**NRC INSPECTION MANUAL** NSIR/DPR/ICB

INSPECTION PROCEDURE 71114

REACTOR SAFETY---EMERGENCY PREPAREDNESS

PROGRAM APPLICABILITY: 2515

71114-01 INSPECTION OBJECTIVES

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 Cornerstone Objective and Performance
Expectation.

01.02 The Cornerstone Objective is "To ensure that the licensee is
capable of implementing adequate measures to protect the public health
and safety in the event of a radiological emergency."

01.03 The Cornerstone Performance Expectation is "Demonstration that
reasonable assurance exists that the licensee can effectively implement
its emergency plan to adequately protect the public health and safety in
the event of a radiological emergency."

71114-02 INSPECTION REQUIREMENTS

02.01 Baseline inspection requirements are identified in each of the
attached inspectable areas:

a.  Exercise Evaluation (Attachment 01)

b.  Alert and Notification System Evaluation (Attachment 02)

c.  Emergency Response Organization Staffing and Augmentation System
    (Attachment 03)

d.  Emergency Action Level and Emergency Plan Changes (Attachment 04)

e.  Correction of Emergency Preparedness Weaknesses (Attachment 05)

f.  Drill Evaluation (Attachment 06)

g.  Force-On-Force (FOF) Exercise Evaluation (Attachment 07)

02.02 The requirements found in the attached inspectable areas represent
the minimum inspection activity to be conducted at each reactor site.
The expected frequency of inspection is given in each inspectable area.

02.03 The accuracy of licensee reported performance indicator (PI) data
will be inspected annually using Inspection Procedure (IP) 71151,
"Performance Indicator Verification."

02.04 The licensee program for problem identification and resolution
will be inspected annually using IP 71152, "Identification and
Resolution of Problems."

71114-03 INSPECTION GUIDANCE

[General Guidance]{.underline}

[Performance Indicators]{.underline}

a.  The "Drill/Exercise Performance" PI (DEP PI)monitors licensee
    performance of event classification, offsite authority notification
    and protective action recommendation (PAR) development.

b.  The "Emergency Response Organization Drill Participation" PI (ERO
    PI)monitors licensee efforts to develop and maintain key skills
    within the ERO through participation in proficiency enhancing
    evolutions, such as drills.

c.  The "Alert and Notification System Reliability" PI (ANS PI)monitors
    reliability of the alert and notification system. This system has
    been identified as the most risk-significant equipment system
    maintained by nuclear plant emergency preparedness programs.

d.  DEP and ERO PIs are linked in that ERO drill participation is only
    credited when performance is assessed for contribution to DEP. The
    details and exceptions to this linkage are contained in Nuclear
    Energy Institute (NEI) 99-02, "Regulatory Assessment Performance
    Indicator Guideline."

[Disposition Of Findings]{.underline}

a.  The need for inspection beyond the Baseline Inspection Program (BIP)
    is determined through the significance and number of inspection
    findings and the status of PIs.

b.  A Significance Determination Process (SDP) has been developed for
    assessing the significance of inspection findings. The details of
    the Emergency Preparedness (EP) SDP are contained in Manual Chapter
    0609, Appendix B.

c.  The BIP is designed for programs operating in the "licensee response
    band," that is, a program with green PIs and only green findings.
    The resources allocated in the BIP are not intended to be sufficient
    for the characterization of potential white, yellow, or red
    findings. Should it be necessary to characterize such findings, and
    the time involved exceeds a few hours, the time should be allocated
    to the SDP rather than the BIP.

[Correction of Weaknesses]{.underline}

a.  Findings of a failure to correct a weakness, or observations of
    program inadequacies should be summarized and provided to the team
    leader for the annual problem identification and resolution
    inspection.

b.  Weaknesses appropriately critiqued by the licensee in evaluated
    exercises are not considered findings. However, the inspector must
    ensure that such items are entered into the licensee corrective
    action system in a manner that will allow review during the
    subsequent off-year exercise and next biennial exercise.

c.  Section IV.F.2.g. of Appendix E to 10 CFR 50, requires that
    weaknesses identified in the EP program be corrected. Inspectors
    should review the correction of licensee and NRC-identified
    weaknesses. However, in the case of personnel performance, a repeat
    performance problem may not in itself, represent a failure to
    correct a weakness. 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 correct. Guidance on determining the
    adequacy of licensee efforts to resolve problems is contained in
    Manual Chapter 0612, in the EP SDP, and Inspection Procedure 71152.

[Risk-Significant Areas]{.underline}

Implementation of the Emergency Plan (the Plan) is dependant on the
performance of the ERO in their EP assignments. There are many areas
important to Plan implementation, but the most risk-significant areas of
performance are:

a.  [Timely and accurate classification of events]{.underline}. This
    includes the recognition of events as potentially exceeding
    emergency action levels. \[10 CFR 50.47 (b) (4)\]

b.  [Timely and accurate notification of offsite governmental
    authorities]{.underline}. This includes adequate performance of
    notifications to state and local authorities as specified in the
    Plan. \[10 CFR 50.47 (b) (5)\]

c.  [Timely and accurate development of PARs for offsite
    authorities]{.underline}. This includes providing PARs to
    governmental authorities, and the decision-making process to develop
    the PARs. \[10 CFR 50.47 (b) (10)\]

d.  [Assessment of offsite consequences]{.underline}. This includes the
    ability to assess and monitor the magnitude and dose consequences of
    potential or actual radioactive releases. \[10 CFR 50.47(b)(9)\]

In general, NRC oversight in EP is focused on adherence to the Plan with
an emphasis on these most risk-significant areas, and inspection
resources should be deployed in a manner to cover these areas.

[Prioritization of Additional Areas for Inspection]{.underline}

Guidance for deployment of inspection resources beyond the most
risk-significant areas is provided below. These areas may generally be
considered in order of importance. Selection for deployment of
inspection resources should be based on knowledge of the program,
previous problems and logistics.

a.  Adequacy of worker protection including accountability, evacuation,
    exposure authorization and thyroid protection \[50.47(b)(10)&(11)\].

b.  Adequacy of interface with offsite authorities (e.g., in the area of
    PAR communication and technical support) \[50.47(b)(6)\].

c.  Timely activation of facilities \[50.47(b)(2)\].

d.  Ability to prioritize mitigation and assessment efforts to protect
    the public health and safety.

e.  Command and control \[50.47(b)(1)\].

f.  Ability to diagnose plant accident conditions.

g.  Ability to formulate mitigating actions.

h.  Ability to implement mitigating actions (e.g., damage control teams)
    under accident conditions.

i.  Adequacy of communications between licensee facilities
    \[50.47(b)(6)\].

j.  Accuracy and completeness of licensee-approved press releases
    \[50.47(b)(7)\].

k.  Readiness and quality of EP equipment and facilities \[50.47(b)
    (8)\].

[Scheduling]{.underline}

Attachment 1 should be scheduled for evaluation of the biennial
exercise. An exercise is to be evaluated biennially at each licensee
site, including one biennial exercise for each licensee at a co-located
site. The PI verification (IP71151) is to be performed annually and
should be performed in conjunction with Attachment 1. Attachment 2,
"Alert and Notification SystemEvaluation," Attachment 3, "Emergency
Response Organization Staffing and AugmentationSystem," and Attachment
5, "Correction of Emergency Preparedness Weaknesses," may be conducted
during a single inspection in the year when there is no biennial
exercise. IP 71151 should also be conducted at that time. Attachment 4,
"Emergency Action Level and Emergency Plan Changes," may be conducted
when changes are received and may be conducted in the regional office.
Attachment 6, "Drill Evaluation,"is conducted annually by the resident
inspector and may be done whenever convenient to the licensee and
inspector schedule. Attachment 7, "Force-On-Force (FOF) Exercise
Evaluation," should be conducted every three years in conjunction with
the FOF exercise, and in place of one Attachment 6 drill evaluation for
that year.

71114-04 INSPECTION RESOURCES

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

71114-05 REFERENCES

NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," and
revisions.

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

Regulatory Guide 1.101, "Emergency Planning and Preparedness For Nuclear
Power Reactors," all revisions.

Regulatory Issue Summary (RIS) 2003-18, "Use of NEI 99-01, 'Methodology
for Development of Emergency Action Levels'," and Supplements.

RIS 2005-02, "Clarifying the Process for Making Emergency Plan Changes."

Inspection Procedure 71152, "Identification and Resolution of Problems."

Inspection Procedure 71151, "Performance Indicator Verification."

FEMA-REP-10, "Guide For the Evaluation of Alert And Notification Systems
For Nuclear Power Plants."

Bulletin 2005-02, "Emergency Preparedness and Response Actions For
Security-Based Events."

END

Attachments:

.01 Exercise Evaluation

.02 Alert and Notification System Evaluation

.03 Emergency Response Organization Staffing and Augmentation System

.04 Emergency Action Level and Emergency Plan Changes

.05 Correction of Emergency Preparedness Weaknesses

.06 Drill Evaluation

.07 Force-On-Force (FOF) Exercise Evaluation

ATTACHMENT 1

Revision History For IP 71114

+--------+------+------------------------+-----+-------+--------------+
| Comm   | I    | Description of Change  | Tr  | Tra   | Comment      |
| itment | ssue |                        | ain | ining | Resolution   |
| Tr     | Date |                        | ing | Compl | Accession    |
| acking |      |                        | Nee | etion | Number       |
| Number |      |                        | ded | Date  |              |
+--------+------+------------------------+-----+-------+--------------+
| N/A    | 06/2 | Completed four-year    | N   | N/A   | ML061580314  |
|        | 9/06 | historical CN search.  | one |       |              |
|        |      |                        |     |       |              |
|        |      | Revised to reflect     |     |       |              |
|        |      | changes to the         |     |       |              |
|        |      | procedure attachments, |     |       |              |
|        |      | add new procedure      |     |       |              |
|        |      | Attachment 07,         |     |       |              |
|        |      | simplify using         |     |       |              |
|        |      | acronyms, and add new  |     |       |              |
|        |      | references.            |     |       |              |
+--------+------+------------------------+-----+-------+--------------+
|        |      |                        |     |       |              |
+--------+------+------------------------+-----+-------+--------------+
|        |      |                        |     |       |              |
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|        |      |                        |     |       |              |
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