RNP-RA/04-0011, Revision 6 to EPJIC-06, Joint Information Center Generic Information, and Revision 15 to EPPRO-01, Program Responsibilities.

Revision 6 to EPJIC-06, Joint Information Center Generic Information, and Revision 15 to EPPRO-01, Program Responsibilities.

ML040220628
Person / Time
Site:	Robinson
Issue date:	01/20/2004
From:	Baucom C Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/04-0011
Download: ML040220628 (44)

Text

Progress Energy 10 CFR 50, Appendix E ByProgress Energy Serial: RNP-RA/04-0011 JAN 2 0 2004 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 TRANSMITTAL OF EMERGENCY PROCEDURE REVISIONS Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5) and Appendix E to 10 CFR 50, Progress Energy Carolinas, Inc. (PEC), is transmitting revisions to H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, Emergency Implementing Procedures. The procedure revisions and effective dates are listed in the attachment to this letter.

A description of the procedure changes are provided on the "Summary of Changes" page for the emergency procedures. Please replace the superseded procedures with the enclosed revisions.

If you have any questions concerning this matter, please contact me.

Sincerely, C. T. Baucom Supervisor - Licensing/Regulatory Programs CAC/cac Attachment Enclosures c: L. A. Reyes, NRC, Region II (2 copies)

NRC Resident Inspector, HBRSEP C. P. Patel, NRC, NRR (w/o Attachment and Enclosures)

Progress Energy Carolinas, Inc.

Robinson Nuclear Plant 3581 West Entrance Road Hartsville, SC 29550

United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/04-0011 Page 1 of 1 Procedure Revisions and Effective Dates Procedure Revision Effective No. Date EPJIC-06, "Joint Information Center Generic Information" 6 12/29/03 EPPRO-01, "Program and Responsibilities" 15 01/06/04

$j Progress Energy Information Use H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 2 PART 5 EPJIC-06 JOINT INFORMA TION CENTER GENERIC INFORMA TION REVISION 6 EPJIC-06 Rev. 6 Page 1 of 8

SUMMARY

OF CHANGES PRR 00113782 SECTION REVISION COMMENTS Entire Converted to Windows XP format.

Procedure Added new This step will allow the Company Spokesperson the ability to share step 3.1 information in the form of Emergency Notification Forms with the representatives of off-site agencies. (NCR 00088800) 8.1.1 Changed CP&L to "Progress EnergyV 8.1.2.2.b Added "NREC" and changed "and' to "or" EPJIC-06 I Rev. 6 l Page 2 of 8 l

TABLE OF CONTENTS SECTION PAGE

1.0 REFERENCES

.....................................................................................................4 2.0 PURPOSE............................................................................................................4 3.0 RESPONSIBILITIES............................................................................................4 4.0 PREREQUISITES ........................... 4 5.0 PRECAUTIONS AND LIMITATIONS ........................... 4 6.0 SPECIAL TOOLS AND EQUIPMENT ............................ 4 7.0 ACCEPTANCE CRITERIA ............................ 4 8.0 INSTRUCTIONS ........................... 5 9.0 RECORDS ........................... 8 10.0 ATTACHMENTS ........................... 8 EPJIC-06 Rev. 6 Page 3 of 8

1.0 REFERENCES

1.1 N/A 2.0 PURPOSE 2.1 This procedure describes the generic functions in the JIC.

3.0 RESPONSIBILITIES 3.1 The Company Spokesperson has the authority to share material with the representatives from the off-site agencies present at the JIC beyond what is normally procedurally required.

4.0 PREREQUISITES 4.1 As per EPJIC-00.

5.0 PRECAUTIONS AND LIMITATIONS 5.1 As per EPJIC-00.

6.0 SPECIAL TOOLS AND EQUIPMENT 6.1 N/A 7.0 ACCEPTANCE CRITERIA 7.1 As per EPJIC-00.

EPJIC-06 I Rev. 6 l Page 4 of 8

8.0 INSTRUCTIONS 8.1 Location and Organization 8.1.1 The Joint Information Center (JIC) is located at the CP&L Southern Region Operations Site at 1755 Mechanicsville Road in Florence, SC.

The facility contains work space for Progress Energy, state, county, and federal agencies. Work space is adjacent to the news media briefing area for the news media.

1. A JIC organization chart is illustrated in Attachment 10.1, JIC Organization, of the parent procedure, EPJIC-00.

8.1.2 Activation

1. JIC activation is required following declaration of an Alert or higher emergency classification.

2. JIC activation prior to an Alert classification may occur at the discretion of the Emergency Response Manager and Company Spokesperson.

a. Early activation may be due to media/public attention or state/county request.

b. The JIC ERO shall be notified to activate the JIC via any combination of beeper, Public Address, NREC, OR Dialogic.

c. The JIC Emergency Response Organization (ERO) shall sign-in and obtain a badge from the Administrative and Badging staff.

1) The ERO shall sign-in on the JIC organization chart in the JIC command room.

I EPJIC-06 I Rev. 6 l Page 5 of 8

8.1.2 Activation (continued)

d. Emergency Response Organization (ERO) members shall verify operability of equipment and availability of reference materials necessary to function.

1) Report deficiencies to the Administrative Staff.

2) Public Information Specialists report deficiencies to Public Information Coordinators.

e. ERO personnel other than the Public Information Specialist and Administrative Assistants shall initiate documentation of activities in the Electronic Display System (EDS) or in a logbook using black ink.

f. Sign and date logbook prior to entry of activities.

9. Public Information Specialist and Administrative Assistants shall maintain EPJIC-04, Attachment, Public/Media Telephone Inquiry Log, and EPJIC-05, Attachment, Press Release Distribution Log, respectively.

3. Announce your name, ERO position title and state of readiness.

4. Provide JIC facility briefing times to those individuals that you are in contact with so that you will be available for the facility briefings.

a. Avoid phone conversations during JIC facility briefings unless there is emergent information to share with the group.

b. Avoidance of phone conversations does not apply to the Public Information Specialists.

5. Receive plant status briefing.

I EPJIC-06 I Rev. 6 7 Page 6 of 8

8.1.2 Activation (continued)

6. Each position with a specific procedure to direct their activities (except Administrative and Badging Staff) shall initiate a written or electronic log of significant emergency response activities.

Generally, logs for teams will be maintained by the team leader.

a. Log your name and the date prior to entry of activities for that shift.

b. Logs shall include communications, key decisions and data collected or transmitted in support of those decisions.

c. For convenience, log books are available for positions required to maintain a log. Scraps of paper, napkins, etc.

are not appropriate for final versions of logs. Final versions of logs should be maintained current.

8.1.3 Turnover

1. The Administrative Assistant shall coordinate shift change with the Administrative and Logistics Manager (ALM) in the EOF.

2. Each ERO member shall brief their relief on event status. Relief staff Public Information Specialists shall be briefed as a group by the Public Information Coordinator before completing turnover.

3. Current shift ERO members shall sign and date the logbook or log out of EDS as applicable.

4. Relief personnel shall log in to EDS or sign and date the logbook prior to assuming duties of their specific position.

EPJIC-06 Rev. 6 Page 7 of 8

8.1.4 Deactivation

1. The decision to deactivate the JIC shall be coordinated with the Emergency Response Manager (ERM).

2. Evaluate condition of equipment/supplies.

a. Report deficiencies to the Administrative Assistant.

b. Public Information Specialists shall report deficiencies to the Public Information Coordinator.

3. Sign and date logbook and other documentation.

a. Provide these materials to the Administrative Assistant.

b. If applicable, log off of the EDS system.

4. The Administrative Assistant will ensure that all documentation is turned over to the Emergency Preparedness (EP) staff.

9.0 RECORDS 9.1 As per EPJIC-00.

10.0 ATTACHMENTS 10.1 N/A l EPJIC-06 I Rev. 6 l Page8of8 I

CJ Progress Energy H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 2 PART 5 EPPRO-01 PROGRAM AND RESPONSIBILITIES REVISION 15 IEPPRO-01 I Rev. 15 l Page 1 of 34

SUMMARY

OF CHANGES PRR 111018 STEP # REVISION COMMENTS 8.1 .2.3.b Added a sentence stating that the yearly plan should identify the drill/exercises that should be counted in the NRC Performance Indicator for drill and exercise performance.

8.1 .2.3.c Revised definitions for categorizing critique observations to include strength, deficiency, weakness, and comment.

8.1.2.3.c Moved statement concerning EP Improvement Form items from Bullet 4 Step 8.1.3.1 and included work request (WR) to Passport products that can be used to resolve EP Improvement Form comments.

8.1 .2.3.c Deleted statement to restrict published comments to those that Bullet 5 would not compromise scenario confidentiality due to Sentence 1 drills/exercises being pre-designated for NRC Performance Indicator in the yearly plan.

8.1 .2.3.c Changed the frequency for completion of the drill critique report to Bullet 7 ten working days.

8.1 .2.3.c Deleted requirement to document final critique report as a self-assessment report.

8.1 .2.3.e Added statement to trend identification and analyze ERO drill processes in accordance with CAP-NGGC-0200.

8.1.3.1 Added annual frequency for the review of the Emergency Plan and Implementing Procedures.

8.1.3.3.d Corrected the title of REG-NGGC-01 0 IEPPRO-01 _ Rev. 15 l Page2of34

TABLE OF CONTENTS SECTION PAGE 8.1 PROGRAM AND RESPONSIBILITIES .................................................... 4 8.1.1 DRILL AND EXERCISE PARTICIPATION ................................................ 4 8.1.2 DRILLS AND EXERCISES .................................................... 5 8.1.3 EP PROCEDURE MAINTENANCE AND PROGRAM IMPROVEMENTS ...... 9 8.1.4 INADVERTENT SIREN ACTIVATION ................................................... 10 8.1.5 EMERGENCY RESPONSE ORGANIZATION BEEPER DISTRIBUTION.... 12 8.1.6 HURRICANE PREPARATION GUIDANCE ............................................. 12 8.1.7 INTENTIONALLY BLANK ................................................... 13 8.1.8 INTENTIONALLY BLANK ................................................... 13 8.1.9 INTENTIONALLY BLANK ................................................... 13 8.1.10 SCENARIO DEVELOPMENT ................................................... 13 8.1.11 DRILL/EXERCISE SELF EVALUATION (AR #44128) ........................... 13 8.1.12 PUBLIC EDUCATION AND INFORMATION ........................................... 14 8.1.13 RECORDS............................................................................................... 15 8.1.14 ATTACHMENTS...................................................................................... 16 8.1.14.1 EP IMPROVEMENT FORM .......................................... 17 8.1.14.2 SIREN SYSTEM INADVERTENT ACTIVATION REPORT .......... 18 8.1.14.3 ERO BEEPER DISTRIBUTION .......................................... 19 8.1.14.4 EP DRILL AND EXERCISE OBJECTIVES ................................... 20 8.1.14.5 ACCEPTANCE CRITERIA .......................................... 27 8.1.14.6 GUIDELINES FOR ERO CRITIQUES .......................................... 34 I EPPRO-01 I Rev. 15 l Page 3 of 34

8.1 PROGRAM AND RESPONSIBILITIES 8.1.1 DRILL AND EXERCISE PARTICIPATION

1. ERO personnel are expected to drill/exercise with their designated team.

a. If they will be unavailable for the drill it is their responsibility to ensure some one from another team will fill their position.

b. Relief team personnel will participate in at least one team Drill, Exercise, or Tabletop each year.

c. Non-Team designated ERO personnel are expected to coordinate with the other persons qualified for their position to ensure the position is staffed for each drill/exercise and that each ERO member participates in at least one Drill per calendar year.

2. ERO personnel filling critical positions shall be observed at least once in a calendar year performing their ERO duties.

3. Unless otherwise directed by Emergency Preparedness (EP), ERO personnel should respond during augmentation for their facility.

a. Those personnel available to respond should establish 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage for the position.

b. Personnel on night shift may be exempted from augmentation, but should be used to establish 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage.

c. After the rotation is established, personnel may be simulated to be sent home and return to their place of work.

d. Personnel are required to keep the manager responsible for their accountability informed of their location should an evacuation be conducted at a later time.

I EPPRO-01 I Rev. 15 l Page4of 34

8.1.2 DRILLS AND EXERCISES

1. Emergency Response Organization (ERO) personnel will participate in periodic drills at least once each calendar year. Additionally one team, on a rotational basis, will participate in the Graded Exercise. The purpose of conducting drills is to ensure that each team has the skills to successfully deal with a real emergency. The following are the types of drills conducted:

a. Medical Emergency Drills: Medical emergency drills will be conducted annually. They will involve a simulated contaminated and injured individual. Off-site portions of these drills may be conducted as part of an exercise.

b. Health Physics Drills: Health Physics drills, including response to and analysis of simulated elevated airborne and liquid samples and direct radiation measurements, will be conducted semi-annually. {NRC Amendment No. 192}

- Participation in the Medical Services (MS-1) drill may also be included.

c. Combined Functional Drills: Combined Functional Drills may include any of the required drills and serve as the primary method of practical training for new ERO members and continuing training for existing members.

2. An Exercise will be conducted as required by 10 CFR, Part 50, Appendix E.

a. The scenario which will ultimately escalate to at least a Site Area Emergency.

b. The scenario will be varied from year to year such that major elements of the Plant, County, and State Plans and emergency organizations are tested within a six (6)-year period. Major elements to be demonstrated are outlined as drill/exercise objectives in Attachment 8.1.14.4. Deletion of any of the elements outlined in Attachment 8.1.14.4 requires PNSC approval. (AR #44128/PNSC Meeting #1999)

IEPPRO-01 I Rev. 15 l Page 5 of 34

8.1.2.2 DRILLS AND EXERCISES (Continued)

c. Consideration should be given to vary the scenarios during the six year cycle to include accidents identified in Chapter 15, Accident Analysis, of the UFSAR. (CR 44132)

d. Combined Functional Drills: Combined Functional Drills may include any of the required drills and serve as the primary method of practical training for new ERO members and continuing training for existing members.

- An integrated drill involving the fire brigade, Dedicated Shutdown procedures (DSP) and the ERO should be practiced once during a two year cycle.

e. Each Exercise scenario will include a list of performance objectives and a description of the expected responses. Specific tasks that should be evaluated are listed in Attachment 8.1.14.4 and 8.1.14.5, "Drill Objectives" and "Acceptance Criteria" respectively.

- Attachments identify the Emergency Response facility where the activity is most likely to occur, however, the objective may be judged acceptable if performed in an alternate location.

- Credit may be taken for objectives that are satisfactorily completed during actual events. A memo should be generated that provides a summary/synopsis of the event and the performance objectives that were demonstrated during the actual event. (AR #79167)

f. An off-hours exercise which starts between 6:00 p.m. and 4:00 a.m. will be conducted once every six (6) years.

g. Advance knowledge of the scenario content and the times of the exercises will be kept to a minimum to ensure a realistic participation by those involved.

I EPPRO-01 I Rev. 15 Page6of34

8.1 .2.3 DRILLS AND EXERCISES (Continued)

3. The EP Staff is responsible for planning and conducting drills and exercises not addressed elsewhere (e.g., Fire Drills are addressed in the Fire Plan). They shall provide:

a. The scenario including objectives for the drill/exercise.

- From time to time "specific objectives" which are in addition to required performance objectives will be added to the Training Exercise Objectives. These may be in response to previous deficiencies, EP TPC items or require that normally simulated items be actually performed. A prompt to consider these items is contained in the pre-drill checklist.

- An extent of play describing the degree of simulation for drill/exercise activities.

- Qualified Controller/Evaluators to evaluate the drill/exercise.

- As a minimum, Controller/Evaluators should be available to evaluate the following:

• each facility activating,

• Environmental Monitoring Teams,

• Mechanical Damage Control Missions (as applicable),

• Electrical Damage Control Missions (as applicable),

• Chemistry/Health Physics Missions,

• Offsite functions to be simulated,

• any special functions (e.g. fire, injury)

b. A yearly plan for ERO exercises. The yearly plan should identify the drill/exercises that should be counted in the NRC Performance Indicator for drill and exercise performance.

c. Critiques will be conducted after each drill/exercise in accordance with Attachment 8.1.14.6 (AR #44128,CAPR). Critique observations should be categorized during the lead evaluator critique roll-up as noted below:

I NOTE: Critique reports for small scale drills may be documented in memo format.

I EPPRO-01 I Rev. 15 l Page 7 of 34 1

8.1.2.3.c DRILLS AND EXERCISES (Continued)

- Strength: an action or activity performed in an above average manner, or in a creative manner to resolve a problem without the violation of a requirement. These are items which all teams should consider adopting.

- Deficiency: an action or activity that results in failure to comply with the Emergency Plan/procedures, or failure to meet the acceptance criteria resulting in inadequate demonstration of a drill/exercise objective; an activity or action which interferes with the ability of the ERO to mitigate the consequences of an accident and protect the health and safety of the public.

- Weakness: an action or activity that interferes with the operation of the Emergency Response Organization to a degree that is correctable, however, if not corrected could to a reduction in the ability of the ERO to protect the health and safety of the public.

- Comment: an action or activity that meets current minimum response requirements and is within procedural requirements, but improvement would increase the efficiency and effectiveness of the response effort.

- Comments reported on EP improvement forms will be screened for entry into Passport as a NCR, PRR, NTM, or WR, as applicable.

- Feedback regarding disposition of items entered on an EP Improvement Form should be provided to the individual who initiated the comment, normally within ten working days.

The draft critique report should be issued for comment to the participating ERO team members within ten working days following the post drill controller/evaluator meeting.

1. If multiple drills are conducted during consecutive weeks, then the seven working day criteria will begin at the end of the final post drill controller/evaluator meeting.

I EPPRO-01 I Rev. 15 l Page 8 of 34

8.1 .2.3 DRILLS AND EXERCISES (Continued)

- The critique report will normally consist of the following:

1. Cover Letter and Summary, signed by the Supervisor of Emergency Preparedness, with a brief statement containing the date the drill(s) was conducted; team(s) that participated; and a summary statement of overall drill performance.

2. Objectives and Objective Status

- The objectives should be listed for each facility.

- The status of each objective will be listed for each facility based on the objective acceptance criteria.

- Satisfactory completion of an objective by any team will satisfy that requirement for the Site.

- Any team failure to demonstrate an objective is a deficiency and will be handled as such. At the discretion of EP Supervision failure to demonstrate an objective(s) may require re-demonstration by the team.

d. A pre-drill and post-drill review of items needed to prepare for the drill/exercise or return to normal following the drill/exercise (i.e., reset simulator telephones).

e. Trend identification and analysis of ERO drill processes in accordance with CAP-NGGC-0200.

8.1.3 EP PROCEDURE MAINTENANCE AND PROGRAM IMPROVEMENTS

1. The annual Emergency Plan and Implementing Procedures Review will be documented as a mandatory self assessment per CAP-NGGC-0201 and should be a cross-functional.

2. Procedure improvements may be recommended by initiating a procedure revision request (PRR) in Action Tracking.

IEPPRO-01 I Rev. 15 l Page 9 of 34

8.1.3 (Continued)

3. Procedure changes to the Robinson Emergency Plan and/or Emergency Procedures will be accomplished as required by AP-044, Procedure Review and Approval Process, and PRO-NGGC-0204.

a. Emergency Preparedness will be responsible to maintain the Emergency Action Levels (EAL) and supporting basis documents, as well as the Emergency Procedures.

b. Documents will be developed and maintained to comply with applicable regulations.

c. The EAL basis document will be revised to reflect NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," or other management directives and policies.

d. All Emergency Procedures, EALs, and the Emergency Plan shall be reviewed per REG-NGGC-001 0, 10 CFR 50.59 and Selected Regulatory Reviews.

8.1.4 INADVERTENT SIREN ACTIVATION

1. Upon receiving a report of an inadvertent siren activation:

a. If a real emergency or drill/exercise is in progress that involves sounding of the sirens, then direct the callers to tune to an Emergency Alerting System Station listed in the emergency public information distributed by Progress Energy.

b. If no event is in progress obtain information requested on attachment 8.1.14.2, Siren System Inadvertent Activation Report and ask the caller if a call back is desired once more information is known.

I EPPRO-01 I Rev. 15 l Page lOf34

8.1.4 INADVERTENT SIREN ACTIVATION (Continued)

2. If an inadvertent siren activation has been confirmed, then notify the following:

a. All County Emergency Operations Center or Warning Points concerning the plant status. This can be accomplished via Selective Signaling or the Bell lines.

Sirens are located as follows:

- Chesterfield County - 13 Siren Locations Siren #'s -01,02,03,04,05,06,09,10,11,15,16,17, and 45

- Darlington County - 28 Siren Locations Siren #'s - 07, 08,12,13, 14,18,19, 20, 21, 22, 23, 24, 25, 26, 27, 30, 31, 32, 33, 34,36, 37, 38, 39, 41, 42, 43, and 44

- Lee County - 4 Siren Locations Siren #'s - 28, 29, 35, and 40 Total Sirens - 45 Siren Locations (All Counties)

b. Notify the Telecommunications Help Desk that an inadvertent siren activation has occurred and request that repair personnel be dispatched to correct the problem. Request a work order Number and a return call when the sirens have been silenced.

c. Notify Emergency Preparedness by phone or pager. The ERO Phone Book has the necessary information.

d. Notify Robinson Communications of the inadvertent siren activation and request immediate notification if a press release is to be issued. A press release relating to this event is reportable to the NRC. Consult AP-030, NRC Reporting Requirements.

I EPPRO-01 I Rev. 15 l Page 11 of 34

8.1.4 INADVERTENT SIREN ACTIVATION (Continued)

3. When the Unit 2 Control Room is notified that the siren(s) have been silenced ensure that:

a. Evaluate AP-030, NRC Reporting Requirements, for potential NRC reporting.

b. Notify the State and County Warning Points concerning the status of the sirens.

c. Notify Robinson Communications.

4. Forward information gathered and any completed Attachment 8.1.14.2 forms to Emergency Preparedness for retention as appropriate.

8.1.5 EMERGENCY RESPONSE ORGANIZATION BEEPER DISTRIBUTION

1. After qualifying as an ERO member, EP will arrange an ERO beeper for the positions identified in Attachment 8.1.14.3, ERO Beeper Distribution.

2. Beepers are to ensure that the plant has the ability to meet the 30-45 minute response staffing requirements.

3. Plant Public Address, Non-Responding Emergency Communicators, dialogic and/or beepers are used to contact the 60-75 minute staff, and other positions not required by NUREGs.

8.1.6 HURRICANE PREPARATION GUIDANCE (CR 16553)

OMM-021 "Operation During Adverse Weather Conditions", provides direction for hurricane/adverse weather preparations. Additional tasks for the EP staff to consider are:

• Establish the response teams.

• Designate and post sleeping areas.

• Set up and test the satellite telephone.

IEPPRO-01 I Rev. 15 l Page 12 of 34

8.1.7 INTENTIONALLY BLANK 8.1.8 INTENTIONALLY BLANK 8.1.9 INTENTIONALLY BLANK 8.1.1 0 SCENARIO DEVELOPMENT Guidelines for the development, conduct, and assessment of drill/exercise scenarios are contained in EPPRO-05, Scenario Development and Drill Control Guidelines.

8.1.11 DRILL/EXERCISE SELF EVALUATION (AR #44128)

1. Evaluate the effectiveness of each of the following drill/exercise cycle phases at least once during the biennial exercise cycle:

a. Analysis

b. Design

c. Development

d. Implementation

2. Select one or more of the following self-evaluation programs to determine the effectiveness of a specific phase:

a. Corrective action

b. Operating experience

c. Self-assessment

d. Benchmarking

3. Probe to identify the following:

a. Flawed defenses

b. Error precursors

c. Weak organizational processes IEPPRO-01 I Rev. 15 l Page 13 of 34

8.1.11 (Continued)

4. Consider the following elements:

a. Results

b. Behaviors

c. Task demands

d. Work environment

e. Individual capabilities 8.1.12 PUBLIC EDUCATION AND INFORMATION

1. Emergency Preparedness and Site Communications shall perform the following actions:

a. In cooperation with the State of South Carolina, local governments and with corporate CP&L efforts, ensure that public education and information efforts are consistent and complementary.

b. Ensure that a public information program for persons living in the possible plume exposure Emergency Planning Zone includes the following elements:

- Brochures or other media containing educational information on emergency preparedness, nuclear power and radiation, and how to contact CP&L for more information.

- Coordination of speakers to address emergency preparedness when requested.

- Supplying news material for the media.

I EPPRO-01 I Rev. 15 l Page 14 of 34

8.1.12.1 (Continued)

c. Ensure that the public education program includes the following information:

- The potential for occurrence of a radiological emergency.

- How to recognize a radiological emergency notification.

- What proper, immediate actions (e.g., return to home, close windows and turn on radio) should be taken upon notification.

- Protective actions to be taken if shelter is prescribed.

- General procedure to follow if an evacuation is required.

- General education on radiation.

- A contact for how to learn more about emergency preparedness.

8.1.13 RECORDS

1. Attachment 8.1.14.2 is to be maintained in the EP Unit files for a period of two years unless otherwise specified.

2. The following documents are to be submitted for retention as vital records in the plant vault per RDC-NGGC-0001:

- Recurring drills/exercise maintenance and testing records documented per EPPRO-02.

- NRC Biennial Graded Exercise scenario narrative/timeline, scope and objectives, and final critique report.

3. For Full Scale Drills/Exercises, copies of the scenario timeline, draft critique reports, attendance records, and final critique reports should be maintained by the EP Staff for a period of six (6) years.

4. For Small Scale Drills, copies of the covered topics, attendance records, and critique reports should be maintained by the EP Staff for a period of six (6) years.

I EPPRO-01 I Rev. 15 l Page 15 of 34 l

8.1.14 ATTACHMENTS 8.1.14.1 EP Improvement Form 8.1.14.2 Siren System Inadvertent Activation Report 8.1.14.3 ERO Beeper Distribution 8.1.14.4 EP Drill and Exercise Objectives 8.1.14.5 Acceptance Criteria 8.1.14.6 Guidelines for Emergency Response Organization (ERO) Critiques I EPPRO-01 I Rev. 15 l Page 16of34l

ATTACHMENT 8.1.14.1 Page 1 of 1 EP IMPROVEMENT FORM DATE: ERO POSITION:

NAME:

RECOMMENDED CHANGE IS IN REFERENCE TO:

EMERGENCY PLAN EMERGENCY FACILITY EP- EP TRAINING (Give Number)

EQUIPMENT OTHER (Ust)

I RECOMMEND THE FOLLOWING CHANGE, ADDITION OR IMPROVEMENT:

(Be specific - list all information)-

For Emergency Preparedness Use AR # (NTM,PRR, NCR, WR):

Date Received:_ Date Originator Notified:

This form is for information only. No record retention requirements apply.

I EPPRO-01 I Rev. 15 l Page 17of 34 l

ATTACHMENT 8.1.14.2 Page 1 of 1 SIREN SYSTEM INADVERTENT ACTIVATION REPORT Date: / I Time:_

Fill out as much of the following information as possible:

1. Incident Date: / I Incident Time:

2. Caller's Name:_ Caller's Phone No.:

3. Location of siren(s) (include County and Community of caller):

The siren number is the preferred information. The siren number is located on the siren pole. If the caller cannot provide the siren number, obtain any information which may aid in identifying the siren. For example, request a description of the siren location, a road number, or of the location of the person who is making the report and the direction from which the sound is coming.

Siren Number(s) or Location

4. Additional questions: (circle one)

- What noise did the siren make (steady tone, wavering tone, etc.)?

- Is the siren still sounding? (Yes / No)

- For what length of time did the siren sound?

(1 min /2 min /3 min / Continuous / Unknown)

- Is more than one siren sounding? (Yes / No)

5. Name of Person Receiving Location Telephone Number Report Completed documents to be maintained in EP Files for a period of two years.

IEPPRO-01 I Rev. 15 l Page 18of34

ATTACHMENT 8.1.14.3 Page 1 of 1 ERO BEEPER DISTRIBUTION All Team Members in the following positions.

SEC OSC Leader AERM POD ERM NRC TAD A&LM EP ERD TAM JIC Director RCD/RCM POA Reactor Engineer ESTL EC Computer Support Superintendent Shift Operations Desk DPTL Company Spokesperson State/County Communicator RC Tech-Damage Control RC Tech Facilities (45 min) En Mon Team (45 min)

JIC Technical Spokesperson Rotational Beeper positions NRC Communicator Environmental/Chemistry Tech PI Communicator Electrical Engineer Security Lieutenant Mechanical Engineer Damage Control Leaders RC Tech-Facilities (75 min)

(1) Mechanics En Mon Team Leader (1) I&C/Electricians En Mon Team (75 min)

(1) Normally on shift, beepers available This information is for resource allocation only. No record retention requirements apply.

l EPPRO-01 I Rev. 15 l Page 19 of 34

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ATTACHMENT 8.1.14.4 Page 1 of 7 EP DRILL AND EXERCISE OBJECTIVES NUREG OBJECTIVE CR TSC OSC JIC EOF FREQ 0654 1 A.1 .e Provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day on shift emergency response X 6 yr F.1 .a personnel as required by the Emergency Plan including the capability of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day manning of communications. .

2 A.4 Demonstrate ability to staff Emergency Response X X X X 6 yr Facilities (ERF) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

3 B.5 Demonstrate the ability to augment shift staff and X X X 2 yr H.4 activate ERFs with Emergency Plan Table 5.3.2-1, B.7 "Capability for Additions" column for 30-45 min and 1b.2 60-75 min.

4 Demonstrate the ability to augment shift staff with: 2 yr B.7.a -Logistics support personnel B.7.b -Technical support for reentry/recovery operations X X

-Management interface with governmental authorities B.7.c -Corporate interface with news media X B.7.d x X NOTE: Deletion of EP Drill and Exercise Objectives from this attachment requires PNSC approval. (AR #44128/PNSC Meeting1999)

'1 OCFR50.47 l EPPRO-01 I Rev. 15 l Page 20 of 34

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ATTACHMENT 8.1.1 4.4 Page 2 of 7 EP DRILL AND EXERCISE OBJECTIVES NUREG OBJECTIVE CR TSC OSC JIC EOF FREQ 0654 5 B.8 Demonstrate the ability to contact Contractors and X Ann private organizations for technical assistance.

6 B.9 Demonstrate the ability to obtain assistance from law X Ann L.4 enforcement, medical, and fire-fighting organizations lb.12 including assistance for contaminated personner.

7 C.2.b Demonstrate the ability to provide a representative to X 2 yr the SEOC (when activated) and County EOCs. l 8 C.3 Demonstrate the ability to coordinate radiological X Ann

'b.9 monitoring and analysis.

9 D.1 Demonstrate the ability to identify and properly X X Ann 1.1 classify events using appropriate procedures, plant 1 b.4 system parameter values, and the EALs.

10 E.2 Demonstrate the ability to alert, notify, and mobilize X X X X X Ann F.1.e ERO personnel 1

I b.2 11 E.3 Demonstrate the ability to make initial emergency X X Ann

'b.5 notification to State and Chesterfield, Darlington, and Lee County Warning Points or EOCs within 15 minutes following declaration of each emergency classification.

NOTE: Deletion of EP Drill and Exercise Objectives from this attachment requires PNSC approval. (AR #441 28/PNSC Meetingl 999)

'10CFR50.47 l EPPRO-01 I Rev. 15 l Page 21 of 34

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ATTACHMENT 8.1.14.4 Page 3 of 7 EP DRILL AND EXERCISE OBJECTIVES NUREG OBJECTIVE CR TSC OSC JIC EOF FREQ 0654 12 E.4 Demonstrate the ability to make follow-up X X Ann

'b.5 notifications to State and Chesterfield, Darlington, and Lee County Warning Points or EOCs within 60 minutes following initial and change of classification notifications.

13 E.7 Demonstrate the ability to formulate protective action X Ann J.7 recommendations and transmit to State and County

'b.10 personnel.

14 F.1 Demonstrate the ability to communicate with State X X Ann F.1.a and County personnel using primary and backup F.1.b communication systems.

15 F.1 .c Demonstrate the provisions to communicate with X X Ann Federal emergency response organizations.

16 F.1 .d Demonstrate the ability to communicate between the X X X X Ann

'b.6 CR, TSC, EOF, OSC, and Enmon teams; 17 F.1 .f Demonstrate the ability to communicate with the NRC X X Ann within 60 minutes following each emergency classification declaration.

18 G.3.a Demonstrate timely activation of the Joint Information X 2 yr G.3.b Center.C NOTE: Deletion of EP Drill and Exercise Objectives from this attachment requires PNSC approval. (AR #44128/PNSC Meetingl999) 1 IOCFR50.47 l EPPRO-01 l Rev. 15 1 Page 22 of 34

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ATTACHMENT 8.1.14.4 Page 4 of 7 EP DRILL AND EXERCISE OBJECTIVES NUREG OBJECTIVE CR TSC OSC JIC EOF FREQ l____ 0654 19 G.4.a Demonstrate the ability to obtain emergency related X 2 yr

'b.7 information.

20 G.4.b Demonstrate the ability to disseminate timely, X 2yr G.4.c accurate, and appropriate emergency information

. including provisions for rumor control.

21 H.6.a Demonstrate the ability to obtain data from X X Ann H.6.b meteorological, hydrologic, seismic, radiological 1.5 monitors, and sampling devices.

22 1.2 Demonstrate the ability to analyze data from post X Ann

'b.9 accident monitoring equipment. {NRC Amendment No. 192}

23 1.3.a Demonstrate the ability to determine the source term X X Ann 1.3.b and magnitude of releases.

24 1.8 Demonstrate the ability to project dosage to the X Ann 1.9 public based on plant and field data.

J.7 25 J.1 Demonstrate the ability to alert and advise individuals X Ann

'b.2 who are visitors, contractors, and members of the public onsite._

NOTE: Deletion of EP Drill and Exercise Objectives from this attachment requires PNSC approval. (AR #44128/PNSC Meetingl999)

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( C C ATTACHMENT 8.1 .14.4 Page 5 of 7 EP DRILL AND EXERCISE OBJECTIVES NUREG OBJECTIVE CR TSC OSC JIC EOF FREQ 0654 26 J.3 Demonstrate the ability to evacuate non-essential X X 6 yr K.7 personnel from site to be monitored and decontaminated at an offsite location.

27 J.4 Demonstrate the ability to monitor, decontaminate X X 6 yr and evacuate non-essential personnel from site.

28 J.5 Demonstrate the ability to account for individuals in X 6 yr the protected area and identify the names of those unaccounted for within 30 minutes.

29 J.6 Demonstrate the ability to provide ERO personnel X X X X 2 yr K.3.a protective clothing, respiratory protection, dosimetry, K.3.b and radioprotective drugs. This also includes determination of doses received and maintenance of dose records 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

30 K.1 Demonstrate the ability to establish onsite exposure X Ann

'b.1 1 guidelines consistent with EPA emergency worker and lifesaving activities.

31 L.2 Demonstrate the ability to provide onsite first aid X Ann capability. _

NOTE: Deletion of EP Drill and Exercise Objectives from this attachment requires PNSC approval. (AR #441 28/PNSC Meetingi 999)

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ATTACHMENT 8.1.14.4 Page 6 of 7 EP DRILL AND EXERCISE OBJECTIVES NUREG OBJECTIVE CR TSC OSC JIC EOF FREQ 0654 32 M.1 Demonstrate the ability to reassess plant conditions X 6 yr M.2 and evaluate recovery/reentry considerations.

M.3 M.4 33 N.1 .b Demonstrate the ability to augment the ERO, during X 6 yr an Exercise, between 6:00 p.m. and 4:00 a.m. or any weekend hours.

34 N.2.d Perform Radiological Monitoring Drills which involve X Ann collection and analysis of all sample media (e.g.,

water, vegetation, soil and air), and provisions for communications and record keeping.

35 N.2.b Perform fire drills which demonstrate the ability of the X 6 yr fire brigade to respond to a fire and interface with offsite fire assistance. .

36 N.2.c Perform medical emergency drills which demonstrate X X Ann the ability to deal with a medical emergency involving a simulated contaminated individual including participation of offsite medical treatment agencies. _

NOTE: Deletion of EP Drill and Exercise Objectives from this attachment requires PNSC approval. (AR #44128/PNSC Meetingl999)

'10CFR50.47 EPPRO-01 Rev. 15 Page 25 of 34

( C ATTACHMENT 8.1.14.4 Page 7 of 7 EP DRILL AND EXERCISE OBJECTIVES

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NUREG OBJECTIVE CR TSC OSC JIC EOF FREQ 0654 37 N.2.e Perform Health Physics Drills which involve response X 6 mo (1) to, and analysis of, simulated elevated airborne and

'b.9 liquid samples and direct radiation measurements in the environment.

38 ACR Perform an offsite hazards drill which will involve X X X X Ann 94- response to, and analysis of simulated offsite 01156 hazards (examples: chlorine, propane, hydrogen, CA .1 gasoline or some other offsite hazard either natural man made). Samples and measurements as well as protective measures should be taken.

39 N.4 Perform a critique at the conclusion of an exercise to X X X X X Ann evaluate the ability of organizations to respond as required.

40 Demonstrate that NRC identified open items resulting from previous exercises are corrected.

41 CR 98- Demonstrate actual use of SCBA's including field X Ann 02026 change out of spare cylinder.

42 J.6.c Demonstrate the ability to control radiological X X X X 2 yr exposure to emergency workers including the issuance of radioprotective drugs.

NOTE: Deletion of EP Drill and Exercise Objectives from this attachment requires PNSC approval. (AR #441 28/PNSC Meetingl 999)

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ATTACHMENT 8.1.14.5 Page 1 of 7 ACCEPTANCE CRITERIA

=___ OBJECTIVE ACCEPTANCE CRITERIA 1 Provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day on shift emergency response This objective is met as long as the staffing requirements personnel as required by the Emergency Plan including of Technical Specifications, Emergency Plan the capability of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day manning of Table 5.3.2-1 "Minimum Shift Size" column are satisfied.

communications.

2 Demonstrate ability to staff ERFs 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. This objective is met when the ERFs are staffed and a shift turnover is complete.

3 Demonstrate the ability to augment shift staff and This objective is met when the staffing requirements of activate ERFs with Emergency Plan Table 5.3.2-1, the Emergency Plan Table 5.3.2-1, "Capability for "Capability for Additions" column for 30-45 min and Additions" column is satisfied.

60-75 min.

4 Demonstrate the ability to augment shift staff with: This objective is met when facilities are capable of being

-Logistics support personnel activated.

-Technical support for reentry/recovery operations

-Management interface with governmental authorities

-Corporate interface with news media 5 Demonstrate the ability to contact Contractors and This objective is met when the ability to contact has been private organizations for technical assistance. demonstrated. The ability to contact should include a verification of the appropriate phone number.

6 Demonstrate the ability to obtain assistance from law This objective is met when the ability to contact has been enforcement, medical, and fire-fighting organizations demonstrated. The ability to contact should include a including assistance for contaminated personnel. verification of the appropriate phone number.

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( C ATTACHMENT 8.1.14.5 Page 2 of 7 ACCEPTANCE CRITERIA OBJECTIVE ACCEPTANCE CRITERIA 7 Demonstrate the ability to provide a representative to This objective is met when the facilities are activated and the SEOC (when activated) and County EOCs. an ERO representative is present.

8 Demonstrate the ability to coordinate radiological This objective is met when appropriate monitoring and monitoring and analysis. analysis data are received. (Portions may be simulated as a control cell.)

9 Demonstrate the ability to identify and properly classify This objective is met when events are correctly classified events using appropriate procedures, plant system in a timely manner.

parameter values, and the EALs.

10 Demonstrate the ability to alert, notify, and mobilize This objective is met when the ERFs are activated.

ERO personnel.

11 Demonstrate the ability to make initial emergency This objective is met when initial notifications are notification to State and Chesterfield, Darlington, and accomplished within the required 15 minutes. Time starts Lee County Warning Points or EOCs within 15 minutes at emergency declaration and ends at first contact.

following declaration of each emergency classification.

12 Demonstrate the ability to make follow-up notifications This objective is met when follow-up notifications are to State and Chesterfield, Darlington, and Lee County accomplished within the required 60 minutes. Time starts Warning Points or EOCs within 60 minutes following at completion of the previous notification and ends at first initial and change of classification notifications. contact.

'1 OCFR50.47 l EPPRO-01 I Rev. 15 l Page 28 of 34

C (7 ATTACHMENT 8.1.14.5 Page 3 of 7 ACCEPTANCE CRITERIA

=___ OBJECTIVE ACCEPTANCE CRITERIA 13 Demonstrate the ability to formulate protective action This objective is met when protective action recommendations and transmit to State and County recommendations are transmitted to the State and personnel. Counties within 15 minutes following the declaration of a General Emergency.

14 Demonstrate the ability to communicate with State and This objective is met when communications have been County personnel using primary and backup established using the Selective Signaling system and one communication systems. of the backup systems.

15 Demonstrate the provisions to communicate with This objective is met by agreement letters.

Federal emergency response organizations.

16 Demonstrate the ability to communicate between the This objective is met when none of the other Objectives CR, TSC, EOF, OSC, and Enmon teams. fail due to communications.

17 Demonstrate the ability to communicate with the NRC This objective is met when communications are within 60 minutes following each emergency established within the required time. Time starts at classification declaration. emergency declaration and ends at first contact.

18 Demonstrate timely activation of the Joint Information This objective is met when the Company Spokesperson Center. has declared the Joint Information Center activated and the information has been entered into the log.

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ATTACHMENT 8.1.1 4.5 Page 4 of 7 ACCEPTANCE CRITERIA OBJECTIVE ACCEPTANCE CRITERIA 19 Demonstrate the ability to obtain emergency related This objective is met when facility briefings between the information. EOF and JIC have been conducted as appropriate.

20 Demonstrate the ability to disseminate timely, accurate, This objective is met when a press conference has been and appropriate emergency information, including conducted by a Company Spokesperson and false provisions for rumor control. information has been corrected by responsible personnel.

21 Demonstrate the ability to obtain data from This objective is met when data has been obtained and meteorological, hydrologic, seismic, radiological provided to appropriate personnel.

l____ monitors, and sampling devices.

22 Demonstrate the ability to analyze data from post This objective is met when core damage assessment has accident monitoring equipment. {NRC Amendment No. been performed in accordance with applicable 192} procedures.

23 Demonstrate the ability to determine the source term This objective is met when source term and release and magnitude of releases. magnitude/dose protection have been accurately determined.

24 Demonstrate the ability to project dosage to the public This objective is met when Dose Projection information is based on plant and field data. included in the General Emergency declaration notification or as a follow-up to the General Emergency notification.

'10CFR50.47 l EPPRO-01 I Rev. 15 l Page 30of34

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ATTACHMENT 8.1.14.5 Page 5 of 7 ACCEPTANCE CRITERIA OBJECTIVE ACCEPTANCE CRITERIA 25 Demonstrate the ability to alert and advise individuals This objective is met when individuals receive, who are visitors, contractors, and members of the understand, and respond as required to notifications public onsite. provided by alarms and PA.

26 Demonstrate the ability to evacuate non-essential This objective is met when personnel are sent to an personnel from site to be monitored and offsite location for decontamination. (Actual transport decontaminated at an offsite location. may be simulated.)

27 Demonstrate the ability to monitor, decontaminate and This objective is met when personnel are able to discuss evacuate non-essential personnel from site. decontamination procedures.

28 Demonstrate the ability to account for individuals in the This objective is met when accountability is completed protected area and identify the names of those within 30 minutes.

unaccounted for within 30 minutes.

29 Demonstrate the ability to provide ERO personnel This objective is met when adequate supplies are protective clothing, respiratory protection, dosimetry, available and dose records are maintained during the drill.

and radioprotective drugs. This also includes determination of doses received and maintenance of dose records 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

'10CFR50.47 l EPPRO-01 I Rev. 15 l Page 31 of 34

( C (7 ATTACHMENT 8.1.14.5 Page 6 of 7 ACCEPTANCE CRITERIA OBJECTIVE ACCEPTANCE CRITERIA 30 Demonstrate the ability to establish onsite exposure This objective is met when emergency worker and guidelines consistent with EPA emergency worker and lifesaving exposure guidelines are implemented.

lifesaving activities.

31 Demonstrate the ability to provide onsite first aid This objective is met when First Responders have capability. provided initial treatment and the victim(s) have been delivered to the rescue squad. (Portions may be simulated as a control cell.)

32 Demonstrate the ability to reassess plant conditions This objective is met when a recovery plan and an and evaluate recovery/reentry considerations. organization is formulated.

33 Demonstrate the ability to augment the ERO, during an This objective is met when augmentation is successfully Exercise, between 6:00 p.m. and 4:00 a.m. or any completed between the hours of 6:00 p.m. and 4:00 a.m.

weekend hours. or any weekend hours.

34 Perform Radiological Monitoring Drills which involve This objective is met when environmental measurement collection and analysis of all sample media (e.g., water, through analysis of water, vegetation, soil, and air sample vegetation, soil and air), and provisions for media have been completed, recorded and communications and record keeping. communicated.

35 Perform fire drills which demonstrate the ability of the This objective is met when the fire brigade arrives at the fire brigade to respond to a fire and interface with scene with appropriate equipment and offsite fire offsite fire assistance. assistance is coordinated. (Portions may be simulated as a control cell.)

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C c ATTACHMENT 8.1.14.5 4,

Page 7 of 7 ACCEPTANCE CRITERIA v ~~~~~OBJECTIVE ACCEPTANCE CRITERIA 36 Perform medical emergency drills which demonstrate This objective is met when First Responders arrive at the the ability to deal with a medical emergency involving a scene and offsite assistance is coordinated. (Actual simulated contaminated individual including transport may be simulated. Off-site medical treatment participation of off site medical treatment agencies. may be demonstrated in conjunction with the medical services (MS-i) drill.)

37 Perform Health Physics Drills which involve response This objective is met when response and analysis is made to, and analysis of, simulated elevated airborne and to simulated elevated airborne and liquid samples and liquid samples and direct radiation measurements in direct radiation measurements in the environment. Credit the environment. may be taken for participation in the medical services

_ ___ _________________ ___ ___ ___ ____ ___ ___ ___ ___ ___ ( M S- i) drill.

38 Perform an offsite hazards drill which will involve This objective is met when an offsite hazard is included in response to and analysis of simulated offsite hazards a drill or exercise and protective measures are taken and (example chlorine, propane, hydrogen, gasoline or the hazard is measured for the protective measures.

some other offsite hazard either natural or man made).

Samples, measurements as well as protective

_____measures should be taken.

39 Perform a critique at the conclusion of an exercise to This objective is met when facility critiques have been evaluate the ability of organizations to respond as conducted.

______ required.

40 Demonstrate that NRC identified open items resulting This objective is met by successful demonstration of the from previous exercises are corrected. task in the area(s) of concern.

41 Demonstrate use of SCBAs including field change out This objective is meet when actual use of SCBAs and of spare cylinder, change out of cylinder are demonstrated.

42 Demonstrate the ability to control radiological exposure This objective is met when the need for radioprotective to emergency workers including the issuance of drugs has been determined in accordance with applicable l__ radioprotective drugs. procedures.

i1OCFR5O0.47 lEPPRO-Ol Rev. 15 lPage 33of 34l

ATTACHMENT 8.1.14.6 Page 1 of 1 Guidelines for Emergency Response Organization (ERO) Critiques Critiques are an important part of the process of self-identifying problems and improvements for the Emergency Response Organization. The following are guidelines for conducting a facilitated critique of the Emergency Response Organization.

Critique Process The facility leader should conduct a facilitated critique as follows: INIT.

1. Assign someone to record the critique notes.

2. Ask for input on each objective and the acceptance criteria on the facility listing.

3. After the participants for each position have completed their input, ask for input from the position evaluators.

4. Probe to identify

• Flawed defenses

• Error precursors

• Weak organizational processes.

4. Consider the following elements:

• Results

• Behaviors

• Task demands

• Work environment

• Individual capabilities

5. If problems are identified, prior to continuing, determine whether the problem should be:

a) identified in a Condition Report (CR),

b) identified on an EP Improvement Form (EPIF), or c) included in the critique as a general comment.

If a Condition Report or EP Improvement Form is warranted, ensure critique participants identify who is responsible to initiate and evaluate the CR or EPIF, and document this in the critique notes.

6. Identify any remediation due to less than acceptable performance and document the recommended remediation in the critique notes.

7. After all of the objectives have been addressed, ask for any general comments from:

• Participants

• Controllers/Evaluators

• NAS

• NRC _

8. Instruct the note taker to electronically transmit the critique notes to EP prior to the Lead Evaluator /Controller Critique (roll-up).

EPPRO-01 I Rev. 15 l Page 34 of 34