ML24256A048
| ML24256A048 | |
| Person / Time | |
|---|---|
| Issue date: | 09/12/2024 |
| From: | Jeffrey Herrera NRC/NSIR/DPR/RLB |
| To: | |
| References | |
| Download: ML24256A048 (1) | |
Text
Inspection Observations
Positives
- Exercise Programs have matured, and critique processes are more thorough and streamlined.
- Advancements in notification technologies have provided efficiencies (Ex.
Everbridge).
- But this comes with RISK! (See NRC Information Notice 2023-06: Emergency Telecommunication Services Changes (ML23289A249)).
- Licensee and offsite response organizations relationships appear strong.
- ERO Teamwork seems to be a strength at most exercises.
- Overall decrease in Green and Greater-than-Green findings.
1 Inspection Observations
Enhancement/Improvement Opportunities (Described further)
- 1. Coordination with FEMA/OROs in scenario development.
- 2. Coordination with licensees, FEMA, and the NRC when reviewing/discussing submitted scenarios.
- 3. Inconsistent documentation provided with scenarios for review.
- 5. HAB exercises, 2nd cycle.
- 6. Rad monitor issues continue.
- 7. Siren issues/concerns.
- 8. Implementation of compensatory measures.
- 9. Map-X
2 Inspection Observations
- 1. Coordination with FEMA/OROs in scenario development
- FEMA/OROs typically prefer scenarios that provide a significant release >3 miles from the site. However, this conflicts with the expectations for scenario diversity.
- Historically, when scenarios do not drive this level of a release the FEMA evaluators will typically go off script and inject rad data to ORO players (typically the Field Teams) which causes confusion with ERO staff in the EOF (typically)
- Coordination needs to be improved so that FEMA/OROs can meet their requirements, the scenario can be reasonably diverse, and ad-hoc drill play does not occur.
- The licensee risks non-compliance with 10 CFR 50 App E.IV.F.2.c if FEMA does not have enough demonstrated to provide input to the NRC for this compliance decision.
3 Inspection Observations
- 2. Coordination with licensees, FEMA, and the NRC when reviewing/discussing submitted scenarios
- Both FEMA and the NRC require the licensee to submit their scenarios NLT 60 -days prior to the exercise for review.
- FEMA and the NRC have typically responded, independently, to the licensee.
- Currently we have been piloting (in RII) a coordinated scenario review meeting between the licensee, FEMA, the NRC, and if applicable, ORO scenario review staff.
- This has been around the 45 -day point.
- FEMA has been able to discuss their needs and eventually settle on an outcome that meets their expectations.
- NRC has been able to ensure that the regulatory requirements continue to be met as well as support brain-storming efforts.
4 Inspection Observations
- 3. Documentation provided with scenarios for review
- Submitted scenario packages need to document the applicable regulations for scenario types the licensee is seeking to comply with.
- For example, App E.IV.F.2.b and App E.IV.F.2.c, and any other 8 -year scenario type.
- Note that the 8-year scenarios have been numbered to aid in tracking.
- Submitted scenario packages need to provide a table of EALs used in the previous exercises (not LOR) to allow for an assessment on scenario diversity.
- If fission barrier matrix EALs are used, provide the LOSS and POTENTIAL LOSS criterion that went into the EAL decision.
5 Inspection Observations
- Licensees should be highly encouraged to attend the FEMA debrief, and participate as necessary, prior to the FEMA/NRC post-exercise public meeting.
- If a licensee does not participate, then they will miss any discussions related to enhancements/issues for (b)(5) notifications and communications issues, (b)(9) dose assessments, and (b)(10) protective action recommendations unless these issue rise to a Level 1 finding. While some OROs will let the licensee know, many do not.
6 Inspection Observations
- 5. HAB exercises, 2nd cycle
- Inconsistent demonstration of HAB Alternate Facility
- Licensees and OROs are required, by regulation, to demonstrate response to a HAB scenario once in an 8-year cycle.
- Licensees have been inconsistent with what they demonstrate at the Alternate Facility.
- It should be used as a TSC/OSC and not just an ERO staging area as much as is reasonable possible as this is the one exercise scenario where this facility is used.
- Note that the name of the facility is inconsistently used. Sometimes it is the Alternate Facility and sometimes it is the Alternative Facility.
- Regardless, the facility in question is the one related to HAB response and not the designated backup to the TSC/OSC unless the licensee has it that way in their emergency plan.
7 Inspection Observations
- 5. HAB exercises, 2nd cycle, cont.
- Licensees are reluctant to allow licensee staff pre-staging at the ICP, and the NRC discourages pre-staging at response facilities during exercises due to the desire to evaluate response times.
- However, the ICP is not actually a response facility in the direct control of licensees (other than support and logistics, typically), and FEMA typically allows ORO responders to pre-stage, and typically pre-setup.
- Licensees may consider pre-staging if they choose to in order to support the ICP performance when the non-licensee ICP staff has been pre-staged. This decision is up to the licensee and should be adequately documented in the scenario package if they will be pre-staging at the ICP.
8 Inspection Observations
- 5. HAB exercises, 2nd cycle, cont.
- Licensees should consider ensuring that the RP and Ops Liaisons in the ICP explains the jargon and terminology they use in the ICP.
- For example, if the licensee liaisons say I -131 is not present in the release then they should follow up with how that may affect KI decisions and what it means.
- More realistic drill play with LLEA, Fire, and EMS
- Work on process of site access for off-site organizations for how is it controlled and executed, i.e., dosimetry/badging/screening/etc.
- Also need to ensure that simulated escorts do not use more staff than what would be available
9 Inspection Observations
- 6. Rad monitor issues continue
- Licensees should continue to ensure that these instruments are calibrated effectively and that all calculations are correct.
- Licensees should continue to ensure that their dose assessment model, including all the inputs, are correct.
- Note that exercises demonstrate how the dose assessment model outputs are used with simulated data, not how the model itself works with real data.
10 Inspection Observations
- 7. Siren issues/concerns
- If offsite sirens become non-functional make sure the appropriate OROs are notified, and appropriate compensatory measures are implemented.
- Licensees should clearly document what constitutes siren failure when evaluating test results.
- Foliage growth or other impediments
- As plants mature so does the environments around them. We have seen instances where tree growth has impacted Metrological towers and Sirens. Note that this could apply to structures as well.
11 Inspection Observations
- 8. Implementation of compensatory measures.
- For a compensatory measure to be considered effective, it should have the following supporting documentation:
- The specific EPlan requirement, which could not be implemented as written, was documented.
- An effective compensatory measure or contingency plan was developed in consultation with OROs (as applicable).
- A documented evaluation concluded that emergency response readiness would be effectively maintained during this period.
- The proposed, or planned, date for restoring compliance with the specific EPlan requirement was documented.
- Prior to implementation, all compensatory measures and/or contingency plans are effectively evaluated, documented, and communicated to all applicable licensee staff, ERO staff, and OROs. 12 Inspection Observations
- 9. Map-X (https://mapx.nrc-gateway.gov/)
- Allows licensees to submit NRC Form 361, Event Notification Worksheet, electronically.
- Licensees are still required by regulation to communicate all events directly to the Headquarters Operations Office.
- This electronic form is intended to simplify communication and data management.
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