NRC INSPECTION MANUAL NSIR

TEMPORARY INSTRUCTION 2515/175

EMERGENCY RESPONSE ORGANIZATION, DRILL/EXERCISE PERFORMANCE INDICATOR,
PROGRAM REVIEW

CORNERSTONE: Emergency Preparedness

2515/175-01 OBJECTIVE

The objective of this Temporary Instruction (TI) is to gather
information to support the program office assessment of the
drill/exercise performance indicator (DEP PI) data.

2515/175-02 APPLICABILITY

This TI applies to all holders of operating licenses for nuclear power
reactors, except nuclear power reactors that have permanently ceased
operations and have certified that fuel has been permanently removed
from the reactor vessel.

2515/175-03 BACKGROUND

The program office is conducting an assessment of the DEP PI at this
time. The calculated DEP PI value may not reflect the licensee=s
performance in each of the three DEP PI performance categories of
classifications, notifications, and PARs. Satisfactory performance in
all three areas of the DEP PI provides the NRC with additional
confidence that licensees are capable of implementing adequate measures
to protect the public. As the DEP PI is currently structured, it may not
provide indication of the licensee=s ability in each of the individual
areas. Since the licensee is only required to submit the eight-quarter,
site average DEP PI data, the NRC does not have the information/data to
assess the individual components of the DEP PI. Accordingly, the staff
has prepared this TI to collect data on the number of successful
opportunities for each of the three response actions separately, during
currently scheduled program inspections.

The objective of the Emergency Preparedness (EP) cornerstone is to
ensure that the licensee is capable of implementing adequate measures to
protect the public health and safety during a radiological emergency.
Licensees maintain this capability through Emergency Response
Organization (ERO) participation in drills, exercises, actual events,
training, and subsequent problem identification and resolution. The
licensee-reported EP PIs are used to assess licensee performance in each
cornerstone and provide a quantitative indication of the licensee=s
ability to implement adequate measures to protect the public health and
safety.

The purpose of the DEP PI is to monitor the timeliness and accuracy of
licensee=s performance in drills and exercises, when presented with
opportunities for classification of emergencies, notification of offsite
authorities, and development of protective action recommendations
(PARs).

The DEP PI is defined as the percentage of all drill, exercise, and
actual opportunities that were performed timely and accurately by Key
Positions, and is calculated on a quarterly basis. The quarterly value
is then used for calculating each licensee=s site average value, which
utilizes DEP PI data from the previous eight quarters. That site average
value is then reported to the NRC on a quarterly basis.

The methodology of its calculation is:

\# of timely & accurate classifications, notifications, & PARs

from DE & AE \* during the previous 8 quarters

[                                                                                                                    ]{.underline}
X100

The total opportunities to perform classifications,

notifications & PARs during the previous 8 quarters

\*DE & AE = Drills, Exercises, and Actual Events

As a minimum, actual emergency declarations and evaluated exercises are
to be included in this PI. In addition, other simulated emergency events
that the licensee formally assesses for performance of classification,
notification or PAR development may be included in this PI. It should be
noted that licensees cannot remove opportunities from the reported PI,
due to poor performance.

In section 0608-08.08.01 of Inspection Manual Chapter (IMC) 0608,
\@Performance Indicator Program,@ it states the following:

> Because of the importance of PIs in the ROP as a source of information
> regarding performance upon which agency actions will be based, PI data
> must be reported accurately. Inspection Procedure 71151, APerformance
> Indicator Verification,@ shall be conducted to review licensees= PI
> data collection and reporting activities for adherence to pertinent
> guidance. It is expected that licensees will make reasonable, good
> faith efforts to comply with the guidance in NEI 99-02, ARegulatory
> Assessment Performance Indicator Guideline@ (i.e., a document which
> was jointly produced by the NRC and the Nuclear Energy Institute
> (NEI). This includes taking appropriate and timely action to identify
> and report performance issues captured by the indicators. It may be
> necessary for inspectors to exercise some judgment on the adequacy of
> licensee actions to make a reasonable, good faith effort to comply
> with the guidance.

In section 03.01.a.8, of Inspection Procedure (IP) 71151, APerformance
Indicator Verification@, it states, in part, the following (under
Verification):

> Review the reported PI data. Review actual emergency plan
> implementation events and evaluated exercise scenarios and a sample of
> drill and training evolution scenarios to verify the number of
> opportunities to classify, notify and develop protective action
> recommendations (PARs). Review licensee critiques for identification
> of failure to classify, notify or develop PARs in a timely and
> accurate manner. Review a sample of documentation forms for
> classification, notification, and PAR activities to verify accuracy.
> If the sample verifies accuracy, accept critique findings for the bulk
> of the PI data. It may be noted that, the resident and regional
> inspectors will periodically observe exercises, drills, and training
> evolutions under the Drill and Exercise inspectable area to verify
> licensee identification of timely and accurate performance. Inspection
> reports documenting these observations should also discuss the PI
> verification aspects of the inspection.

NEI 99-02, provides guidance necessary for licensee=s to collect and
report the data elements used to compute the PI, which ties directly
into the NRC=s ROP. More specifically, the guidance describes licensee
quarterly indicators reports that are to be submitted to the NRC for use
in assessing licensee performance. Further, demonstration of exercises
involving onsite and offsite programs, form the key observational tool
used to support, on a continuing basis, the reasonable assurance finding
that adequate protective measures can and will be taken in the event of
a radiological emergency. The PIs for onsite EP draw significantly from
performance during simulated emergencies and actual declared
emergencies.

2515/175-04 INSPECTION REQUIREMENTS

[General]{.underline}

This TI shall be conducted utilizing regional inspection resources, and
is to be applied to all holders of operating licenses for nuclear power
reactors, except nuclear power reactors that have permanently ceased
operations and have certified that fuel has been permanently removed
from the reactor vessel. The regional inspectors will perform this TI,
as part of their routine inspection activities (e.g., when they perform
normally scheduled baseline and PI verification inspections).

[Specific]{.underline}

04.01 The inspector shall collect the data necessary to complete
Attachment 1 of the TI. The inspector shall ensure that the data
collected is from the previous 8 quarters for the following:

a.  Separate number of quarterly opportunities versus the number of
    quarterly successes, for performance of classification, notification
    and PAR development.

b.  Percentile result of the separate, quarterly DEP PI data elements.

c.  Reported quarterly DEP PI data (i.e., the site average percentage
    value, using previous 8 quarters of data).

04.02 The inspector shall report the results of this inspection as
described in section 05.

04.03 Inspectors should ensure completion of Attachment 1, ATI 2515/175,
Emergency Response Organization, Drill/Exercise Performance Indicator
Program Review, Licensee Data Tables.@ This is a request for data that
is not normally requested and/or reported.

04.04 The inspector may provide the licensee=s data via electronic means
(e.g., fax or email), or it can be mailed in.

2515/175-05 REPORTING REQUIREMENTS

The results of this TI inspection procedure shall be forwarded to the
NSIR/DPR group office, Attention: Ronald V. Schmitt. The email address
is: <Ronald.Schmitt@nrc.gov> or [rvs@nrc.gov.]{.underline} The fax
number for the office is 301-415-6382. The mailing address is: USNRC,
Ronald V. Schmitt, MailStop T03B46M, Washington, D.C. 20555. The
inspector performing the TI will note its performance in Section 40A5
(Other Activities) of the applicable inspection report. The report
should state "...that the inspector performed TI 2515/175, ensured the
completeness of the TI's Attachment 1, and then forwarded the data to
NRC, HQ".

2515/175-06 COMPLETION SCHEDULE

This TI will be completed no later than December 31, 2009.

2515/175-07 EXPIRATION

This TI will expire on June 30, 2010.

2515/175-08 CONTACTS

For technical support regarding the performance of this TI and other
emergent issues, contact Ronald V. Schmitt via email at
<Ronald.Schmitt@nrc.gov> or rvs@nrc.gov, or by telephone at
301-415-4082.

2515/175-09 STATISTICAL DATA REPORTING

All direct inspection effort expended on this TI is to be charged to the
baseline inspection program (IP 71151) with an IPE code of BI.

2515/175-10 ORIGINATING ORGANIZATION INFORMATION

10.01 [Organizational Responsibility]{.underline}

This TI was initiated by the Licensing and Inspection Branch
(NSIR/DPR/EP).

10.02 [Resource Estimate]{.underline}

Inspections conducted under this TI are not expected to require staff
hour expenditures exceeding those required for inspections of these
licensees using the current inspection procedure IP 71151 "Performance
Indicator Verification".

10.03 [Training]{.underline}

No specialized training is needed to perform inspection requirements in
this TI beyond basic training for inspectors (specified in IMC 1245,
\"Inspector Qualifications\"). However, if technical support is needed
during the inspection, contact the EP group technical contact stated in
section 08.

2515/175-11 REFERENCES

NRC Inspection Manual, Manual Chapter 0608, APerformance Indicator
Program@ (ADAMS Accession No. ML070360605), dated February 27, 2007

NRC Inspection Manual, Inspection Procedure 71151, APerformance
Indicator Verification@ ((ADAMS Accession No. ML070720376), dated June
28, 2007

NEI 99-02 (Revision 5), ARegulatory Assessment Performance Indicator
Guideline@, dated July, 2007

END

  ------------------------ ------- ------- ------- ------- ------------ ------- ------- ------- -------
  **Facility Name:**                                       **Docket                             
                                                           Number(s):                           
                                                           50-**                                

  **CLASSIFICATIONS**                                                                           

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  ***Number of successes,                                                                       
  per quarter***                                                                                

  ***Planned number of                                                                          
  opportunities, per                                                                            
  quarter***                                                                                    

  ***Total percentage, per                                                                      
  quarter***                                                                                    

  ***Reported DEP PI                                                                            
  percentage value, using                                                                       
  previous 8 quarters of                                                                        
  data***                                                                                       
  ------------------------ ------- ------- ------- ------- ------------ ------- ------- ------- -------

  ------------------------ ------- ------- ------- ------- ------------ ------- ------- ------- -------
  **Facility Name:**                                       **Docket                             
                                                           Number(s):                           
                                                           50-**                                

  **NOTIFICATIONS**                                                                             

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  ***Number of successes,                                                                       
  per quarter***                                                                                

  ***Planned number of                                                                          
  opportunities, per                                                                            
  quarter***                                                                                    

  ***Total percentage, per                                                                      
  quarter***                                                                                    

  ***Reported DEP PI                                                                            
  percentage value, using                                                                       
  previous 8 quarters of                                                                        
  data***                                                                                       
  ------------------------ ------- ------- ------- ------- ------------ ------- ------- ------- -------

  ------------------------ ------- ------- ------- ------- ------------ ------- ------- ------- -------
  **Facility Name:**                                       **Docket                             
                                                           Number(s):                           
                                                           50-**                                

  **PROTECTIVE ACTION                                                                           
  RECOMMENDATIONS (PARs)**                                                                      

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  ***Number of successes,                                                                       
  per quarter***                                                                                

  ***Planned number of                                                                          
  opportunities, per                                                                            
  quarter***                                                                                    

  ***Total percentage, per                                                                      
  quarter***                                                                                    

  ***Reported DEP PI                                                                            
  percentage value, using                                                                       
  previous 8 quarters of                                                                        
  data***                                                                                       
  ------------------------ ------- ------- ------- ------- ------------ ------- ------- ------- -------

+--------+-------+----------------------+------+---------+-------------+
| Comm   | Issue | Description of       | Trai | T       | Comment     |
| itment | Date  | Change               | ning | raining | Resolution  |
| Tr     |       |                      | Requ | Com     | Accession   |
| acking |       |                      | ired | pletion | Number      |
| Number |       |                      |      | Date    |             |
+========+=======+======================+======+=========+=============+
| N/A    | 06/   | This Temporary       | None | N/A     | ML081020312 |
|        | 05/08 | Instruction (TI) is  |      |         |             |
|        |       | being issued to      |      |         |             |
|        | CN-0  | gather information   |      |         |             |
|        | 8-017 | for support of the   |      |         |             |
|        |       | programmatic         |      |         |             |
|        |       | assessment of        |      |         |             |
|        |       |                      |      |         |             |
|        |       | Drill/ Exercise      |      |         |             |
|        |       | Performance (DEP)    |      |         |             |
|        |       | Performance          |      |         |             |
|        |       | Indicator (PI) data. |      |         |             |
+--------+-------+----------------------+------+---------+-------------+