UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

REGION III 

2443 WARRENVILLE ROAD, SUITE 210 

LISLE, IL 60532-4352 

June 1, 2011 

MEMORANDUM TO: Timothy Kobetz 

Chief, Reactor Inspection Branch 

Division of Inspection and Regional Support 

Office of Nuclear Reactor Regulation 

FROM: Julio Lara /RA/ 

Team Leader, Technical Support Staff (TSS) 

Division of Reactor Projects (DRP) 

Region III 

SUBJECT: COMPLETION OF TEMPORARY INSTRUCTION (TI) 2515/184, 

“AVAILABILITY AND READINESS INSPECTION OF SEVERE 

ACCIDENT MANAGEMENT GUIDELINES (SAMGs)" AT 

REGION III SITES - REVISION 

 The enclosure to this Memorandum contains the responses to the specific questions 

asked in Section 03.01 of the TI. This Memorandum supersedes my Memorandum previously 

submitted on May 27, 2011, as it contains a correction for one inspection item. The completion 

of this TI will also be documented in the second quarter NRC Integrated Inspection Report for 

each site, 05000xxx/2011003. 

 Please contact me at 630-829-9731 if you have any questions. 

Enclosure: 

As stated 

DISTRIBUTION: 

See next page 

CONTACT: Julio Lara, Team Leader, TSS 

 DRP, Region III 

 (630) 829-9731
UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

REGION III 

2443 WARRENVILLE ROAD, SUITE 210 

LISLE, IL 60532-4352 

June 1, 2011 

MEMORANDUM TO: Timothy Kobetz 

Chief, Reactor Inspection Branch 

Division of Inspection and Regional Support 

Office of Nuclear Reactor Regulation 

FROM: Julio Lara /RA/ 

Team Leader, Technical Support Staff (TSS) 

Division of Reactor Projects (DRP) 

Region III 

SUBJECT: COMPLETION OF TEMPORARY INSTRUCTION (TI) 2515/184, 

“AVAILABILITY AND READINESS INSPECTION OF SEVERE 

ACCIDENT MANAGEMENT GUIDELINES (SAMGs)" AT 

REGION III SITES - REVISION 

 The enclosure to this Memorandum contains the responses to the specific questions 

asked in Section 03.01 of the TI. This Memorandum supersedes my Memorandum previously 

submitted on May 27, 2011, as it contains a correction for one inspection item. The completion 

of this TI will also be documented in the second quarter NRC Integrated Inspection Report for 

each site, 05000xxx/2011003. 

 Please contact me at 630-829-9731 if you have any questions. 

Enclosure: 

As stated 

cc w/encl: Distribution via ListServe 

DISTRIBUTION: 

See next page 

CONTACT: Julio Lara, Team Leader, TSS 

 DRP, Region III 

 (630) 829-9731 

DOCUMENT NAME: G:\DRPIII\1-Secy\1-Work In Progress\RIII_TI-184_Completion_MemoRev1.docx 

 Publicly Available Non-Publicly Available Sensitive Non-Sensitive 

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl 

"E" = Copy with attach/encl "N" = No copy

OFFICE RIII RIII RIII RIII 

NAME JLara:cs 

DATE 06/01/11 

OFFICIAL RECORD COPY 
Memo to T. Kobetz from J. Lara dated June 1, 2011 

SUBJECT: COMPLETION OF TEMPORARY INSTRUCTION (TI) 2515/184, “AVAILABILITY 

AND READINESS INSPECTION OF SEVERE ACCIDENT MANAGEMENT 

GUIDELINES (SAMGs)" AT REGION III SITES - REVISION 

DISTRIBUTION:

cc w/encl: M. Satorius, RIII 

 C. Pederson, RIII 

 A. Lewin, NRR 

 F. Brown, NRR 

 D. Merzke 

 S. Orth 

 J. Heck 

 A. Barker 

 DRPIII 

 DRSIII 

 P. Buckley 

 T. Tomczak 

RidsNrrDorlLpl3-1 Resource 

RidsNrrDorlLpl3-2 Resource 

RidsNrrDirsIrib Resource 

RidsNrrPMBraidwood Resource 

RidsNrrPMByron Resource 

RidsNrrPMClinton Resource 

RidsNrrPMDCCook Resource 

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RidsNrrPMFermi2 Resource 

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RidsNrrPMPrairieIsland Resource 

RidsNrrPMQuadCities Resource
Enclosure 

NRC TEMPORARY INSTRUCTION 2515/184 

Site Page #

BRAIDWOOD STATION, UNITS 1 AND 2 ............................................................................................... 1–2 

BYRON STATION, UNITS 1 AND 2 ......................................................................................................... 3–4 

CLINTON POWER STATION ................................................................................................................... 5–7 

D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 ................................................................... 8–12 

DAVIS-BESSE NUCLEAR POWER STATION ..................................................................................... 13–15 

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 ............................................................... 16–18 

DUANE ARNOLD ENERGY CENTER ................................................................................................. 19–24 

FERMI POWER PLANT, UNIT 2 .......................................................................................................... 25–27 

KEWAUNEE POWER STATION .......................................................................................................... 28–32 

LASALLE COUNTY STATION, UNITS 1 AND 2 .................................................................................. 33–35 

MONTICELLO NUCLEAR GENERATING PLANT ............................................................................... 36–40 

PALISADES NUCLEAR PLANT ........................................................................................................... 41–43 

PERRY NUCLEAR POWER PLANT .................................................................................................... 44–45 

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 ........................................................................... 46–49 

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 .............................................. 50–53 

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 .......................................................... 54–55 
1 Enclosure 

BRAIDWOOD STATION, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? Various. Dates ranging from 2002 

through 2011. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

 X The SAMG procedures were kept in 

an “Information Only” binder. 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X Yes, SAMGs are located in the 

control room but not all of them. 

The SAMGs related procedures 

located in the control room are: 

SACRG-1, “Severe Accident Control 

Room Guidelines Initial Response”; 

SACRG-2, “Severe Accident Control 

Room Guidelines for Transients after 

the TSC is Functional." 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

X Corporate level procedure CC-AA102. If a configuration change has 

the potential to impact the SAMGs, 

then this procedures requires the 

creation of a station action tracking 

item to ensure the applicable 

procedures are revised. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

 X Revision 1 of the industry guidance 

was issued in October 2001 and have 

not been incorporated into the site’s 

SAMGs. 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 The initial training is a review of the 

procedures and some tabletop 

exercises. Licensed operators, 

SROs, TSC Decision Makers and 

TSC Evaluators are trained 

periodically by an annual read and 

sign and through periodic exercise 

participation that involve SAMGs 

usage. 
BRAIDWOOD STATION UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

2 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X All received training. 

Did they receive periodic

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

X All received periodic training. 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

X 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

X Periodic exercises involving SAMG 

usage are scheduled at a minimum of 

every 6 years. 
3 Enclosure 

BYRON STATION UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? 1997 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

 X The SAMG procedures were kept in 

an “Information Only” binder. 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

X Corporate level procedure CC-AA102. This procedure is not being 

followed. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

 X Revision 1 of the industry guidance 

was issued in October 2001 and have 

not been incorporated into the site’s 

SAMGs. 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 The initial training is a review of the 

procedures and some tabletop 

exercises. Licensed operators, 

SROs, TSC Decision Makers and 

TSC Evaluators are trained. 

Periodic retraining is required every 

6 years per corporate procedure 

EP-AA-122-1001. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X All received training. 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

X All received periodic training. 
BYRON STATION UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

4 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

X 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

 X 
5 Enclosure 

CLINTON POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? • CPS 4701.01, “SAG-1 Primary 

Containment Flooding,” 

Revision 4 on September 7, 2007 

• CPS 4702.01, “SAG-2 RPV 

[Reactor Pressure Vessel], 

Containment, and Radioactivity 

Release Control,” Revision 4a on 

September 28, 2009 

• CPS 4750.01, “SAMG Team – 

Technical Support Guidelines 

(TSG),” Revision 0d on 

December 21, 2009 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

 X The SAMG procedures were kept in 

an “Information Only” binder along 

with the station’s Emergency 

Operating Procedures (EOPs). 

Current controlled procedure copies 

except for CPS 4702.01, however, 

were available in the EOF from the 

licensee’s computer database. 

CPS 4702.01 is undergoing revision 

and was not retrievable from the 

licensee’s computer database during 

the inspection. The licensee wrote 

action request (AR) 01212213 to 

identify this problem with an action 

assigned to provide current copies of 

the SAMG and EOP flowcharts to the 

EOF. This action has been 

completed. 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X The SAMG procedures are covered 

under the licensee’s procedure 

control and document management 

system; however, there is no 

requirement for periodic SAMG 

procedure reviews and revisions. 

The licensee captured this issue in 

CR 01212213. 
CLINTON POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

6 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? 

(Y/N/Partially-describe) 

X Procedural guidance for review of 

design changes to prompt updating 

SAMG procedures is contained in 

CC-AA-102, “Design Input and 

Configuration Change Input 

Screening.” 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X The licensee has incorporated 

appropriate changes to its SAMG 

procedures through Revision 3 of the 

BWR Owners’ Group Emergency 

Procedure and Severe Accident 

Guidelines. A high-level comparison 

revealed many differences, but those 

differences appeared to be 

appropriate. 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 Initial training for designated 

Emergency Response Organization 

(ERO) staff and all licensed operators 

is conducted in classroom under the 

Licensed Operator Training Program. 

Designated ERO staff includes the 

Station Emergency Director, 

Operations Manager, Technical 

Manager, Mechanical Engineer, 

Core Thermal/Hydraulic Engineer, 

and Electrical Engineer. 

Refresher/periodic SAMG training is 

conducted for the above individuals in 

classroom under the Licensed 

Operator Requalification Program 

annually. ERO staff takes the same 

classroom training as the licensed 

operators. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X 

Did they receive periodic training 

(Y/N/document periodicity) on the 

SAMGs and how they relate to 

their assigned duties? 

X Refresher/periodic SAMG training is 

conducted in classroom under the 

Licensed Operator Requalification 

Program annually. 

(2) Can they articulate their 

responsibilities with respect to the 

use of SAMGs (Y/N/document 

who would actually implement the 

licensee’s SAMGs)? 

X Designated ERO staff and all 

licensed operators would be 

involved in implementing the SAMG 

procedures. Designated ERO staff 

includes the Station Emergency 

Director, Operations Manager, 

Technical Manager, 
CLINTON POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

7 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

Mechanical Engineer, 

Core Thermal/Hydraulic Engineer, 

and Electrical Engineer. 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

X The licensee has an administrative 

requirement to conduct a drill that 

uses the SAMG procedures once 

every 6 years. A drill was performed 

at Clinton Power Station on June 15, 

2005, and was therefore due again in 

2011. The inspectors observed a drill 

on May 17, 2011, that was credited 

towards the 6-year licensee 

administrative requirement. 

However, the inspectors noted the 

following: 

• A drill involves only one of the 

five ERO duty teams. Although 

the same drill may be used for 

training more than one of the 

ERO duty teams during the year, 

all individuals who are qualified 

for implementing the SAMG 

procedures during an emergency 

are not necessarily included in a 

periodic exercise/drill that uses 

the SAMG procedures every 

6 years. The licensee’s ERO 

training and qualification 

procedure does not require all of 

the above designated ERO staff 

and licensed operators to 

participate in a drill that uses the 

SAMG procedures. 

• The drill observed on May 17th

involved only ERO staff in the 

TSC. It did not include licensed 

operators in the plant simulator. 
8 Enclosure 

D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 

2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? There has not been any full scale 

updates or revisions to the SAMGs 

and they have not been updated to 

incorporate Westinghouse Owners 

Group (WOG) Severe Accident 

Management Guidance, Revision 1, 

dated October 2001. 

However, various procedures have 

been updated based on licensed 

operator feedback during training 

or for other minor issues 

(i.e., formatting or typographical 

errors). Four guidelines are at 

Revision 4, which were issued on 

April 8, 2009: 

• Severe Accident Control Room 

Guidelines, SACRG-1, “Initial 

Response” and SACRG-2, 

“Transients After the TSC is 

Functional”; and 

• 2 Severe Accident Guidelines, 

SAG-1, “Feeding the Steam 

Generators” and SAG-2, 

“Depressurize the RCS.” 

Regarding the other guidelines, 

11 have been revised once; 3 have 

been revised twice; 2 have been 

revised 3 times; and 12 have never 

been revised. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X The inspectors verified that controlled 

copies of the SAMGs were located in 

the TSC. 

However, several discrepancies were 

noted: 

• Two revisions of SACRG-2 

(Revision 3 and Revision 4) 

were located in the TSC with 

Revision 3 filed in the guideline 

binder and Revision 4 filed 

behind SACRG-1 in the SACRG1 guideline binder; 
D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 

2515/184 

9 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

• Two guidelines were missing 

from the TSC (SAG-7-2, 

“Prevent Hydrogen Burn;” 

SAG-7-3, “Operate Hydrogen 

Recombiners”); and 

• One guideline (SAG-5, “Reduce 

Fission Product Releases”) in 

the TSC was the wrong revision 

(Revision 0 instead of 

Revision 1). 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X This information is based on 

reviewing documents from the 

licensee’s Nuclear Document 

Management group that indicated a 

controlled copy of all the SAMGs was 

located in the EOF. 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X Controlled copies of control room 

specific guidelines, Severe Accident 

Control Room Guidelines (SACRG-1 

and SACRG-2), as well as the 

computational aids (CA) were 

located in each unit’s control room. 

In addition, controlled copies of all 

the SAMGs were located in the 

Shift Manager Office, which is located 

just outside the control rooms. 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X SAMGs are controlled documents 

and therefore are required to be 

audited each year in accordance 

with PMP-2030-DOC-001, 

“Document Control,” to verify that 

they are up-to-date. 

However, the inspectors concluded 

that the audits were not effective 

because several guidelines in the 

TSC were missing or outdated; the 

audits were random samples and 

therefore did not review all the 

procedures; and, operations 

department could not find records for 

the last completed audit. 

Also, nothing in the licensee’s 

document management system 

requires the SAMGs to be reviewed 

or revised on a periodic basis. 
D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 

2515/184 

10 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

 X Nothing in the licensee’s 

configuration control and change 

management systems specifically 

requires the SAMGs to be reviewed 

for impact from plant modifications. 

However, there was evidence that the 

SAMGs would get revised if setpoints 

in emergency operating procedures 

changed. Specifically, SAG-0, 

“TSC Diagnostic Guide,” was revised 

when the reference temperature for 

degraded core cooling, as specified in 

OHP-4023-FR-C.2, “Degraded Core 

Cooling,” was changed from 700F to 

757F in February 2007. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X The licensee’s guidelines’ format and 

high level steps are generally 

consistent with the WOG guidance. 

However, the SAMGs have not been 

revised to incorporate the WOG, 

Revision 1, guidance, which impacted 

17 guidelines. This issue has been 

entered into the licensee’s corrective 

action program. 

Also, the inspectors noted some 

differences with respect to the 

content and number of attachments 

contained in the WOG guidance as 

compared to the licensee’s specific 

procedures; and the licensee 

developed separate guidelines for 

some guidelines whereas the WOG 

guidance had separate sections 

within a single guideline. 

For example, the WOG guidance 

contained three sections within 

SAG-5, “Reduce Fission Product 

Releases,” to address releases from 

containment, the steam generators, 

and the auxiliary building, while the 

licensee developed SAG-5-1, 

SAG-5-2, and SAG-5-3 to address 

the 3 release paths. 
D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 

2515/184 

11 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 Training is generally conducted as 

classroom training. However, some 

operators have been trained using 

tabletop scenarios utilizing the 

procedures. 

Initial license candidates receive 

SAMG training during their 

qualification process. 

Licensed operators get refresher 

training on the SAMGs every 3-years. 

The Site Emergency Coordinator 

(SEC-TSC), SEC Assistant (TSC), 

Plant Evaluation Team (PET) -

Operations and PET-Training 

emergency response (ERO) 

personnel get training on SAMGs and 

refresher training every 3 years. 

However, the licensee had previously 

identified that SAMG training for 

ERO personnel was not conducted in 

2010 as scheduled, which was 

entered into their corrective action 

program. 

The inspectors noted that training for 

ERO personnel in the TSC is not 

required for initial qualifications but is 

required within 1 year of qualifying. 

Also, SAMG training for any ERO 

personnel in the EOF is not required 

by the training procedures. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X See “e” above for details. 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

X See “e” above for details. 
D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 

2515/184 

12 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

X Yes, all interviewees could generally 

describe how the SAMG network 

would be implemented and what their 

specific role would be. 

The SEC-TSC would be the primary 

decision maker with support from 

PET-Ops and PET-Training when 

determining which mitigation strategy 

within the SAMGs to implement. 

The developed mitigation strategy 

would then be delivered to the control 

room and discussed with the Shift 

Manager prior to implementing. 

The Shift Manager would discuss the 

strategy with the Unit Supervisor 

(SRO) who would then direct the ROs 

and other crew members to 

implement the strategy. 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

 X There have not been any emergency 

preparedness exercise or drill 

scenarios that would require the 

SAMGs to be utilized. Training has 

primarily been lesson plans taught in 

the classroom with a limited amount 

of tabletop scenarios that walked 

through how to implement the 

guidelines. 
13 Enclosure 

DAVIS-BESSE NUCLEAR POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? Revision 00 of the Davis-Besse 

SAMGs are dated 12/10/1997. 

The SAMGs have not been updated; 

Revision 00 is still in use. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X Two controlled copies and bases 

documents are located in the TSC. 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

 X They do not keep a copy in the EOF, 

however, there are copies nearby, 

located across the hall in the TSC. 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X One controlled copy and bases 

document is kept in the control room. 

In addition, one copy is kept for 

senior reactor operators at the work 

control center desk, located in the 

same vicinity as the outage control 

center. 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

X The SAMGs are controlled 

documents. The administrative 

procedure NG-EN-00550, “Severe 

Accident Management,” covers the 

revision, review and approval process 

to revise the Davis-Besse SAMGs. 

This procedure does not provide a 

periodicity for the review process of 

the SAMGs. The SAMGs have not 

been revised since issuance in 1997. 

Procedure RA-EP-02320, 

Emergency Technical Assessment, 

provides methodology for estimating 

core damage and describes 

engineering assessment activities 

during an emergency response to a 

major off-normal event. 

This procedure refers to SAMGs and 

is covered by the procedure control 

and document management process. 

Procedure NG-NS-00500, Nuclear 

Emergency Response, requires an 

annual review of RA-EP-02320. 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

 X SAMGs cover a regime that the 

licensee has considered to be outside 

the licensing basis and are not 

described in the USAR or technical 

specifications. Therefore, the 

SAMGs are not considered in part of 

the design change or 50.59 process. 
DAVIS-BESSE NUCLEAR POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

14 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

In addition, the licensee’s 

administrative procedure NG-EN00550, “Severe Accident 

Management,” determined that the 

50.59 review process is not 

applicable to the implementation or 

modification of the Davis-Besse 

SAMGs. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X The Davis-Besse SAMGs are 

consistent with B&W Owners Group 

Generic Severe Accident Guidelines 

(GSAG) dated March 11, 1994. A list 

of material changed, added to, or 

removed from the GSAG is 

documented in an appendix to the 

Davis-Besse SAMG. 

Some variations from the guidance 

documents have been made to 

accommodate site specific plant 

design differences. The changes do 

not significantly affect the outcome of 

the SAMGs. 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 SAMG initial training is conducted as 

a computer based training course. 

SAMG requalification training is a 

computer based training course 

required every two years. Training is 

required for the Emergency Assistant 

Plant Manager, Shift Manager, 

Shift Engineer, Unit Supervisor, 

Emergency Director, Core Thermal 

Hydraulic Engineer, Emergency Plant 

Manager, SAM Engineer, and TSC 

Engineering Manager. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X The senior reactor operators, certain 

TSC staff, and TSC managers have 

received initial training on the 

SAMGs. 

Reactor operators are not required to 

be trained on the SAMGs. 
DAVIS-BESSE NUCLEAR POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

15 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

X SAMG requalification training is a 

computer based training course 

required every two years. 

Reactor operators are not required to 

be trained on the SAMGs. 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

X The TSC engineers and managers 

are responsible for analyzing the 

specific plant conditions and 

evaluating the potential to use the 

guidelines in the SAMGs. The TSC is 

responsible for providing their 

recommendation to the control room 

staff. The operating crew would be 

responsible for implementing the 

SAMGs. Senior reactor operators are 

responsible for giving direction to 

reactor operators and other available 

personnel to perform the required 

tasks. 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

 X Davis-Besse does not design 

Emergency Preparedness 

Drill/Exercise scenarios that would 

purposely drive the plant to the use of 

SAMGs. 

The Operations training department 

indicated that SAMG tabletop drills 

are conducted on years when the 

computer based training is not 

offered. Tabletop training 

documentation was not able to be 

provided to the inspectors and could 

not be verified. 
16 Enclosure 

DRESDEN NUCLEAR POWER STATION UNITS 2 AND 3 - NRC TEMPORARY INSTRUCTION 

2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? August 16, 2009 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X SAMGs are controlled by Dresden 

Administrative Procedure DAP 09-04, 

“Control of Dresden Emergency 

Operating Procedures,” Revision 18. 

There was no administrative 

requirement for periodic review and 

revision. 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

X Licensee procedure CC-AA-102, 

“Design Input and Configuration 

Change Impact Screening,” 

Revision 20, requires a review of the 

SAMGs before a design change. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X The major headings of the SAMGs 

correspond to the BWROG 

Emergency Procedure and 

Severe Accident Guidelines, 

Appendix B: Technical Basis, 

Volume 2, Revision 2, March 2001. 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 Licensed Operators and select 

members of the licensee’s 

Emergency Response Organization. 

Initial training is conducted in the 

classroom. Requalification training is 

annual and consists of a read and 

sign of three lesson plans. 

The inspectors reviewed licensee 

lesson plan Severe Accident 

Management Phenomenology, 

Revision 3, August 2009. The course 

material stated: 

“External cooling of the reactor 

pressure vessel may not be 

possible if the pressure vessel has 

a support skirt without holes of 

sufficient size to vent the steam 

generated from the boiling 

process. If steam is not vented, a 

steam blanket is formed around 
DRESDEN NUCLEAR POWER STATION UNITS 2 AND 3 - NRC TEMPORARY INSTRUCTION 

2515/184 

17 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

the lower vessel head, displacing 

water from the region and 

impeding the heat removal 

process. At Dresden there is only 

one inspection hole in the skirt, 

and it is approximately 3 feet 

below the vessel bottom head. 

Therefore there is no vent path for 

the steam above this elevation.” 

The inspectors questioned this 

material. The licensee provided 

drawing M-1175D-5, Revision A, 

which showed that the center of the 

inspection port was actually 1.5 feet 

above the vessel bottom head. 

The licensee documented this in 

Issue Report 1215029. 

A potential generic issue was 

identified during this review as 

discussed below: 

The inspectors reviewed NUREG/CR5869, “Identification and Assessment 

of BWR In-Vessel Severe Accident 

Mitigation Strategies.” The inspectors 

interpreted NUREG/CR-5869 to 

mean that due to the location of the 

inspection port, and the absence of 

any other vents, there would still be a 

steam void below the reactor vessel 

head, and that the flooding of the 

containment would not prevent 

eventual failure of the reactor vessel 

bottom head. 

The inspectors reviewed the BWR 

Owners Group Emergency Procedure 

and Severe Accident Guidelines, 

Appendix B: Technical Basis, 

Volume 2, Revision 2, which stated: 

“Flooding the containment to 

above the elevation of core debris 

inside the RPV [reactor pressure 

vessel] also provides some 

cooling to the debris, even if the 

water cannot enter the RPV, by 

heat transfer through the vessel 

wall. Most RPV skirts are not 

vented, however, and trapped 
DRESDEN NUCLEAR POWER STATION UNITS 2 AND 3 - NRC TEMPORARY INSTRUCTION 

2515/184 

18 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

noncondensibles can prevent 

water in the drywell from 

contacting parts of the lower head. 

The external cooling provided by 

flooding is therefore insufficient to 

ensure that core debris will be 

retained in the RPV, but may 

delay vessel failure by several 

hours and precludes in-core 

instrument thimble failures.” 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X Yes, all those interviewed remember 

receiving initial SAMG training. 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

X The members of the ERO 

remembered that they receive an 

e-mail once per year that asks them 

to perform a read and sign of three 

lesson plans. 

The operators recalled periodic 

training in the past but not in the last 

4 or 5 years. The Shift Managers get 

the read and sign e-mail every year 

also, but when it was shown to them, 

they could not recall it. 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

X 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

 X The training for operators does not 

include a practical exercise of walking 

through the SAMGs. Simulator 

exercises proceed to the point of 

recognition that entry into the SAMGs 

is necessary and the exercise is then 

terminated. The Emergency 

Response Organization training 

includes a SAMG walk through once 

every 6 years. 
19 Enclosure 

DUANE ARNOLD ENERGY CENTER - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? Duane Arnold’s SAMGs are primarily 

governed by the following Severe 

Accident Guideline (SAG) flowcharts. 

SAG-1; Primary Containment 

Flooding; Revision 5; 

August 22, 2010 

SAG-2; RPV, Containment & Rad 

Release Control; Revision 6; 

August 22, 2010 

SAG-3; Hydrogen Control; 

Revision 5; January 11, 2011 

Note that the SAG flowcharts are 

supported by several other 

procedures: SAG bases documents, 

the SAG Plant Specific Technical 

Guidelines (PSTG), the SAG 

Implementation Guide, and Severe 

Accident Management Procedures 

(SAMPs). All SAG support 

documents have last been revised 

between August, 2010, and April, 

2011. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

X The DAEC SAGs are considered 

controlled documents in accordance 

with the licensee’s Document 

Management System. 

Following issuance of TI 2515/184, 

but prior to NRC inspection of the TI, 

the licensee identified three items 

related to this inspection subsection: 

Administrative Control Procedure 

(ACP) 1406.7, Emergency Operating 

Procedure Maintenance Program, 

covers programmatic controls for the 

Emergency Operating Procedures 

(EOP) program. The licensee 
DUANE ARNOLD ENERGY CENTER - NRC TEMPORARY INSTRUCTION 2515/184 

20 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

identified that ACP 1406.7 did not 

include the SAG flowcharts and 

related procedures. As an 

enhancement, the licensee initiated 

CR 01650497 to include the SAG 

procedures with ACP 1406.7. 

The licensee identified that periodic 

reviews were not required to be 

performed for the SAGs and SAMPs. 

The licensee initiated Routine Work 

Task (RWT) 01651253 to require 

periodic reviews of the SAG 

flowcharts and support procedures. 

The licensee identified that the 

DAEC Quality Assurance Topical 

Report only required periodic reviews 

of EOPs, Abnormal Operating 

Procedures (AOPs), and Emergency 

Plan procedures once every two 

years. The licensee initiated 

Condition Report (CR) 01651247 to 

require periodic review of the SAGs. 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

X Procedure ACP 1203.52, 

Assessment of Potential Impact on 

EOPs/SAGs, covers review of SAG 

and SAG-related procedures with 

respect to any design modifications at 

the site. 

The licensee also utilizes an 

EOP/SAG impact checklist that is 

used during modification package 

screening to determine if there would 

be any impact on SAMG procedures. 

Following issuance of TI 2515/184, 

but prior to NRC inspection of the TI, 

the licensee identified some editorial 

changes within ACP 1203.52 and 

initiated Procedure Change Request 

(PCR) 01651263 to revise the 

procedure. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X The DAEC SAG flowcharts are based 

on Revision 2 of the BWR Owners’ 

Group Emergency Procedure and 

Severe Accident Guidelines. 

The licensee developed and 

maintains a differences document 

between the SAGs and the PSTG. 
DUANE ARNOLD ENERGY CENTER - NRC TEMPORARY INSTRUCTION 2515/184 

21 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

The inspectors performed an 

independent high-level comparison of 

the SAGs with the BWR Owners’ 

Group Guidelines, identified some 

differences, and verified that the 

licensee had captured them in the 

site’s SAG/PSTG differences 

document. The inspectors concluded 

that the DAEC SAGs were consistent 

with the BWR Owners’ Group 

Guidelines and that the licensee had 

identified noteworthy differences. 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 Training on SAGs at DAEC is 

outlined in Emergency Planning 

Department Manual (EPDM) 1014, 

Severe Accident Management 

Training Guidelines and Matrices. 

Severe Accident Guideline training is 

required for emergency response 

organization (ERO) personnel 

designated as performing an 

evaluator, decision maker, or 

implementer roles with respect to the 

SAGs. 

Training for SAGs consists of detailed 

training for decision maker and 

evaluator positions, and overview 

training for implementer positions. 

All SAG evaluators, decision makers, 

and implementers are required to 

complete initial training through 

classroom study, self-study or 

computer-based instruction, and 

tabletop drills. Refresher training is 

also required to be completed on a 

biennial (every two years) basis for all 

SAG-related positions. This training 

consists of classroom review and 

tabletop exercises. 

The normal ERO-designated SAG 

decision makers consist of the 

Technical Support Center (TSC) 

Operations Supervisors, typically 

consisting of current or past senior 

licensed operators. 

The normal ERO-designated SAG 

evaluators are members of the TSC 

Accident Management Team (AMT). 

The AMT consists of the individuals 

qualified as TSC Operations Liaisons, 
DUANE ARNOLD ENERGY CENTER - NRC TEMPORARY INSTRUCTION 2515/184 

22 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

Reactor Engineers, and Technical 

Analysis Engineers. 

The normal ERO-designated SAG 

implementers consist of control room 

licensed and non-licensed operators. 

Following issuance of TI 2515/184, 

but prior to NRC inspection of the TI, 

the licensee identified that 

qualification cards for SAG training 

allowed for completion of SAG 

training within 6 months of being 

qualified as a SAG decision maker or 

evaluator. The licensee generated 

CR 01651230 to remove this 6 month 

exception and require SAG 

qualification prior to assuming duty as 

a decision maker or evaluator. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 The inspectors interviewed 

two licensed reactor operators and 

two licensed senior reactor operators 

(SAG implementers), two AMT 

evaluators (one TSC Reactor 

Engineer, and one TSC Operations 

Liaison), and two TSC Operations 

Supervisors (decision makers). 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X All individuals interviewed stated that 

they had received initial training on 

the SAG program and procedures. 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

X All individuals interviewed stated that 

they had received periodic training on 

a biennial basis. All individuals 

interviewed stated that the periodic 

refresher training was tailored to their 

specific assigned SAG roles and 

responsibilities. 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

X All individuals interviewed were able 

to articulate their general 

responsibilities with respect to their 

decision making, evaluating, or 

implementing roles. All individuals 

that were interviewed understood 

what the other SAG roles were and 

how their specific roles and 

responsibilities were related. 

Depending on when refresher training 

was last taken, the level of detail 

regarding the individuals’ specific 

responsibilities varied. However, all 

individuals were, at a minimum, 

aware of their fundamental 
DUANE ARNOLD ENERGY CENTER - NRC TEMPORARY INSTRUCTION 2515/184 

23 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

responsibilities with respect to use of 

the SAGs. 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

X Per EPDM 1014, one ERO response 

drill or exercise is required to include 

use of the SAGs on a biennial basis. 

This allows for a periodic exercise on 

use of the SAGs by a decision maker, 

and evaluators and implementers 

scheduled for the drill or exercise 

being conducted that day. 

Participation in an ERO response drill 

or exercise that uses SAGs is not a 

requirement for maintaining 

qualification as a decision maker, 

evaluator, or implementer, so not all 

SAG-qualified individuals have 

participated in an ERO response drill 

or exercise where SAGs were used. 

However, SAG-qualified individuals 

are required to participate in tabletop 

exercises every two years during 

refresher training. 

The inspectors requested a paper 

copy of the most recently performed 

ERO response drill that included use 

of the SAGs as part of their review. 

Following this request, the licensee 

identified two issues: 

ERO response drills or exercised with 

SAG use were conducted when the 

SAGs were first implemented in 1998. 

These drills were performed on a 

yearly basis (at a greater frequency 

than EPDM 1014 required) from 1999 

through 2002, and 2005 through 

2009. An ERO response drill or 

exercise with SAG use was not 

conducted in calendar year 2004. 

Although EPDM 1014 requires an 

ERO response drill or exercise with 

SAG use on a biennial basis, 

Emergency Plan Implementing 

Procedure (EPIP) 6.1, Drill and 

Exercise Program, and EPDM 

Form EP-035, Drill/Exercise Objective 

& Evaluation Process, stated that the 

facility should perform an ERO 
DUANE ARNOLD ENERGY CENTER - NRC TEMPORARY INSTRUCTION 2515/184 

24 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

response drill or exercise with SAG 

use on an annual basis. 

Based on these discrepancies, 

the licensee initiated CR 01652552 

to revise EPIP 6.1 and EP-025 to 

reflect the biennial requirements of 

EPDM 1014. The licensee concluded 

that although an ERO response drill 

or exercise with SAG use was not 

conducted in calendar year 2004, 

there were no current concerns with 

the ability of the ERO SAG decision 

makers, evaluators, and 

implementers to use the SAGs 

since all individuals had maintained 

required SAG qualifications. 
25 Enclosure 

FERMI POWER PLANT, UNIT 2, NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? Revision 2 was issued in March 2003 

for Severe Accident Guides (Control 

Room). The Severe Accident 

Technical Guides (TSC), Revision 1, 

were revised in September 2009. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X The TSC staff is responsible for 

implementing the SAMGs. There are 

controlled copies of the SAMGs for 

each of the required TSC staff 

members. 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

 X The EOF staff does not implement 

SAMGs. Copies are available in the 

EOF through the electronic 

document system. 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X The Control Room crew initiates the 

SAMGs. There are two sets of the 

Severe Accident Guides and one set 

of Severe Accident Technical Guides 

in the Control Room. 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X The SAMGs are not controlled under 

the licensee’s procedure control and 

document management system. The 

SAMGs are controlled as part of the 

Radiological Emergency Response 

Preparedness (RERP) plan, not a 

procedure. The SAMGs are 

controlled through General 

Administration Conduct Manual 

MGA14 (Severe Accident 

Management Program). 

The MGA does not contain a 

requirement for a periodic review. 

c Does the licensee’s configuration 

control and change management 

systems cause the licensee to update 

SAMGs to reflect design changes? 

(Y/N/Partially-describe) 

X The 50.59 applicability determination 

process, Section 2.3.1, requires a 

review of RERP plans (see 

Section 'b') during the engineer 

design change process. However, 

there is no specific item which 

indicates a review of SAMGs should 

be done. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X The licensee’s SAMGs are 

consistent with the latest industry 

guidance and differences are well 

documented. The differences make 

the SAMGs plant specific. 

The SAMG strategy to fill the drywell 

to provide ex-vessel cooling maybe 
FERMI POWER PLANT, UNIT 2, NRC TEMPORARY INSTRUCTION 2515/184 

26 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

impacted by the design of the vessel 

support skirt. This information was 

originally provided by GE. The lower 

support skirt assembly is 

manufactured by Combustion 

Engineering and has four inspection 

holes around the skirt. The holes are 

covered and will not allow steam or 

water flow in the area of the bottom 

of the vessel after flood-up of the 

drywell. The licensee has the BWR 

owners group guidelines stating that 

the skirt did not provide a vent path 

to keep water on the bottom of the 

vessel and that this could be a 

potential issue during the use of the 

SAMG procedures. The licensee 

captured the issue as a missed 

opportunity in CARD 11-24978. 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 Training is performed in the 

classroom and TSC through 

procedural discussions and 

self-study. The licensed operator 

positions receive initial and 

requalification (every 4 years) 

training on SAMG procedures. 

This includes the Control Room crew 

and the Technical Engineer in the 

TSC. The Emergency Director, 

I&C Engineer, Thermal/Hydraulic 

Engineer, and System Engineers 

receive initial training only. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the 

SAMGs during an emergency to 

determine: 

 Interviewed 4 licensed operators, 

2 TSC managers, and 2 of each of 

the separate TSC engineering 

positions. 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X For non-licensed personnel, 

SAMG training only included 

self-study (read and sign). 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

 X Licensed operators receive 

requalification training every 4 years. 

The non-licensed TSC staff does not 

receive periodic training. 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

 X Of the personnel interviewed, all but 

one could articulate their 

responsibilities. 

One person interviewed did not 

recognize that the system engineer 
FERMI POWER PLANT, UNIT 2, NRC TEMPORARY INSTRUCTION 2515/184 

27 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

position, a position the person is 

qualified for in the TSC, was 

responsible for part of SAMGs. 

SAMGs are implemented by the 

control room staff through the 

Emergency Operating Procedure 

Flowcharts. 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

 X The licensed operators receive 

classroom training every 4 years. 

This does not include implementation 

of the SAMGs in the simulator. 

The 6 year EP (Emergency Planning) 

matrix, including SAMGs, only 

requires one SAMG drill during the 

6 year period. Therefore, only the 

team that is playing in the drill and 

the controllers participate. One drill 

every 6 years does not cover all TSC 

ERO (Emergency Response 

Organization) members. 
28 Enclosure 

KEWAUNEE POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? Fifteen of the 25 SAMG-related 

procedures were last revised on 

October 3, 2000. The remaining 10 

were subsequently revised at various 

dates through the licensee’s 

configuration control and change 

management programs. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X Controlled copies of the SAMGs were 

available as hard copies and 

electronically. 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X Controlled copies of the SAMGs were 

available as hard copies and 

electronically. 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X Controlled copies of the SAMGs were 

available as hard copies and 

electronically. 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X SAMGs were covered by the 

licensee’s procedure control and 

document management program, 

including requirements for periodic 

review and revision; however, the 

inspectors identified that the periodic 

reviews required by station procedure 

were not recently performed or 

documented. The inspectors 

determined that the last periodic 

review for the SAMGs was completed 

in 2005. 

The licensee concurred with the 

inspectors’ observations and initiated 

condition report (CR) CR427092. 

The inspectors also noted that in 

April 2011 the licensee wrote 

CR 419676, which documented the 

periodic review of SAMGs were not 

adequate based on the number of 

guideline issues identified during a 

licensee review. 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

X Procedure DNES-AA-GN-1002, 

“Nuclear Engineering Standard – 

Document Impact Summary,” 

Revision 5, required a review of the 

SAMGs when changes were being 

made to the plant. 

The inspectors reviewed several 

recent design changes and verified 

that the SAMGs had been updated. 
KEWAUNEE POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

29 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X The SAMGs were consistent with the 

Westinghouse Owners Group 

(WOG), “Severe Accident 

Management Guidance,” Revision 0, 

dated June 1994, with the exception 

of SAG-3, “Inject Into The RCS,” 

Revision C and SAG-6, 

“Control Containment Conditions,” 

Revision C. 

In addition, the inspectors determined 

that the licensee did not currently 

implement the background 

documents for all the SAMGs in the 

electronic procedures program. 

The licensee concurred with the 

inspectors’ observations and initiated 

CR 426999 to evaluate the issue. 

The inspectors also determined that 

the latest revision of the WOG 

document (Revision 1, dated October 

2001) had not been incorporated into 

the SAMGs. The inspectors 

determined that the licensee 

committed to periodic reviews of the 

SAMGs, per Section 5 of NEI 91-04, 

“Severe Accident Issue Closure 

Guidelines,” in a letter to the NRC 

dated January 30, 1995. Section 5.1 

of licensee procedure NAD-14.06, 

“Severe Accident Management 

Program Maintenance and Control,” 

dated October 6, 2009, required that 

the engineering group review new 

correspondence from industry and 

regulatory agencies to determine the 

potential impact on the existing 

SAMGs and associated basis 

documents. The inspectors 

determined that the licensee had not 

reviewed the impact of Revision 1 of 

the WOG guidance on the SAMGs 

nor conducted any self-assessments 

of the SAMGs. The inspectors 

identified that 17 of the licensee’s 

SAMGs could be affected by WOG 

Revision 1. 

The licensee concurred with the 

inspectors’ observations and initiated 

CR 426999 for this issue. 
KEWAUNEE POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

30 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 Operators

All licensed operators received 

training on SAMGs as part of their 

initial license class and then 

biennially. Training generally 

consisted of a combination of the 

following methods: 

classroom lecture; tabletop drills; 

simulator/frozen simulator scenarios; 

read and sign; and some self-study. 

The initial training consisted of 

completion of SAMG-specific lesson 

plans for the shift manager, control 

room supervisor, shift technical 

advisor, and reactor operator 

positions. 

Non-licensed auxiliary and equipment 

operators did not receive any 

SAMG training. The licensee 

concurred with the inspectors’ 

observation and initiated CR 423711 

and CR 423733 for this issue. 

Other Emergency Response 

Organization (ERO) Members

The other positions in the ERO that 

received initial SAMG training were 

the Emergency Director, Severe 

Accident Management (SAM) Team 

Leader, SAM Core Hydraulics 

Engineer, and SAM Operations Lead. 

The training methods for these 

members generally consisted of a 

combination of the following methods: 

classroom lecture; tabletop drills; 

read and sign; and some self-study. 

The inspectors noted that the 

overview training for the Emergency 

Director did not cover all the specific 

actions contained in the SAMGs and 

that increased training in this area 

may be warranted for this position. 

The licensee concurred with the 

inspectors’ observations and initiated 

CR 427900 for this issue. 
KEWAUNEE POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

31 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

The inspectors determined that no 

continuing training requirement 

existed in the training program for 

these other ERO members. 

In addition, the inspectors noted that 

certain key positions in the ERO that 

included additional decision makers, 

evaluators, and implementers 

(e.g., TSC Director, Engineering 

Coordinator, Event Operations 

Director, maintenance personnel) 

did not receive either initial or 

continuing training. The licensee 

concurred with the inspectors’ 

observations and initiated CR 424870 

and CR 427517 for these issues. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X The level and detail of training varied 

for the different emergency response 

positions. 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

 X As described in Section 'e,' licensed 

operators receive periodic re-training 

on SAMGs; however, other ERO 

members did not because a 

continuing training program was not 

established for those positions with 

respect to SAMGs. 

All interviewees expressed that 

additional training through static 

simulator walkthroughs or periodic 

drills/exercises would be beneficial. 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

X 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

 X The inspectors determined there 

were no exercises on SAMG use 

since August 18, 1998, when a 

plant-wide drill was conducted as 

part of initial implementation of the 

SAMGs at Kewaunee. The only 

exception to this observation was 

licensed operators who received 
KEWAUNEE POWER STATION - NRC TEMPORARY INSTRUCTION 2515/184 

32 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

SAMG requalification training 

biennially. 

The licensee agreed with the 

inspectors’ observations and initiated 

CR 427519 for this issue. 
33 Enclosure 

LASALLE COUNTY STATION, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? LSAMG-101 Primary Containment 

Flooding (Unit 1), Revision 6, 

March 2, 2011; 

LSAMG-102 RPV, Containment, and 

Radioactive Release Control (Unit 1), 

Revision 6, March 2, 2011; 

LSAMG-201 Primary Containment 

Flooding (Unit 2), Revision 6, 

March 2, 2011; 

LSAMG-202 RPV, Containment, and 

Radioactive Release Control (Unit 2), 

Revision 6, March 2, 2011; 

LSAMG-003 Technical Support 

Guidelines, Revision 0, May 1, 2000. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

X 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

X 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 Initial training consisted of a 

classroom tabletop session 

comprising a walkthrough of the 

SAMG procedures, and scenario 

examples. 
LASALLE COUNTY STATION, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

34 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

Reactor Operators, Senior Reactor 

Operators, and TSC Emergency 

Response Organization staff 

responsible for SAMG 

implementation. 

Training periodicity: All staff 

members with SAMG responsibilities 

receive initial training, described 

above. Periodic training differs by 

role: SROs cover 1⁄2 of the SAMG 

procedures yearly, such that all 

SAMGs will be covered every 

2 years; TSC SAMG implementing 

staff receive annual power point 

refresher training packages. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X Yes: RO1, RO2, SRO1, SRO2, 

TSC Staff 1, TSC Staff 2, TSC Mgr 2. 

No: TSC Mgr 1 (Station Emergency 

Director): Although this individual, 

who was a previously licensed SRO, 

received SAMG training as part of his 

licensed operator training, he had not 

received any initial SAMG training as 

part of his current TSC managerial 

role. 

Did they receive periodic training 

(Y/N/document periodicity) on the 

SAMGs and how they relate to 

their assigned duties? 

X Yes: SRO2, TSC Staff 1. 

No: 

RO1: Could not recall any periodic 

SAMG training. 

RO2: Indicated that sporadically, 

SAMG scenarios would arise in 

annual training cycle; however, the 

SAMGs would not be executed. 

The scenario would end when the 

entry conditions were met for 

SAMG entry. 

SRO1: Individual had only been 

licensed for less than a year and was 

not yet aware of any periodic training. 
LASALLE COUNTY STATION, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

35 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

TSC Staff 2: Was unaware of any 

periodic training requirements but 

indicated that sporadically, 

SAMG scenarios would arise in 

EP drills/exercises. 

TSC Mgr 1: Individual could not 

recall any periodic training. 

TSC Mgr 2: Individual was not sure 

that periodic training requirements 

existed for his position of TSC 

Director. 

(2) Can they articulate their 

responsibilities with respect to the 

use of SAMGs (Y/N/document 

who would actually implement the 

licensee’s SAMGs)? 

X 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

X Periodicity: Every 6 years on a 

limited scope basis for the positions 

of SAMG Evaluators/Decision 

Makers, and ERO TSC positions. 

For Operators, SAMG scenarios 

would sporadically arise in annual 

training cycle drills; however, the 

scenario would end when the entry 

conditions were met for SAMG entry. 
36 Enclosure 

MONTICELLO NUCLEAR GENERATING PLANT - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? SAMG Flow Charts 

A.7-SAMG-01—Primary Containment 

Flooding 

Revised 3/30/05 

A.7-SAMG-02—RPV, Containment, 

and Radioactivity Release Control 

Revised 2/16/07 

A.7-SAMG-03—Combustible Gas 

Control 

Revised 2/23/11 

Technical Support Guidelines 

A.7-TSG-01—Introduction; Revised 

12/15/98 

A.7-TSG-02—Control Parameter 

Status Assessment; Revised 8/25/08 

A.7-TSG-03—Plant Status 

Assessment; Revised 3/17/08 

A.7-TSG-04—System Status 

Assessment; Revised 3/25/08 

A.7-TSG-05—EOP/SAMG Action 

Status Assessment; Revised 3/7/07 

A.7-TSG-06—Abnormal System 

Configuration; Revised 6/24/09 

Actions within the SAMGs are carried 

out via EOP support procedures, and 

these procedures are referenced 

within the SAMG procedures when 

necessary. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X 
MONTICELLO NUCLEAR GENERATING PLANT - NRC TEMPORARY INSTRUCTION 2515/184 

37 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X These documents are classified as 

vital controlled documents, and are 

revised in accordance with the site’s 

QA program. The inspectors marked 

“No” because the QA program does 

not specify a required review 

frequency for these procedures. 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs 

to reflect design changes? 

(Y/N/Partially-describe) 

X 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 Type of Training Conducted:

The site uses position-specific lesson 

plans and mentoring guides to train 

individuals on the SAMG procedures. 

For those Senior Reactor Operators 

(SROs) designated as the SAMG 

decision makers, these lesson plans 

are presented as a classroom training 

session. 

Individuals receiving evaluator 

training had initially received a 

onetime classroom training session in 

order to be considered qualified for 

this position. Over time, this one-time 

classroom training had transitioned to 

a computer based training course 

involving a review of the classroom 

lesson plans and slide shows. At the 

time of this inspection, the licensee 

was in the process of transitioning 

these training courses back to 

classroom trainings. 

People Trained on SAMGs:

Individuals qualified in the Emergency 

Response Organization (ERO) as 

Operations Group Leaders (OGLs), 

Emergency Directors (EDs), 

Emergency Managers (EMs), 

Engineering Group Leaders (EGLs), 
MONTICELLO NUCLEAR GENERATING PLANT - NRC TEMPORARY INSTRUCTION 2515/184 

38 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

and the Reactor Operators (ROs) and 

SROs are provided training on the 

SAMGs. Other TSC staff designated 

to serve as SAMG evaluators on the 

SAMG Accident Management Team 

(AMT) receive training as well. 

Frequency of Training:

SROs and ROs receive biennial 

training on the SAMGs. TSC staff 

designated as evaluators, and certain 

TSC managers initially received 

onetime training, but were assigned 

biennial training requirements in 

November 2010, but they have not 

yet received any refresher training. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 Interviewees included: 

• Two ROs (SAMG implementers); 

• Two SROs - one Control Room 

supervisor and one newly qualified 

SRO. (They would be SAMG 

implementers if on duty in the 

control room at the time of the 

event. They would be TSC 

Operations Group Leader 

(SAMG decision maker) or 

Assistant Operations Group 

Leader (evaluator) if they are on 

call at the time of the event); 

• Two TSC staff—a Nuclear 

Engineer and an Engineering 

Coordinator (both of these 

positions are designated as SAMG 

evaluators; other TSC staff 

positions that were not specifically 

designated as SAMG evaluators 

did not receive SAMG training and 

were not interviewed); 

• Two TSC managers designated to 

implement the SAMGs—at 

Monticello, off-duty Shift Managers 

(SMs) and Control Room 

Supervisors (CRSs) in their TSC 

positions as Operations Group 

Leaders are the managers 

designated as SAMG decision 

makers, and are responsible for 
MONTICELLO NUCLEAR GENERATING PLANT - NRC TEMPORARY INSTRUCTION 2515/184 

39 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

directing SAMG implementation 

(all of them are also SROs). 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X 

Did they receive periodic training 

(Y/N/document periodicity) on the 

SAMGs and how they relate to their 

assigned duties? 

 X The inspectors marked “No” because 

the two TSC staff members 

interviewed (SAMG evaluators) said 

that they did not receive any formal 

periodic training on the SAMGs. Note 

that this has already been addressed 

by the licensee, in that the training 

program was updated in November 

2010 to require biennial SAMG 

training for TSC evaluator positions. 

All other interviewees (all ROs and 

SROs) were receiving training on an 

approximate 2 year frequency, from 

what they could recall. 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

 X Overall, interviewees were able to 

articulate their SAMG functions. 

SROs and ROs easily described their 

control room functions during SAMG 

implementation, and SROs that were 

SMs and CRSs also described most 

aspects of their TSC Manager SAMG 

responsibilities. 

However, the SMs and CRSs in their 

roles as the Ops Group Leaders 

(the TSC managers designated as 

the SAMG implementation “decision 

makers”) did not identify themselves 

as the decision makers. They also 

did not discuss their role in the 

formation and direction of the 

Accident Management Team 

(the team formed upon transition 

into the SAMGs, charged with 

SAMG strategy implementation). 

The inspectors marked “No” 

because both of these are 

important leadership aspects of 

their TSC Manager SAMG roles. 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

 X There was a tabletop exercise 

performed in 2000 for individuals that 

would implement the SAMGs during 

an emergency, but periodic exercises 

have not been performed. In 2008, 
MONTICELLO NUCLEAR GENERATING PLANT - NRC TEMPORARY INSTRUCTION 2515/184 

40 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

the licensee created a 6 year EP drill 

objective which would test the site’s 

ability to implement the SAMGs, but 

this drill objective is due in 2013, and 

the site has yet to exercise this 

objective. 

In follow-up to the IER 11-1 

evaluations performed by the 

licensee, a corrective action program 

action has been created to further 

evaluate SAMG training for 

improvements. 
41 Enclosure 

PALISADES NUCLEAR PLANT - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? The SAMGs were last updated in 

May 2004 with the exception of the 

phase 1 SAMG. Phase 1 was 

updated in September 2005. 

Although required to be updated 

by various documents, in 2008 the 

licensee identified that the SAMGs 

were not updated to reflect plant 

changes. The licensee has not 

updated SAMG’s as of 

May 16, 2011. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

 X The TSC is located adjacent to the 

control room. Control room 

personnel can readily access the 

TSC copy. In addition, electronic 

versions of the SAMGs are 

available on the internal website. 

The inspectors concluded that the 

control room staff has adequate 

access to the SAMGs. 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X The SAMGs do not conform to the 

licensee’s standard procedure 

format. The SAMG format is 

governed by the SAMG writer’s 

guide. The licensee requires the 

SAMGs to be updated; however, 

the licensee has not revised the 

SAMGs since 2005. The licensee 

identified that the SAMGs included 

hydrogen recombiners that are no 

longer installed. The inspectors also 

identified that the SAMGs do not 

reflect changes made as part of 

sump strainer modifications 

(Generic Safety Issue, GSI-191). 

The SAMGs are controlled outside 

the normal document control 

process. 

The licensee does not have a 

periodic review requirement. 

The licensee Quality Assurance 

Program Manual states “...controls 

are in effect to ensure that 
PALISADES NUCLEAR PLANT - NRC TEMPORARY INSTRUCTION 2515/184 

42 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

procedures are reviewed for possible 

revision upon identification of new or 

revised source material potentially 

affecting the intent of the 

procedures.” For SAMGs, the 

writers guide requires a periodic or 

biennial review. No documented 

review exists. 

c Does the licensee’s configuration 

control and change management 

systems cause the licensee to update 

SAMGs to reflect design changes? 

(Y/N/Partially-describe) 

 X The licensee’s configuration 

management procedure covers 

SAMGs. In addition, the 

implementing procedure 

(Engineering Change Process) 

identifies severe accident 

procedures (SAMGs) for evaluation 

for impact. 

However, there are examples 

(hydrogen recombiners and sump 

strainers) where the licensee did not 

update the SAMGs as required. 

Therefore, the inspectors concluded 

that the change management 

systems do not cause the SAMGs to 

be updated to reflect design 

changes. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X The inspectors compared the 

general layout and contents of the 

generic SAMGs with the site specific 

SAMGs. The inspectors concluded 

that the site’s guidance was 

consistent with the generic SAMGs. 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 The licensee trains all Shift 

Managers, control room shift 

communicator, the TSC manager 

and three other TSC positions on 

SAMGs. Each person receives initial 

SAMG training and is tested each 

year on SAMGs. Prior to the test, 

they have the option to take 

computer-based training on the 

SAMGs. 

f Interview 4 licensed operators 

(2 reactor operators and 2 senior 

reactor operators), 2 TSC staff, and 2 

TSC managers assigned to apply the 

SAMGs during an emergency to 

determine: 

 
PALISADES NUCLEAR PLANT - NRC TEMPORARY INSTRUCTION 2515/184 

43 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X Reactor Operators are not trained on 

SAMGs. SRO and TSC staff and 

manager received initial traiing on 

the SAMGs. 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

X Reactor Operators do not receive 

periodic training on the SAMGs. 

SRO and TSC staff and managers 

do receive periodic training on the 

SAMGs. 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the 

licensee’s SAMGs)? 

X Some responders had difficulty 

articulating who would order 

implementation of the SAMGs. 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)?

 X The licensee does not conduct 

drills/exercises that use SAMGs. 

The licensee has initiated a condition 

report to address the issue at the 

fleet level. 
44 Enclosure 

PERRY NUCLEAR POWER PLANT - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? Bases – September 12, 2008 

Flowcharts – January 23, 2005 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

X 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

X Any changes to the plant (physical or 

procedural) as a result of SAMGs 

receive 50.59 screenings; however 

changes to the plant do not prompt a 

SAMG review. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

All licensed individuals and those 

engineers qualified Core/hydraulic 

Engineer or System Analysis 

Engineer receive classroom training 

as part of the 2-year Licensed 

Operator Requalification training 

cycle. The classroom training is 

basically tabletop style, working 

through the flowchart. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) X 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

X There is no specific training for any 

position. All personnel receive the 

same training regardless of their 

assigned duties. Training is focused 

on overall understanding – seems 
PERRY NUCLEAR POWER PLANT - NRC TEMPORARY INSTRUCTION 2515/184 

45 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

targeted to Operations Advisor 

(implementer of SAMGs). 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

X The SAMGs are implemented by the 

Operations Advisor, which is a 

qualified Senior Reactor Operator 

stationed in the TSC, when directed 

by the TSC Operations Manager. 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

 X 

As part of the 2-year training, the 

group does a tabletop exercise. 

The SAMGs are not exercised during 

EP drills/exercises. 
46 Enclosure 

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? The latest date of revision of the 26 

SAMG-related procedures ranged 

from May 3, 2002, to April 11, 2011. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X The SAMGs are available as hard 

copies and electronically. 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X The EOF and alternate EOF each 

have one set of SAMG procedures. 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X The SAMGs are available as hard 

copies and electronically. 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

X The licensee has included SAMGs as 

part of the annual emergency 

preparedness procedure review 

required by 10 CFR 50.54(t). 

This requirement is referenced in 

licensee procedure EP 8.0, 

“Maintaining Emergency 

Preparedness,” Revision 50. 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

X The licensee utilizes various 

procedures for controlling the 

different types of design changes. 

These procedures all require a review 

of related procedures and 

documentation to determine any 

procedures that are affected by the 

related activity, and, if so, direction is 

provided to revise the procedures. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

 X The licensee’s SAMG procedures 

generally followed the outline of 

Revision 0 of the Westinghouse 

Owners Group (WOG) “Severe 

Accident Management Guidance” 

document. The licensee performed 

a review of the steps outlined in 

Revision 0 of the WOG guidance and 

identified several differences. 

The licensee initiated condition 

reports CR 01652376, “SAMG Deltas 

Identified in Comparison with 

WOG SAMGs,” and CR 01652400, 

“Background Documents for the 

Guidelines in PBNP’s SAMG Set,” 

to assess the lack of a basis for 

deviations from the guidance. 

The licensee has not incorporated 

Revision 1 of the WOG document into 

its procedures. The licensee wrote 

CR 01630510, “IER1 11-1 Evaluate 

Delta Between Rev. 0 and Rev. 1 
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

47 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

WOG SAMGs,” to assess the failure 

to update the procedures when the 

guidance was revised. 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 The schedule for initial and 

requalification training is governed by 

multiple procedures. In addition to 

the training elements discussed in 

this section, Section 'g' below 

contains additional information 

relevant to training requirements. 

Initial training methods vary 

depending on emergency response 

organization (ERO) position. 

Training methods generally consisted 

of a combination of the following 

methods: classroom lecture; tabletop 

drills; simulator/frozen simulator 

scenarios; read and sign; mini-drills; 

exercise participation under 

instruction; computer-based training, 

and some self-study. Training lesson 

plans and related ERO position 

qualification guides existed to 

support training of licensee staff filling 

the ERO duty roster. 

Procedure, Emergency Preparedness 

PBN EP TP, “Training Program 

Description,” Revision 10, Section 3.2 

establishes the qualification 

requirements for initial training. 

However, this section is not clear on 

the integration of SAMG training. 

A specific requirement for initial 

SAMG training was not clearly 

delineated in the procedure; however, 

initial training requirements were 

established and each initial 

qualification guide contained a 

check-off for completion of SAMG 

training. The inspectors reviewed 

the training records for SAMG 

qualification and found that all 

emergency preparedness personnel 

had received initial training in 

SAMGs prior to being assigned an 

ERO position. 
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

48 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

Training periodicity is discussed in 

Section 'g' below. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 In addition to the required eight 

interviews, one non-licensed STA 

was interviewed. The responses of 

the nine staff members were 

consistent. 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X Initial training used self-study, read & 

sign training, classroom training, 

tabletop exercise, and “frozen” 

simulator walkdowns. The level and 

detail of training varied by ERO 

positions and depended on which 

year (how long ago) the training was 

conducted. 

Did they receive periodic training 

(Y/N/document periodicity) on the 

SAMGs and how they relate to 

their assigned duties? 

X Seven of nine interviewees 

suggested enhancements or 

modifications to the training 

frequency or program content, 

especially for the events in Japan. 

The licensee initiated a condition 

report to conduct a training needs 

analysis relative to this observation 

(CR 01649793, “Consider Additional 

SAMG Training Frequency”). 

(2) Can they articulate their 

responsibilities with respect to the 

use of SAMGs (Y/N/document 

who would actually implement the 

licensee’s SAMGs)? 

X Interviewees were knowledgeable of 

different roles established for the 

implementation of the SAMGs. 

Roles included implementer, decision 

maker, and evaluator/advisors. 

Each person interviewed was able to 

articulate their role in support of 

SAMG implementation. 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

X Periodic retraining has been 

completed on SAMGs, however, the 

consistency, frequency, and 

documentation of the training could 

be improved. 

Site procedures require a maximum 

retraining frequency of 6 years. 

Procedure EP 8.0, “Maintaining 

Emergency Preparedness,” 

Revision 50, Section 3.3.1, requires 

that “The scenarios for drills and 

exercises will be varied such that all 

major elements of the emergency 

response plans and preparedness 

organizations are tested within a 

six year period.” Procedure EPG 1.0, 

“Emergency Preparedness Drill 
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/184 

49 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

Guideline,” Revision, 17, Section I.7, 

“Severe Accident Management 

Guidelines,” states, “Demonstrate the 

ability to identify and implement 

appropriate SAG Strategies,” with a 

frequency of 6 years. Other station 

procedures discussed 2 and 3 year 

training requirements related to 

SAMGs. 

Records to support the 3-year 

tabletop drill refresher training 

requirement were available but 

incomplete. Specifically, training 

records were incomplete and for 

some licensee staff members 

tabletop drill training had not been 

performed within the 3-year required 

frequency. 

The licensee initiated CR 01651861, 

“Gaps in Training/Tabletop and 

Records for SAMG ERO,” to evaluate 

the inspectors’ observations. 
50 Enclosure 

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 - NRC TEMPORARY 

INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? There are 24 SAMG procedures per 

unit. Nineteen of the 24 procedures 

are the original revision. 

The remaining five SAMG procedures 

are either Revision 1 or 2 which were 

approved between 2007 and 2009. 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X SAMGs are covered by the licensee’s 

procedure control and document 

management system. However, a 

change to the Quality Assurance 

(QA) manual in 2005 eliminated the 

requirement for periodic review and 

revision of procedures. This change 

to the QA manual was approved 

by the NRC in a letter dated 

March 24, 2005. 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

X The SAMGs are not covered by the 

50.59 process as the SAMGs are 

related to beyond design basis 

events. However, the licensee’s 

modification process contains specific 

steps to ensure that potential impacts 

to SAMGs are considered as part of 

the modification review and approval 

process. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

 X All of the SAMG procedures reviewed 

by the inspectors were consistent 

with Revision 0 of the Westinghouse 

Owners Group (WOG) documents. 

However, the WOG issued Revision 1 

to the SAMG guidance documents in 

2001. Based upon the inspectors 

review and a discussion with the 

licensee’s SAMG procedure writer, 

the inspectors found that the licensee 

had only partially incorporated the 

Revision 1 guidance. Specifically, 

some SAMGs contained the Rev. 1 

guidance, but a majority did not. 

This issue is being evaluated since 

the licensee had a biennial procedure 
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 - NRC TEMPORARY 

INSTRUCTION 2515/184 

51 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

review and revision requirement per 

the QA manual prior to March 2005. 

In addition, the licensee’s failure to 

revise the SAMGs based upon the 

WOG’s Revision 1 guidance appears 

to conflict with the licensee’s current 

QA manual which states, “NSPM 

[Northern States Power – Minnesota] 

also establishes programmatic 

procedure preparation, review and 

usage controls that ensure 

procedures are technically and 

administratively correct. 

These controls ensure that 

procedures are reviewed when 

pertinent source material is revised, 

when unusual incidents occur, when 

plant modifications are made, and 

when significant deficiencies are 

identified. Procedures may also be 

reviewed because of industry 

experience reviews. Revisions are 

made as necessary.” 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 SAMG training is predominantly 

conducted through the use of 

classroom training and self-study. 

The licensee has standards to 

provide both licensed operators and 

selected emergency response 

organization (ERO) members with 

initial SAMG training. Those ERO 

members include SAMG Decision 

Makers, SAMG Evaluators, and 

SAMG Implementers (licensed 

operators). While the licensed 

operators were provided with SAMG 

training every other year, no standard 

existed to provide continuing SAMG 

training to ERO personnel. The 

inspectors found that the licensee 

currently does not require the TSC 

Directors (lead individual in the TSC) 

to complete SAMG Decision Maker 

training as part of their qualifications. 

As a result, approximately half of the 

currently qualified TSC Directors had 

not received any initial SAMG 

training. In addition, those individuals 

qualified as SAMG Decision Makers 
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 - NRC TEMPORARY 

INSTRUCTION 2515/184 

52 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

and Evaluators were not assigned to 

specific ERO teams. Due to this 

weakness, there is a possibility that 

the licensee could be responding to a 

SAMG-related event without having a 

qualified SAMG Decision Maker or a 

SAMG Evaluator at the site. 

Further questioning of the licensee’s 

EP training staff identified that the last 

initial SAMG training session for ERO 

staff members was completed in 

2001. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

 X The licensee’s current EP structure 

does not require that the TSC 

managers or TSC staff members 

receive SAMG training as part of their 

qualifications. The licensee has 

established specific EP positions for 

SAMG decision makers and SAMG 

evaluators. However, the individuals 

that fill these positions are not 

assigned to a specific EP team. If 

these individuals are needed, the 

licensee would have to call them out 

and direct that they report to the TSC. 

The inspectors reviewed the 

licensee’s current EP team roster to 

identify if any of the current TSC 

managers had received SAMG 

training. Of the seven individuals 

currently qualified as a TSC manager, 

only three had received SAMG initial 

training. The inspectors interviewed 

one TSC member and two SAMG 

evaluators. As expected, the 

inspectors found that the TSC 

member had not received initial 

SAMG training (because it was not 

required) while the SAMG evaluators 

had received initial SAMG training. 

The licensee wrote CR 1276003. 

All licensed operators interviewed 

had received initial SAMG training. 
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 - NRC TEMPORARY 

INSTRUCTION 2515/184 

53 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

This training occurs shortly after the 

operators receive their NRC licenses. 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

 X In general, the licensee does not 

provide periodic SAMG training to 

TSC personnel nor do they provide it 

to their qualified SAMG decision 

makers or SAMG evaluators. 

However, two of the three TSC 

managers discussed above had 

received periodic SAMG training 

because these individuals were also 

licensed operators. 

The licensee conducts periodic 

SAMG training (both classroom and 

self-study) for all licensed operators 

every other year. 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

X 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

X The licensee performs one 

SAMG-related drill or exercise during 

each six year cycle. The last SAMG 

drill/exercise was conducted in 

April 2005. The current six year 

cycle began in 2006. The licensee 

plans to complete a SAMG-related 

drill or exercise prior to the end of 

the current six year cycle 

(December 2012). Of note, the 

SAMG drill/exercise that is performed 

only allows one out of the licensee’s 

four EP teams to receive the training. 

As a result, it may be many years for 

each EP team member to participate 

in a SAMG-related drill or exercise. 
54 Enclosure 

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - NRC TEMPORARY 

INSTRUCTION 2515/184 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

a When were the SAMGs last updated? December 2007 

Are controlled copies of the SAMG 

located in the technical support center 

(TSC)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the emergency operations 

facility (EOF)? (Y/N) 

X 

Are controlled copies of the SAMG 

located in the control room? (Y/N) 

X 

b Are SAMGs covered by the licensee’s 

procedure control and document 

management system, including the 

requirements for periodic review and 

revision? (Y/N) 

 X SAMGs are covered by the document 

control program. SAMGs do not have 

a periodic review independent of 

reviews based on changes to the 

plant, procedures, and related 

documents. 

c Does the licensee’s configuration control 

and change management systems 

cause the licensee to update SAMGs to 

reflect design changes? (Y/N/Partiallydescribe) 

X Required reviews for potential 

revisions to the EOPs and SAMGs 

based on changes to the plant, 

procedures, and related documents. 

d Perform a high-level comparison of the 

site’s SAMGs with available industry 

guidance (e.g., owner’s group guidance 

document and other industry standards 

as applicable). Are the SAMGs 

consistent with the owners group 

guidance (if any) having been 

incorporated (Y/N/comments)? 

X Consistent with BWR Owners’ Group 

EP/SAG Revision 2, March 2001. 

e How is training conducted on the 

SAMGs? 

Who is trained on the SAMGs? 

What is the periodicity of training? 

 SAMG training is conducted through 

EOP drills, hands on training, 

classroom lectures, and the 

simulator. 

SROs/ROs/NLOs and SAMG 

qualified engineers receive initial and 

periodic training. 

SROs and engineers receive training 

on an annual basis. ROs and NLOs 

receive training during the 2-year 

training cycle. 

f Interview 4 licensed operators (2 reactor 

operators and 2 senior reactor 

operators), 2 TSC staff, and 2 TSC 

managers assigned to apply the SAMGs 

during an emergency to determine: 

 

(1) Did they receive initial training 

on the SAMGs? (Y/N) 

X 
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - NRC TEMPORARY 

INSTRUCTION 2515/184 

55 Enclosure 

Letter or 

Number 

Inspection Item Yes No Response/Comments 

Did they receive periodic 

training (Y/N/document 

periodicity) on the SAMGs and 

how they relate to their assigned 

duties? 

X Periodicity was consistent with 

comments from Section 'e.' 

(2) Can they articulate their 

responsibilities with respect to 

the use of SAMGs 

(Y/N/document who would 

actually implement the licensee’s 

SAMGs)? 

X SROs/ROs/NLOs would fulfill the 

SAMG implementers and decision 

maker roles. 

SAMG evaluator would be fulfilled by 

qualified engineers. 

g Have there been periodic exercises on 

the use of SAMGs by individuals who 

would implement them during an 

emergency (Y/N/document periodicity)? 

X Required SAMG drill every 6 years.