Issue Date: 12/31/96 - 1 - 82701

NRC INSPECTION MANUAL PERB

INSPECTION PROCEDURE 82701

OPERATIONAL STATUS OF THE EMERGENCY PREPAREDNESS PROGRAM

PROGRAM APPLICABILITY: 2515

SALP FUNCTIONAL AREA: PLANT SUPPORT (PLTSUP)

82701-01 INSPECTION OBJECTIVES

01.01 To determine whether the licensee's emergency preparedness program is maintained in a state of operational readiness.

01.02 To determine whether changes to the licensee's emergency

preparedness program since the last inspection meet commitments,

NRC requirements, and affect the licensee's overall state of

emergency preparedness.

82701-02 INSPECTION REQUIREMENTS

02.01 Emergency Plan and Implementing Procedures

a. If significant or major changes have been made to the

emergency preparedness program, assess whether these changes

have adversely affected the licensee's overall state of

emergency preparedness and have been appropriately incorporated into the licensee's emergency plan and implementing

procedures.

b. Verify that major or significant changes to the emergency

plan and implementing procedures have been reviewed, approved, and distributed in accordance with approved licensee

procedures and NRC requirements before implementation.

02.02 Emergency Facilities, Equipment, Instrumentation, and

Supplies

a. Determine whether key facilities and equipment are adequately

maintained and determine whether changes made since the last

inspection are technically adequate, meet NRC requirements,

licensee commitments, and are appropriately incorporated into

the emergency plan and implementing procedures. Include 2

licensee offsite communication circuits in this determina- 2
82701 - 2 - Issue Date: 12/31/96

2 tion.

b. Determine whether changes to emergency facilities, equipment,

instrumentation, and supplies have adversely affected the

licensee's emergency preparedness program.
Issue Date: 12/31/96 - 3 - 82701

02.03 Organization and Management Control. If changes have

been made to the emergency organization or management control

systems, determine the effect of these changes on the licensee's

emergency preparedness program and verify that these changes have

been properly incorporated into the emergency plan and implementing

procedures.

02.04 Training

a. Interview a small sample of individuals assigned key roles

for emergency response to determine whether they have been

trained as required and understand their emergency assignments, responsibilities, authorities, and changes to the

implementing procedures.

b. If changes have been made to the licensee's emergency

preparedness program since the last inspection, determine

whether responsible personnel are aware of the changes,

understand them, and have been adequately trained to implement them.

02.05 Independent and Internal Reviews and Audits

a. Examine independent and internal review and audit reports for

the licensee's emergency preparedness programs since the last

inspection to determine compliance with NRC requirements and

licensee commitments.

b. Evaluate the licensee's corrective actions for audit identified deficiencies and those identified during drills and

exercises.

02.06 Effectiveness of Licensee Controls

a. Evaluate the effectiveness of the licensee's controls in

identifying, resolving and preventing problems by reviewing

such areas as corrective action systems, root cause analyses,

safety committees, and self assessment in the area of

emergency preparedness.

b. Determine whether there are strengths or weaknesses in the

licensee's controls for the identification and resolution of

the reviewed issues that could enhance or degrade plant

operations or safety. 

02.07 Public Meeting. Conduct a public meeting following the 2

exit meeting with the licensee if the staff has determined that a 2

significant breakdown of the emergency preparedness program has 2

occurred or there is strong public interest. 2

2

82701-03 INSPECTION GUIDANCE

General Guidance 

Evaluations conducted in accordance with this procedure are limited

to the staff, activities, records, and facilities of the licensee.
82701 - 4 - Issue Date: 12/31/96

Where necessary to verify licensee performance, concerning

interactions with organizations and persons involved in offsite

emergency preparedness, these activities are limited to reviews of

pertinent records available through the licensee. If additional

information is needed about offsite emergency preparedness, it can

be obtained from FEMA.

Specific Guidance

03.01 Emergency and Implementing Procedures

a. An assessment of all changes that may substantively impact

the emergency plan, since the last inspection, may be

accomplished by reviewing the bases for licensee evaluations

of these changes on program effectiveness and discussing them

with licensee management. A review of the implementing

procedures will indicate whether these changes have been

appropriately incorporated. Professional judgement must be

exercised to determine the impact of specified changes on the

overall state of emergency preparedness.

b. Requirements for changes to emergency plan and implementing

procedures are found in 10 CFR 50.54(q) and 10 CFR 50,

Appendix E. Requirements for procedural controls are found

in the Technical Specifications and relevant administrative

procedures. This assessment includes, but is not limited to,

careful examination of the following:

1. Whether changes considered to decrease the effectiveness

of the approved emergency plan were implemented before

NRC review and approval.

2. Whether temporary changes were made permanent or cancelled in accordance with approved procedures that govern

such changes.

3. Whether all changes were submitted to NRC within 30 days

after the changes were made.

4. Whether signatures on actual concurrence sheets are

consistent with those required for concurrence.

5. Whether changes were reflected as appropriate in other

station procedures.

6. Whether current copies of the emergency plan and implementing procedures are readily available in the Emergency

Response Facilities (ERFs) and control room. 

7. Licensee distribution lists should indicate whether

appropriate personnel and organizations were sent copies

of changes to the emergency plan and implementing

procedures. Discussions with a small sample of key
Issue Date: 12/31/96 - 5 - 82701

licensee emergency response personnel and a review of the

distribution lists will confirm whether copies of changes

to the emergency plan and implementing procedures were

dispatched and received in a timely manner.

03.02 Emergency Facilities, Equipment, Instrumentation and

Supplies. Requirements for emergency facilities, equipment and

supplies are found in 10 CFR 50.47(b), 10 CFR 50, Appendix E,

Technical Specifications, NUREG-0737 and Supplement 1 to

NUREG-0737. 

a. Essential emergency facilities, equipment, instrumentation,

and supplies should be maintained in a state of operational

readiness by the licensee. Determination of their status may

be accomplished by discussion with cognizant licensee

personnel and direct observation of the ERFs and a small,

representative sample of other essential facilities, equipment, instrumentation and supplies. It is important to

verify that any changes in this area meet NRC requirements

and licensee commitments and are appropriately incorporated

into the emergency plan and implementing procedures. This

assessment includes, but is not limited to the following:

1. The operational readiness of the ERFs and changes that

modify their effectiveness or timely activation. Such

changes may include, but are not limited to, changes in

size, location, physical facilities, supplies, internal

arrangements, and use during normal operations. ERFs

include the Operational Support Center, Technical Support

Center, and Emergency Operations Facility. The status of

emergency preparedness equipment, instrumentation and

supplies in the control room can be determined by direct

observation. 

2. Technical adequacy, operability (if applicable), and

maintenance of facilities, equipment, instrumentation,

and supplies used in emergency response that are not part

of the ERFs. Careful examination of communications

equipment, in-plant and onsite radiological survey

equipment, data acquisition systems, testing of ERF's air

cleaning systems, and emergency kits is important.

Changes made to licensee offsite communication circuit(s) 2

should be evaluated for the effect of those changes on 2

the ability of the circuit(s) to survive or recover from 2

a severe natural disaster or fire. Offsite communication 2

circuit recovery plan(s) and onsite repair support for 2

these circuits should be included in this review. 2

b. Professional judgement must be exercised to determine the

impact of specified changes on the licensee's emergency

preparedness program.

03.03 Organization and Management Control. Discussions with

cognizant licensee management and the review of relative documentation, are methods to determine whether changes have been made to

the licensee's emergency organization or management control

systems. If changes have been made, professional judgement must be
82701 - 6 - Issue Date: 12/31/96

exercised to determine the effect of these changes on the licensee's overall emergency preparedness program. Reviewing

relevant portions of the emergency plan and implementing procedures

is a way to verify that all changes are included. Changes that can

adversely impact the administration or management of the licensee's

routine and overall emergency preparedness program, include

changes in organizational structure; responsibilities, authorities

and staffing of key emergency response personnel; interfaces and

coordination between onsite, offsite, and corporate organizations;

and shift staffing. Such changes include, but are not limited to,

the following:

a. Changes in the duties assigned to the Emergency Planning

Coordinator. This may include changes in the reporting

chain, assignment of additional responsibilities outside the

emergency preparedness area, or actual reassignment of the

Emergency Preparedness Coordinator's functional responsibilities to another individual. Such changes may not be reflected in the implementing procedures, but are normally

obtainable by examining the organizational or administrative

procedures and by interviewing licensee personnel.

b. Reorganization involving either the corporate or plant staffs

that may result in some areas of the emergency organization

functional responsibilities not being covered by an assigned

individual or a loss of alternate or backup functions.

c. Assignment and qualifications of individuals new to the

emergency organization. A review of the training and

qualification records of individuals assigned functional

responsibilities in the emergency organization since the last

inspection, will indicate whether the individual(s) completed

all training requirements before the new assignment and are

qualified to fulfill the newly assigned responsibilities.

d. Changes in key offsite support personnel or methods of

coordination with them. This information is normally

obtained from the licensee or from the FEMA RAC Chairman).

e. Changes in personnel availability which may impact augmentation of the emergency organization (e.g. personnel moves

further from the plant).

f. Changes in agreements with offsite support organizations.

03.04 Training

a. Requirements for training are found in 10 CFR 50.47(b)(15)

and 10 CFR 50, Appendix E, Item IV.F. It is important to

interview the Emergency Coordinator, Emergency Directors in

the ERFs, the Shift Supervisor, and selected individuals

involved in the notification process. As part of the

interview process, a walk-through with the shift crew,

including the Shift Supervisor and Shift Technical Advisor,

on one or more shifts (as necessary to assess training

effectiveness rather than individual performance), is
Issue Date: 12/31/96 - 7 - 82701

required. It is essential that this be done with minimal

interference with normal operations. Duplication of any

areas inspected in the Reactor Operator Licensing Program is

not to be done, unless weaknesses in emergency response were

identified in the examination report from the facility's

previous qualification or requalification exams. During the

walk-through, responsible licensee emergency response staff

and management, as appropriate should be able to (1) evaluate

hypothetical conditions or data them, (2) identify respective

emergency action levels, (3) evaluate or, where appropriate,

perform dose calculations (4) classify the emergency using

the latest procedures, and (5) recommend appropriate protective actions. Where weaknesses are identified during the

reactor operator qualification or requalification exams or

during the annual emergency preparedness exercise, and

additional inspection is required, followup inspection can be

performed under Inspection Procedure 82206, "Knowledge and

Performance of Duties," as a regional initiative.

1. The licensee should use the correct procedures and

demonstrate proficiency during each step in the classification and notification processes. Classifications

should be correct. Notifications should be made as

required. Both classifications and notifications should

be done in a timely manner.

2. For each emergency class, the licensee should demonstrate

profi- ciency for initiating protective actions onsite

and recommending those to be taken offsite. Requirements

for protective actions are found in 10 CFR 50.47(b)(2).

b. A small sample of significant changes to the licensee's

procedures and equipment can be examined and discussed with

responsible personnel to determine whether they are aware of

the changes, understand them and have received training

appropriate for their use.

03.05 Independent and Internal Reviews and Audits

a. Independent and internal reviews or audits of the licensee's

emergency preparedness program is generally done on a 12

month cycle. Requirements may be found in 10 CFR 50.54(t).

The qualifications of the respective audit personnel are

normally found in the licensee's QA Manual. Criteria for

auditors normally includes training and experience commensurate with the scope, complexity and special nature of the

activities being audited. Audit personnel are required to

have no direct responsibility for the development or implementation of the emergency preparedness program. Was an

audit plan and check list used for the audit? Examination of

selected audit reports will indicate whether NRC requirements

have been met. Were the scope and depth of the audit

comprehensive enough to provide a complete overview of the

entire program? Items requiring particular attention are

negative findings, improvement items, trends and actual or

potential programmatic weaknesses. Negative trends and

actual or potential programmatic weaknesses are to be
82701 - 8 - Issue Date: 12/31/96

discussed with licensee management. 

b. The examination of the licensee's corrective action system(s)

for four or five of the most serious problems identified by

the audits, inspections, enforcement actions, drills,

exercises, and LERs are to be selected and reviewed. Does

the licensee have a separate system for tracking drill and

exercise deficiencies and weaknesses? By a review of the

licensee's corrective action system(s), commitments, maintenance logs, work orders and other relevant documentation, and

by discussions with responsible personnel and direct observation, it can be determined whether identified problems were

reviewed by appropriate management, prioritized commensurate

with safety significance, appropriately assigned and whether

corrective actions were technically correct and performed in

a timely manner. 

03.06 Effectiveness of Licensee Controls

a. When safety issues, events or problems are reviewed, the

adequacy of the results of licensee controls may be assessed

by determining how effective the licensee was in performing

the following:

1. Initial identification of the problem.

2. Elevation of problems to the proper level of management

for resolution (internal communications and procedures).

3. Root cause analysis.

4. Disposition of operability issues.

5. Implementation of corrective actions.

6. Expansion of the scope of corrective actions to include

applicable related systems, equipment, procedures and

personnel actions.

b. The determination of whether there are strengths or weaknesses in the licensee's controls will be limited to those

issues, events, or problems reviewed in detail. The evaluation will not draw sweeping conclusions about the licensee's

overall control program but is to be very specific in

identifying any licensee strengths or weaknesses with the

individual items reviewed.

2 03.07 Public Meeting. The region should conduct a public 2 meeting if: (1) the preliminary results of the inspection indicate 2 a significant breakdown of the licensee's onsite emergency 2 preparedness program has occurred; or (2) there is strong public 2 interest as demonstrated by past and present communications with 2 members of the public. The identification of three or more 2 exercise weaknesses may be indicative of a significant programmatic 2 breakdown; consideration should be given to the root cause of the 2 weaknesses and the performance record of the licensee in the EP
Issue Date: 12/31/96 - 9 - 82701

area. The public meeting should follow the formal exit meeting 2

with the licensee, complying with the ten day notification 2

requirements discussed in IMC 1100. 2

2

NOTE: For additional inspection guidance, please refer to

Inspection Procedure 40500, "Effectiveness of Licensee

Controls in Identifying, Resolving, and Preventing Problems."

82701-04 RESOURCES

The estimated time to complete this procedure is 35 hours of direct 2

onsite inspection effort (when conducting public meetings, add an 2

additional 10 hours). 2

2

82701-05 REFERENCES

Memorandum to Office Directors and Regional Administrators from 2

James M. Taylor, Executive Director for Operations, dated February 2

12, 1966, "Meetings Between NRC Staff and the Public." (NUDOCS 2

72852/356-357) 2

2

Regulatory Guide 1.97, "Instrumentation for Light-Water Cooled

Nuclear Power Plants to Assess Plant and Environs Conditions During

and Following an Accident," Revision 3, May 1983 (Microfiche

Address: 04393/323-326).

Regulatory Guide 1.101, "Emergency Planning and Preparedness for

Nuclear Power Reactors," Revision 3, August 1992. 

NUREG-0396, "Planning Basis for the Development of State and Local

Government Radiological Emergency Response Plans in Support of

Light Water Nuclear Power Plants," December 1978 (Microfiche

Address: 00567/260 - 00568/40).

NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and

Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980 (Microfiche

Address: 01997/314 - 01998/71). 

NUREG-0696, "Functional Criteria for Emergency Response Facilities," February 1981 (Microfiche Address: 08158/270-313).

NUREG-0731, "Guidelines for Utility Management Structure and

Technical Resources," September 1980 (Microfiche Address:

06910/234-265).

NUREG-0737, "Clarification of TMI Action Plan Requirements,"

November 1980 (Microfiche Address: 07003/27-284) and Supplement 1,

January 1983 (Microfiche Address: 17301/342-363).

EPA-520/1-75-001-A, "Manual of Protective Actions for Nuclear

Incidents," January 1990. 
82701 - 10 - Issue Date: 12/31/96

ANSI/ANS 3.1-1981, "Selection, Qualification and Training of

Personnel for Nuclear Power Plants," (Supersedes ANSI

N18.1-1971-77) (Microfiche Address: 65959/199-225).

END