ATTACHMENT 71114.07

INSPECTABLE AREA: Emergency Preparedness component, of the
Force-On-Force (FOF) Exercise Evaluation

CORNERSTONE: Emergency Preparedness

INSPECTION BASES: Interim compensatory measures (ICM) were issued under
Commission Order, dated February 25, 2002. The Commission endorsed
implementation guidance provided by the Nuclear Energy Institute (NEI)
on March 8, 2002. The guidance developed in support of ICM Nos. 5.a and
5.d is applicable to this inspection. The ICMs and supporting guidance
are located in documents which contain safeguards information.

> A security event may be a rapidly developing situation which requires
> the licensee to respond to multiple contingencies. Generally, the ICMs
> and supporting guidance required licensees to review procedures and
> staffing to ensure an adequate response to terrorist events. This
> inspection verifies that the licensee can conduct the Emergency
> Preparedness (EP) portion of FOF exercises, identify emergency
> response weaknesses via a formal critique process, and correct those
> weaknesses through the corrective action program. Overall, the EP
> portion of FOF exercises has enhanced the integrated response to
> terrorist-based events. This inspection activity is associated with
> planning standard 10 CFR 50.47(b)(14).
>
> This inspection procedure complements IP 71130.03, AContingency
> Response - Force-on-Force Testing,@ with respect to the integration of
> security, plant operations and emergency response. Specific elements
> include, but are not limited to:

1.  Communications between plant operations and security supervision,
    including the flow of required information for decision-making.

2.  Command and control, including a common understanding of operations
    and security activities during a security event.

3.  Coordination of offsite responders, plant operations personnel, and
    security with respect to personnel safety and access to plant
    equipment.

> This inspection verifies aspects of the Emergency Preparedness
> Cornerstone for which there are no indicators to measure performance.

LEVEL OF EFFORT: The inspector will perform the following:

> Review EP weaknesses identified in the previous FOF exercise
> inspection report to use as a basis for evaluation.
>
> Evaluate the licensee=s ability to integrate security, plant
> operations, and emergency response actions during a terrorist event,
> through observation of the EP portion of the FOF exercise, and to
> assess its own performance via a formal critique in order to identify
> and correct EP weaknesses.

71114.07-01 INSPECTION OBJECTIVE

01.01 To evaluate the EP portion of the FOF exercise, including the
adequacy of actions to integrate security, plant operations and
emergency response, and the licensee=s critique process to identify and
correct EP weaknesses.

71114.07-02 INSPECTION REQUIREMENTS

The EP portion of FOF exercises are conducted with a limited Control
Room staff and limited simulation of the EP infrastructure that supports
the staff. These limitations affect the realism of the response and
limit the value for performance evaluation in that weaknesses noted may
be attributable to the drill simulation rather than personnel
performance. This should be taken into account by the inspector during
the exercise evaluation.

Evaluation of licensee emergency response activities under this
attachment will be performed concurrently with FOF exercises scheduled
by the Office of Nuclear Security and Incident Response (NSIR)/Division
of Security Operations (DSO) under the Physical Protection Cornerstone.

02.01 Review any EP corrective actions identified during the previous
FOF exercise that will be demonstrated during the current FOF exercise,
to determine whether corrective actions have been completed and
adequately address the causes.

02.02 Perform independent observations of licensee exercise performance
based on the scope of demonstration identified. Emphasis is to be placed
upon the adequacy of the operations-security interface and emergency
response actions during a terrorist event. Also, observe whether
corrective actions reviewed under Section 02.01 were effective in
correcting the identified weaknesses.

02.03 Determine whether inspector-identified EP weaknesses were captured
during the licensee=s exercise critique and entered into the corrective
action program.

02.04 If applicable, determine whether licensee assessment of EP
performance with regard to activities contributing to the Drill and
Exercise Performance (DEP) Performance Indicator (PI) is in accordance
with the applicable criteria of NEI 99-02, ARegulatory Assessment
Performance Indicator Guideline.@

71114.07-03 INSPECTION GUIDANCE

The primary focus of this inspection is to evaluate the licensee=s
critique of the operations‑security interface and emergency response
actions during a simulated terrorist event. Any qualified inspector may
perform this inspection. Additionally, each regional office has overall
responsibility for the performance of this inspection procedure. In
preparation, review the licensee procedure for control room response to
a terrorist attack, and the Emergency Plan and Implementing Procedures
(EPIPs) that provide instructions for classification, notification,
protective action recommendation (PAR) development, and contingencies
for the response to a security event. Develop an understanding of the
criteria for timely and accurate completion of these activities based on
scenario events and EPIP guidance. Also, review NRC Bulletin 2005-02
(ML051740058), AEmergency Preparedness and Response Actions For
Security-Based Events,@ and Regulatory Issue Summary (RIS) 2006-12,
Endorsement of Nuclear Energy Institute Guidance AEnhancements to
Emergency Preparedness Programs for Hostile Action@ (ML061530290), and
the following generic communications for a listing of identified good
practices to enhance the development and conduct of the EP component of
FOF exercises:

-   RIS 2004-15, AEmergency Preparedness Issues: Post 9/11\"
    (ML041810037)

-   RIS 2006-02, AGood Practices for Licensee Performance During the EP
    Component of FOF Exercise@ (ML052970294)

Activities will be controlled and assessed for EP weaknesses using the
normal critique process. Exercise weaknesses must be entered into the
corrective action process and corrected. EP inspection results (i.e.,
with no findings greater than Green) will be documented in the resident
inspector=s quarterly, integrated inspection report. If greater than
Green findings are identified, a stand-alone inspection report will be
issued. In the event that the inspector identifies an EP issue, with an
associated FOF (Safeguards) component, the EP inspection results will be
documented in the FOF inspection (IP 71130.03) report issued by NSIR/DSO
and will not be publicly available.

The determination of whether the risk-significant activities of
classification, notification and PAR development will be counted toward
the DEP PI is reflected by the level of simulation and is left to the
licensee=s discretion. However,10 CFR 50.47(b)(14) and Appendix E to
Part 50 require that the licensee critique its exercise performance and
correct EP weaknesses even if no DEP PI opportunities were identified.

> Note: The FOF exercise schedule is Sensitive Unclassified
> Non-Safeguards Information and should be handled accordingly.

Discuss EP objectives and level of demonstration for EP activities with
licensee EP personnel about 30 days prior to the FOF exercise, and
inform the DSO Team Leader of the contact. The inspector performing this
procedure shall also contact the regional EP Branch Chief to aid in the
discussion of inspection findings. Use the following guidelines to frame
the discussion with the licensee:

-   Controller(s) should be knowledgeable in their area of evaluation
    (operations, EP, etc.) and of the scenario and expected plant and
    ERO response (i.e., able to provide earned information as the
    scenario flow dictates). Controllers should be provided with a
    sufficiently detailed scenario and cues to realistically simulate
    personnel and activities required by the licensee=s emergency plan,
    including any challenges or failures that are part of the planned
    scenario. To accomplish this, the controller responsible for
    developing EP/operations-related injects should be provided advance
    access to the proposed scenario as a Atrusted agent@ per the
    guidelines in Addendum 3 to IP Attachment 71130.03.

-   The EP portion of the FOF exercise should be conducted in a
    designated facility other than the actual control room. Exercise
    conduct in a simulator would be desirable, but other alternatives
    are adequate to support the demonstration (i.e., Technical Support
    Center/Operations Support Center with communication methods that
    emulate those available in the control room and provide access to
    plant procedures).

-   At a minimum, the following resources should be pre-identified to
    emulate on-shift control room staffing:

-   A qualified Shift Manager (SM) to perform operations-security
    interface and emergency response activities from the simulated
    control room.

-   A Control Room Supervisor/Foreman to simulate plant operations
    functions and interfaces that are expected to occur.

-   At least one person to implement emergency response actions, such as
    notifications (e.g., Shift Communicator). If the responsibilities
    for this position are limited to performing notifications, and are
    not required to complete forms for notifications or personnel
    call-outs, etc., then the resource may be provided by a
    knowledgeable person rather than a person qualified in that position
    (i.e., an emergency planner rather than an operator).

-   If designated on-shift staff (i.e., Shift Communicator) are not
    normally located in or adjacent to the control room, and response to
    the control would be prohibited based on the postulated scenario or
    SM direction, then available control room staff should demonstrate
    performance of these actions based on contingencies provided in
    licensee procedures or training.

To the extent possible, tasks noted in the following paragraphs will be
demonstrated during the NRC-observed FOF scenario based on the duration
of the security portion of the FOF exercise (per Attachment 71130.03).
Further demonstration of EP aspects will not be required following
termination of the security portion of the FOF exercise. However, the
termination of exercise play should be coordinated between the lead
security and control room controllers to allow the demonstration of EP
activities currently underway.

0

a.  **Offsite notifications:** Timely initial and follow-up contact with
    State and local agencies, and the NRC, per the EPIPs, for event
    classification, offsite protective action recommendations (PARs), as
    applicable, and event status.

> [Extent of Play]{.underline}**:** This should include, at a minimum,
> the accurate completion of appropriate forms, demonstration of the
> ability to perform offsite notifications (i.e., availability of
> communications equipment and on-shift personnel, and knowledge of
> associated procedures). The level of simulation should at least be
> timed to simulate resource deployment.

1.  **Notification of State and local authorities** B Actual performance
    of notification is not required unless needed to support DEP credit.

2.  **NRC notification** B Refer to RIS 2006-12, which supplements NRC
    Bulletin 2005-02, Attachment 3, for additional information
    concerning NRC notification of a security event. If the accelerated
    notification does not include the emergency classification, then a
    separate notification should be demonstrated per 10 CFR 50.72(a)(3)
    following the completion of State/local notifications.

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b.  **Mobilization of emergency response organization (ERO):**

> [Extent of play:]{.underline} This should include, as a minimum, the
> assessment of appropriate alternate offsite assembly facility or
> location, identification of appropriate callout scenarios and
> mechanisms, completion and approval of appropriate forms, and a
> walk-through of procedural steps required to activate designated call
> out method(s) or other means used to direct ERO personnel to an
> alternate assembly facility or location. Actual calls need not be
> made, but should be timed to simulate resource deployment. Refer to
> RIS 2006-12, which supplements NRC Bulletin 2005-02, Attachment 5, for
> additional information concerning ERO augmentation during a security
> event.

c.  **Onsite announcements:**

> [Extent of play:]{.underline} This includes, as a minimum, the
> identification of required communications, including message text, to
> be made to site personnel from the control room per the EPIPs and
> imminent threat procedure(s), dealing with event classification,
> onsite protective measures, etc., using designated site communications
> systems. Actual announcements, while encouraged to enhance performance
> during the FOF exercise, need not be made. However, the text of the
> message, at a minimum, needs to be communicated to the controller.
> Refer to RIS 2006-12, which supplements NRC Bulletin 2005-02,
> Attachment 4, for additional information concerning onsite protective
> measures during a security event.

d.  **Security/Operations communications:**

> [Extent of play:]{.underline} This includes as a minimum, the actual
> communication of the following information between the designated
> control room and security command control point (i.e., CAS, SAS) using
> the appropriate primary and backup communications systems per station
> procedures.

1.  The location of intruders and impact of intruder activities to allow
    for the timely implementation of appropriate plant imminent threat
    actions and the timely assessment of event classification.

2.  equipment concerns/priorities,

3.  proposed movement of on-shift staff (equipment operators, fire
    brigade, etc.),

4.  operation of plant equipment that may impact security response
    (steam/heat or radiological conditions restricting access, etc.),

5.  onsite protective measures, and response by offsite responders
    (fire-fighting, ambulance, etc.) to the site.

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e.  **E-Plan emergency classifications:** Prompt and accurate
    classification of postulated events, based on emergency action
    levels (EALs).

> [Extent of play:]{.underline} This includes, as a minimum, the actual
> declaration by the SM of the initial and any subsequent emergency
> classifications per the station-specific EALs based on postulated
> events, to include the required announcements to the designated
> control room staff, etc., as identified in the EPIPs. Refer to RIS
> 2006-12, which supplements NRC Bulletin 2005-02, Attachment 2, for
> additional information concerning acceptable emergency classification
> level definitions and emergency action levels for use during a
> security event.
>
> Note: The prepared scenario should clearly identify the expected event
> classifications and associated emergency action levels, as well as
> onsite protective actions and offsite protective action
> recommendations. Any deviations from the expected scenario may be
> credible, but should be reviewed for accuracy by the inspector.

f.  **Onsite protective actions:**

> [Extent of play:]{.underline} This includes, as a minimum, the actual
> identification by the SM of the appropriate onsite protective actions
> based on security threat (i.e., seek cover, assembly/accountability,
> site evacuation, search and rescue, etc.) using the guidance contained
> in the EPIPs. Refer to RIS 2006-12, which supplements NRC Bulletin
> 2005-02, Attachment 4, for additional information concerning onsite
> protective measures during a security event. The ability to
> effectively communicate protective measures to onsite personnel will
> be demonstrated under Item Ac.@ above.

g.  **Assess radiological release:**

> [Extent of play:]{.underline} This includes, as a minimum, the actual
> identification by the SM of any monitored or unmonitored release(s) in
> progress, and a walk-through of required immediate actions per the
> EPIPS to assess the impact of the release(s) on the public.

h.  **Offsite PARs:** Prompt and accurate identification of the
    appropriate PARs using station-specific PAR methodology, based on
    event classification, plant conditions, and actual or projected
    offsite doses.

> [Extent of play:]{.underline} This includes, as a minimum, the actual
> identification by the SM of appropriate offsite PARs based on
> walk-through of options as identified in the EPIPs. The ability to
> effectively communicate PARs to offsite agencies will be demonstrated
> under Item Aa.@ above.
>
> Note: Exercise play may be terminated based on the successful response
> by station security to the postulated security event prior to
> escalation of the emergency classification that would require
> consideration of offsite PARs.

i.  **Designated control room response:**

> [Extent of play:]{.underline} This includes, as a minimum, the
> following:
>
> Note: The SM is not expected to develop detailed accident mitigation
> strategies beyond those identified in developing the target set.

1.  Discussion of appropriate in-plant response to equipment issues, and
    consideration as to how plant actions are performed.

2.  Based on the report of an actual or perceived imminent physical loss
    of the control room, walk-through actions for a control room
    evacuation based on station procedures, including physical
    protective measures (i.e., from friendly or hostile fire) for
    personnel leaving the control room. In addition, discuss
    contingencies for performing offsite notifications after evacuation
    and prior to the activation of emergency facilities, as applicable.

03.01 Review the previous FOF exercise inspection report and EP
critiques for any FOF exercises conducted by the licensee, and select a
sample of EP corrective actions for inspection during the present
exercise. Consider trends, repeat items and items that could represent a
failure to meet an EP planning standard. Priority should be given to
critique items that were problems with the operations-security interface
and emergency response to a security event, rather than classification,
notification and PAR development, as is normal in other exercise
evaluations. Determine whether corrective actions have been completed
and adequately address the causes.

03.02 During the exercise, develop independent observations of the
licensee=s performance based on the EPIPs and imminent threat procedures
using the scope of demonstration identified in Section 03.01. Identify
any apparent EP performance weakness(es) or issues of inappropriate
participant Aprompting@ in the operations-security interface and
emergency response actions during the security event. Verify that
corrective actions reviewed under Section 02.01 were effective in
correcting the identified weaknesses.

Note: Inspectors must understand that security events may proceed
rapidly resulting in EP activities occurring at a rapid pace. For
example, an event could transition from an Unusual Event to a Site Area
Emergency within a few minutes. The inspector must exercise judgement in
the evaluation of licensee emergency response. Specifically,
classification of lower level emergencies may be overcome by fast moving
events and the successful classification of higher level emergencies.

> Note: Prompting of exercise participants is not a finding under the
> assessment process because it represents no risk significance in
> itself. However, if applicable, prompting would render a DEP PI
> opportunity a failure and should be documented when observed.

03.03 Following the exercise, observe the licensee=s evaluator meetings
and critiques where exercise weaknesses are identified. Observe the
licensee=s presentation of exercise weaknesses to site management.
Critique emphasis should be on the operations-security interface and
emergency response actions in response to the security event.

Determine if the licensee critique identified the exercise weakness(es)
and issues of inappropriate participant Aprompting@ observed by the
inspector. If the inspector identified exercise weaknesses that the
licensee did not, it may represent a failure to adequately assess
exercise weaknesses, and a potential finding under 10 CFR 50.47(b)(14).
Findings associated with licensee critique failures shall be assessed
for significance, addressed during the NRC exit meeting, and documented.

> Note: Documentation will be accomplished by one of the following
> methodologies: (1) inclusion in the resident inspector=s quarterly,
> integrated inspection report, (2) written in an stand-alone inspection
> report, if necessary due to the finding being found to be a color,
> greater than Green, or (3) in the event that the inspector identifies
> an EP issue, with an associated FOF (Safeguards) component, the EP
> inspection results will be documented in the FOF inspection (IP
> 71130.03) report issued by NSIR/DSO and will not be publicly
> available.
>
> Note: Inspector-identified EP weaknesses must be held confidential
> until after the formal licensee critique.

Verify that licensee-identified exercise weaknesses are entered into the
licensee corrective action system in a manner that will allow NRC review
of the resolution in the future, (i.e., during subsequent EP exercises).

> Note: Poor exercise performance is not a regulatory issue if the
> licensee identifies and corrects any exercise weaknesses. Refer to IP
> 71114.01, Section 03.04 thru 03.06, for further guidance on the
> evaluation of licensee critiques, findings, and performance problems
> that may represent a trend or a repeat weakness.

03.04 Gather copies of completed forms and checklists that support or
document classification, notification and PAR development activities and
other areas selected for inspection.

If applicable, determine whether the licensee properly dispositioned the
classification, notification and PAR development activities, with regard
to PI statistics. The licensee=s assessment of performance shall be in
accordance with the criteria of NEI 99-02, Section 2.4, AEmergency
Preparedness Cornerstone, Drill/Exercise Performance.@ Any discrepancies
should be discussed with licensee management and documented.

> Note: FOF exercises are only included in PI statistics at the
> discretion of the licensee and must be identified in advance. However,
> PI opportunities cannot be removed from the statistics due to poor
> performance.

71114.07-04 RESOURCE ESTIMATE

The direct inspection effort for this attachment is estimated to be, on
average, 6-10 hours every three years, regardless of the number of
reactor units at a site. This inspection effort does not require any
additional resources from the inspection program since it utilizes hours
already allotted in Inspection Procedure (IP) 71114.06 (see Section 05,
AProcedure Completion@).

71114.07-05 PROCEDURE COMPLETION

This procedure is considered complete when all the 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 one (1). The inspector shall ensure that a
sample size of 1 is reported in the RPS, Item Reporting (IR), and
completion noted in the RPS, Inspection Planning (IP), when the
procedure is completed in its entirety. The performance of this IP meets
the requirements of observing an EP drill or simulator-based training
evolution in IP 71114.06, and should be performed in place of that
drill/training evolution every three years at each power reactor site.
This should be done even if the licensee has determined not to include
the FOF exercise in its PI statistics.

Attachments:

Revision History Page

END

Attachment 1

Revision History For IP 71114.07

+--------+-------+-------------+-------------+----------+--------------+
| Comm   | Issue | Description | Training    | Training | Comment      |
| itment | Date  | of Change   | Needed      | Co       | Resolution   |
| Tr     |       |             |             | mpletion | Accession    |
| acking |       |             |             | Date     | Number       |
| Number |       |             |             |          |              |
+--------+-------+-------------+-------------+----------+--------------+
| N/A    | 12/   | New         | Yes         | 12/13/05 | ML053490213  |
|        | 30/05 | Procedure   |             |          |              |
+--------+-------+-------------+-------------+----------+--------------+
| N/A    | 10/   | Enhance     | No          | N/A      | ML062840369  |
|        | 25/06 | procedural  |             |          |              |
|        |       | guidance    |             |          |              |
|        | CN    | based on in |             |          |              |
|        | 0     | the field   |             |          |              |
|        | 6-029 | use.        |             |          |              |
+--------+-------+-------------+-------------+----------+--------------+
| N/A    | 10/   | Cl          | No          | N/A      | ML072390215  |
|        | 04/07 | arification |             |          |              |
|        |       | of          |             |          |              |
|        | CN    | guidance,   |             |          |              |
|        | 0     | for         |             |          |              |
|        | 7-031 | do          |             |          |              |
|        |       | cumentation |             |          |              |
|        |       | of report,  |             |          |              |
|        |       | sample      |             |          |              |
|        |       | size, and   |             |          |              |
|        |       | completion  |             |          |              |
|        |       | status.     |             |          |              |
+--------+-------+-------------+-------------+----------+--------------+
|        |       |             |             |          |              |
+--------+-------+-------------+-------------+----------+--------------+
|        |       |             |             |          |              |
+--------+-------+-------------+-------------+----------+--------------+
|        |       |             |             |          |              |
+--------+-------+-------------+-------------+----------+--------------+