ML20198K005

Summary of 981112-13 Meeting with Industry Representatives in Washington,Dc Re Development of Performance Measures to Be Used by NRC to Aid in Assessing Emergency Preparedness at Npps.List of Meeting Attendees & Meeting Handouts Encl

ML20198K005
Person / Time
Issue date:	12/08/1998
From:	Sullivan R NRC (Affiliation Not Assigned)
To:	Baranawsky P NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
References
PROJECT-689 NUDOCS 9812300320
Download: ML20198K005 (29)

Text

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O cth 91 UNITED STATES p

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066 4001 December W, 1993' MEMORANDUM TO: Patrick W. Baranawsky, Chief Reliability and Risk Assessment Branch Safety Program Division Office for Analysis and Evaluation of Operational Data FROM:

Randolph L. Sullivan, EP Specialist h

Emergency Preparedness and Environrnenta?.

Health Physics Section Emergency Preparedness and Radiation Protection Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF NOVEMBER 12, & 13,1998, PUBLIC MEETING REGARDING EMERGENCY PREPAREDNESS PERFORMANCE MEASURES On November 12 & 13,1998, representative 7 of the nuclear industry met with representatives of the Nuclear Regulatory Commission (NRC) at the offices of the Nuclear Energy Institute in Washington, DC. Attachment 1 provides a list of meeting attendees.

j The purpose of the meeting was to discuss the development of performance measures to be used by NRC to aid in assessing emergency preparedness at operating nuclear plants. The handouts from the meeting are included as Attachment 2.

The following topics and actions were discussed at the meeting:

The group discussed the process to develop Emergency Preparedness (EP)

Performance Indicators (Pis).

The group discussed the handout on the draft NRC document on EP Pls. Comments were provided and discussed. NRC stated that the EP Comerstone document would be revised and available for the next meeting.

i Action:

NRC staff to revise document to reflect insights gained and be prepared to discuss it at the next meeting (scheduled for November 19,1998).

The agenda for the next meeting (scheduled for November 19, W98) was discussed.

The group discussed' the proposed thresholds for the Pls. There was general consensus on the thresholds provided. Copies of the handout of the analysis documents were provided.

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f) 2 The possibility of conducting a workshop on the implementation of the PI process was discussed. A proposed schedule and content were discussed, but no commitment was made to hold the workshop.

Project No. 689 Attachments: As stated cc w/att: See next page DISTRIBUTION: See attached page DOCUMENT NAME: G:\\MTGNOV12.WPD n

PEq;Rh (A@'RB OFFICE:

PERB/NRR.g RSULLidkd hR Bh NAME:

MAN DATE:

12/ [/98 12/f /98 12/f /98 OFFICIAL RECORD COPY

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2-1 The possibility of conducting a workshop on the implementation of the PI process was

- discussed.. A proposed schedule and content were discussed, but no commitment was j

made to hold the workshop.

Project No. 689 Attachments: As stated cc w/att: See next page

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Djstribution: Mtg. Summary w/ NEl re EP Performance Measures Dated Neombor A.

1498 Hard Cooy PUBLIC PERB R/F OGC ACRS RSullivan EMail SCol' ins /FMiraglia BSheron BBoger JRoe DMatthews CMiller B7.alcman RSullivan FKantor SRoudier SMagruder GTracy, EDO AMadison

4 Nuclear Energy Institute Project No. 689 cc:

Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy Institute Suite 400 Suite 400 1776 i Street, NW 1776 l Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineering, Inc.

Suite 400 12300 Twinbrook Parkway, Suite 330 1776 i Street, NW Rockville, Maryland 20852 Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708 i

Mr. Anthony Pietrangelo, Director Licensing Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advar.ud Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708

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ATTACHMENT 1 i-I

.I NRC PUBLIC MEETING ON EP PERFORMANCE MEASURES i

11/12 & 13/98 List of Attendees i

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Name Oraanization l

A. Nelson NEl l

B. McBride VEPCo R. Sullivan NRC/NRR F. Kantor NRC/NRR I-S. Roudier NRC/NRR i

R. Lewis Lewis Group i

D. Miller PSE&G l

[

'M. Vonk CECO j

'D. Purkey NUS i

C. Anderson SCE i

R. Kohler DLCo I

W. Renz VEPCo l

3 T. Kuhr Duke Power

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. S. Hook Northeast Utilities j

. P. Serra STP j

W. Yarosz lilinois Power i

R. Kitts TVA I

W. Lee Southern Co.

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4 Emergency Preparedness Corner Stone GENERAL DESCRIPTION Emergency Preparedness (EP) is the final barrier in the defense in depth NRC regulations provide for ensuring the public health and safety while allowing -operation of civilian nuclear reactor p.-way it is related to the Reactor Safety Strategic Performance Area. 10 CFR Part 50.47 and App'endix E to Part 50, define the requirements of an EP program and the licensee commits i

ementation of these requirements through an Emergency Plan (the Plan). A high level of ecreases the risk of affecting the public health and safety in the event of a radiol:.,gical emergency.

i Statement of Oktive

.w Ensure that the.h[cenbee is capable ofimplementing adequate measures

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public health and safety in the event of a radiological emergency.

Desired Result / Performance Ex'pectation b

Demonstration that a rease labic< assu\\

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rance exists that the licensee can effectively implement emergency plans toTdeqDaiely protect the public health and safety in the event of a radiological emergency.

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KEY ATTRIBUTES OF LICENSEE PERFORMAp'CE TIIAT CONTRIBUTE TO E

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EMERGENCY PREPAREDNESS 4

The key attributes of an EP program are the ability of the Emergency Response Organization 1

(ERO) to implement the Plan, the ability to activate the ERO in a tinfeTyiiiinner, the readiness

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and quality of the equipment and facilities that support the ERO and the quality of the emergency plan implementing procedures (EPIPs) the ERO uses to implement theMan. Figure 1 depicts these key attributes.

Measures taken to protect the public from the effects of a radiological emergency must necessarily involve action by both licensee and governmental authorities in the vicinity of the reactor. The facets of the EP program that involve recognition of the accident, mitigation ofits affects, assessment of the offsite impact and communication ofinformation to governmental 4

authorities, including protective action recommendations, are generally referred to as onsite EP.

The program, procedures and systems maintained to implement governmental actions are referred to as ogsite EP. The licensee is responsible for developing and implementing the onsite EP program and provides support to the offsite program as required. The NRC is responsible for ensuring the adequacy of the overall program, but relies on the Federal Emergency Management Agency (FEMA) to assess the offsite program. The development and collection of performance November 7,1998 1

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indicators (PI's) for offsite EP is not considered necessary or appropriate because FEMA performs regular assessments of offsite EP programs that are the basis for reasonable assurance that adequate protective measures can and will be taken in the event ofa radiological emergency.

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ERO Performance (Human Performance) 5 VT The imppentation of the Plan is dependant on the performance of the ERO in their EP assignments.))1ese duties are in addition to routinejob duties and the opportunity to acquire j

proficiehefT(generally provided only during training opportunities such as drills. There are 1

many areas important to Plan implementation, but the risk significant areas of ERO performance are:

Timelv and accuradclassification of events; including the recognition of events as potentially exceidmgmmergency action levels (EALs) and any assessment actions l

necessary to support the classification; this is measured by a PI; l

Timely and accurate notification of offsite governmental authorities; including adequate performance of notifications as splified in the Plan; this is measured by a PI; 4

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Timelv and accurate develonm)ent an7 communication of n i

recommendations to offsite authorities; including providing prohive action recommendations (PARS) to governmental amhoraies, the decision making process to develop the PARS, any accident assessment ne'c' essa'ry to support PAR development, the l

protection of emergency workers and direct inte7fdce with offsite authorities; this is measured by a PI and inspection; and

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Emergency Resnonse Organization readiness; including training of the ERO to ensure proficiency,' the efficacy of the assessment program to identity dsif6iencies in ERO

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proficiency and the efficacy of the corrective action program to!clorrect these deficiencies; this is measured by a PI and inspection.

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ERO Activation i

L Licensee systems to activate the ERO are critical to implementing the Plan in a timely manner.

This involves a notification system for individual ERO members, training in its use and testing to ensure facility activation goals can be met. The risk significant area for ERO activation is:

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The demonstration of timelv activation of the ERO; including the functioning of notification systems, efficacy ofindividual training and adequacy of the duty roster to provide replacement individuals when necessary; this is measured by inspection.

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l-Equipment and Facilities Equipment and facilities required to i.aplement licensee emergency response are specified in the Plan. The availability and quality of this equipment and facilities is a risk significant area:

Availability of the Alert and Notification System; including all facets of the system and rmenswed in accordance with FEMA direction; this is measured with a Pl.

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Arailability of communication channels; including channels to governmental authorities a'iftftween emergency response facilities; this is measured by inspection.

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l Availability of caninment and facilities; including surveillance of equipment and facilities; this is beds' red by inspection.

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m EPIP Quality i

EPIPs are used by the ERO to implemenptical facets of the emergency response. The response is tested regularly in drills andgxercises and the quality of EPIPs is generally improved j

through assessment of performance. Tihe nsjk ignificant areas of EPIP quality are:

l Classification of events; this is measured by a PI and inspection of procedure configuration; m.

NotificaPon of offsite covernmental authorities s is measured by a PI; and i

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Develonment and communication of orotective action recommendations to offsite authorities; this is measured by a Pl.

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r~p Offsite EP h

.i State / local governmental authorities are responsible for implementing protective actions to protect the public health and safety. While the licensee must supply appropriate information to the governmental authorities to allow the timely implementation of protective actions, only governmental authorities are authorized to implement the actions. The risk significant areas of offsite EP are:

1 Timelv activation of covernmental authorities; including activation of all elements necessary for response; this is measured by FEMA evaluation, Implementation of orotective actions; including activation of Alert and Notification System, provision of protective action instructions to the public, traffic control, worker protection, and care of evacuees; this is measured by FEMA evaluation; and November 7,1998 3

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i,o Offsite Emergency Response Organization readiness; including provision of training for the offsite ERO; this is measured by FEMA evaluation, i

4 PERFORMANCE INDICATORS 4

a CompliancedEP programs with regulation is largely assessed through observation of response i

to simuldted e2e' rgencies, although routine inspection of onsite programs are currently conducted e

i by NRC {assds's the state of readiness. Demonstration exercises form the key observational tool currentifused to support, on a continuing basis, the reasonable assurance finding that adequate protective measures can and will be taken in the event ofa radiological emergency. This is especially true for the most risk significant facets of the EP program. This being the case, the i

PI's proposed for onsite[Ebaw significantly from performance during simulated emergencies but are supplemented by [winsee self assessment and NRC inspection. NRC assessment of the adequacy of offsite EP.Aill'iih (as it does currently) on regular FEMA assessments.

1 1.0 Drill / Exercise Performance (DEP), collected quarterly, for use in a six month trend and a two year rolling average.

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Fraction, (' numerator and denommat'o7,} of successful performance opportunities over all opportunities for:

7 Classification of Emergencies Notification I

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Protective Action Recommendation

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p-m Basis:

Recognition and subsequent classification of events is ajsk significant activity.

Classification should lead to activation of the ERO as appropriate to the emergency class and notification of governmental authorities.

i Timely and accurate notification of offsite authorities is a risk significant activity.

Notification should lead to mobilization of governmental authorities, as appropriate.

The timely and accurate development and communication of PARS is a risk i

significant activity. It requires that several supporting activities be performed l

including: accident assessment, quantification of radiological release magnitude, i

projection of the potential dose to the public and communication to government authorities. Communication of PARS should lead to actions by governmental i

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authorities to protect the public health and safety.

If plant staff assigned EP duties consistently perfonns these activities in a timely and accurate manner, it indicates that the EP program is operating at or above the threshold oflicensee safetyperformance above which the NRC can allow licensees to address weaknesses with NRC oversight through a risk informed

• nspection program.

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Requiremptsj Only activities that are formally critiqued for the timely and accurate performance of these activities shall be included in this statistic.

Simulated emergency events that are identified as in advance of performance as opportunities for this PI shall be included in the statistics, i.hh[ candidate opportunity c n not be removed from the data set due to po3rperformance. Opportmaues shall include actual emergency dedaranons and the biennial exercise and may include other drills of appropriate scope and operating shift simulator evaluations conducted by the licensee training organization.

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Operating shift sim[ulator evaluations should be included

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J evolution is beinNaiuated and is of such a character as to require classification ifit werW real event.

i No minimum is set for these obsenational opportunities, but a statistical analyses performed on the datahillyecognize that the more opportunities provided the more accurately the PF numerical value represents licensee performance. Statistical opporMeties should include multiple events during a single drill, evolution, etc., if supported by the scenario as follows:

YT each expected recognition and classificatsn opportunity shouM be

included, 1

notification opportunities should include notifications made to the state / local governmental authorities for initial emergency classification, upgrade of emergency class, initial PARS and changes in PARS, and PAR opportunities should include the initial PAR and any changes to the PAR necessary due to meteorological changes or plant status changes.

All declared emergency events and the biennial exercise shall be formally November 7,1998 5

critiqued for compliance with approved EPIPs and adequacy of those EPIPs, at least in the areas identified as risk significant. All PI statistics from these events shall be reported.

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Data Reporting Frequency Data wonb beDN ovided every 3 months j

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PI Threshold W

The threshold for the green zone (need standed wording here)is two fold:

j 85% for the prerianh;ix months 4

90% for the previous two years 1

Discussion to follow, there is a good basr[s'for this and industry acceptanc t

TBP i

The threshold for the red zone is:

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s 60% for the previous two years TBD j

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2.0 Emergency Response Organization Readiness (EROR) a A

j Percentage of ERO and operating shift crews that have participated in a drill or exercise j

in the past 24 months.

l Basis:

EP programs ensure the readiness oflicensee personnel, facilities and equipment to support response to emergencies and protect the public health and safety. The j

previous PI (DEP) measures the performance of segments of the ERO in risk significant activities during simulated and actual emergencies. However, there are l

several supporting activities that are not measured by DEP,.ach as ERO ability to 5

diagnose plant accident conditions, formulate mitigating actions and implement them under accident conditions. EROR measures opportunities that the total ERO has been given to gain proficiency as an integrated organization. It is expected that the licensee assessment program will critique these drill / training opportunities i

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and identify areas for i orovement and that the licensee corrective action program will ensure these impu /ements are canied out. It is expected that this training will contribute to proficiency and overall ERO readiness. In this way EROR indicates the proficiency of the ERO. EROR also measures the drill / training opportunities provided to operating shift crews.

If a licensee consistently ensures that the ERO is proficient, it indicates that the P program is operating at or above the threshold oflicensee safetyperformance

' ove which the NRC can allow licensees to address weaknesses with NRC

oversight through a risk informed inspection program.

Requirements:

KERO participation indicated is that of the essential positions cgitted to in the Plan and the operating shift crews. Plant workers, sMr'y personnel and others that are on shift or may be called secunt tahe emergency but do not fill positions on EP duty rosters or are not part of the operating shift crews are not required to be captured in this PL However, positions that are formally on the EP duty roster, but not-committed to in thgEmergency Plan and others important to emergency response may be mel' ded.

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/3 Participation may be either as a drill / exercise participant or as an evaluator t

(but not as an observer). Only participation in the drills, exercises and evolutions that are used to provide =mput to the DEP PI may be used in the statistics for this Pl. Multiple ah(gfees to a given ERO position could take credit for the same drill /exe[cise if their participation is a meaningful and thorough opportunity to gam proficiency in the assigned position.

Evaluated simulator evolutions that contribute to the DEP PI statistics would be considered for operation shift crew faitiEipation. However,if all crews have participated in more than one evaluah d simulator evolution during the measurement period, it may only be gLanted as 100% and not more.

Data Reporting Frequency Data would be provided every 3 months P1 Threshold The threshold for the green zone (need standard wording here)is:

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1 90% for the previous two years i

Discussion to follow, I have industry buy in, but no basis other than our expert opinion.

TBP The threshold for the red zone is:

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s 3.0 Alert and Notificat on System (ANSR)

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Percent availabili70 Alert and Notification System

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Basis:

The Alert and Notification System (ANS) is a critical link to notifying the public of the need to take protective actions. The licensee maintains the ANS and local

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governmental authorities rate it when necessary. Assurance that the system has a high rate of availab increases the assurance that the licensee can protect the public health and ng an emergency.

If an EP program consistently ensures that the ANS is in a high state of readiness it indicates that the program is operatiag=aker above the threshold officensee safetyperformance above which the NRC aan allow licensees to address weaknesses with NRC oversight throu kiskinformedinspectionprogram.

Requirements:

Statistical information gathered in support of system availability reports given to FEMA would form basis of this Pl. It is proposed that the following rules be applied to gathering of thiMtEN r

Failure of a siren is indicated by failure of any portion of the system that would have prevented it from perfonning its safety function, i.e., creating its design sound level and pattern.

The period assumed for the failure would be IAW the direction to the state / licensee from FEMA on gathering statistics (industry en resolve inconsistencies in data collection)

Periodic testing is in accordance with FEMA guidance and actually tests the ability of the siren to perform its intended safety function.

Data Reporting Frequency Data would be provided every 6 months November 7,1998 8

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- PI Threshold The threshold for the green zone (need standard wording here) is:

94 % for the previous year Discuss low, I do not have industry buy in, and there is no basis other than expert opinion. pere)s a lot of room between this and 90%

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Tne threshold for the reNA is:

k 90% for the presinnbyear i

. This is the FEMA requirement and is acceptable to the industry.

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TBP

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l INSPECTION AREAS P

i The inspection areas discussed below are necessary tojensure the licensee EP program is allow licensees to address weaknesses with NRC ove&poperating a i

ht through a risk informed inspection l

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i program.

Verification that the collection of data is in compliance with]the O

4 guidelines described for PI's.

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Review the efficacy of the self assessment program to gather valid statistics through the j

accurate critique of successes and failures during performance opportunities.

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Review conduct of testing of the Alert and Notification System for compliance with FEMA guidance.

i Review of FEMA evaluation of the biennial exercise.

l Review of the FEMA finding of reasonable assurance.

1 Review of the licensee self assessment of ERO activation tests, to include the conduct of j

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s tests, the results, trends in results and associated corrective actions. Attention should be paid to the licensee correction of repeat failure This area has the potential for development ol

, out it could not be accomplished in i

the current time frame. The PI could be similar to the following:

q Percentage of essential ERO positions that successfully responded in each 6

of the last 4 pager tests.

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Requirements:

Pager tests indicate the readiness of the ERO to fill duty l

roster positions during emergencies that take place during off-normal hours. Only statistics from tests during off-g normal hours may be included. The results of all such tests M.

shall be included, i.e., a test may not be removed from the data set due to poor performance. The frequency tests may be set or changed at licensee discretion, but results from th_e lastgour must be included in the Pl. Successful response means 4 hat it could reasonably be expected that the position

[uhave been filled within the facility activation time goal spec'ified in the Emergency Plan. A position is filled i

by one qualified individual. Multiple individuah tilling a i

single position sangt be counted as moie than one success m the statistics.

e Review that the EAL scheme has been maintamed in the NRC approved configuration or i

that changes have met the requirements of 10 CFR 50.54(q).

Review the efficacy of the self assessment program io identiFphiblems in the following areas:

s.

ERO proficiency in general, ERO ability to diagnose plant accident conditions, formulate mitigating actions and implement them under accident conditions, readiness and quality of EP equipment and facilities, i

I direct interface with offsite authorities during exercises and drills that involve offsite authoiity participation, e.g., review the self assessment of l

the adequacy of direct interface with offsite authorities in the area of PAR communication, adequacy of communication channel testing, communication system availability, timely correction of communication channel deficiencies, implementation of severe accident management guides, and November 7,1998 10

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l adequacy of worker protection during exercises and drills.

l Review self assessment of actual declared events, the biennial exercise and missed -

declaration of events during the inspection period.

Review the efficacy of the corrective action program to correct identified deficiencies, find 1md address trends and address repeat deficiencies.

Pts Notf7theTP group has no control over:

M E.W:ctive EOP implementatm' by licensed operators n

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This was handed off tnM buthas to be picked up else where!

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i Table 1 Emergency Preparedness Cornerstone Kev Attribute Areas to Measure Means to Comments Measure ERO Phorm'abce Timely and accurate PI Recognition and subsequent

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classification of classification of events is a risk events significant activity. Classification should lead to activation of the ERO as appropriate to the

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emergency class and notification psx of governmental authorities.

a w Timely and accurate PI Timely and accurate notification notification of offsite of otTsite authorities is a risk governmental z

significant activity. Notification should lead to mobilization of authorities h]\\

governmental authorities, as appropnate.

Timely and accurate PI The timely and accurate development and and 7 development and communication conununication of Risk q of PARS is a risk significant protective action informed activity. It requires that several recommendations to inspeciitin supporting activities be performed offsite authorities including: accident assessment, quanti 6catinn of radiological releasd$knilude, projection of the potenskl dose to the public and communiSion to government authorities. Communication of PARS should lead to actions by

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governmental authorities to protect the public health and safety.

November 7,1998 12

i Kev Attribute Areas to Measure Means to Comments hieasure Emergency Response PI EROR measures opportunities that Organization and the total ERO has been given to readiness Risk gain proficiency as an integrated informed organization. It is expected that p

t inspection the licensee assessment program will critique these drill / training opportunities and identify areas for improvement and that the Ibensee corrective action program will ensure these improvements y) are carried out. It is expected that u u-this training will contribute to l

proficiency and overall ERO readiness. In this way EROR

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indicates the proficiency of the _

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~g ERO.

ERO Activation The demonstratloa ofk-Risk Activation of the ERO is critical to timely activation of informed implementing the Plan in a timely the ERO inspe g manner during emergencies.

Eauipment and Availability of the P1 q

The ANS is a critical link to Facilities Alert and notifying the public of the need to Notification System take protective actions. The licensee maintains the ANS and local gpymmental authorities operat6 it sche'n necessary.

Assurancithat the system has a high rate 1Mvailability increases the assurance that the licensee can protect the public health and safety during an emergency.

Availability of Risk Communications channels are communication informed critical to the notification process, channels inspection the PAR process and the funcitioning of the ERO during emergencies.

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Ke Attribute Areas to Measurg Means to Comments Measure Availability of Risk The facilities and equipment equipment and informed identified in the Plan are critical to facilities inspection the funcitiong of the ERO during Ds emergencies EPIP Q lity Classification of P1 This EPIP supports the recognition 1

events and subsequent classification of events is a risk significant activity.

Classification should lead to activation of the ERO as y

appropriate to the emergency class c k and notification of governmental authorities.

Classification of Risk This EPIP suports the recognitiorr events g

informed and subsequent classification of inspection events is a risk significant activity.

Classification should lead to activation of the ERO as 2

appropriate to the emergency class 7

and notification of governmental g

authorities.

Notification of offsite PI 1

This EPIP supports the timely and governmental accurate notification of offsite authorities authorities is a risk significant activittyfication should lead to mobihzation of governmental authoritiefskas appropriate.

November 7,1998 14

0 Kev Attribute Areas to Measure Means to Comments Measure Development and PI This EPIP supports the timely and communication of accurate development and protective action communication of PARS is a risk recommendations to significant activity. It requires p;d offsite authorities that several supporting activities jj be performed including: accident assessment, quantification of j

radiological release magnitude, projection of the potential dose to

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the public and communication to government authorities.

u i Communication of PARS should lead to actions by governmental aathorities to protect the public _

A health and safety.

Offsite EP Timely activatio

\\ FEMA State / local governmental A

-Evaluation authorities are responsible for governmental authorities implementing protective actions to protect the public health and T9 safety. While the licensee must N

supply appropriate information to the governmental authorities to allow the timely implementation of protective actions, only goveuyu-mi; authorities are authorized to implement the actions. };

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Kev Attribute Areas to Measure Means to

. Comments Measure Implementation of FEMA State / local governmental protective actions; Evaluation authorities are responsible for implementing protective actions to l

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protect the public health and safety. While the licensee must I

supply appropriate information to the governmental authorities to j

allow the timely implementation j

ofprotective actions, only

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governmental authorities are I

authorized to implement the dw actions.

Offsite Emergency FEMA State / local governmental

Response

g Evaluation authorities are responsible for Organization 3

implementing protective actions to jk protect the public halth and readiness i

safety. While the licensee must supply appropriate information to 2

the governmental authorities to 9

allow the timely implementation d

of protective actions, only A

governmental authorities are i

authorized to implement the actions.

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Table 2 Performance Indicators PI Name Measurement Area Defination Threshold Drill /Eremse Timely and accurate Fraction,(numerator The threshold for the PerforEnckDEP) classification of and denominator,) of green zone (need events -

successful standard wording -

l jj performance here)is two fold:

Timely and accurate opportunities over all i

plification of offsite opportunities for:

85% for the previous six months l [gjernmental uthorities Classification of

.luE Emergencies 90% for the previous Timely and accurate two years development and Notification communicatio protective actj \\

Protective Action recommendanons Recommendation offsite authontres Emergency Emergency Response ' Perge ofERO The threshold for the 4

Response

Organization andjcpersting shift green zone (need Organization readiness crewdat have standard wording i

Readiness (EROR) par,icipated in a drill here)is:

or exercise in the past 1

24 months.

90% for the previous F7(,yvo years i

Alert and Availability of the Percent availability The threshold for the Notification Alert and of Alert and A. green zone (need System (ANSR)

Notification System Notification System standard wording here)is:

i' 94 % for the previous year The threshold for the

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red zone is:

i 90% for the previous year November 7,1998 17 l

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4i NOTE TO:

Randy Sullivan i

j FROM:

Serge Roudier i

l DATE:

11/12/1998

SUBJECT:

THRESHOLDS SECTION FOR THE EMERGEN DNESS (EP) CORNERSTONE l

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j Drill / Exercise Performance Threshold (DEP)

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The threshold for the green zone is two fold:

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85% for the previous six months (data r ry 3 m l

90% for the previous two years (

ort i

l The first threshold, also referred to as '

'rt-te rform shold"is designed to trigger NRC action upon licensee's perfo deel ver th t 6 months. The second threshold, also referred to as "long-term pe ce old"is igned to trigger NRC action upon licensee's performance decli the p his dichotomy between "shon-term" and "long

" threshol emed n lance the significance of short-term and long-te ance asli in performance over a long period of time may be as a

' e noted in a shorter period).

l-Basis for the hres l

Thelon perfo

'1old of 90 % has been determined based on an analysis of eme y preparednes In findings traced back to 1994. The findings were pulled from f

i ins ion reports of the 1 NRC evaluated exercises. A systematic assessment of each l

g related to the ofinterest (classification, notification, PARS) was performed to l

ine the succe perfonnance opportunities. Successful performance opportunities were for eae onths period so that the corresponding average and standard deviation The following results were found:

i i

1

l 1

i 24 months Number of Estimated Average of Standard j

period Failures Number of Successes Deviation Opportunities

• 1996-1997 24 680 96 %

8%

i 1994-1995 27 730 96 %

g%

{

4 opportunities per exercise for Classification and 4 ortuni ification 2 opportunities per exercise for PARS l

The NRC feels very confident with the data and the res given j

data (NRC inspection repo ts).

l' Examining Inspection reports was found to be the more nvenient way of accessing data regarding past performance associated with the p cise Performance l

Indicator. However, inspection reports only address ppo iated with NRC j

evaluated drills, which are a small part of the op that li e to measure l

Drill / Exercise performance. Other licensees easur rmance stem from j

non-NRC evaluated drills, shift simulator 1e ncy events. Data regarding those opportunities were not r y avai determine the DEP Threshold. The DEP Threshold was on th a pul C evaluated exercises, which are believed to represent a s of licens perfonnance. On any given 24 i

months period, around 70 exerci etio 8 in th od 1996-1997 and 73 in the period l

1994-1995) are performed b t C,r d 700 opportunities for classification, j

notificatio PARS for le indus t-specific basis however, this l

corresp proxi 10 opp per 24 months. In the future, it is expected

{

that lic lect siderably more opportunities to measure Drill / Exercise l

performanc peci as been estimated that at least 200 opoortunities will be l

available for r ch p ual basis, or 400 on a 24 months basis.

I l

Based mentio finspection findings, an emergency preparedness expert panel com of NRC and resentatives came to an agreement as to what long-term thr Id to utilize. The alculated the threshold by taking the past 4 years average, j

d shing it by one s ard deviation, and rounding it up. The panel came up with a 90 %

j erm threshold.

j ths Threshold I

)

Li g-term threshold (24 months), the short-tenn threshold (6 months) has been selected based on the inspection findings analysis. The short-term threshold is less stringent that the long-term threshold to allow licensee to fix short term problems. An emergency preparedness expert i

panel composed of NRC and industry representatives came to an agreement to fix this threshold 2

l j

i i

9 at 85 %. This value corresponds to the successful performance opportunity average of the industry for the past 4 years diminished by 1.645 x the standard deviation.

DE mslon of past individual plant performance against the thresholds i

Tests ofindividual plant performarv e against the 24 months threshold were performed for the l

period 1994-1997. Had performance indicators been in use in the period 1994-19 would have shown the following:

l l

Number of Plants Total Ar.2m of Plants Per lants not Meeung the g the Thr-l Threshold 1994 1 (0 70 98.5 %

l 1995 3(23 70 96 %

l 1996 N/A 70 1997 7(3) j l

("

Cooper l

(2)

Cooper, Palo Verde, Wolf Cree -

l (3)

Haddam Neck, Three Mile I

, Prai

land,

'ities, Palo Verde, River Bend,

{

Washington Nuclear 2 j

The table te s to confirm r

onable ue chosen for the long-term threshold.

i i

Thresh tions In 1998, the d Ch plant potentially presenting the most concerns with i

regards to err es rever, The Drill / Exercise performance indicator for Clinton [

past ates atstanding performance. It has to be noted that the j

emer preparedne program had not been able to identify the weaknesses that led linton's 1998 i

i ofindividual p erformance against the 6 months threshold have not been performed

}

e lack of ent plant-specific data in ar4y 6 months interval. It is believed that I

e available in the future to validate the short-term threshold. The 6 months j

validated after a year ofimplementation. This will also give an opportunity to res months threshold.

j Implementation proposals j

i 3

4

}-

)

For sake of first-time implementation of the Drill / Exercise performance indicator and threshold, j

it will be assumed that in the past 21 months all licensees demonstrated 96 % of successful i

perfonnance, which corresponds to the past four years average.

1

)

Alert and Notification System Performance Threshold (ANSB) l The threshold for the green zone is:

i 94% for the previous year (data reported every 6

)

j i

f Threshold Basis i

The threshold of 94 % has been determined based on f yearly sirens ity j

traced back to 1994 for a representative sample of plants ely 15 plants). The j

minimum value found was.96.2 %. The sirens availabil' e 15 plants was 98.2 %.

1 An emergency preparedness expert panel composed of' C

resentatives came to I

an agreement to utilize a 94 % threshold for siren lity.

Il need to be j

revisited after a year ofimplementation.

The threshold for the reu zone is:

90% for the previous year epo very 6 ths) i l

Threshold Basis l

l This thr based acc teria of sirens availability.

1 l

Implement sals l

For sake of ntati the Alert and Notification System performance indicator and thre ds, it wil that in the past 6 months all licensees demonstrated 98.2 % of siren ailability perfo hich corresponds to the calculated past four years average for j

the is sampled.

l l

e anizat' eadin ss e man re olsdE_R_QE) i r the green zone is:

90% for the previous two years (data reported every 3 months) 4

s l

Threshold Basis l

No past data was readily available to help set the threshold value. An emergency preparedness l

expert panel composed of NRC and industry representatives came to an agreement to utilize a 90

% threshold for ERO readiness. This value will te2d to be revisited after a year of implementation.

The threshold for the red zone is to be determined.

Implementation proposals For sake of first-time implementation of the EROR p ance' tor be assumed that in the past 21 months all licensees d

% ofER performance.

l l

5

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