**ATTACHMENT 82001.06**

REMEDIAL EXERCISES

82001.06-01 INSPECTION OBJECTIVES

01.01 To determine that the extent of condition of performance problems
in response to emergency conditions

01.02 To provide inspection information in support of the determination
of whether the licensee EP program can meet the EP Cornerstone
Performance Expectation and whether the program can operate in the
licensee response band.

82001.06-02 INSPECTION REQUIREMENTS

02.01 Verify that the emergency preparedness exercise or drill meets the
licensee\'s commitments and regulatory requirements.

02.02 [Control Room]{.underline}. Observe and evaluate the performance
of licensee emergency response personnel in the control room, as they
perform the following activities during a drill or exercise:

a.  Facility management and control

b.  Analysis of plant conditions and corrective actions

c.  Detection and classification of emergency events

d.  Protective action decision making

e.  Notifications and communications

f.  Implementation of onsite protective actions

g.  Dose assessment

h.  Evaluation of post‑accident sampling results

i.  Dispatch and coordination of monitoring teams

02.03 [Technical Support Center (TSC)]{.underline}. Observe and evaluate
the performance of licensee emergency response personnel in the TSC as
they perform the following activities during a drill or exercise:

a.  Staffing and activation of the TSC

b.  Facility management and control

c.  Accident assessment and classification

d.  Dose assessment

e.  Protective action decision making

f.  Notifications and communications

g.  Implementation of protective actions

h.  Assistance and support to control room

i.  Evaluation of post‑accident sampling results

j.  Dispatch and coordination of monitoring teams

02.04 [Emergency Operations Facility (EOF)]{.underline}. Observe and
evaluate the performance of licensee emergency response personnel in the
EOF as they perform the following activities during a drill or exercise:

a.  Staffing and activation of the EOF

b.  Facility management and control

c.  Accident assessment and classification

d.  Offsite dose assessment

e.  Protective action decision making

f.  Notifications and communications

g.  Implementation of protective actions

h.  Interaction with offsite officials, NRC, and other organiza­tions

02.05 [Operational Support Center (OSC)]{.underline}. Observe and
evaluate the performance of licensee emergency response personnel in the
OSC as they perform the following activities during a drill or exercise:

a.  Staffing and activation of the OSC

b.  Facility management and control

c.  Performance of support functions

d.  Provide personal protection for workers

02.06 [Corporate Command Center (CCC)]{.underline}. Observe and evaluate
the performance of licensee emergency response personnel in the CCC as
they perform the following activities during a drill or exercise:

a.  Staffing and activation of the CCC

b.  Performance of support functions

02.07 [Offsite Monitoring]{.underline}. Observe and evaluate the
performance of licensee offsite monitoring teams as they perform the
following activities during a drill or exercise:

a.  Activation and deployment of the monitoring teams

b.  Surveys, sampling and analysis

02.08 [Corrective Action Or Rescue Teams]{.underline}. Observe and
evaluate the performance of licensee corrective action and rescue teams
as they perform the following activities during a drill or exercise:

a.  In‑plant repair actions

b.  Rescue operations

c.  Ensuring personal safety

02.09 [Security and Accountability]{.underline}. Observe and evaluate
the licensee\'s security practices during a drill or exercise:

a.  Security

b.  Accountability

02.10 [Emergency News Center (Joint Public Information
Center)]{.underline}. Observe and evaluate the performance of licensee
emergency response personnel in the Emergency News Center as they
perform the following activities during a drill or exercise:

a.  Staffing, activation, and facility control as applicable

b.  Processing and dissemination of information to the media

02.11 [Onsite Emergency Medical Services]{.underline}. Observe and
evaluate the performance of the licensee\'s onsite medical response team
during a drill or exercise.

02.12 [Post‑Accident Sampling Team (PASS)]{.underline}. Observe and
assess the performance of the PASS team during a drill or exercise.

02.13 [Critique]{.underline}. Assess the licensee\'s critique.

02.14 [Public Meeting]{.underline}. Participate in a public meeting
following the exit meeting with the licensee.

02.15 Determine the effectiveness of licensee corrective actions in
addressing ERO Performance issues.

02.16 Provide inspection information on the results of drill evaluation
to support the determination of whether ERO Performance supports the
Cornerstone Performance Expectation.

02.17 Provide inspection information on the results of drill evaluation
to support the determination of whether the EP program can operate in
the licensee response band.

82001.06-03 INSPECTION GUIDANCE

[General Guidance]{.underline}

This attachment is a part of the EP Cornerstone Supplemental Inspection
Procedure and may be used to inspect remedial exercises or demonstration
drills being presented by the licensee for the purpose of establishing
confidence that the objectives stated in section 82001.06-01 are met.
The use of the term Aremedial exercise@ is rare. In the few cases where
such oversight is necessary, it is more common that the licensee
Ainvites@ NRC to observe a scheduled drill, In any case, the guidance of
this procedure may be used to structure the inspection. It should be
noted that this procedure does not use the inspection techniques of the
Baseline Inspection Program for exercises. In general use of this
procedure is predicated on the conclusion that this licensee EP program
is not operating in the licensee response band. If the licensee is
considered in the licensee response band and yet a remedial exercise is
necessary, perhaps due to scenario or exercise control problems, the
baseline procedure should be used.

Evaluations conducted in accordance with this procedure are limited to
the staff, activities, records, and facilities of the licensee (or
applicant). Where necessary to verify licensee (or applicant)
performance, concerning interactions with organizations and persons
involved in [offsite]{.underline} emergency preparedness, inspectors are
to limit their activities to reviews of pertinent records available
through the licensee (or applicant). If additional information is needed
about [offsite]{.underline} emergency preparedness, it can be obtained
from FEMA.

The general practices for a team inspection are to be used for the
planning and conduct of this inspection and for the preparation of the
inspection report. During an exercise or drill, observation and
evaluation of licensee performance in the control room, the TSC, OSC and
the EOF, as appropriate, is required. However, the lead inspector may
adjust the extent of observation in each area, as needed, to concentrate
on areas where past licensee performance was considered unacceptable.

There are three aspects of the drill to consider. The development of a
technically accurate and challenging scenario to test the plans,
procedures, equipment, and implementation of the licensee\'s emergency
response capabilities. The implementation of the plans and procedures.
The last aspect is the critique following the exercise or drill in which
the licensee makes a candid self‑evaluation in terms of (1) the
scenario, (2) the adequacy of the emergency equipment, facilities, and
procedures, (4) the players\' responses, and (5) the effective use of
evaluators and controllers.

Interference with the players or the controllers by NRC evaluators
should not occur, nor should the controllers prompt, coach, or otherwise
interfere with the performance of the players. NRC evaluators may seek
information from the controllers regarding the drill, but should not
interact with the players directly.

The inspectors should become familiar with the scenario upon arrival on
site to understand how to evaluate performance. Review any changes made
to the scenario and tour the facilities to become familiar with
equipment, displays, procedures and supplies to be used to perform the
evaluated tasks.

[Specific Guidance]{.underline}

This section contains both general and specific guidance, and these are
not numbered to correspond with inspection requirements in Section 02.

03.01 The requirements for ­exercises are found in 10 CFR 50.47(b)(14)
and 10 CFR Part 50, Appendix E, Part IV.F.

The scenario developed should address previously identified weaknesses.
It may be appropriate to review the scenario and the scenario objectives
to ensure licensee efforts will support the inspection procedure
objectives. The criteria for review of the objectives and scenario may
be drawn from the licensee performance issues which resulted in the need
for this remedial exercise. In the absence of a regulatory action
regarding the remedial exercise (e.g., CAL, Order,) the inspector (and
Regional Management) will have to negotiate with the licensee to ensure
an appropriate test of the emergency plan. It is expected that the
licensee will consider it appropriate to re-confirm the ability to meet
the EP Cornerstone Performance Expectation. However, this may not always
be the case and pursuit of a regulatory action may be necessary before
the Inspection Procedure objectives can be met. The guidance of
Attachments 1 and 2 of this procedure may be helpful in describing
appropriate elements of a challenging scenario.

The licensee should be informed that the scenario must be kept
confidential. If confidentiality is not maintained, the inspection may
be postponed until a later date when confidential a scenario is
available for use.

The use of a simulator is desirable during these drills, but not
mandatory. The decision to use the simulator should be left to the
licensee. However, it may be pointed out that the realism of the
simulator would aid shift personnel in recognizing emergency conditions.

The licensee should include statistics of drill performance in the EP
performance indicators.

03.02 [Control Room]{.underline}

a.  [Facility Management and Control]{.underline}. Does the shift
    supervisor coordinate and oversee control room response, redirecting
    the response as necessary? Are actions performed in accordance with
    applicable procedures and instructions?

b.  [Analysis of Plant Conditions and Corrective Actions]{.underline}.
    Are control room operators able to correctly interpret control room
    instrument displays? From these and other sources of available
    information, are operators able to recognize that events are
    progressing abnormally, determine plant status and develop
    appropriate strategies to bring the plant to a safe shutdown
    condition if necessary?

c.  [Detection and Classification of Emergency Events]{.underline}. Are
    control room operators able to classify an emergency using emergency
    action levels (EALs) on the basis of plant conditions and confirm
    (where possible) the emergency classification by dose calculations
    or monitoring? After recognizing and classifying the emergency, do
    control room operators correctly implement the immediate actions of
    the emergency plan implementing procedures (EPIPs)?

d.  [Protective Action Decision Making]{.underline}. After classifying
    an event, are control room operators able to determine protective
    actions for onsite and offsite personnel without waiting for a dose
    assessment? Do they recommend protective actions on site and off
    site, on a timely basis, that are consistent with those in the
    approved onsite emergency plan and the EPIPs? Guidance on protective
    actions is provided in NUREG‑0654. To the extent that time permits,
    the licensee (or applicant) should consider the following in
    promptly deciding appropriate offsite protective actions:

    1.  Current plant status

    2.  Current dose assessment and dose projection

    3.  Expected duration of release

    4.  Evacuation time estimates

    5.  Local sheltering efficiencies

    6.  Current meteorological parameters (wind speed, wind directions,
        and stability class) and projected weather conditions

    7.  Local geography

    8.  Time of day

e.  [Notifications and Communications]{.underline}

    1.  Are onsite personnel promptly notified of the following:

        a.  Emergency conditions

        b.  Emergency classifications

        c.  Activation of the emergency organization and facilities

        d.  Protective actions

        e.  Radioactivity release status

        f.  Any changes in these conditions

    2.  Are offsite officials, including NRC, promptly notified of the
        following:

        a.  Emergency conditions

        b.  Emergency classifications

        c.  Activation of the emergency organization and facility

        d.  Radioactivity release status

        e.  Potentially affected population

        f.  Projected population doses

        g.  Recommended protective actions

        h.  Any changes in these conditions

    3.  A communications link is to be maintained between the control
        room, the TSC, the OSC, and the NRC, if requested. A
        knowledgeable staff member is to be available to notify licensee
        (or applicant) personnel and State and local authorities of an
        emergency and to maintain communications within 15 minutes after
        the emergency is declared. Federal authorities are to be
        notified within 1 hour of emergency declaration and the
        Emergency Response Data System (ERDS) is to be activated within
        1 hour of event declaration for Alert and above.

f.  [Implementation of Onsite Protective Actions]{.underline}. The
    control room initiates onsite protective actions until the TSC or
    the EOF is activated.

    1.  For a Site Area Emergency or a General Emergency, nonessential
        personnel are evacuated (may be simulated) from the site to the
        offsite locations(s) specified in the emergency plan.
        Appropriate protective measures are initiated for those
        personnel remaining on site (e.g., accountability, protective
        clothing, KI).

    2.  For a General Emergency with imminent major releases projected,
        evacuation of nonessential onsite staff should be directed
        without monitoring or decontaminating them. For General
        Emergencies in which major releases are not imminent, evacuation
        should be initiated following monitoring and decontamination. Is
        the licensee (or applicant) able to accomplish the initial
        accountability within 30 minutes of the order for the assembly
        of all nonessential personnel and able to account for all
        remaining personnel continuously thereafter? Habitability of the
        control room and assembly areas is to be assessed periodically
        by the licensee.

g.  [Dose Assessment]{.underline}. Are approved procedures for dose
    assessment available and do personnel know how to use them? If a
    release is anticipated or in progress, are control room personnel
    able to correctly and rapidly assess and integrate information from
    the reactor system\'s status and trends, source‑term assumptions,
    post‑accident sampling system (PASS) samples, and meteorological
    information to define the magnitude and location of the onsite and
    offsite impact? These assessments need not be as sophisticated or as
    accurate as dose projections made by the TSC or the EOF but are to
    be sufficiently accurate to determine onsite protective actions and
    offsite protective recommendations as necessary. If a release is
    under way, do personnel promptly initiate onsite sampling and
    monitoring to confirm the composition of the releases (i.e., iodine
    fraction), to better define the source term and to confirm projected
    doses? Is dose assessment performed in the TSC or the EOF once these
    facilities are activated?

h.  [Evaluation of Post-Accident Sampling Results]{.underline}. If
    appropriate, the control room may request that a post‑accident
    containment air or primary water sample be obtained to confirm the
    composition of any release (i.e., iodine fraction). The results of
    the samples would be used to redefine or confirm the condition of
    the reactor, the emergency classification, the source term, and
    projected doses. Post‑accident sampling may be directed from the TSC
    after this facility has been activated.

i.  [Dispatch and Coordination of Monitoring Teams]{.underline}. If a
    release is anticipated or in progress, the Emergency Director may
    deploy teams to perform environmental sampling at appropriate
    locations to characterize the size, location, and intensity of the
    plume. The teams could be asked to take measurements of radiation
    levels, radioiodine or gross beta levels in the air, or to collect
    samples of water, vegetation and milk to determine the
    concentrations of radionuclides in these samples. Onsite and offsite
    monitoring may be directed from the TSC or the EOF after these
    facilities have been activated.

03.03 [Technical Support Center (TSC)]{.underline}. Are approved plant
procedures current, readily available and used in the TSC? Is the EOF
kept informed of the status of the emergency? Are proper functions
transferred to the EOF when that facility becomes operational? Are all
concerned parties notified of such a transfer? Is the TSC equipped to
perform intended functions? Are job aids, such as status boards,
accurate and kept current?

a.  [Staffing and Activation of the TSC]{.underline}. Guidance on the
    staffing of the TSC can be found in Table 2 of Supplement 1 to
    NUREG‑0737. The licensee\'s or (applicant\'s) staffing of the TSC
    can be found in site emergency plans or implementing procedures. Are
    relief personnel properly and adequately briefed?

b.  [Facility Management and Control]{.underline}. Are congestion and
    noise levels kept to a minimum? Are bound or other permanent‑type
    logs kept and all important data, calculations, notifications, and
    decisions recorded as they occur? For Alerts, Site Area Emergencies
    and General Emergencies, the TSC, through procedure, is designed to
    be activated and prepared to perform the following functions within
    about 1 hour after an emergency is declared:

    1.  Manage site activities

    2.  Provide technical support to reactor operations

    3.  Manage corporate emergency resources (These functions are
        normally transferred to the EOF after it is activated)

    4.  Manage radiological effluent and environs monitoring and dose
        projections (Monitoring and dose projections are normally
        transferred to the emergency operations facility (EOF) after it
        is activated)

c.  [Accident Assessment and Classification]{.underline}. The following
    tasks are normally performed by the staff in the TSC:

    1.  Use EALs, as appropriate, to classify the emergency

    2.  Initially assess and continuously reassess reactor conditions

    3.  Confirm the emergency classification or reclassify the emergency

    4.  Maintain an overview of the reactor and plant conditions using
        the expertise of technical staff and the information provided by
        them or from other sources

    5.  Use the results of post‑accident sampling or monitoring, as
        appropriate, to redefine reactor conditions and the emergency
        classification

    6.  Provide this information to proper personnel (control room, EOF,
        NRC, offsite authorities, corporate management, etc.)

d.  [Dose Assessment]{.underline}. If a release is in progress, do TSC
    personnel promptly initiate onsite and offsite sampling and
    monitoring to confirm the composition of the release (i.e., iodine
    fraction), and to define the source term and projected doses? If a
    release is anticipated or in progress, do TSC personnel correctly
    assess and integrate information from the reactor system\'s status
    and trends, radiological monitoring, source‑term assumptions, and
    meteorological information to define the magnitude and location of
    the onsite and offsite impact? Do TSC personnel use the results of
    post‑accident sampling and radiological monitoring to redefine
    projected doses, as appropriate? Are approved procedures for dose
    assessment available and do personnel know how to use the
    procedures?

e.  [Protective Action Decision Making]{.underline}. As appropriate, do
    TSC personnel use plant conditions to decide on protective actions
    for onsite and offsite personnel without waiting for a dose
    assessment? Do TSC personnel promptly recommend protective actions
    onsite and offsite consistent with the criteria in the approved
    onsite emergency plan? It is expected that within 15 minutes of the
    classification of General Emergency conditions, TSC personnel (or
    control room personnel if the TSC is not staffed and functional)
    recommend appropriate protective actions to offsite officials.
    Guidance is provided in NUREG‑0654. To the extent that time permits,
    the licensee (or applicant) should use the following parameters for
    determining appropriate protective actions:

    1.  Current plant status

    2.  Current dose assessment and dose projection

    3.  Expected duration of release

    4.  Evacuation time estimates

    5.  Local sheltering efficiencies

    6.  Current meteorological conditions (wind speed, wind direction,
        and stability classification) and projected weather conditions

    7.  Local geography

    8.  Time of day

f.  [Notifications and Communications]{.underline}

    1.  Are all communications systems functioning properly?

        a.  Does the TSC establish and maintain a primary communications
            link with the control room?

        b.  Do TSC personnel communicate frequently with each other and
            with other centers, especially with the control room?

    2.  It is expected that the licensee promptly notifies onsite
        personnel of the following:

        a.  Emergency conditions

        b.  Emergency classification

        c.  Activation of the emergency organization and facility

        d.  Protective actions

        e.  Radioactivity release status

        f.  Any changes in these conditions

    3.  Are follow‑up notifications of the emergency to Federal, State,
        and local emergency response organizations and recommendations
        for public protective actions made as required? (This function
        is normally transferred to the EOF after it is activated).

g.  [Implementation of Protective Actions]{.underline}. It is expected
    that responsible TSC staff perform the following tasks:

    1.  Confirm that the onsite protective actions above have been
        implemented

    2.  Direct that all onsite personnel are accounted for

    3.  Confirm that all personnel are accounted for and, if not
        accounted for, begin search and rescue for missing personnel
        (initial accountability is normally completed within about 30
        minutes of the declaration of the emergency). The licensee (or
        applicant) is to be able to account for onsite personnel
        continuously thereafter.

    4.  Confirm and periodically assess the habitability of the TSC, the
        OSC, and assembly areas. Functions of the TSC are to be
        transferred to habitable areas if necessary.

    5.  Confirm that offsite authorities are aware of the li­censee\'s
        recommendations for protective actions.

    6.  Determine from the offsite authorities what, if any, protective
        actions are being taken.

    7.  Inform management and NRC of these actions

h.  [Assistance and Support to the Control Room]{.underline}. Does the
    TSC coordinator (the person in charge) oversee the analysis and
    corrective action response? Are actions performed in accordance with
    approved procedures? Performance of other functions should not
    interfere with direction or determination of corrective action. Are
    corrective actions implemented in an effective and timely manner?
    Are potential offsite consequences of corrective actions considered
    and discussed with offsite officials? Are the resources necessary to
    perform the required analyses available? Are those performing the
    analyses and making decisions aware of important trends or changes
    of status. Are job aids, such as status boards, used effectively and
    in a manner not to interfere with the performance of corrective
    actions? Do those in charge of operations, maintenance, and
    radiation protection consult frequently and as necessary with each
    other and with offsite members of licensee\'s (or applicant\'s)
    emergency response support organizations (e.g., consultants,
    corporate personnel, and contractor personnel) about corrective
    actions?

i.  [Evaluation of Post-Accident Sampling Results]{.underline}. If
    appropriate, does the licensee (or applicant) request that
    post‑accident containment air or primary water samples be obtained
    to confirm the composition of any release (i.e., iodine fraction)
    and use the results of the post‑accident sampling to redefine or
    confirm the condition of the reactor, the emergency classifica­tion,
    the source term, and projected doses, as appropriate?

j.  [Dispatch and Coordination of Environmental Monitoring
    Teams]{.underline}. If a release is anticipated or is in progress,
    does the licensee or applicant deploy an initial environmental
    sampling team(s) to appropriate locations to (1) intercept the
    plume, (2) direct the team(s) regarding geographical movement (e.g.,
    remain at predesignated locations, go to the approximate center,
    begin a traverse from location to location), (3) direct the teams
    regarding measurements or samples to be taken (e.g., gross beta (B),
    air, water, vegetation, milk, TLDs), and (4) use results of
    monitoring to redefine the source term and projected doses, as
    appropri­ate?

03.04 [Emergency Operations Facility (EOF)]{.underline}. Are the correct
functions transferred to the EOF in a timely manner, when this facility
becomes operational? Are all concerned parties notified of such a
transfer? Are plant procedures used in the EOF current, readily
available and reviewed and approved as required? Is the EOF properly
equipped to perform intended functions? Are job aids, such as status
boards, accurate and kept current? For Site Area Emergencies and General
Emergencies, the EOF should be activated and prepared to perform the
following functions within about 1 hour after an emergency is declared:

a.  [Staffing and Activation of the EOF]{.underline}. Guidance for
    staffing of the EOF is specified in Table 2 of Supplement 1 to
    NUREG‑0737 and the licensee\'s staffing is listed in the site
    emergency plans or implementing procedures. Personnel should not be
    prepositioned before commencement of the exercise. Are the personnel
    performing key functions knowledgeable in their duties and
    responsibilities? Are relief personnel properly and adequately
    briefed?

b.  [Facility Management and Control]{.underline}

    1.  Are congestion and noise levels kept to minimum?

    2.  Are bound or other permanent‑type logs kept and all important
        data, calculations, notifications, and decisions recorded
        chronologically?

    3.  At the request of personnel in the TSC, the control room, or in
        other locations, are outside resources are obtained in a timely
        manner and managed from the EOF (before activation of the EOF,
        this function may have been initiated at the TSC)?

    4.  Overall radiological effluent and environs monitor­ing and dose
        projections are normally managed from the EOF. (Before
        activation of the EOF, this function may have been performed at
        the TSC.)

c.  [Accident Assessment and Classification]{.underline}. Are personnel
    activating the EOF able to adequately and accurately perform the
    following tasks:

    1.  Use EALs, as appropriate, to classify an emergency

    2.  Initially assess and continuously reassess reactor conditions

    3.  Confirm the emergency classification or reclassify the emergency

    4.  Maintain an overview of the reactor and plant conditions using
        the expertise of the staff and the information provided by them
        or other sources

    5.  Use the results of post-accident sampling or monitoring, as
        appropriate, to redefine reactor conditions and the emergency
        classification

d.  [Offsite Dose Assessment]{.underline}. If a release is anticipated
    or is in progress, does the licensee correctly assess and integrate
    information from the reactor system\'s status and trends,
    radiological monitoring, source‑term assumptions, and meteoro­logical
    information to define the magnitude and location of the offsite
    impact? If a release is anticipated or in progress, does the
    licensee deploy an initial environmental sampling team(s) to
    appropriate locations to (1) intercept the plume, (2) direct the
    team(s) regarding geographical movement (e.g., remain at a
    predesignated location, go to the approximate center, begin a
    traverse from location to location), and (3) direct the team(s)
    regarding measurements or samples to be taken (e.g., gross beta,
    air, water, vegetation, milk, TLDs? Are the results of monitoring
    used to redefine the source term and projected doses as appropriate?
    Is the licensee (or applicant) able to promptly and correctly
    project the direction and maximum dose within the plume EPZ and the
    distance to which the EPA\'s PAGs are projected to be exceeded? Does
    licensee (or applicant) staff, responsible for protective action
    recommendations, communicate with the reactor systems\' status
    personnel to comprehend plant status and trends and anticipate
    radiological consequences as events progress? Does the licensee (or
    applicant) obtain necessary current and forecasted meteorological
    information from onsite systems and appropriate offsite sources
    (e.g., supplemental systems, the National Weather Service)? Does the
    licensee (or applicant) assure that assessments are updated as
    tangible changes in plant status, release, or meteorological
    conditions become evident, are forecasted, or are refined from
    confirmatory measurements? Are current approved procedures used for
    dose assessment and do personnel know how to use them? Is a backup
    dose assessment system available if the primary system fails? Is the
    staff trained in using the alternate system?

e.  [Protective Action Decision Making]{.underline}. As appropriate, the
    licensee is to assess the status of the reactor core, reactor
    systems and containment to recommend offsite protective actions
    without waiting for a dose assessment. (Before activation of the
    EOF, this function may have been initiated at the TSC.) Does the
    licensee promptly recommend offsite protective actions that are
    consistent with those in the approved offsite emergen­cy plan?
    Guidance on protective measures are found in Appendix I of
    NUREG‑0654. To the extent that time permits, the licensee (or
    applicant) should consider the following in determining what
    protective actions are appropriate:

    1.  Current reactor and plant status

    2.  Prognosis of accident

    3.  Expected duration of release

    4.  Evacuation time estimates

    5.  Local sheltering efficiencies

    6.  Current and projected weather conditions

    7.  Local geography

    8.  Time of day

f.  [Notifications and Communications]{.underline}

    1.  Do EOF personnel communicate frequently with each other and with
        other centers (especially with corporate headquarters and with
        offsite authorities)? Is a primary communications link with the
        TSC established and maintained? Do personnel in the EOF also
        communicate with the NRC Site Team? Do all primary
        communica­tions systems function properly and, if they do not,
        are backup systems available? Does the licensee (or applicant)
        establish and maintain a communications channel to offsite
        authorities, including the NRC?

    2.  If not already accomplished by TSC or control room personnel, it
        is expected that offsite officials, including NRC, are promptly
        informed of the following:

        a.  Emergency conditions

        b.  Emergency classification

        c.  Radioactivity release status

        d.  Potentially affected population

        e.  Projected population doses

        f.  Recommended protective actions

        g.  Any changes in these conditions

    3.  Do responsible personnel in the EOF notify Federal, State and
        local emergency response organizations of the emergency, and
        make recommendations for public protective action (before
        activation of the EOF, this function may have been initiated at
        the TSC)?

g.  [Implementation of Protective Actions]{.underline}. Does the
    licensee confirm and periodically assess the habitability of the
    EOF? If the EOF has to be evacuated, its functions are to be
    transferred to alternate facilities without disruption of offsite
    interaction, command and control, dose projections, or protective
    action decisionmaking. Does the licensee confirm that offsite
    authorities are aware of the licensee\'s recommendations for
    protective actions? Does the licensee determine from the offsite
    authorities what, if any, protective actions are being taken? Is
    licensee management and the NRC informed of these actions? Is the
    licensee aware or informed of the status of offsite protective
    actions?

h.  [Interaction with Offsite Officials]{.underline}. Are the offsite
    representatives at the EOF and the site briefed upon arrival and
    kept informed of changing conditions without interfering with the
    onsite response? Are offsite monitoring and sampling results
    coordinated with offsite officials?

03.05 [Operational Support Center (OSC)]{.underline}. Is the OSC
properly equipped to perform intended functions? Is reliable voice
communication established with the control room, the TSC, and the EOF?
Is habitability of the OSC confirmed and periodically assessed? If need
be, are the functions of the OSC transferred to a more habitable area?
Do all primary communications systems to the TSC, the EOF and the repair
teams function properly and if they do not, are backup systems
available?

a.  [Staffing and Activation of the OSC]{.underline}. The OSC is to be
    quickly staffed, activated, and fully functional. Are licensee (or
    applicant) personnel assigned to the OSC identified in the Emergency
    Plan and/or the implementing procedures? Guidance on staffing is
    presented in Table 2 of Supplement 1 to NUREG‑0737. Are relief
    personnel properly and adequately briefed?

b.  [Facility Management and Control]{.underline}. Are operations at the
    OSC supervised by licensee (or applicant) officials predesignated in
    the emergency plan and procedures? Is the manager‑in‑charge
    knowledgeable of his or her duties and responsibilities. Are
    congestion and noise levels kept to a minimum. Is the OSC staff
    periodically briefed on plant and radiological conditions? Are
    personnel who will perform specific tasks as requested by
    management, the TSC, or the control room assigned in a timely manner
    and given clear instructions? Are teams dispatched from the OSC
    briefed, tracked, and debriefed upon return to the OSC? Is a
    pre‑implementation planning meeting involving operations,
    maintenance, and health physics held to reduce exposure by means of
    appropriate tool selections, routes of travel, development of
    tempo­rary procedures, etc.? (These actions may be performed in the
    TSC or the control room.) Exposure and exposure limits of personnel
    are to be considered in planning activities. (These actions may be
    performed in the TSC or the control room.)

c.  [Performance of Support Functions]{.underline}. Is communication
    with the teams dispatched from the OSC maintained? For conditions
    requiring iodine protection, do personnel promptly implement
    appropriate iodine‑protective measures (use appropriate respiratory
    protection or take KI)? Normal plant configuration and activity
    controls should be in effect whenever practicable. Are in-plant
    teams fully aware of procedural provisions for performing
    activities? Procedure adherence is required unless authorization to
    deviate is specifically provided. If normal use of procedures is
    impracticable, or if assigned activities cannot be accomplished
    using existing/available procedures, the extent of authorized and
    implemented deviation from procedures is to be clearly identified to
    and clearly reported by the activity performers. Also, to the
    maximum practicable extent, are deviations from prescribed
    system/component line-ups or alignments documented, and identified
    to the responsible control room, TSC, and EOF staffs?

03.06 [Corporate Command Center (CCC)]{.underline}. If called for in the
emergency plan or procedures, is the Corporate Command Center activated
and prepared to perform its functions in a timely manner? Are congestion
and noise levels kept to a minimum? Is the CCC properly equipped to
perform intended functions? Are reliable voice communications
established with the site (primarily the EOF)?

a.  [Staffing and Activation of the CCC]{.underline}. Are licensee (or
    applicant) officials predesignated in the emergency plan or related
    procedures to manage operations? Is the senior manager knowledgeable
    of his or her duties and responsibilities and able to perform
    intended functions?

b.  [Performance of Support Functions]{.underline}. When called upon for
    assistance, does the CCC provide timely support in such areas as
    Government liaison, logistics, and finance?

03.07 [Offsite Monitoring]{.underline}

a.  [Activation and Deployment of Monitoring Teams]{.underline}.
    Licensee staff capable of performing offsite surveys are to be
    prepared to implement their functions in a timely manner. Are
    vehicles available and readily accessible to transport the teams and
    capable of functioning under adverse weather conditions? Are
    calibrated instrumentation and equipment available for monitoring
    and for taking samples? Is instrumentation to detect radioiodine at
    levels as low as 10‑7 uCi/cc under field conditions available? Are
    teams equipped with an adequate communications system (e.g., a radio
    that permits unimpeded transmission and reception of data and
    instructions over the entire plume emergency planning zone (EPZ))?
    Are teams adequately briefed on radiological conditions, their
    mission and plant conditions before they are dispatched? Are
    monitoring teams dispatched in a timely manner? Personnel should not
    be prepositioned before commencement of the exercise.

b.  [Surveys, Sampling and Analysis]{.underline}. Are team members able
    to demonstrate proficient use of protective equipment such as
    protective clothing and respirators? Are teams able to quickly
    locate sampling and monitoring locations (for example, predetermined
    sample sites)? Do team members exhibit proficiency in collecting,
    bagging, and marking samples, and in reading monitoring results in
    accordance with procedures (e.g., open and closed G.M. window
    readings, where appropriate)? Are teams kept informed of changing
    conditions in the field? Do team members keep track of their
    individual radiological exposures? Are monitoring results promptly
    and correctly reported to the TSC and/or the EOF?

03.08 [Corrective Action or Rescue Teams]{.underline}. Are team actions
initiated and performed promptly following the decision to conduct an
operation? Before entry, does the team consult and coordinate with the
control room and receive a briefing on potential hazards. Is the team
provided with adequate protective equipment such as self‑contained
breathing apparatuses (SCBA) with sufficient stay times, and monitoring
equipment with sufficient ranges (e.g., up to 1000 R/hour)? Team
exposure is to be monitored constantly and not exceed accepted
guidelines or preestablished values. Is communication with the team
maintained by the control room, the TSC, or the OSC? Are team personnel
qualified by training or experience to perform the job specified, in a
high radiation environment, and are they trained in the use of the
appropriate protective equipment? Are team personnel able to demonstrate
proficiency in the use of protective equipment?

03.09 [Security and Accountability]{.underline}

a.  Is access control maintained at the site in a manner not to
    interfere with the response to an emergency (e.g., response of
    offsite assistance is not hindered)? Are security practices or
    procedures such that they do not impede movement and access of site
    operating and response personnel to plant areas during an emergency
    situation (e.g., computer‑controlled doors to vital areas fail in
    the open position upon loss of electrical power, essential personnel
    have keys to locked doors or can easily obtain keys, anti‑passback
    features do not hinder reentry)? Any practice or procedure to allow
    easy access during emergencies must be compatible with the
    licensee\'s (or applicant\'s) Physical Security and Contingency
    Plans developed in accordance with 10 CFR Part 73 and 10 CFR 73,
    Appendix C. Is access control maintained at the control room, the
    OSC, the TSC, and the EOF? Are security personnel monitored for
    exposure and appropriate protective actions taken as appropriate?

b.  Are all onsite personnel accounted for and the names of missing
    individuals achieved within about 30 minutes of the declaration of a
    Site Area Emergency or a General Emergency? Is a search‑and‑rescue
    operation initiated promptly for missing people? Are all onsite
    personnel continuously accounted for during the emergency response?

03.10 [Emergency News Center (Joint Public Information
Center)]{.underline}

a.  Is information disseminated to the media/press by the licensee
    accurate and timely? Are news releases properly coordinated with the
    NRC and other offsite officials? Are media personnel prohibited from
    interfering with the emergency response? Is corrected or
    supplemental information promptly released in the event of error or
    misinformation in news stories (e.g., rumor control)? Is information
    given to the public by the licensee (or applicant) prepared to the
    technical level that the public can understand? Is news updated
    periodically whether or not the status has changed?

b.  Are adequate numbers of telephones available for press use? Are
    licensee (or applicant) personnel giving the briefings technically
    qualified and able to answer media questions accurately and quickly?

03.11 [Onsite Emergency Medical Services]{.underline}

a.  Is appropriate consideration given to first aid treatment of the
    victim(s) and associated radiological hazards? Are first aid
    treatment and decontamination efforts commensurate with the extent
    of the injuries? To the extent possible, are radiological control
    efforts onsite and during transport to offsite medical facilities
    utilized?

b.  Are offsite medical facilities informed, in advance of a victim\'s
    arrival, of both medical and radiological conditions? Is pertinent
    medical and radiological information provided to offsite responders
    and/or medical facility staff?

c.  Does a qualified radiological control technician accompany the
    injured person to the hospital? Are hospital personnel adequately
    briefed by the radiological control technician on the extent of the
    injury and on any contamination levels?

03.12 [Post‑Accident Sampling Team]{.underline}. When the licensee
analyzes the post‑accident primary coolant and containment atmosphere
samples, required exposure limits for the in‑plant team operations are
to be maintained. The team is to be qualified and capable to take and
analyze coolant and containment atmosphere samples under emergency
conditions. The team is to be able to proficiently implement the
post‑accident sampling procedure, wear, or simulate the wearing of, the
appropriate protective clothing and equipment (e.g., SCBA), and follow
the appropriate radiation protection procedures. Are appropriate tools
used, and samples properly transported? Are samples analyzed using the
appropriate precautions to prevent personnel exposure and contamination
of the lab? Are samples analyzed for noble gases, radioiodine, cesium,
nonvolatile isotopes, hydrogen, chlorides, and boron? Are the results of
these analyses available in the TSC within a time frame consistent with
the commitments in the emergency plan (This is generally three hours
after the samples are requested, but individual licensee commitments
should be verified)?

03.13 [Critique]{.underline}. At the end of an exercise or drill, each
facility is to hold a critique with the controllers and players while
the details are fresh. For exercises, this preliminary critique is
followed by a formal critique that evaluates the overall performance of
the exercise and the interaction of facility representatives and players
with one another. During the critique, do the evaluators provide an
unbiased and candid evaluation of the exercise, identifying the areas of
strength as well as weakness and areas needing improvement? Are
corrective actions defined and scheduled?

03.14 [Public Meeting]{.underline}. The Region should conduct a public
meeting if: (1) the preliminary results of the inspection indicate that
a significant breakdown of the licensee\'s onsite emergency preparedness
program has occurred or (2) there is strong public interest as
demonstrated by past and present communications with members of the
public. The identification of three or more exercise weaknesses may be
indicative of a significant programmatic breakdown; consideration should
be given to the root cause of the weaknesses and the performance record
of the licensee to the EP area. The public meeting should follow the
formal exit meeting with the licensee, complying with the ten-day
notification requirement discussed in NRC Management Directive 3.5.

If the exercise is FEMA evaluated, FEMA will conduct a public meeting
and the NRC team leader is expected to be present. Guidance on
appropriate NRC statements at the meeting may be found in Baseline
Inspection Procedure 71114.

03.15 The evaluation of licensee performance should be used to determine
whether the identified extent of condition is adequate and provide
inspection information to support the determinations listed in the
inspection objectives.

82001.01-04 RESOURCE ESTIMATE

It is estimated that conduct of this attachment will take 120 hours.

END