ML20195H662

Draft NRC Inspection Manual,Inspection Procedure 71114, Reactor Safety - Emergency Preparedness

ML20195H662
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Issue date:	05/07/1999
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71114, NUDOCS 9906170109
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EPPRO.WPD NRC INSPECTION MANUAL PIPB INSPECTION PROCEDURE 71114 REACT (> SAFETY - EMERGENCY PREPAREDNESS 71114-01 INSPECTION OBJECTIVE 01.01 The objective of this procedure is to gather information to determine, in conjunction with the performance indicators, whether a licensee is meeting the objectives of this cornerstone which are to ensure that the licensee is capable of implementing adequate measures to protect the public health and safety during a radiological emergency 71114-02 INSPECTION REQUIREMENTS 02.01 Baseline inspection requirements are identified in each of the attached inspectable areas of; Drill and Exercise Inspection (Attachment 01)

Alert and Notification System Testing (Attachment 02)

Emergency Response Organization Augmentation Testing (Attachment 03)

Emergency Action Level Changes (Attachment 04)

Problem Identification and Resolution (included as part of each inspectable area) 02.02 These recuirements represent the minimum inspection activity to be conductec at each reactor site at the frequencies shown in each inspectable area.

02.03 The effectiveness of each licensee to identify and resolve problems in i' this cornerstone area will also be inspected annually using the baseline inspection program procedure for evaluating licensee Problem '

Identification and Resolution programs.

02.04 Evaluations of emergency plan changes are conducted under the Reactor ,

Safety inspectable area:  !

Changes to License Conditions and Safety Analysis Report  ;

02.05 The accuracy of licensee reported performance indicator data will also j be inspected annually using the baseline inspection program procedure -

for performance indicator Verification.

71114-03 INSPECTION GUIDANCE 03.01 Three perfo'rmance indicators exist in this cornerstone.

a. The " Drill and Exercise Performance" Performance Indicator in this cornerstone monitors timely and accurate event classifications, timely and accurate notifications of offsite authorities and timely and accurate protective action recommendations Issue Date: 5/07/99 ~

71114 DRAFT 9906170109 990520 PDR REVGP ERGNUMRC PDR ,

b. The " Emergency Response Organization Participation" Performance Indicator monitors emergency response organization readiness.

c. The " Alert and Notification System Reliability" Performance Indicator monitors availability of the alert and notification system.

l 03.02 Disposition of findings

a. A Significance Disposition Process has been developed for assessing the significance of inspection findings. The process determines Agency disposition of the finding. The level and type of licensee inspection is determined through the significance and number of Inspection findings and the status of performance indicators.

b. Findings that are related to the problem identification and resolution program should be passed on to the team leader for the annual inspection of that area.

c. Weaknesses and deficiencies identified by the licensee in evaluated exercises are not considered findings. However, the insp'ector must ensure that such items are entered into the licensee corrective action system in a manner that will allow review during the subsequent two evaluated exercises.

d. Appendix E Section IV.F.4.g. of 10 CFR 50, requires that weaknesses and deficiencies be corrected. Inspectors are ex)ected to review the correction of licensee and NRC identified weacnesses and deficiencies.

However, in the case of personnel performance, a repeat performance problem may not in itself, represent a failure to correct. The inspector must ' review licensee efforts to correct the item and the reasons for the repeat problem. If the problem is localized it would not be appropriate to determine that it represents a failure to resolve in the significance determination process.

03.03 Risk Significant Areas Implementation of the Emergency Plan (the Plan) is de)endant on the performance of the emergency response organization (ERO) in their emergency preparedness (EP) assignments. There are many areas im)ortant to Plan l implementation, but the most risk significant areas of ERO perforence are:

a. Timely and accurate classification of events: including the recognition of events as potentially exceeding emergency action levels and any assessment actions necessary to support the classification.

b. Timely and accurate notification of offsite covernmental authorities; including adequate performance of notifications to state and local authorities as specified in the Emergency Plan. )

c. Timely and accurate develooment of orotective action recommendations for offsite authorities; including providing protective action recommendations (PARS) to governmental authorities, the decision making process to develop the PARS and any accident assessment necessary to support PAR development.

03.04 Prioritization of Additional Areas for Inspection DRAFT 71114 Issue Date: 5/07/99

Guidance for prioritization of inspection resources in deployment beyond the  !

risk significant areas'is provided below. These areas may generally be '

considered in order of 1m)ortance. Selection should be based on knowledge of l

the program, previous prol.l ems and logistics.

a. ability to assess the affect and magnitude of radioactive releases (e.g., dose projection, source term determination and use of survey data) (50.47(b)9),

b. adequacy of worker protection, including accountability, evacuation, exposure authorization and thyroid protection (50.47(b)(11),

c. adequacy of interface with offsite authorities, e.g., in.the area of PAR communication and technical support (50.47(b)(6),

, d. timely activation of facilities (50.47(b)(2).

E e. ability to use assessment information to 3rioritize mitigation and assessment efforts to lealth and safety,

f. command and control,50.47(b)(1),

(protect the public

g. ability to diagnose plant accident conditions,

h. ability to formulate mitigating actions, i 1. ability to implement mitigating actions (e.g., damage control teams) under accident conditions, and

j. readiness and quality of EP equipment and facilities. (50.47(b)(8).

71114-04 REFERENCES

a. NEI 99-02 Regulatory Assessment Performance Indicator Guideline

b. -Emergency Preparedness Position (EPPOS) on Timeliness of Classification of Emergency Conditions, EPPOS No. 2

c. Emergency Pre)aredness Position (EPPOS) on Emergency Plan and Implementing 3rocedures Changes EPPOS No. 4

d. Inspection Procedure 52117. Problem Identification and Resolution.  !

71114-05 INSPECTION RESOURCES  !

Estimates'of inspection resources are identified within each inspectable area.

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ATTACHMENT 01 i

INSPECTABLE AREA: Drills Exercises and Actual Event Evaluation CORNERSTONE: Emergency Preparedness INSPECTION BASES: This ins)ection verifies aspects of the Emergency Preparedness Cornerstone for w1ich there are no indicators to measure performance. This Inspection evaluates the licensee problem identification and resolution program (PI&R) as it relates to performance during drills, 3 exercises, identified training evolutions and actual events.

The Drill / Exercise Performance (DEP) performance indicator (PI) measures licensee performance in specific risk significant performance activities. The Emergency Response Organization Participation (ERO) PI provides an indication of licensee efforts to maintain emergency preparedness (EP) through the conduct of and emergency response vganization participation in drills.

Through evaluation of performance a drills, exercises and training evolutions, the licensee PI&R is upected to ensure adequate emergency plan implementing procedures (EPIP) quality, facility and equipment readiness and Emergency Response Organization proficiency. The efficacy of the EP training program is reflected in the adequacy of Emergency Response Organization performance. This inspection evaluates the adequacy of the licensee PI&R in meeting this expectation.

LEVEL OF EFFORT: The level of effort for this inspectable area encompasses three related activities:

a. Inspection of the EP related PI&R to evaluate the program effectiveness as well as identify issues worthy of inspection during the evaluated exercise. This is performed by regional specialists.

b. Inspection of selected drills and training evolutions to validate that the licensee is appropriately identifying classification, notification and PAR opportunities and the assessing success or failure of performance in those opportunities. This is performed by the Resident Inspector.

c. Inspection of the Biennial Exercise to evaluate the licensee PI&R as it relates to ERO performance, 3rocedure quality, ERO readiness and facilities and equipment. T11s is performed by the Resident Inspector and regional specialists.

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l The expected resource allocation is as follows:

Event Review of PI&R Drills and Biennial Exercise Training Evolutions l

l EP Specialists 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Resifent 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> l Fregt ency biennial 1 drill / year biennial l

2 training evolutions /

, year  !

-01 INSPECTION OBJECTIVE

' 01.01 Evaluate the EP related PI&R for effectiveness and to identify issues worthy of inspection during the evaluated exercise.

01.02 Evaluate the conduct of selected drills and training evolutions.

01.03 Evaluate licensee conduct and assessment of the Biennial Exercise.

-02 INSPECTION REQUIREMENTS:

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02.01 Evaluate EP related PI&R l Review licensee procedures applicable to the PI&R as related to the EP program.

a. Review actual emergency plan activations and determine if the licensee effectively implemented the requirements of the Plan. Paview licensee self assessment of actual events.

b. Review the effectiveness of all licensee EP related corrective actions assigned as a result of an event self assessment.

c. Review drill scenarios and critiques and determine whether the self assessment properly identified failures to implement the Plan or EPIPs.

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d. Review a sample of corrective actions identified as a result of drill self assessment.

e. Review audit (s) performed in accordance with 10 CFR 50.54(t).

f. Review a sampling of other self assessment documents, as available (e.g., 0A assessments).

g. Determine if there are any PI&R issues that are appropriate for reyiew during the biennial exercise to determine the effectiveness of j corrective actions. ]

l 02.02 Drill and Training Evolution Observation DRAFT 71114 Issue Date: 5/07/99 i 1

a. Plan to inspect drills and simulator based training evolutions in which shift operating crews participate.

b. Observe the drill / training evolution.

c. Compare ins)ection findings against licensee identified findings to determine w1 ether the licensee is properly identifying failures in clanification, notification and protective action recommendation (PAR) development activities.

d. Determine whether licensee assessment of performance is in accordance with the applicable criteria.

02.03 Biennial. Exercise

a. Plan to inspect the biennial exercise.

b. Develop independent observations of licensee performance in classification, notification and PAR development activities and the l other areas during the exercise.

c. Observe the licensee's presentation of exercise findings to upper levels of site management and determine if the licensee critique l identified the problems observed by the inspection team. )

d. Identify trends. repeat failures and areas of 1 represent a failure to meet a planning standargerformance that may

e. Identify and performance areas that may indicate a programmatic problem I worthy of additional review.

f. Represent NRC at the FEMA public meeting.

g. Determine whether licensee performance in conduct of the exercise is adequate.

-03 Inspection Guidance 03.01 Review of PI&R The primary focus of this inspection is to evaluate the )

efficacy of the licensee PI&R program as related to EP. However, this inspection provides an opportunity to identify areas for inspection during the biennial inspection. For this reason it is conducted in conjunction with the biennial inspection. This creates the need for advance planning with the licensee to provide the necessary files for review without adversely impacting preparations for the exercise.

a. Review procedures applicable to the PI&R as related to EP activities.  ;

Responsibility for conduct of PI&R may be assigned to multiple departments, e.g., Quality Assurance for audits. Emergency Preparedness for drills and Training for simulator evolutions. Include PI&R related ,

procedures for actual events, drills, exercises audits, program reviews and performance indicator systems. 4

b. For every actual emergency plan activation since the last inspection (if any), review all facility event related documentation including:

notification forms, logs and checklists. Based on event documentation.

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independently determine if the licensee effectively implemented the

. requirements of the Plan. Specifically, consider the timeliness and accuracy of classification, notification and PAR development. (Note:

' events requiring actual emergency plan activation may be inspected under the event follow up inspection) Review licensee implementation of ,

other aspects of the Plan as appropriate to the event. Consider the l completeness of records. Review licensee self assessment of events. '

Compare the licensee self assessment against the inspector's independent evaluation of records of the event (s) to determine if the i

licensee correctly identified issues for resolution. Consider any evaluation documented by the resident inspector concerning event response.

, c. Review the effectiveness of all licensee corrective actions assigned as l a result of an event self assessment. Determine the effectiveness of licensee corrective actions.

d. Select a sample of drills (if available) for review of licensee self assessments. Review critiques scenario summaries and EPID forms and checklists used to sup3 ort and document classification, notification and PAR development. rom review of drill documentation, determine whether the self assessment 3roperly identified failures to implement the Plan or EPIPs in the risc significant areas and other areas. Use the prioritization guidance provided to select other areas for review.

e. Review a sample of corrective actions identified as a result of drill self assessment. The sample should include all corrective actions associated with classification, notification and PAR development activities. Additional corrective actions should be selected from across the remaining response areas in accordance with the prioritization guidance provided in the General Guidance Section. For i repeat items or trends determine whether corrective actions should have '

precluded recurrence. ,

1 I f. Review audit (s) performed in accordance with 10 CFR 50.54(t). Evaluate adequacy of audits to comply with regulatory requirements. Determine whether the timeliness of audits is consistent with regulatory l requirements and licensee program changes. Review the effectiveness of I a sample of corrective actions identified. Prioritization should be given to problems associated with classification, notification and PAR l development activities. A sample of corrective actions fr~n other i

areas should also be reviewed.

g. Review a sampling of other self assessment documents, as available (e.g., OA assessments). Review the disposition of a sample of the L corrective actions identified. Determine if problems identified in the l self assessments were addressed in an appropriate and timely manner. I i

h. Select a sampling of ERO performance and/or EP equipment related problems identified and/or problems that were resolved, for insoection during the biennial exercise. Prioritize problems in the risk significant areas highest, but if there are important problems in other areas, an attempt should be made to allocate resources in manner that will allow inspection of those areas. Use the prioritization guidance provided to identify areas for inspection.

DRAFT 71114 Issue Date: 5/07/99 i

For further guidance on the ins 3ection of R EP related PI&R rogram, l see Inspection Procedure 71152 3roblem Identification and Reso ution Procram.

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03.02 Drill and Trainino Evolution Observation. The primary focus of this )

inspection element is to verify licensee self assessment of l classification, notification and PAR development during drills and l training evolutions identified as contributing data to the Drill and Exercise Performance PI.

a. Obtain the licensee's schedule of drills and trainin evolutions that will contribute to EP PI statistics. Inspect 1 dril and 2 simulator )

j based training evolutions in which shift operating crews partici) ate.

'The resident may aerform this activity unannounced. Note that t1e licensee is not o) ligated to include any simulator based training in the PI statistics. 4 Review the selected scenario to identify the timing and location of j classification, notification and PAR development activities and for

-licensee expectations of ERO response. Responsibility for classification, notification and PAR development activities may transition from control room to TSC to E0F.

Review the EPIPs that provide instructions for classification, notification and PAR development activities, to develop an understanding of successful implementation.

b. Observe the drill / training evolution. Review checklists and forms used for classification, notification and PAR development activities.

Determine whether the drill / training evolution is of appropriate scope to be included in the PI statistics. See the reference section for the 1 guidance document. '

c. Compare ins)ection findings against licensee identified findings to determine w1 ether the licensee is properly identifying failures in classification, notification and PAR development activities. Verify that the licensee properly dispositions failures. The failures themselves are not an issue, unless the PI falls below the threshold warranting increased NRC involvement.

Note: Drill and training evolutions activities are only included at the discretion of the licensee. Additionally, the licensee may wish to collect "as found" operator proficiency information.

d. Determine whether licensee assessment of performance is in accordance with the applicable criteria. Refer any discrepancies to regional management.

03.03 Biennial Exercise. The focus of this inspection element is to evaluate.

licensee self assessment of Emergency Response Organization performance. Emphasis should be placed on licensee assessment of classification, notification and PAR development activities, but the inspectors will also evaluate other as)ects of performance and assessment. Poor performance during t1e exercise will be assessed through the Drill and Exercise Performance PI. However, poor performance could indicate that the EP program has deteriorated to a point where it that no longer meets a planning standard. The inspection team should further assess such areas.

Issue Date: 5/07/99 71114 DRAFT

a. Obtain a copy of the scenario and review for a summary understanding.

Identify the opportunities for classification, notification and PAR development activities. Ensure the understanding is consistent with licensee understanding or note differences.

Develop a plan to deploy inspection resources in a manner to observe as man" classification, notification and PAR develo) ment activities and oths activities as resources allow. Consider t1e prioritization guidance provided in the general guidance section. Selection of other areas for inspection should be based on resource availability past history, PI&R program concerns and/or practical logistical limitations.

Review for understanding, licensee Emergency Plan and EPIPs that provide requirements and implementation instructions for classification, notification and PAR development activities. Develop an understanding of the criteria for successful completion of these activities based on EPIPs and the scenario. The reference section provides the guidance document.

Review the 3revious biennial exercise inspection report and licensee critique. Review critiques and where available. 0A reports, from a sampling of drills since the previous biennial exercise. Review problem areas identified during the review of the PI&R program, those identified by the previous inspection team and those identified by the licensee. Consider trends, repeat items and items that could represent.

a failure to implement or meet a planning standard. Compile a list of these items for inspection during the exercise.

b. During the exercise, develop independent observations of licensee performance in classification, notification and PAR development activities and the other areas selected. Gather copies of completed forms and checklists that support or document classification, notification and PAR development activities and other areas selected for inspection. Inspector observations of the exercise must be held confidential until after the formal licensee critique. Following the exv tise, observe licensee critiques and evaluator meetings where exercise weaknesses and deficiencies are identified. Observe the licensee's presentation of exercise findings to upper levels of site management.

c. Determine if the licensee critique identified the exercise weaknesses and problems observed by the inspection team. If the inspectors identified exercise weaknesses and deficiencies that the licensee did not, it may be appropriate to discuss those problems with responsible management rather than with the full audience of the formal criticle.

Failures of the licensee PI&R should be documented and assessed. fhose items should be addressed during the NRC exit meeting and assessed for significance. Verify that licensee identified exercise weaknesses and deficiencies are entered into the licensee PI&R in a manner that will allow NRC review of the resolution in the future.

d. Using the results of previous drills and exercises, determine if problems identified by the inspectors and the licensee, represent continuation of a trend or repeat of a failure to implement a planning standard. Determine if the licensee identified the trend or repeat problem. Determine _whether the licensee entered the problem into the corrective action system. For trends and repeat issues, determine ORAFT 71114 Issue Date: 5/07/99 j i

whether the licensee identified the failure in accordance with their corrective action system. Failures of the problem resolution program should be documented and assessed

e. During an exercise (or actual event) a failure to implement a planning standard does not necessarily indicate a failure to meet the planning standard. However, serious failures may indicate a programmatic problem worthy of additional review. Additionally, performance problems may reflect a deterioration of the EP program element to the point that the applicable planning standard is no longer met. Review the PI&R history of the identified problems to obtain relevant information. Determine, immediately if possible, if the program no longer meets the applicable planning standard. If this can not be accomplished immediately, confer with regional management for direction. The concern and the results of the additional review should be communicated to the licensee and assessed for significance,

f. The lead inspector, or alternate, should represent NRC at the FEMA public meeting.

g. The inspection effort should allow the inspection team to make the determination that "the onsite Emergency Plans are adequate and that the licensee is capable of implementing them" or not.

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DRAFT 71114 Issue Date: 5/07/99

ATTACHMENT 02 INSPECTABLE AREA: Alert and Notification System Testing CORNERSTONE: Emergency Preparedness  !

INSPECTION BASES: The alert and notification system (ANS) is a critical link in the system for prompt notification of the public of the need to take protective actions. Assurance that the system has a high rate of availability increases the assurance that the licensee can protect public health and safety during an emergency. The ANS im)lements a portion of the risk significant planningstandard,10CFR50.47(3)(5). A performance indicator (PI). ANS Reliabiiity, addresses performance in this area. However, for the statistics of the PI to be valid, the testing program must be conducted in accordance with guidance. The inspection verifies testing program compliance.

Inspection guidance for systems that do not rely on sirens is under development.

LEVEL 0F EFFORT: Initial implementation of this procedure may require additional effort if design of system tests has not been previously verified.

LOE: 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Biennial. (Initial implementation: 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />)

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-01 INSPECTION OBJECTIVE 01.01 Evaluate the design of the siren system testing program for compliance l with commitments. l 1

01.02 Review siren system and testing program modifications. j 01.03 Review problem identification and resolution program (PI&R) as it applies to the alert and notification system.

-02 INSPECTION REQUIREMENTS 02.01 Siren System Testing Program Evaluation

a. Review design of siren system for understanding.

b. Review the licensee siren system testing procedure and determine compliance.

c. Evaluate testing,

d. Review testing after all maintenance.

e. Observe a siren test and determine the timeliness of data collection.

02.02 Program Review

a. Review changes to the siren system or to the testing procedure.

b. Review the PI&R as it relates to the siren system. j Issue Date: 5/07/99 71114 DRAFT

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c. Determine whether the PI&R has been effective in correcting siren l system problems.

-03 INSPECTION GUIDANCE 03.01 Siren System Testina Proaram Evaluation. Evaluation of the siren  !

system testing program need only be performed once. Subsequent inspections j may make use of the initial evaluation to assess any changes.

J a, Review applicable design documents for the siren system for understanding of features important to testing. System documentation is available in system evaluation reports or may be available from l licensee system descriptions.

b. Review the licen'see siren system testing procedure and determine compliance with commitments. A typical testing procedure would include the elements of NUREG-0654, Appendix 3, as follows:

c. Silent test: every two weeks j

d. Growl test: quarterly and after preventive maintenance is performed

e. Complete cycle test; at least annually i Review testing commitments approved by the Federal Emergency Management l Agency that may justify deviations from the guidance. Consider that some systems are sounded regularly in lieu of the growl and/or silent I tests. '

f. Determine if each test, as performed, actually tests the elements of the system necessary for the system to perform its design function, e.g. , consider if the silent test v*fies the ability of the sirens to receive and process radio signalf 'xtent consistent with the i system design and the test being For example:

e did the siren receive the r 1, e did it process the radio s e did all expected functions responu to the radio signal, and e is the test designed to verify the ability of the siren to process radio signals and perform its design function.

g. Determine if a siren test is required by procedures to be conducted after maintenance that could disable a system function. Determine if such tests are consistently conducted.

h. Observe a siren test and verify that the test is conducted in accordance with procedure and that as conducted it supports the determination made by the inspector in item c above. Review the method used for collection of test data and determine if it is timely, e.g., a siren failure would be recognized in the near term. Some testing processes rely on a visit to the siren to determine test success and siren status. This may delay collection of data for a 3eriod. While this is not desirable, it is acceptable. Inspectors s1ould verify that the data is consistently collected in a reasonable (not absolute) time frame, at least before the next test, but preferably within a couple of DRAFT 71114 Issue Date: 5/07/99

g days. . Verify that data collection (? tJally gathers information on siren status rather than just the. conduct of the test.

-03.02 Program Review

a. Determine if changes to the siren system or to the testing procedure could affect testing results. If such changes have been implemented or are going to be implemented, review the changes to determine adequacy.

If there have been changes to the system, observe a licensee representative conduct a siren test. Determine that the test and/or system, as changed, continues-to meet requirements and the determination made in the evaluation of siren system testing program.

b. Review the system testing record since the last inspection to identify problems that should have been resolved by the licensee's PI&R. Review the disposition of problems, if any, through the licensee PI&R. Review any response to significant events that stressed the siren system, such as high winds, etc. Determine the timeliness of problem resolution efforts made to recover from such events. Determine whether problems are recurrent in certain sirens, or areas and licensee problem

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resolution. Review any spurious siren activations and associated .

problem resolution. l

c. Determine whether the PI&R has been effective in correcting siren system problems.

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Attachment 03 INSPECTABLE AREA: Emergency Response Organization Augmentation CORNERSTONES: Emergency Preparedness INSPECTION BASES: The licensee system to augment the on shift staff with Emergency Response Organization (ERO) members is an important process that supports the ERO Readiness" key attribute of the EP Cornerstone. ERO augmentation is critical to implementing the Emergency Plan in a timely manner and Emergency Plan commitments in this area meet Planning Standard 10 CFR 50.47(b)(2). This inspectable area verifies aspects of the EP Cornerstone for which that are no indicators to measure performance.

LEVEL OF EFFORT: Initial implementation of this procedure may require additional effort if design of augmentation system has not been previously verified.

LOE: 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Biennial. (Initial implementation: 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />)

-01 INSPECTION OBJECTIVES 01.01 To verify that the design of the ERO augmentation system supports )

licensee ability to achieve facility activation goals.

01.02 To verify that the capability to staff facilities within goals is maintained.

01.03 To verify that the licensee problem identification and resolution program as related to ERO augmentation is effective.

-02 INSPECTION REQUIREMENTS 02.01 Review the' design of the augmentation system

a. Determine the licensee commitments to ERO augmentation.

b. Determine that the system as designed, will support augmentation of the ERO in accordance with the facility activation goals.

c. Review status of back up ER0 augmentation system.

02.02 Review of Augmentation System

a. Review changes to the system and process.

b. Review the results of augmentation tests.

c. Review the effectiveness of the PI&R as it relates to ERO augmentation.

d. Review licensee self assessments that relate to ERO augmentation.

Issue Date: 5/07/99 71114 DRAFT

03 INSPECTION GUIDANCE 1 General Guidance l ERO augmentation tests that require personnel to report to their emergency I

response duty locations are not mandatory, but do provide a high level of assurance that activation goals can be met. Many sites have re gnized the value of such " report-in" tests and have committed to perform trem periodically. However, other combinations of testing and verification, if properly implemented, can provide a reasonable level of assurance.

l Commitments on this subject are contained in the licensee Emergency Plan and j may vary between sites.

After initial ins)ection of augmentation system design, subsequent inspections need not repeat t1e review, but should emphasize changes to system design, l conduct of system drills and tests and the effectiveness of the PI&R.

L Soecific Guidance 03.01 Review the design of the augmentation system

a. Review the site Emergency Plan to determine the approved commitment for i l activation of the ERO and associated facility activation goals.

b. Review the design of the augmentation system and processes against facility activation goals and notification methods described in Emergency Plan. _ Process details may be found in emergency plan

. implementation procedures.

l To be effective, augmentation systems must include a set of the l following elements, sufficient to provide reasonable assurance that l

facility activation goals can be met:

e current ERO duty roster that reflects qualified personnel to fill ,

positions. required by the emergency plan, J e a mechanism to ensure a sufficient number of individuals are available to staff their assigned positions (e.g., either j sufficient depth of qualified individuals, normally considered to l be 3 or more, or a formal roster assignment schedule), )

e verification that individuals can respond in a timely manner.

e.g., verification that ERO members live within an appropriate i travel time from their duty locations or through an actual report- l in drill where personnel report to their duty locations and are i timed, e a notification system for individual ERO members, e.g., pagers, automated telephone systems, etc.,

e training of ERO members in proper response to the notification system, e procedures for system activation, e personnel qualified to activate the system, DRAFT 71114 Issue Date: 5/07/99

1 l o practices and/or procedures that are implemented if the normal augmentation system is not available and e verification of augmentation system ability to ensure facility activation goals can be met, e.g.. unannounced off-hours report-

, in drills, unannounced off-hours " call-in" drills, actual events, etc.

l Determine whether the ERO augmentation system supports facility activation goals.

c. Auomentation Backuo System. Review any tests or implementations of the back-up augmentation system (or practice.) If no tests have been conducted, review the major. elements of the back-up system to determine if they are current, e.g., call-trees and call-out telephone lists. Determine by interview and/or 3rocedure review, whether appropriate personnel know how to implement the bacc-up system.

l 03.02. Review of Augmentation System i i a. Review changes made to the augmentation system hardware, software and l procedures since the previous inspection and determine their impact on the effectiveness of the process. Determine whether the system as i modified, will provide reasonable assurance that the Emergency Plan facility activation goals can be met. Hardware systems, e.g., pagers, may be vendor owned and operated. Changes to these systems may not be apparent, but the licensee is expected to ensure the systems are maintained in proper working order through the conduct of system tests or other surveillance activities. Determine whether system operation is verified by the licensee.

b. Review the results of several augmentation system drills (call-in, report-in, etc.) Include augmentation results from all actual Emergency Plan activations that have occurred since the last inspection. Determine whether the results have been evaluated accurately and that the conclusions reached are valid. Determine whether tests of the system adequately re) resent ERO augmentation, e.g., call-in drills are supplemented wit 1 travel time verification and/or report-in drills are conducted periodically.

c. For problems identified during drills or system tests, verify that the ,

license has initiated immediate corrective actions to assure a i functional augmentation process and that the problem was entered into a licensee corrective action system for final corrective action.

d. Review a sample of the problems identified from augmentation system i drills or system tests performed since the last inspection and assess the effectiveness of corrective actions. Review identified problems to identify trends and repeat failures by individuals. key ERO positions or equipment.

For repeat items, review the associated problem resolution actions to assess the adequacy of the problem identification and resolution program as related to the augmentation testing program. Consider the i

disposition of personnel performance problems as well as equipment l- failures. A repeat item does not necessarily indicate a failure of the problem identification and resolution process in itself. However, a Issue Date: 5/07/99 71114 DRAFT l

trend of repetition of failures that' bring into question the licensee's ability to augment the ERO and activate facilities within committed goals may require additional inspection effort to determine the adequacy of the resolution process. This effort may require interviews with management or other individuals and further review of licensee problem resolution.

For additional Inspection Procedure 52117 Problem Identification and Resolution Programs.

e. Review all licensee self assessments of augmentation drills and testing since the last inspection to determine the coverage and depth of the i assessment, knowledge level of the reviewers, and the proper i classification of the findings. Determine whether identified problems l were placed in the corrective action program and resolved.

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DRAFT 71114 Issue Date: 5/07/99

ATTACHMENT 04 INSPECTABLE AREA: Emergency Action Level Revision Review CORNERSTONES: Emergency Preparedness INSPECTION BASES: Recognition and subsequent classification of events is a risk significant activity because classification leads to activation of the Emergency Response Organization (ERO) and notification of governmental authorities. This activity implements planning standard 10 CFR 50.47(b)(4).

However, if the emergency action level (EAL) scheme has been changed in a manner that decreases its effectiveness. it may not result in the appropriate emergency classification. This inspectable area verifies that the EAL scheme continues to meet the planning standard. There are no indicators to measure performance of this aspect of the Cornerstone.

LEVEL OF EFFORT: Inspection activities in this area include review and assessment of all changes to the EALs.

L0E: 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. Biennial (this is an average across regions and may not be indicative of any single plant)

-01 INSPECTION OBJECTIVE:

01.01 Review all changes to licensee EALs to determine that the changes did ,

not decrease the effectiveness of the Emergency Plan.

-02 INSPECTION REQUIREMENTS 02.01 Review EAL changes to determine that they have not decreased the effectiveness of the Emergency Plan.

-03 INSPECTION GUIDANCE General Guidance All. (i.e., 100 percent), of technical changes to the EALs must be reviewed and approved by NRC. However, need not be reviewed in detail, purely other administrative changes, than to verify that they such asfact, are, in typos. ;

i administrative changes. This effort may be conducted at the regional office.  ;

but is considered direct inspection effort. Changes should be reviewed withing 1 90 days of the time they are submitted. This may not be possible for extensive changes to the EAL scheme. In these cases, the submission is reviewed by headquarters and should be completed within 6 months of receipt.

Specific Guidance 03.01 Review EAL changes

a. Review any submissions of EAL changes. Review supportirig documentation of the licensee's determination that the changes to EALs have not decreased the effectiveness of the Plan as required by 10 CFR 50.54(q).

Issue Date: 5/07/99 71114 DRAFT

c Determine if there was agreement by. State and local government with the EAL changes.

b. Review the Emergency Plan section and emergency plan implementing procedures (EPIP) that contain the EALs to identify changes that have occurred since the last review.

c. Determine that the EPIP and the Emergency Plan EAL scheme are consistent.

d. The basis documents for EALs are generally NUREG-0654 and/or NUMARC/NESP-007 Rev.2 (to be revised as NEI-99-001and/or NEI-97-003 Rev.3). Changes that have been formally approved by NRC or that are consistent with the NRC generic EAL guidance documents are not considered to be a decrease in effectiveness. EAL schemes that deviate substantially from.these documents should be referred to headquarters for review. The reference section provides guidance on review of EALs.

e. Determine whether the change is acceptable and document that determination in accordance with the reference guidance.

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