractors, HPs, vendors, etc.) upon arrival in response to a request for assistance, prior to their assimila-tion into the emergency organization?
- 3. 2 Program Implementation a.
Do training records indicate that all required training had been com-i pleted in the manner required?
b.
Did discussions with licensee and non-licensee emergency personne.1 assigned to each of the functional areas of emergency activity indicate that the training actually took place?
c.
Was the training content consistent with the content as described in the licensee's records?
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I 4.0 EMERGENCY FACILITIES AND EQUIPMENT l
Objective To verify h t the licensee has emergency facilities and equipment that will allow him m efficiently and effectively respond to the scope of emergencies defined in his plan and procedures.
a
.E Basis a
I The nature of emergency facilities and equipment varies considerably from one licensee to another.
It is often dependent on the design and physical character-istics of the licensee's buildings, site and the number of units operating.
Emergency equipment such as types of instrumentation, sampling media, samplers, etc., are subject to licensee's preferences and budget allowance limitations.
Emergency equipment not only has to be readily available and consistent with the plan and procedures, but its characteristics.must be such that users can accomplish their intended actions arc objectives with the use of the equipment.
1 For example, if the stated objective is to be.able to detect airborne radio-iodine concentratons of at least 1E-07 pCi/cc, the instrument filter media, j
and air samplers and their intrinsic parameters (e.g., instrument sensitivity, 1
retention efficiency of sampling medium, air sampler's flow-rate, etc. ) must be such that detection and measurement can, in fact, te readily and accurately determined. A substantial change in any of the critical parameters, (e.g.,
decrease in detector efficiency, lower medium retention efficiency, change in the flow-rata, etc.) will significantly alter the results, and the objectives of the emorgi:ncy plan and procedures may not be achievable in this area.
j The above considerations require.that all equipment and facilities should be looked into with great care for technical details, to insure that in addition to beir.;g available, they are apable of producing the results demanded by the licensee's emergency plan (
5.:edures.
The scope of such inquiry into technical detail may be limited to emergency 1
i equipment other than that used on a routine basis (e.g., by the health physics i
group) or to equipment that, although used routinely, is in any way modified (e.g., calibrated differently, etc.) for custom use during emergencies.
In the case of radiation survey meters, TLDs, and pocket dosimeters, that are part of emergency kits but included within r:utine health physics activities, A it may be necessary to verify that the calibration procedures are adequate.
I review of sections of the Health Physics Appraisal and recent inspection
-[
report's applicable to these areas should be performed.
The depth of the inquiry into technical detail should also be limited to those 4
3 aspects, judged by the reviewer, to be essential to the objectives of the i
emergency plan and procedures (e.g., it would be inefficimt to verify step-by-step calibration of instrumentation, or whether TLDs contain the substances specified by the supplier, or whether such quantities are within the specifica-tions expected, etc.).
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Licensee checks of operability should cohtain provisions for checks with sources, instructicns of how to perform such tests, and criteria for acceptance i
or rejection of equipment.
Adequacy of airborne radiciodine and particulate detection and measurement systems should consider:
The efficiency of the detector system; The adsorption characteristics of the sampling medium; The retention efficiency of the sampling medium; The air flow rates and sampling time; The determination of amount of radioactivity in ::ampling medium; Calculation of data; Determination of MOL (Minimum Detectable Limit) and the upper limit of f
detection for the system for consistency with required PAGs; Calibration of air sampling equipment and detector system; Effects of high background; Sampling medium protection from rain and snow during and after sampling; Upper range alarm points, and EALs of area and process monitors should be I
consistent with expected high readings during emergencies; Conversion charts, multi point recorder charts and tables should be readily available and easy to read and interpret; 3
Determination as to whether calibrations are based on theoretical models or on empirical data; Whether calibrational models are adequate (e.g., do not assume a line source when in fact the geometry demands a three dimensional source);
Samples of gases and particulates should be representative (e.g., are isokinetic probes used for the main stack sampling of particulates etc?);
Are detectors shielded to prevent interference from other sources of radiation that may co.ifound results; and Equipment input (AC, DC) co. ; stent with use.
Throughout the review, consider the impact of multi-unit operation on the emergency facility and equipment adequacy.
Certain multi-unit sites may use caricon monitors with the readouts in only one of the two control rooms.
A.A 1
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Guidance Select a sampling of records to vrsrify that inventories, maintenance and calibrations are being performed.
Types of equipment should include:
survey instruments; emergency kits; comeunications; area and process radiation monitors,
?
resoiratory orotection eouipment. air samplers; dosimeters, etc.
Inspect effluent monitoring systems, meteorological monitoring systems, process j
monitors specified-in the plan and procedures to verify availability and operability.
Pay particular attention to any common monitors at multi-unit h
sites.
Inspect each generic type of emergency kit and verify accuracy of the inventory, location, operability and serviceability of contents. Operability checks of radiation survey equipment should be performed using appropriate check sources.
(Use the licensee's emergency equipment inventory procedure to perform the verification).
Request a test of the various alarms (evacuation, fire, etc.).
Position individuals at various locations to verify adequacy.
Interview a number of station personnel to verify audibility / visibility of emergency alarms.
Inspect the TSC, OSC, EOF, control room and associated decisional aids (e.g.,
isopleths, procedures, conversion charts, etc.).
Inspect the onsite medical treatment and decontamination facilities.
Visit assembly / reassembly areas.
Inspect licensee vehicles used for emergencies.
P The team may desire or find it necessary to verify the calibration of selected l
emergency instrumentation.
It'may be possible to coordinate the visit of the l
Regional Independent Measurements van to assist in this effort, or to use the R-meter system used in the teletherapy verification program.
This system can be used to establish a known gamma field to check both dose rate instrumentation and dosimeters which are used for emergencies.
Beta calibration sources also shJuld be obtained and taken to the site to verify the beta calibration of beta-gamma emergency instrumentation.
If the team is traveling to the site by automobile, these sources can be carried in the vehicle (appropriately marked as radioactive c>aterials).
If the team is traveling by aircraft, the sources should i
be taken to the site by the van (if it is used) or shipped via truck freight or mailed in care of the resident inspector, prior to the appraisal visit rather than carrying them aboard commercial aircraft or in personal luggage".
"Before transporting or sending radioactive standards to the licensee's site, team
)
members must be aware of provisions of governing regulations:
l 1.
U.S. Postal Publication #6 on Radioactive Materials (December 1975).
i 2.
IE Temporary Instruction #TI 2800/3.
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In the event the Regional Laboratory van cannot be scheduled to visit the site
'j during the appraisal, the team leader may wish to maxe arrangements to have J
the calibration of emergency instrumentation verified during its next scheduled C
visit.
It may also be appropriate for the appraisal team to use reference standards available from the licensee, provided these standards are traceable and corrected for decay.
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- 0654, Rev. 1 PLAN / PROCEDURE ACCEPT.
IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA COMMENTS upon for emergency detection, classification and assessment 1
in place and operable?
f b.
Were all such monitor readouts i
located in the control room?
l-i c.
Are readouts readily observable?
I 4.2.1.4 Meteorological Instrumentation H.5.a NUREG 0654, j
H.8 Appx 2 Appendix 2 E.4.3 E.4.g
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a.
Do meteorological instruments P
provide the basic parameters required by the emergency plan and procedures?
b.
Are all instruments (e.g.
sensers and readouts) operable and calibrated?
l c.
Are meterological instrument j
readouts located in the control room and in other locations (e.g. EOF, TSC) so that they are readily accessible to the users? (If a single system of l
readouts is used for a multi-unit site, readout data should be readily accessible to both control rooms.)
i A-4.30 j
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.I NUREG
- 0654, Rev. 1 PLAN / PROCEDURE ACCEPT.
IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA COMMENTS d.
Are there provision for obtaining meteorological l
information for followup i
messages from the plant to offsite authorities (see Section 5.4.1 for inter-facing area).
e.
Are there provisions for obtaining representative, real time meteorological information for dose pro-jections and protective action decision making if-the onsite primary system becomes inoperable?
f.
Is equipment installed to inform the licensee that tornadoes, hurricanes or high winds have or may occur at or near the site?
I g.
Is there adequate assurance that the data unavailability goals can be obtained?
h.
Are operability checks per-formed on an adequate frequency? (See Section
~
5.5.1 for interfacing.)
i.
Are these checks and calibra-tions adequate?
l A-4.31
f s
HUREG
}l
- 0654, Rev. 1 PLAN / PROCEDURE ACCEPT.
IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA COMMLNIS J.
Is inoperable instrumentation detectable and promptly a
restored?
fi k.
Are there written procedures for calibration? (See Section 5.5.1)
(
1.
Are meteorological data / pro-jections appropriately inte-grated into radiological assessment / projection pro-cedures? (See section 5.4.2 for interface area.)
i 4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection NUREG-0041 a.
Are self contained breathing (SCBA) devices reserved for emergency use?
b.
Is there a capability for refilling SCBA devices, and 5
would this equipment be useable under conditions in which the internal areas of the plant have high airborne / direct levels of radiation?
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5.0 PROCEDURES
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Objective (s)
To verify that the licensee has adequate procedures for implementing the Emergency Plan.
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To evaluata the adequacy of the useability, scope and content of the procedures.
'1 Basis The scope of procedures which implement the emergency plan should address the ac tions to be taken to maintain a constant state of reaainess as well as the acttans to be taken during emergencies.
In this regard, Administrative, Maintenance, Health Physics, Chemistry, and various other classes of station proceduras can have applicability to implementation of tne emergency plan.
Where existing procedures are applicable to aspects of emergency plan imple-mentation, a simple reference is adequate. There is no need to reiterate all information in the controlling procedure.
For example, in a precedure governing the inventory and maintenance of emergency equipment, certain of the items may l
be calibrated using standard procedures.
It is suffic'ient for the controlling procedure to state that the instruments will be calibrated in accordance with the procedure. The reference should, however, be specific.
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Procedures should not have been developed in a vacuum.
Input from users and field testing are important elements.
During interviews with personnel, discuss their impressions relative to the useability of procedures.
The procedural control should start with the identification of standard condi-tions and follow these conditons through the identification as an emergency condition, classification, control and remission of the condition.
In aedition,
- j if the conditions require offsite assistance or create a potential or real 7
I hazard to the public, the procedures must insure the prompt notification of i
offsite authorities. The notification must verify receipt of the communication from the first notification to the termination of the emergency.
It should be possible then to take an off-standard condition and follow it through the procedural control to its resolution. This procedural control will involve whatever personnel resources and assistance agencies are required by the condition.
It should be clear that procedural control does not neces-sarily mean doing every action by the numbers, however, it should prnvide the necessary guidance to insure that the necessary information is available, recorded and transmitted to allow analyses and judgements to be made and the necessary emergency actions implemented.
Implementing instructions describe what and when various actions must be performed.
In essence, these instructions are planned immediate response actions which are required for each emergency condition.
Implementing proced-ures describe how and by whom the actions are to be performed.
These detailed procedures are developed for implementing specific tasks or methods identified in the implementing instructions.
Their scope, content and perspective should reflect these two separate, yet related, purposes.
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s Energency Action levels (EALs) are:
specific installed plant instru.tentation readings; radiological dose rates or orojected doses; ano specific contamination levels of airborne, waterborne or surface-deposited concentrations of radioactive materials.
They are thresholds for initiating specific emergency measures such as declaration of a particular class of emergency, implementation of a notification procedure or recommendation or implementation of a particular protective action.
Specific EALs based on installed plant instrumentation are necessary to ensure prompt detection of actual or potential emergencies and the timely implementa-tion of the emergency plan.
EALs of this type may appear in eithe-the Emergency Operating procedures (EOPs) or in the Emergency Plan Implementing Procedures related to the emergency classes covered by the licensee's emergency plan, or in both places.
Licenste's are required by RG 1.33 to develop E0Ps for specific types of accidents.
Implementation of the E0Ps are precipitated by the operators receiving specific instrument indications or combinations of indications.
Consequently, these instrument indications should result in implementation of the E0Ps and, where the emergency plan so indicates, the subsequent declaration of an emergency under the emergency plan.
These instrument indications are, therefore, EALs and must be related to implementation of the emergency plan and the declaration of a particular class of emergency in the following ways:
a.
Key instrument responses should be listed in the " Action Level Section" of the appropriate Emergency Plan Implementing Instruction applicable to the particular class of emergency; and b.
The instrument responses should also be tied to the E0Ps which either directs the shift supervisor to declare a particular class of emergency or refers him to the appropriate Emergency Plan Implementing Instruction.
Both the Implementing Instructions and Procedures must be prioritized to ensure that "offsite authorities will be notified within 15 minutes follow-ing a serious initiating event.
In addition to the instelled instrument readings witch are related to the E0Ps, there are other instruments whose responses should be considered as EALs for declaration of a particular class of emergency (e.g. ARMS and PRMs).
As in the case of installed instrument responses which result in the implementation of a particular E0P, responses on ARMS and PRMs result in the implementation of Alarm Response or Abnormal Event Procedures.
Consequently, ARM and PRM instrument responses should be directly related to a particular class of emergency in the same ways that other instrument readings were. Also other initiating conditions such as sample results, offsite dose measurements, and severe weather conditions should be related to the declaration of specific emergency classes.
Supplementary procedures are those which govern the maintenance of the response cacability.
They may be associated with the implementing procedures or consist of a combination of administrative, HP, maintenance or other procedures.
Regardless of their designatien, certain minimal tasks must be covered.
i-Guidance Compare the listing of procedures from the Appendix of the Emergency Plan witn j
the listing of procedures provided by the licensee to verify completeness of
- both, Review the procedures in comparison with Section 5.0 and the licensee's defini-s tion of the emergency organization.
,I Verify that the procedures were reviewed and approved in accordance with the licensee's technical specifications.
Verify telephone numbers (a sampling) to verify they are current.
Compare the hardware and facility locations and specifications 4 th those actually in place. This may be done during a site tour, in conjunction with l
the inventory of equipment, or during the walk-throughs.
l Verify that copies of the plan and procedures have been distributed in accordance j
with the approved distribution list.
l Verify that procedural actions properly mesh, particularly with respect to personnel assignments, time sequences, and locations.
Verify that action statements are explicit and listed separately.
Verify that prerequisites, precautions, and limitations are indicated before the applicable action statements.
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NUREG 0654 PLAN ACCEPT.
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IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA COMMLN15 r
A General pubitc, including transients and persons at recreational facilities?
d.
Are the notification action levels consistent with 10 CFR 50.72 and NUREG 0654, Appendix I?
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e.
Are planned messages, announcements and alares used for initial notifications?
f.
Is the content of these messages included j
in the relevant procedure?
g.
Does the notificat.lon procedure contain a listing of all persons and agencies who are included in the response scheme and the means to be used to make contact?
h.
Where a telephone is to be used, are the telephone numbers listed?
1.
Is there an authentication scheme for initial notifications to offsite authorities?
5.4.2 Assessment Actions 1.2 P.J.
1.3a a.
Is there an overall procedure which 1.3b orchestrates the implementation of 1.4 the accident assessment scheme 1.5 (operational and radiological) for 1.6 gathering information and data upon 1.10 which to base decisions to escalate, J.7 de-escalate, take corrective actions H.4 or recommend protective actions onsite and offsite?
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0654 PLAN ACCEPT.
r IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA COMMENTS b.
Is the procedure written for use by the Individual assigned overall responsi-l bility for directing the radiological assessment program?
J Does the procedure identify the priority c.
system and sources of information avall-able, to include area and process radia-tion monitor readings, meteorological instruments (and a backup source), in plant radiation survey teams, offsite radiation survey teams, plant chemistry, and plant operating parameters, to include:
The source term of release of radioactive material; The magnitude and duration of the releases of radioactive materials; and, 4
The magnitude of any resulting con-tamination, both onsite and offsite?
d.
Are action levels and protective action j
guides specified which will be used by assessment personnel as a basis for considering or initiating emergency measures to terminate, or mitigate the
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actual or projected consequences determined from the assessment process?
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e.
Is there a means, based on installed control room instrumentation, for
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initially projecting exposures or t
exposure rates to the whole body j
and thyroid of individuals located
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within the plume exposure Emergency I'1anning Zone and personnel onsite?
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.s NUREG 0654 PLAN ACCEPT.
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IMPLEMENTATION AREA ELLMENT REFERENCE CRilERIA COMMENTS I
f.
Are there provisions for determining the containment source term using the containment monitor and containment air sampling?
g.
Are there provisions for making initial' dose projections in the event instaIIed control room instru-mentation is offscale or inoperable?
h.
Are there provisions for immediate notification of state and local agencies in the event initial assess-ment actions indicate an actual or potential exposure to the whole body or thyroid of persons in the plume exposure EPZ in excess of the lower limits of the EPA protective action guides (applicable guides shall be 4
those for the child.)
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Are there provisions for trend analysis of assessment data?
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j.
Are there provisions for continuous update of assessment information to those offsite agencies responsible for implementing assessment and protective actions in behalf of the general population?
k.
Is there a description of or reference to the data required from the radiolog-ical environmental monitoring program including TLos, soll, vegetation, animal i
feed, etc., and a reference to the procedures to be implemented?
n. r.
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NUREG i
lHPLEMENTATION AREA ELEMENT REFERENCE CRITERIA COMMIN15 0654 PLAN ACCEPT.
'l 1.
Do the procedures include provisions for using data from area and process radiation monitors and in plant surveys for assessment under accident conditions?
m.
Does the licensee have interin methods 4
(e.g., use of portable instrumentation or I
calculational methods) for estimating high level releases?
5.4.2.1 Offsite Radiological Surveys H.12 P.J.
I.7 a.
Are the methods and equip-K.l.c ment to be used to perform emergency offsite radio-logical surveys specified?
b.
Is the procedure written from the viewpoint of the person performing the actual survey?
c.
Are prepositioned survey points or locations used to determine precise location where measurements are made within the plume EPZ?
d.
If not, what method is used to determine where measure-ments are made?
e.
Is this system consistant with State and local offsite monitoring requirements?
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SECTION 6.0 COORDINATION WITH OFFSITE GROUPS 1
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i 6.0 COORDINATION WITH OFFSITE GROUPS Objective 4
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To verify that the licensee has developed and implemented an adequate program for coordinating emergency planning and response activities with non-licensee i
groups and persons.
Basis If onsite aspects of a licensee's emergency response are implemented properly, l
but not adequately coordinated with offsite groups, the ultimate effectiveness of the response may be adversely affected. Consequently, there is a need for licensee's to coordinate their response activities with key offsite groups before and during an emergency.
The generic groupings of offsite groups that should be coordinated will fall into the following categories:
Federal government State government Local government Local services support (fire, ambulance / rescue, medical treatment facility, physicians)
Contractors / vendors (NSSS, fuel, environmental monitoring, etc.)
Other utilities Newsmedia General public i
The specitic groups involved within each category will vary depending upon the i
site.
For example, a site located near a major airport or waterway should coordinate with the FAA and Coast Guard. A site which has a railroad line crossing the owner controlled area or passing nearby should coordinate with the railroad company, 'especially if trains coyld block ingress or egress of the site.
Each of the above categories have different coordination needs based on their role.
Those which directly support implementation of aspects of the licensee's plan have needs similar to members of the licensee's emergency organization.
They should be familiar with the licensee's site, access procedures, their roles, limits on their authorities and the hazards involved in fulfilling their role.
The groups normally falling into this category are local services support and contractors.
Other groups need a more ger.eral understanding of the licensee's entire plan but a more detailed understanding of the licensee's assessment methoos, protec-tive action decision making scheme, communication / notification methods, sources and nature of information that will be available, and accident consequences.
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These groups normally include the state and local governmental agencies respon-g sible for accident assessment and implementation of protective actions in g
behalf of the public.
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,i The newsmedia and general public also have need for coordination of their j
activities.
This is best accomplished before an emergency rather than during.
J A basic understanding of where information will be provided and general roles d
and actions are important.
Guidance
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Compile a listing of all agencies and groups listed in the Emergency Plan and procedures who are not licensee employees.
4 Discuss the role of each agency and group with the EPC or other responsible Ifcensee individual.
Interview responsible individuals from each agency (in person or by telephone) and verify that training has been provided (See Section 3.0 questions).
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verify that the ifcensee has provided the agency with current relevant proced-
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ures and training that had been agreed to.
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Verify that the plan and procedures of the licensee and.offsite agencies mesh and that the agency's understanding of its role matches the licensee expectation o
as described in the plan and procedures.
If the licensee has provided equipment to the agency which the licensee is responsible for maintaining (e.g., offsite medical treatment facility, voice and data communication systems, portable radiological monitors),* inventory the equipment and verify operability.
dj Verify that the licensee has met all commitments to offsite agencies and p
groups to their satisfaction.
a Verify the agreement / contracts between the licensee and the various offsite groups are current and wil'1 be honored by the agencies.
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HUREG 0654 PLAN ACCEPT.
IMPLEMENTA110N AREA ELEMENT REFERENCE CRITERIA COMHLNTS C00RDINAT10N WITH OFFSITE GROUPS
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6.1 Offsite Agencies A.3 P. J.
B.9 Did each agency representative express E.1 a.
an understanding of its responsibilities E.3 and procedures in response to an emergency E.4.a-n at the licensee's facility that was L.1 consistent with the agreement and licensee L.4 procedures and the expectations of both parties?
b.
Has the licensee contacted these agencies either for the purpose of drills, excercles (See Sections 7.0 and 5.5.2) and training (See Section 3.0)?
Were the agencies having emergency response c.
roles within the EPZ provided with controlled copies of the licensee's plan and procedures in accordance with the plan and procedure distribution list? (See Section 5.5.3) d.
Did each agency representative interviewed express satisfaction with the coordination efforts of the licensee in relation to:
Notifications; Frequency and nature of training provided; Routine planning information exchange?
e.
Are the licensee's protective action recommendations consistent with those of the offsite agencies?
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Had the key offsite agencies reviewed the Emergency Actions to be taken for each esegency class and associated recommendations?
g.
Are the agreements / contracts between the licensee and the varfous offsite groups current?
h.
Will the groups honor the agreements?
6.2 General Pubitc G.1 P.J G.2 s
a.
Does the utility provide for dissemina-G.5 tion of emergency planning information to the pubile within the plume exposure EPZ, including the transient population?
b.
Is emergency action information coordinated with State and local agencies?
c.
Is information updated and disseminated at least annually?
d.
Does the information provided to the pubile tell how they will be notified and what their actions should be in the event of an emergency?
e.
Does this public information include accurate, understandable information about radiation?
f.
Ilow is this dissemination accomplished?
For example, information in the telephone book, information in utility bills, posting in public places, etc.
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NUREG D654 PLAN ACCEPT.
IMPLEMENTAll0N AREA ELEMENT REFERENCE CRITERIA CDHMENTS
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Is the information ln a form that is likely to be available in a residence during an emergency.
h.
Is the information in a form that is likely to be available and observable in public areas (e.g., recreation areas)?
i.
Does the utility provide a contact for additional information?
6.3 News Media G.5 i
a.
Does the utility have a program for familiarizing the news media with:
emergency plans; points of contact for release of public information; space allocated for their use; information about radiation?
normal plant operation versus accident operation; i
accident sequences.
h.
Is the program conducted annually?
c.
Has the program been conducted at least once?
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SECTION 7.0 1
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ORILLS, EXERCISES AND WALK-THROUGH e
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7.0 ORILLS/ EXERCISES AND WALK THROUGH Objectives To verify that the licensee has implemented the drill / exercise program.
To verify that the licensee's emergency organization, using the resources available at the site, is capable of performing the sequence of crucial tasks necessary to detect an amargency, assess the consequences, notify key licensee and non-licensee personnel and groups, make protective action decisions, and
.take onsite or recommend offsite protective actions.
8 asis As discussed in Section 3.0, the truest test of training adequacy occurs when an individual is under stress in conditions which approximate those anticipated to exist when a certain type performance is expected.
Training adequacy is one of several areas to be evaluated through the conduct of drills and exercises.
Other areas to be evaluated concurrently include the adequacy of procedures, facilities and equipment. When properly conducted and observed, drills and k
exercises are an important indicator of the potential effectiveness of a
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Itcensee's emergency response program. Certain licensees may conduct drills and exercises which amount to little more than " stage plays." Participants are aware of the date, time, scenario content, and may even be pre-assigned to a specific function well in advance.
The drills and exercises may be scheduled to take place at times when the response will be unencumoered by a full daylight compliment of workers, thereby not providing an adequate picture of the account-ability provisions.
Exercise scenarios may also be written which do not require I
an emergency response in emergency functional areas which are not addressed or are weak in the licensee's preparedness program.
Consequently, when reviewing drills and exercises which have been conducted, the reviewer should be aware that drills and exercises can be structured to avoid the detection of problems.
Proper observation of drills and exercises can indicate significant weaknesses.
The value of the observations can be seriously questioned, however, if the licensee fails.to consider participant comments or to promptly evaluate and correct noted deficiences. The reviewer may face a situation where a Itcensee claims that drills / exercises constitute training and therefore there is no need for a clearly defined training program.
It must be remembered that some training is one of the benefits to be derived from conducting drills and exercises. Embers of the emergency organization must be trained in basic skills and knowledge prior to participating in drills. Otherwise, observed problems are too easily attributed to faulty training when, in fact, the problems may have their origin in faulty procedures, equipment, and facilities.
The individual's lack of training simply " masks" the root problem.
Although the reviewer's findings cased on the first six sections may indicate i
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that all portions of the emergency plan are in place, this alone will not provide adequate assurance that the implementation of the plan will be effective in practice. Consequently, the final phase of the implementation appraisal must involve first-hand observation of individuals actually performing tasks which they would be assigned during an emergency, using procedures and equipment that are available.
During these walk-throughs, osbervation of and discussion with the demonstrator will assist in confirming or correcting the reviewers t
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preliminary findings. Due to the fact that walk-throughs will include frequent questioning of participants by the appraiser, no attempt should be made to
" time" the beginning to end sequence.
Smaller segments (tasks), however, i
should be timed to provide the reviewer with a general feel for the relative smoothness and timeliness with which tasks are performed. The appraiser should be aware that his presence may bias an individual's performance both f,
positively and negatively. As a result, using the walk-through method may not permit the reveiwer to accurately evaluate specific time criteria to be met by l
the licensee's plan. The reviewers must use their best judgement in tne determination.
The time aspects will be reviewed again during the joint NRC/ FEMA exercise observation.
The reviewer should limit his findings to the more obvious areas related to adequacy of training, facilities, equicment and procedures and ensure there are no major imoediments to effective imolementa-tion of critical tasks.
i The reviewer must evaluate the individual's performance in comparison with the i
established response scheme and not limit himself to a subjective impression j
of the adequacy of the individua M performance.
For example, an individual I
may appear to meet the objective of a task, yet have used methods and equipment l
entirely different from those prescibed by the plan and procedures.
The i
reasons for his acti.ons must be investigated thoroughly to reveal the cause.
Coordination with plant management is vital prior to conducting these walk-throughs. Management must be informed of the specific scope and nature.
Guidance Review records of drills conducted to verify that the required types and numbers have been held per the procedure.
j Verify that drill identified improvements have been evaluated by management and corrections implemented.
Discuss the drills, with several participants, including representatives of any offsite agency that participated.
Contact plant management and coordinate the scope of the employee's involvement in preparation for walk-throughs.
t Select an accident scenario falling into the General E.nergency category (use general emergency EALs).
Review the appropriate emergency, alarm response and abnormal occurrence procedures and the EPIPs so that cue events will be in the context of the EALs applicable to the particular plan and procedures.
EMERGENCY PLANNING (WALKTHROUGH GU10ANCE)
Walk-throughs involve first hand observation of selected individuals in selec-ted tasks within the emergency response.
Such tasks involve:
the handling of equipment, interpretation of instrumentation, application of proper conversion
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4 fai: tors, following procedures, and awareness of information flow patterns related to the specific task.
Walk-throughs should be conducted within the last half of the on-site appraisal and, if possible, should cover all shifts.
Walk-throughs may require simultaneous observation by more than one ooserver in order to follow the logical causal chain of responses and the resulting flow of information and data relay (e.g., one cbserver may be located in the control room following EALs, emergency classification aspects, while another may be located in the EOF to observe the actions of off-site monitoring teams or other action that would ensue as a logical consequence from specific emergency response cues.)
EXAMPLE:
Pre-requisite - Site's Emergency Plan and Procedures specified that i
the Shift Supervisor would detect and classify emergencies based on i
certain EALs and that initial assessment is left to the Health Physics technician on shift.
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Procedure - Observer goes to Control Room and requests to talk to l
Shift Supervisor (55); advises him that he would like to interview
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his concerning his emergency response duties) requests him to consider l
l a certain set of conditions, assume certain EALs, and invites him to talk about his actions and go through the motions,.but without disturbing the normal operation of the plant.
He may emchasize that whatever the outcome of his actions, they will not reflect on his individual abilities and that a feeling for training, procedure adequacy and other interrelated factors are being ascertained.
For example, the observer may say that the Main Stack Gaseous Monitor is l
found to be reading 900 thousand counts per second, and that other monitors indicate that a gaseous release to the environment may have.
i occurred. Once the SS has identified tne monitor, he may use the i
same in conjunction with other indications to classify the type of emergency and that he would turn his attention to plant stabilization as well as notification of certain on-site personnel, such as the health physics technician and that it would be up to him to interpret i
the data and make an initial dose assessment estimate. At this l
point, the observer may request the SS to call the health physics i
technician to come to the Control Room to talk to the observer concerning emergency response.
The observer will then explain l
briefly his intent, and request the technician to describe his i
actions in the event the monitor mentioned was reading 900 thousand cps.
The health physics Technician may or may not know how to l
convert the data to release rate and to perform adequate dose pro-jections.
If he does not, the observer would take note and then will provide him with data and ask what he would do with the data.
If he does not know, the observer could suggest that he proceed according to procedure (if in this case, he is supposed to give the data to the SS, the observer then wait 1d ask the SS what he would do with the data, who he would notify and when; what other actions he would take; etc.
If the following logical action is an off-site survey, the observer may request tnat the SS explain how he would go about selecting and notifying those who would perform the survey.
The observer may select to terminate tnis part of the walk-through a-7 1 L.
y at this time, or alternatively he may have another observer positioned at the EOF to observe the actions of the monitoring team.
(Note:
l There is no need for timing response at this time. The follow up action could be observed later during the day.)
Observers could request that certain selected individuals from the t
Emergency Call List be assigned to the EOF to be interviewed by the f
appraiser. Once the appraiser briefs the persons involved on what is expected from them and why, he would determine whether they have j
been trained to perform this task, and their awareness of their functions, their relationships with other points of the emergency organization from whom would they expect to receive directions, where they would take the data, etc.
The appraisers would observe the use of procedures and equipment, j
means of transportation of the survey team, and logistics related to the perfonnance of the surveys. Finally, he would inquire about l
where the information would go, as well as records of surveys, etc.
Walk-throughs should be designed in such a manner that normal plant operation and activities are not disturbed.
The distinguishing character-istic is a " low key" approach, as contrasted with more formal exercises and drills. The main purpose of the walk-through is to ascertain the response efficiency of selected key emergency personnel using actual equipment and procedures.
The individual performance would be taken more as a reflection of training than personal competence or lack of it.
Walk-throughs should be designed and carried out so that they allow simultaneous testing of organizational factors, equipment, procedures, and training.
ORGANIZATIONAL: Verify whether elements of the emergency organization are properly (e.g., consistently) correlated with the expected response to a specific task.
EQUIPMENT AND FACILITIES:
Ascertain whether the equipment (e.g., instru-mentation) used in relation to the response is adequate to provide the desired output, etc.
PROCEDURES:
Determine whether the procedures are clear, coherent, timely and useful and in reality test the same.
TRAINING:
To verify that the individual was adequately trained to perform the specific task demanded by his position in the emergency response organization as related to the task in hand; whether he was aware of what was expected'from him; how to do the task expected from him; and whether he knew what information was relevant, in what form (e.g., units) and where this information should be transmitted.
ADDITIONAL: Walk-throughs should consider strategies for multiple unit sites and augmentation of the emergency organization.
A-7.4
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Review the appropriate emergency, alarm response and abnormal oc urrence pro-cedures and the EPIPs so that cue events will be in the context of the EALs applicable to the particular plan and procedures.
On the daylight shift and during at least one backshift poeferably both backshifts),
l walk through the following tasks:
)
1.
Emergency detection (use EALs as cue events).
2.
Emergency classification.
3.
Notifications (NRC, State, licensee emergency organization).
4.
Oose calculations (with monitors operable and inoperable).
5.
Assessment actions.
a.
Primary coolant sampling and analysis.
b.
Containment sampling and analysis, c.
In plant radiofodine sampling and analysis, d.
Offsite environmental sampling and analysis, e.
Potential loss of containment.
6.
Protective action decision making.
7.
Operation of emergency equipment.
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n 7
7.0 DRILLS, EXERC15ES 4
& WALK-THROUGHS A
T I 7.1 17.2 PROGHAM PROCEDURE WALK THRU 2,j.4 6.6 IMPLEMENTED EQUATE OBSERVATION 2.2.
l 7.2.1 l 7.2.3 7.2.6 l7.27 l7.29 EMERGENCY POST-ACCIDENT IN PLAN 1 NOTIFICATION PHOTECTIVE ACTION DETECTION SAMPLING &
SAMPLING &
DECISIONMAKING ANALYSIS ANALYSIS 7.2.2 7.2.4 7.2.6 7.2.8 EMERGENCY DOSE CONTAINMENT AIR OFFSITE CLASSIFICATION CALCULATIONS S AMPLING &
ENVIRONMENTAL ANALYSIS SAMPLING &
ANAlyglS e
s t
5 NUREG 0654 PLAN ACCEPT.
IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA C00MENTS DRILLS AND EXERCISES SECil0N "N" Appendix E SLCTION F 7.1 Program laplementation a.
Have all drills and exercises required by the plan and procedures been conducted?
b.
Were they conducted in accordance with the established procedure?
c.
Have drill-identified improvement items been resolved?
d.
If not, are they receiving priority attention commensurate with their importance?
e.
Were drills coordinated with offsite agencies and groups to include their participation and consents?
- 7. 2 Walk-lhrough Observation P.J.
a.
Has the capability been demonstrated
-to notify responsible state and local governmental agencies of the appropriate protective actions within 15 minutes of discovery of the initiating events?
b.
Did the observed individuals demonstrite the basic skills and knowledge necessary to perfore the assigned tasks (s)?
c.
Were the equipment and facilities specified in the procedure used to complete the observed tasks?
A-7.7
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i NJREG 0654 PLAN ACCEPT.
IMPLEMENTATION AREA ELEMENT REFERENCE CRITERIA CO M NTS d.
Were the equipment and facilities operable and adequate?
e.
Were the procedures understandable to the user, up-to-date and complete?
f.
Did you observe any impediments to timely and effective performance of the following:
1)
Emergency detection; (EAL Recognition) 2)
Energency classification; 3)
Notifications; a)
NRC b)
State government c)
Local government d)
Licensee site organization e)
Licensee augmentation organization 4)
Dose calculations; a)
Monitors operable b)
Monitors inoperable c)
Field survey results 5)
Post Accident coolant sampling and analysis (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> standard);
A-1.8 i
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l 7
NUREG 0654 PLAN ACCEPT.
IMPLEMENTATION AREA ELEMENT REFERENCE CR11ERIA C0PetEN15 i
6)
Containment air sampling and analysis
{
(3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> standard);
7)
Stack effluent sampling and analysis (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> standard);
8)
Liquid effluent saapilng and analysis (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> standard);
9)
In plant radiolodine saapilng and analysis (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> standard);
- 10) Oftsite environmental saapilng and analysis; a)
Noble gas b)
Radiciodine c)
Particulate d)
Contamination
- 11) Protective Action decision making?
8 A-7.9 l
1