Nrc Inspection Manual Nrr/Nmss

NRC INSPECTION MANUAL NRR/NMSS

INSPECTION PROCEDURE 82501

DECOMMISSIONING EMERGENCY PREPAREDNESS PROGRAM EVALUATION

PROGRAM APPLICABILITY: 2561

82501-01 INSPECTION OBJECTIVE

To determine whether the licensee's emergency preparedness program is maintained in a state of operational readiness and whether changes made to the licensee's emergency preparedness program since the last inspection continue to meet commitments, the Nuclear Regulatory Commission (NRC) requirements, and have not negatively affected the licensee's overall state of emergency preparedness (EP).

This inspection procedure is applicable to nuclear power reactor licensee site(s) that are permanently shut down in accordance with 10 CFR 50.82(a) and is / are not located on a site with an operating nuclear power reactor. Decommissioning power reactor licensees retain their Part 50 or Part 52 license after permanent shutdown and remain subject to the same EP requirements as operating power reactors until an exemption request is submitted and approved by the NRC. The exemption must then be appropriately implemented in the licensee’s emergency response plan (E-plan) before compliance with the given regulation is no longer required. NSIR/DPR-ISG-02 “Interim Staff Guidance Emergency Planning Exemption Requests For Decommissioning Nuclear Power Plants,” provides guidance for processing exemptions to the EP requirements for nuclear power reactors that are undergoing the process of decommissioning, previously approved exemption request(s), the rationale for the approval and the approximate time table for exemption approvals. Inspectors should review this document for information as to what exemptions could be expected for a given licensee’s point in the decommissioning process. This procedure is not applicable to sites at which all fuel is removed from the spent fuel pool (SFP) and placed in dry cask storage.

82501-02 INSPECTION REQUIREMENTS

02.01 Review current E-plan and approved exemption request(s) since the last inspection for understanding and appropriate implementation.

02.02 Perform, as applicable to the licensee’s current E-plan, the following attachments.

a.  Maintenance of Emergency Preparedness (Attachment 01)

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b.  Emergency Response Organization Staffing and Augmentation System (Attachment 02)

c.  Emergency Action Level and Emergency Plan Changes (Attachment 03)

d.  Alert and Notification System Evaluation (Attachment 04)

82501-03 INSPECTION GUIDANCE

The following inspection guidance section and attachments provide methods and examples of how the inspection requirements could be completed. Use of the following guidance is at the discretion of the inspector.

03.01 Review approved exemption request(s)

a.  Review the approved regulatory exemption request(s) applicable to EP and determine what attachments to this inspection procedure are applicable to be performed.

b.  Review the sections affected by approved regulatory exemption(s), if any, of the licensee’s current E-plan to ensure appropriate implementation.

03.02 Perform, as applicable to the licensee’s current E-plan, the attachments to this procedure.

82501-04 RESOURCE ESTIMATE

Recommended average annual inspection hour efforts for this inspection procedure’s attachments are listed below. Actual inspection hours will be expected to move toward the lower end of the range as exemptions are submitted and approved.

·  Attachment 1 between 9 and 20 hours

·  Attachment 2 between 6 and 10 hours

·  Attachment 3 between 3 and 5 hours

·  Attachment 4 between 2 and 5 hours.

82501-05 PROCEDURE COMPLETION

This procedure is considered complete when applicable inspection requirements listed in the procedure have been satisfied. For the purpose of reporting completion in the Reactor Program System (RPS), the sample size is defined as 1. A sample size of 1 will be reported in RPS when the procedure is completed in its entirety.

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82501-06 REFERENCES

NSIR/DPR-ISG-02 “Interim Staff Guidance for Emergency Planning at Decommissioning Sites”

IN 05-19, “Effect Of Plant Configuration Changes On The Emergency Plan” (ML051530520)

RG 1.219, “Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors”

NUREG/CR-4831, “State of the Art in Evacuation Time Estimate Studies for Nuclear Power Plants,” March 1992.

NUREG/CR-6863, “Development of Evacuation Time Estimates for Nuclear Power Plants,” January 2005.

NUREG/CR-6451 “A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants” (ML082260098)

NUREG/CR-7002, “Criteria for Development of Evacuation Time Estimate Studies

NEI 10-05, “Assessment of On-Shift Emergency Response Organization Staffing and Capabilities”

FEMA REP-10 “Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants” (ML102510343)

NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants"

NSIR/DPR-ISG-01, “Interim Staff Guidance Emergency Planning for Nuclear Power Plants”

END

Issue Date: 09/04/14 3 82501

ATTACHMENT 1

MAINTENANCE OF EMERGENCY PREPAREDNESS

01.00 INSPECTION OBJECTIVE

Evaluate the efficacy of licensee efforts to maintain their Emergency Preparedness (EP) programs by verifying accurate and appropriate identification and correction of EP weaknesses during actual event critiques, drill and exercise critiques, program assessment activities (e.g., EP reviews performed in accordance with 10 CFR 50.54(t)) as well as review of Letters of Agreement (LOA) and/or Memorandums of Understanding (MOU), 10 CFR 50.54(q) plan change process and practice, and licensee maintenance of facilities, systems, and equipment important to emergency preparedness, record(s) of evacuation time estimate (ETE) population evaluation and E-plan provisions for, and implementation of, primary, backup and alternate emergency response facility (ERF) maintenance [10 CFR Part 50.47(b)(10) and Appendix E IV.3, 5 & 6; IV.E.8.b]

02.00 INSPECTION REQUIREMENTS

02.01 Review the licensee’s corrective action program (CAP) for EP issues.

02.02 Review documentation for all actual events that resulted in the implementation of the
E-plan since the last inspection to determine the adequacy of licensee actual event response.

02.03 Review all EP-related corrective actions identified in any actual event self-assessment for effectiveness and timeliness of completion.

02.04 Review a sample of drill and exercise critique documentation to determine if EP weaknesses are being properly identified and entered into the CAP.

02.05 Review a sample of EP corrective actions for effectiveness and timeliness of completion.

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

02.07 Review a sample of EP corrective actions from other EP self-assessment documents, such as QA assessments of EP program elements, for effectiveness and timeliness of completion.

02.08 Review LOA and/or MOU that support the E-plan for appropriate content and to verify they have not expired.

02.09 Review 10 CFR 50.54(q) plan change process and practice.

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02.10 Review licensee maintenance of facilities, systems, and equipment important to emergency preparedness.

02.11 Review licensee record(s) of evacuation time estimate (ETE) population evaluation.

[10 CFR 50.47(b)(10) and Appendix E.IV.3, 5 & 6]

02.12 Review licensee E-plan provisions for, and implementation of, primary, backup and alternate emergency response facility (ERF) maintenance. [10 CFR Part 50.47(b)(8) Appendix E §IV.E.8.a(i), a(ii), b, c, d & e]

03.00 INSPECTION GUIDANCE

The primary focus of this inspection is to evaluate the efficacy of a licensee’s ability to identify and correct EP weaknesses.

The following inspection guidance section and attachments provide methods and examples of how the inspection requirements could be completed. Use of the following guidance is at the discretion of the inspector.

03.01 Review licensee procedures for the following areas to ensure there is an adequate level of guidance to meet the required area task.

a.  EP CAP

b.  Identification of EP weaknesses and/or deficiencies during an actual event or during drills and exercises.

c.  EP Audits

d.  EP Program Reviews

e.  Critique Conduct

Note: responsibility for conduct of critiques may be assigned to multiple departments, (e.g., Quality Assurance for audits, Emergency Preparedness for EP drills and exercises, and Operations Training for simulator evolutions).

03.02 Determine the adequacy of licensee actual event response by:

a.  Reviewing E-plan implementation documentation since the last inspection for:

1.  Documentation of notification forms

2.  Thoroughness and accuracy of logs

3.  Completeness of checklists.

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b.  Determine if:

1.  The licensee effectively implemented the requirements of the E-plan.

2.  Classifications, notifications and, if performed, protective action recommendation (PAR) development were timely and accurate. [10 CFR Part 50.47(b)(10)]

Note: Actual event E-plan implementation may be inspected under the event follow-up inspection.

c.  Ensuring all EP weaknesses identified during the inspector’s review of event records were entered into the CAP program.

d.  Determine if licensee corrective actions for weaknesses occurring during an event were timely and effective consistent with the safety significance of the condition.

03.04 Review a sample of licensee self-assessments of drill and exercise performance (if available) to verify that:

a.  Weaknesses identified for classification, notification and PARs are appropriately documented in the CAP. [10 CFR Part 50.47(b)(10)]

b.  Emergency preparedness implementing procedures forms and checklists used to support and document classification, notification, and PAR development are consistently and accurately used.

[10 CFR Part 50.47(b)(10)]

c.  Documentation summaries of the drill and exercise critique and scenario are consistent and accurate.

d.  The critique process properly identifies performance weakness (es) in classification, notification, PARs and does assessment activities. [10 CFR Part 50.47(b)(9) & (10)]

03.05 Review lists of EP-related CAP entries initiated and closed since the previous inspection. Select samples from each category to review for the effectiveness of correction actions, based on the following:

Note: Although 10 CFR 50.47(b)(14) requires that exercise weaknesses be identified and corrected, licensees may enter other deficiencies (e.g., procedure deficiencies, instrument failures, etc.) into its corrective action program. Both categories should be included in the sample selection.

Note: If corrective actions appear to be complete, but not yet fully effective, consideration may be given to allow more time for performance improvement. Future drills and exercises would be expected to show such improvement. Actions taken by the licensee to enhance or improve performance need not be evaluated for effectiveness.

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a.  Review all corrective actions associated with classification, notification, PAR development, and dose assessment and note any degraded performance.

[10 CFR Part 50.47(b)(9) & (10)]

b.  Select a sample of corrective actions from other EP areas for review. The guidance provided in Attachment 5 “Prioritization of Additional Areas for Inspection” may be used to select other areas for review.

c.  If repeat items or trends are noted in corrective actions:

1.  Determine whether corrective actions should have precluded recurrence. Determination of a failure to correct a drill or exercise weakness requires a detailed review of the weakness and the associated corrective actions.

2.  Determine if the licensee identified the trend or repeat weakness and entered it into the corrective action system. A single repetition of a weakness should not automatically be deemed an ineffective corrective action. Conversely, a single successful demonstration of a weakness should not necessarily be considered an effective corrective action.

d.  Select a sample of closed corrective actions and perform a review to assess the completeness and effectiveness of the corrective actions.

1.  Review the specific corrective actions for that weakness and similar occurrences of that weakness in actual events, drills, exercises, and training evolutions.

2.  Review relevant corrective actions, self-assessments, and inspection records for the inspection cycle with an emphasis on similar weaknesses.

3.  Assess corrective action effectiveness based on the complete history of the issue. Obtain a complete picture of the current problem by reviewing previous corrective actions to identify any pattern(s) of recurring performance problems in similar activities that would identify other ineffective corrective actions.

e.  Select a sample of corrective actions for equipment and facilities or other areas of EP as deemed appropriate. Perform a detailed review of: [10 CFR Part 50.47(b)(8) Appendix E §IV.E.8.a(i), a(ii), b, c, d & e]

1.  Closure documentation,

2.  Corrective actions taken, and

3.  Consistency of in-field completed corrective actions and the closure documentation.

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f.  In reviewing the corrective actions, remain alert to program elements that have few or no corrective actions recorded. Although the program elements may very well not warrant a corrective action, the lack could be evidence of a deficient critique. The inspector should inspect that area for compliance with the E-plan commitments.

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

a.  Evaluate adequacy of audits for compliance with regulatory requirements.

b.  Determine if the scheduling of audits is consistent with regulatory requirements and licensee program changes.

1.  If the licensee is using the 10 CFR 50.54(t)(1)(ii) option, review the licensee’s performance indicators (See statements of consideration at 64 FR 14814 dated March 29, 1999).

c.  Review the effectiveness of a sample of corrective actions resulting from the audit. Prioritization should be given to problems associated with classification, notification, dose assessment activities and PAR development. [10 CFR Part 50.47(b)(4), (5), (9) & (10)]

d.  Select a sample of corrective actions from other EP audit areas for review. The guidance provided in Attachment 5, “Prioritization of Additional Areas for Inspection,” to this procedure, may be used to select other areas for review.

03.07 EP self-assessment corrective actions.

a.  Review a sample of corrective actions from other EP self-assessment documents, for example:

1.  QA assessments of drill and exercise performance

2.  Emergency response organization (ERO) readiness

3.  EP facility readiness [10 CFR Part 50.47(b)(8) Appendix E §IV.E.8.a(i), a(ii), b, c, d & e]

b.  Review the disposition of the sample of corrective actions identified.

c.  Determine if the licensee’s sampled corrective actions were timely and effective.

03.08 Review the licensee’s annual review / update of LOAs/MOUs described in the E-plan to be updated as needed and reviewed to be current on an annual basis. Verify that:

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Note: In general, LOAs/MOUs with Federal agencies with emergency planning responsibilities are not needed, since the Federal agencies are required by law to provide assistance. However, the inspector should be alert to instances in the E-plan where it may be appropriate for a letter of agreement with a local Federal office or representative of a Federal agency, such as a local Coast Guard station.

a.  Arrangements for offsite response organization (ORO) resources remain in effect and have not expired.

b.  The type and extent of ORO resources needed to support onsite response activities during an emergency including hostile action have been identified and documented.