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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

KING OF PRUSSIA, FA 19406-1415

May 27, 2OLL

Timothy J. Kobetz i

Chief, Reactor Inspe$tion Branch

Division of Inspectioq and Regional Support

RaymondJ.Powell ft

Chief, Technical Support and Assessment Branch

Division of Reactor Projects

MEMORANDUM TO:

Region lCompletion of Temporary Instruction (Tl)-184,

"Availability and Readiness Inspection of Severe Accident

Mitigation Guidelines (SAMGs)"

This memorandum documents Region I completioi,l of Tl-184.

at 610-337-6967 if you have any questions.

Attachment: As stated

The attachment to this memorandum contains the fesponses to the specific questions asked in

Section 03.01 of the Tl for each Region I site. The completion of this Tl will also be documented

in the second quarter 2011 NRC Integrated Inspection Report for each site. Please contact me
MEMOMNDUM TO:

May 27,2O11

Timothy J. Kobetz

Chief, Reactor lnspeotion Branch

Division of Inspection and Regional Support

FROM: Raymond J. Powell /RA/

Chief, Technical Support and Assessment Branch

Division of Reactor Pfojects

SUBJECT: Region I Completion 0f Temporary lnstruction (Tl)-184,

"Availability and Readiness Inspection of Severe Accident

Mitigation Guidelines (SAMGS)"

This memorandum documents Region I completion of Tl-184.

The attachment to this memorandum contains the responses to the specific questions asked in

Section 03.01 of the Tl for each Region I site. The completion of this Tl will also be documented

in the second quarter 2011 NRC Integrated Inspection Report for each site. Please contact me

at 610-337-6967 if you have any questions.

Distribution (w/encl):

W. Dean

D. Lew

D. Roberts

J. Clifford

C. Miller

P. Wilson

F. Brown

SUNSI Review Complete: RJP _ 

(Revieuier's Initials)

DOCUMENT NAME: G:\DRP\BRANCH TSAB\TI-184\COmpletion of Tl-184 Memorandum.docx

After declaring this document "An Otficial Agency Record" it will be released to the Public.

To receive a copy of this document, indicate in the box: "C" = Copy without attachmenUenclosure

"E" = Copy with attachmenVenclosure "N" = No copy

MLI114

OFFICIAL RE RD COPY
EXHIBIT 1

TABLE OF RESULTS

BEAVER VALLEY

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last updated? July 30, 2010.

Are controlled copies of the SAMG

located in the technical support center

ffsc)? ff/N)

Yes Verified by inspector.

Are controlled copies of the SAMG

located in the emergency operations

facilitv (EOF)? (Y/N)

No FENOC states SAMGs not provided to EOF

personnel since they have no SAMG

im plementation responsibilities.

Are controlled copies of the SAMG

located in the control room? (Y/N)

Yes Verified by inspector.

b Are SAMGs covered by the licensee's

procedure control and document

management system, including the

requirements for periodic review and

revision? (Y/N)

Yes SAMGs are under Chapter 53E & 53F in

document control system (FILENET) and

subject to 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?

ff/N/Partial lv-descri be)

Yes Design lnterface Evaluations (DlEs) are

conducted for SAMGs for design changes

by Operations (DlE 5 & 9), and Training

(DrE 8 & 46).

d Perform a high-level comparison of

the site's SAMGs with available

industry guidance (e.9., 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/comme1!q?-

Yes There is evidence of continual evaluation

and updates to site-specific guidelines and

training material to reflect industry

standards based on inspector review of

control document reviews.

e How is training conducted on the

SAMGS?

Who is trained on the SAMGs?

What is the oeriodicitv of traininq?

One-time, 1 -day instructor-lead classroom

training for licensed operators after NRC

licensee exam is taken. No expiration date

for initialtraining.

f Interview 4 licensed oPerators (2

reactor operators and 2 senior reactor

operators), 2 TSC staff, and 2 TSC

managers assigned to aPPIY the

SAMGs during an emergency to

determine:

(1) Did they receive initial training

on the SAMGs? (Y/N)

Yes

Did they receive periodic

training (Y/N/document

periodicity) on the SAMGs and

how they relate to their

assioned duties?

No TSC staff received specific training for their

emergency response position duties,

separate from initial training, but without

periodic training.

(2) Can they articulate their

responsibilities with resPect to

the use of SAMGs

(Y/N/document who would

No, with

cornment

The majority of peoPle were able to

articulate their SAMG responsibilities, but

not all. All were aware that control room

licensed operators implement BV SAMGS.

Beaver Valley

Page 1
Letter or

Number

lnspection ltem Yes No Response/Comments

actually implement the

licensee's SAMGs)?

g Have there been periodic exercises

on the use of SAMGs by individuals

who would implement them during an

emergency (Y/N/document

periodicitv)?

No

Beaver Valley
EXHIBIT 1

TABLE OF RESULTS

CALVERT CLIFFS

Calvert Cliffs

Page 1

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last

updated?

ERPIP 600 05/1212010

ERPIP 601 0710712009

ERPIP 602 0312112001

ERPIP 603 0312112001

ERPIP 604 0312112001

ERPIP 605 0312112001

ERPTP 606 0312112001

ERPTP 607 0312112001

ERPIP 608 0312112001

ERPIP 609 0312112001

ERPIP 610 0312112001

ERPIP 611 0411512011

ERPIP 6120512712009

ERPIP 613 0712812009

Are controlled copies of the

SAMG located in the technical

suooort center fiSC)? ry/N)

Yes There are two controlled copies of the

SAMGs in the TSC.

Are controlled copies of the

SAMG located in the emergencY

operations facility (EOF)? (Y/N)

Yes There are two controlled copies of the

SAMGs in the EOF.

Are controlled copies of the

SAMG located in the control

room? ff/N)

Yes There is only one controlled copy of

the SAMGs 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)

Yes The periodic review is every two

years. The inspectors identified that

the last periodic review was not

completed for 3 SAMGs (ERPIP 606,

608, and 610). The licensee initiated

a condition report (CR) to review this

issue.

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)

Yes CNG-CM-1.01 -1 003, "Design

Engineering and Configuration

Control," Attachment 12, and CNGFES-007, "Preparation of Design

Inputs and Change lmpact Screen,"

require that emergency preparedness

and ERPIP impacts be evaluated.

The SAMGs are located in the

ERPlPs. Therefore, the inspector

concluded that the licensee's

configuration control and change

management systems cause the

licensee to update SAMGs to reflect

desion chanoes.
Letter or

Number

Inspection ltem Yes No Response/Comments

d Perform a high-level comparison

of the site's SAMGs with available

industry guidance (e.9., 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/com ments)?

Yes The SAMGs are consistent with the

owner's group guidance.

e How is training conducted on the

SAMGs?

Who is trained on the SAMGs?

What is the periodicity of training?

Licensed operators and auxiliary

operators received initial classroom

training. Periodic training for licensed

operators and auxiliary operators is

provided every 4 years. However, the

licensee had previously identified that

continuing training is not defined for

users of SAMGs who are members of

the Emergency Response

Organization but not covered by other

continuing training programs. Only a

discussion factor is required for

qualification of personnel using

SAMGs in their ERO position. The

licensee issued a CR to review this

issue.

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

emeroencv to determine:

(1) Did they receive initial

training on the SAMGs?

(Y/N)

Yes The Licensed operators received

initial classroom training. The TSC

Reactor Engineer also received initial

classroom training. However, only a

discussion factor was required for

qualification of the remaining

members of the TSC staff that were

interviewed. The licensee issued a

CR to review this issue.

Did they receive periodic

training (Y/N/docu ment

periodicity) on the SAMGs

and how they relate to their

assigned duties?

No, with

comment

The licensed operators receive

periodic classroom training every 4

years. The TSC Reactor Engineer

receives periodic self-study training

annually. The other members of the

TSC staff did not receive periodic

training unless the individual was a

drill participant for the required annual

exercise on SAMGs. The licensee

issued a CR to review this issue.

(2) Can they articulate their

responsibilities with

respect to the use of

SAMGs (Y/N/document

who would actually

implement the licensee's

SAMGs)?

Yes In general, all of the licensed

operators and TSC personnel

interviewed articulated their

responsibilities with the respect to the

use of SAMGs and who would actuallY

imolement the SAMGS.

Calvert Cliffs

Page 2
Letter or

Number

Insoection ltem Yes ItJo Resoonse/Comments

g Have there been periodic

exercises on the use of SAMGs

by individuals who would

implement them during an

emergency (Y/N/docum ent

oeriodicitv)?

Yes The Constellation fleet requirement is

every 6 years. However, Calvert

Cliffs' internal requirement is annually.

The last one conducted was April 6,

2011.

Calvert Cliffs

Page 3
EXHIBIT 1

TABLE OF RESULTS

FITZPATRICK

FitzPatrick

Page 1

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs

last updated?

. SAOG 1a 24 October2006

o SAOG-1b 12 October 2004

o SAOG-1c 12 October 2004

. SAOG-1d 12 October 2004

. SAOG-1e l2October 2004

. SAOG-1f 12 October 2004

. SAOG-2 24 October 2006

Are controlled copies of the

SAMG located in the

technical support center

(Tsc)? ry/N)

Yes

Are controlled copies of the

SAMG located in the

emergency operations

facilitv (EOF)? (Y/N)

Yes

Are controlled copies of the

SAMG located in the

control room? ff/N)

Yes

b Are SAMGs covered by the

licensee's procedure

control and document

management system,

including the requirements

for periodic review and

revision? (Y/N) No, with

comment

Yes, the SAOGs are covered by

FitzPatrick's procedure control and

document management sYstem.

Specifically, the SAOGs are controlled by

AP -02.02, "Emergency Operating

Procedures and Severe Accident Operating

Guidelines."

No, the SAOGs are not subject to a

requirement for periodic review and revision

AP-02.02 states, "Perform EOP and SAOG

periodic reviews per AP-02.04 [Control of

Proceduresl ." AP-02.04 lists procedures

that require periodic review, and the SAOGs

are not on that list.

c Does the licensee's

configuration control and

change management

systems cause the

licensee to update SAMGs

to reflect design changes?

(Y/N/Partial ly-descri be) Yes

Yes, FitzPatrick's design change

management procedure, EN-DC-1 15,

"Engineering Change Process," would

cause the licensee to update the SAOGs to

reflect design changes. Specifically, one of

the impact screening criteria is to determine

whether the proposed activity affects severe

accident procedures (SAPs), SAP actions,

or SAP input parameters. Also, AP-02.02,

"Emergency Operating Procedures and

Severe Accident Operating Guidelines,"

requires that SAOG changes be screened

oer EN-Ll-1 00, "Process Applicability
Letter or

Number

lnsoection ltem Yes No Response/Comments

Determination," which performs 10 CFR

50.59 screening.

The inspectors noted that the design

change update process does not extend

back to the SAOG bases document, "James

A. FitzPatrick Nuclear Power Plant

Emergency Procedure and Severe Accident

Guidelines." Specifically, the inspectors

noted that the bases document references

the steam condensing mode of RHR as a

possible path to vent the reactor pressure

vessel, although the steam condensing

mode of RHR has long been retired. The

licensee entered this issue into their

corrective action program.

d Perform a high-level

comoarison of the site's

SAMGs with available

industry guidance (e.9.,

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)?

Yes

The inspectors performed a high-level

comparison of applicable portions of the

industry bases for SAMGs, 'BWR Owner's

Group Emergency Procedures and Severe

Accident Guidelines," and FitzPatrick's

bases document, "James A. FitzPatrick

Nuclear Power Plant Emergency Procedure

and Severe Accident Guidelines." The two

documents were nearly identical, with the

difference being inclusion in the FitzPatrick

document of site specific systems and

parameters, deletion of non-existent

equipment, and deletion of materials that

were not applicable.

The inspectors performed a high-level

comparison of the industry standard BWR

severe accident guideline (SAG) flow charts,

SAG-1, "Primary Containment Flooding,"

and SAG-2, "Containment and Radioactivity

Release Control," and the FitzPatrick

SAOGs. The inspectors noted that

FitzPatrick had broken down SAG-1 into six

separate SAOGs, 1a - 1'f , that correspond to

steps RC/F-1 through RC/F-6. Also,

FitzPatrick combined the RPV pressure and

reactor power (RC/P and RC/Q) legs, and

located it in SAOG-2, as oPPosed to

separate legs in SAG-1. Beyond these (and

other) organizational differences, the

inspectors did not note any major content

differences between the industry standard

SAGs and FitzPatrick's SAOGs.

e How is training conducted

on the SAMGs?

Who is trained on the

SAMGS?

What is the periodicity of

SAOG training is conducted as a part of

initial licensed operator qualification training

(three 3-hour classroom sessions), and

every two years as a part of licensed

ooerator reoualification traininq (LORT) (one

FitzPatrick

Page 2
Letter or

Number

lnspection ltem Yes No Response/Comments

training? 3-hour classroom/tabletop session). The

inspectors verified that LORT on the SAOGs

was last conducted during the fourth quarter

of 2009, and is next scheduled for fourth

quarter 2011.

Four positions in the Emergency Response

Organization (ERO) (System Assessment

Advisor, Parameter Assessment Advisor,

Reactor Engineer, and TSC Radiological

Coordinator) receive computer-based

training on severe accident management,

including the SAOGS, during initial

qualification and periodically thereafter

(every two years). There is no formal initial

or periodic training on the SAOGs for other

members of the ERO.

+

I 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

emerqencv to determine:

(1) Did they receive

initial training on the

SAMGs? (Y/N)

No, with

comment

The SROs and ROs indicated that they

received training on the SAOGs during initial

training for initial qualification and that

SAOG training is included in the continuing

requalification program.

The TSC personnel (two Emergency Plant

Managers and two TSC Managers)

indicated that they did not receive initial or

periodic training on the SAOGs as a part of

their ERO qualification.

Did they receive

periodic training

(Y/N/document

periodicity) on the

SAMGs and how

they relate to their

assiqned duties?

No, with

comment

(2) Can they articulate

their responsibilities

with respect to the

use of SAMGs

(Y/N/document who

would actually

implement the

licensee's SAMGs)?

No, with

comment

Among the individuals interviewed, a few

indicated that the SAOGs would be

implemented by the ERO (i.e., from the

TSC/EOF), with the control room operators

playing a support role. However, most

indicated that the Shift Manager (SM) would

direct transition and run the SAOGs, with

the ERO providing support.

The Emergency Preparedness Director

indicated that the SAOGs were controlled by

Operations, and that the SM would direct

transition to, and implementation of the

SAOGS.

g Have there been periodic

exercises on the use of

SAMGs by individuals who

would imolement them

No

FitzPatrick

Page 3
Letter or

Number

Inspection ltem Yes No Response/Comments

during an emergency

(Y/N/document

periodicity)?

FitzPatrick

Page 4
EXHIBIT 1

TABLE OF RESULTS

R. E. GINNA

Ginna

Page 1

Letter or

Number

lnspection ltem Yes No Resoonse/Comments

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

1998 with the exception of SAG-1

and CA-2, which were last updated

in 2010.

Following issuance of WOG

guidance in 2001, some of the

SAMGs should have been updated,

but were not. The licensee

identified this on May 5, 2011, and

entered this issue into the corrective

action proqram (CAP).

Are controlled copies of the SAMG

located in the technical support center

(TSC)? (Y/N)

Yes Two had a few pages missing -

licensee placed into CAP

Are controlled copies of the SAMG

located in the emergency operations

facilitv (EOF)? (Y/N)

No, with

comment

Accessible by computer - no hard

copies

Are controlled copies of the SAMG

located in the control room? (Y/N)

Yes Only SACRG-1 and SACRG-2;

SACRG-2 was missing a page -

licensee placed into CAP

b Are SAMGs covered by the licensee's

procedure control and document

management system, including the

requirements for periodic review and

revision? (Y/N)

Yes SAMGs are covered by a similar,

but separate process than other

procedures such as EOPs; periodic

review is required once every 5

VEATS

c Does the licensee's configuration

control and change management

systems cause the licensee to update

SAMGs to reflect design changes?

ff/N/Partial ly-d escri be)

No Licensee identified this on MaY 6,

2011 - licensee placed into CAP

d Perform a high-level comparison of

the site's SAMGs with available

industry guidance (e.9., 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)?

Yes Very closely match and are

consistent with the WOG guidance;

however, have not been uPdated

with 2001 WOG guidance; licensee

identified this on May 5, 2011 -

licensee placed into CAP

e How is training conducted on the

SAMGs?

Who is trained on the SAMGs?

What is the periodicity of training?

TSC ERO and controlroom

operators receive initial classroom

training;TSC ERO receive tabletoP

refresher training at 36 month

periodicity (TSC ERO includes:

TSC Director; Operations

Assessment Manager; Technical

Assessment Manaqer; and Nuclear
Letter or

Number

Inspection ltem Yes No Response/Comments

Assessment); licensee has records

of completed training; SROs/ROs

receive refresher training annually.

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)

Yes All received initial classroom

training

Did they receive periodic

traini ng (Y/N/document

periodicity) on the SAMGs and

how they relate to their

assigned duties?

Yes TSC ERO receive periodic training

(36 month periodicity); SROs/ROs

receive some periodic training

during LORT - licensee is

evaluating enhancing this training;

training covers how SAMGs relate

to assigned duties

(2) Can they articulate their

responsibilities with resPect to

the use of SAMGs

(Y/N/document who would

actually implement the

licensee's SAMGs)?

Yes AIITSC ERO and SROs/ROs

interviewed knew that the control

room implements the initial SAMGs

(SACRG-1 or SACRG-2), and all

other SAMGs are implemented in

the TSC

g Have there been periodic exercises

on the use of SAMGs by individuals

who would implement them during an

emergency (Y/N/document

oeriodicitv)?

No, with

comment

Licensee requirement to conduct

SAMG exercises was established in

2009 with a 6 year periodicity;

exercises are currently being

olanned
EXHIBIT 1

TABLE OF RESULTS

HOPE CREEK

Letter

or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last uPdated? 11t19t2009

Are controlled copies of the SAMG

located in the technical support center

/TSC)? (Y/N)

Yes

Are controlled copies of the SAMG

located in the emergency operations

facilitv (EOF)? ry/N)

No

Are controlled copies of the SAMG

located in the control room? (Y/N) Yes

b Are SAMGs covered by the licensee's

procedure control and document

management system, including the

requirements for periodic review and

revision? (Y/N)

Yes

c Does the licensee's configuration control

and change management systems cause

the licensee to update SAMGs to reflect

desiqn chanses? (Y/N/Partially-describe)

Yes

d Perform a high-level comparison of the

site's SAMGs with available industry

guidance (e.9., owner's group guidance

document and other industry standards

as applicable). Are the SAMGs

consistent with the owners grouP

guidance (if any) having been

incoroorated (Y/N/com ments)?

Yes

e How is training conducted on the

SAMGs?

Who is trained on the SAMGs?

What is the periodicity of training?

Training is conducted in the

classroom

Licensed operators are trained

every 2 years

TSC staff are trained everY 6 Years

f f nterview 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) Yes

Did they receive periodic training

(Y/N/document periodicity) on the

SAMGs and how theY relate to

their assigned duties?

Yes Training is conducted every 6 years

(2) Can they articulate their

responsibilities with respect to the

use of SAMGs (Y/N/document

who would actuallY imPlement the

licensee's SAMGs)?

Yes

The shift personnel would

implement the SAMGs under the

direction of the Shift Manager (SM).

The SM would be given

recommendations bY the technical

support supervisor in the TSC.
Letter

or

Number

lnspection ltem Yes No Response/Comments

g Have there been periodic exercises on

the use of SAMGs by individuals who

would implement them during an

emergency (Y/N/document periodicity)?

Yes

Periodic exercises that use the

SAMGs are conducted everY 6

years

Hope Creek

Page 2
EXHIBIT 1

TABLE OF RESULTS

INDIAN POINT UNIT 2

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last updated? April 2011

Are controlled copies of the SAMG

located in the technical support center

(TSC)? (Y/N)

Yes

Are controlled copies of the SAMG

located in the emergency operations

facility (EOF)? (Y/N)

No

Are controlled copies of the SAMG

located in the control room? (Y/N)

Yes Only required to have SACRG-1

and SACRG-2 procedures staged.

b Are SAMGs covered by the licensee's

procedure control and document

management system, including the

requirements for periodic review and

revision? (Y/N)

No, with

commenl

All SAMG documents are covered

by the site procedure control and

management system. There is,

however, no requirement for

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/Parti al I y-descri be)

Yes

d Perform a hiqh-level comparison of

the site's SAMGs with available

industry guidance (e.9., owner's group

guidance document and other industry

standards as applicable). Are the

SAMGs consistent with the owner's

group guidance (if any) having been

incorporated (Y/N/com ments)?

Yes The SAMG's are closely aligned

with the industry guidance.

However, background and

deviation documents were not

available for review. Entergy

personnel believe they were

developed but their location

unknown. Licensee entered issue

in corrective action program.

e How is training conducted on the

SAMGS?

Who is trained on the SAMGs?

What is the periodicity of training?

Initial and periodic training is

provided by operations for licensed

operators and by the emergencY

preparedness organization for TSC

staff (SAMG Evaluators) and TSC

Manager [Emergency Plant

Managers (EPM)1. Licensed

operators are trained on SACRG-1

and SACRG-2 but they do not

receive training on the remaining

SAMG procedures. Specifically, the

trainino is limited to pointinq out the

Indian Point 2

Page 1
Letter or

Number

Inspection ltem Yes No Response/Comments

SAMG procedures.

Licensed Operators (SROs/ROs) :

Initial training is conducted as a

classroom presentation.

Periodic refresher training is

conducted as a classroom

presentation every 5 years. Some

licensed operators have

participated in SAMG drills but it is

not a training requirement.

SAMG Evaluators and EPMs:

Initialtraining is conducted as a

classroom presentation and

drill/tabletop exercise.

Periodic refresher training is

conducted as an annual computer

based training,

I 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 the following

personnel:

2 ROs

2 SROs (1 STA qualified)

2 SAMG Evaluators

2 EPMs

(1) Did they receive initial training

on the SAMGs? (Y/N)

Yes

Did they receive periodic

training (Y/N/document

periodicity) on the SAMGs and

how they relate to their

assigned duties?

Yes Licensed Operators: Refresher

classroom training once every 5

years.

SAMG Evaluators and EPMs:

Annual computer based refresher

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)?

Yes Licensed operators: lmplement

the initial phase of the SAMGs from

the control room and transfer

control of the SAMG

implementation to the TSC once

operational.

SAMG Evaluators and EPMs:

Indian Point 2

Page 2
Letter or

Number

Inspection ltem Yes No Response/Comments

Once the TSC has assumed control

of SAMG implementation, the

SAMG Evaluator recommends

actions to the EPM (SAMG

decision maker) for execution.

g Have there been periodic exercises on

the use of SAMGs by individuals who

would implement them during an

emergency (Y/N/docu ment

periodicity)?

Yes SAMG Drillsffabletop exercises are

performed every 2 years.

lndian Point 2
EXHIBIT 1

TABLE OF RESULTS

INDIAN POINT UNIT 3

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last updated? April2011

Are controlled copies of the SAMG

located in the technical support center

(TSC)? (Y/N)

Yes

Are controlled copies of the SAMG

located in the emergency operations

facility (EOF)? (Y/N)

No

Are controlled copies of the SAMG

located in the control room? (Y/N)

Yes Only required to have SACRG-1,

SACRG-2, SAGs, SAEG-2, and

DFC procedures staged.

b Are SAMGs covered by the licensee's

procedure control and document

management system, including the

requirements for periodic review and

revision? (Y/N)

No, with

comment

AIISAMG documents are covered

by the site procedure control and

management system. There is,

however, no requirement for

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/Partial ly-describe)

Yes

d Perform a hiqh-level comparison of

the site's SAMGs with available

industry guidance (e.9., owner's group

guidance document and other industry

standards as applicable). Are the

SAMGs consistent with the owner's

group guidance (if any) having been

incorporated (Y/N/com ments)?

Yes

e How is training conducted on the

SAMGs?

Who is trained on the SAMGs?

What is the periodicity of training?

Initial and periodic training is

provided by operations for licensed

operators and by the emergencY

preparedness organization for TSC

staff (SAMG Evaluators) and TSC

Manager [Emergency Plant

Managers (EPM)1.

Licensed Operators (SROs/ROs):

Initial traininq is conducted as a

lndian Point 3

Page 1
Letter or

Number

Inspection ltem Yes No Response/Comments

classroom presentation.

Periodic refresher training is

conducted as a classroom

presentation every 5 years. Some

licensed operators have

participated in SAMG drills but it is

not a training requirement.

SAMG Evaluators and EPMs:

Initial training is conducted as a

classroom presentation and

drill/tabletop exercise.

Periodic refresher training is

conducted as an annual comPuter

based training.

f

lnterview 4 licensed operators (2

reactor operators and 2 senior reactor

operators), 2 TSC staff, and 2 TSC

managers assigned to aPPIY the

SAMGs during an emergency to

determine:

Interviewed the following

personnel:

2 ROs

2 SROs (1 STA qualified)

2 SAMG Evaluators (TSC staff)

2 EPMs (TSC Managers)

(1) Did they receive initial training

on the SAMGs? (Y/N)

Yes

Did they receive periodic

training (Y/N/document

periodicity) on the SAMGs and

how they relate to their

assigned duties?

Yes Licensed Operators: Classroom

refresher training once everY 5

years.

SAMG Evaluators and EPMs:

Annual computer based refresher

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)?

Yes Licensed operators: lmPlement

the initial phase of the SAMGs from

the control room and transfer

control of the SAMG

implementation to the TSC once

operational.

SAMG Evaluators and EPMs:

Once the TSC has assumed control

of SAMG implementation, the

SAMG Evaluator recommends

actions to the EPM (SAMG

decision maker) for execution.

lndian Point 3

Page2
Letter or

Number

lnsoection ltem Yes No Response/Comments

g Have there been periodic exercises on

the use of SAMGs by individuals who

would implement them during an

emergency (Y/N/document

periodicity)?

Yes SAMG Drillsffabletop exercises are

performed every 2 years.

lndian Point 3
EXHIBIT 1

TABLE OF RESULTS

LIMERICK

Limerick

Page 1

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last

updated?

Severe Accident Management

Procedures (SAMP) 1, RPV and

Primary Containment Flooding Control,

May 6,2011

SAMP-2. Containment and Radioactive

Release Control, September 2,2010

Are controlled copies of the

SAMG located in the technical

support center (TSC)? (Y/N)

Yes

Are controlled copies of the

SAMG located in the emergencY

operations facility (EOF)? (Y/N)

Yes

Are controlled copies of the

SAMG located in the control

room? (Y/N)

Yes

b Are SAMGs covered by the

licensee's procedure control and

document management system,

including the requirements for

periodic review and revision?

(Y/N)

No, with

comment

Controlled hard copies of the SAMPs

are maintained in pre-established

locations on site (such as the main

control room, TSC, etc). The SAMPs

are also available electronically

through the licensee's electronic

document management system.

However, there is no requirement for

periodic review or revision of the

SAMPS.

c Does the licensee's configuration

control and change management

systems cause the licensee to

update SAMGs to reflect design

changes? (Y/N/Partiallydescribe)

Yes

Per procedure CC-AA-102, "Design

Input and Configuration Change lmpact

Screening," Section 4.1.21, interface

with Operations/Operations support is

required if a configuration change

package has the potential to impact

station Emergency OPerating

Procedures or SAMPS.
Letter or

Number

Inspection ltem Yes No Response/Comments

d Perform a high-level comparison

of the site's SAMGs with

available industry guidance (e.9,

owner's group guidance

document and other industry

standards as applicable). Do

the SAMGs line up with the

owners group guidance (if any)

having been incorporated

(Y/N/comments)?

Yes

Limerick's SAMP-1 and SAMP-2

procedures are in close alignment with

Revision 2 of BWR Emergency

Procedure Guidelines/Severe Accident

Guidelines. Slight variations exist to

accommodate plant specific design

differences, preferred procedure

formatting, and site preferred

terminology. These differences, and

the basis for them, are detailed in

Appendix A to SAMP-1 and SAMP-2.

e How is training conducted on the

SAMGs?

Who is trained on the SAMGs?

What is the periodicity of

training?

All initialtraining is conducted by

classroom instruction. Refresher

training may be conducted in the

classroom or by read-and-sign (for

certain positions - details below).

All licensed operator candidates, TSC

manager candidates, and certain TSC

staff receive training on the SAMPS.

The licensed operator candidates

receive 24 hours of classroom

instruction for initial training. TSC

managers (Site Emergency Directors)

receive 2 hours of initial classroom

instruction to become qualified as

"SAMP Decision-Makers." Certain TSC

staff (the Technical and Operations

Managers) receive 2 hours of initial

classroom instruction to become

qualified as "SAMP Evaluators."

Licensed operators are trained

annually on SAMP procedures. All

Decision-Makers and Evaluators are

trained annually by attending t hour of

classroom instruction or completing

read-and-sign 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:

(1) Did they receive initial

training on the SAMGs?

(Y/N)

Yes

Limerick

Page2
Letter or

Number

Inspection ltem Yes No Resoonse/Comments

Did they receive periodic

train ing (Y/N/document

periodicity) on the SAMGs

and how they relate to

their assigned duties?

Yes

(2) Can they articulate their

resoonsibilities with

resoect to the use of

SAMGs (Y/N/document

who would actually

implement the licensee's

SAMGs)?

Yes

lmplementer - Control Room

Supervisor

Decision-Maker - Site Emergency

Director

Evaluators - Technical and Operations

Manager in TSC

g Have there been periodic

exercises on the use of SAMGs

by individuals who would

implement them during an

emergency (Y/N/docu ment

periodicity)?

Yes

Per EP-AA-122-1001, Drills and

Exercise Scheduling, Development and

Conduct, Revision 13, SAMG

exercises are to be performed on at

least a 6 year periodicity. The last

SAMP exercise performed at Limerick

was on June 13, 2006.

Limerick

Page 3
EXHIBIT 1

TABLE OF RESULTS

MILLSTONE

Letter or

Number

Inspection ltem Yes No Resoonse/Comments

a When were the SAMGs last uPdated? Unit2: T|OB

Unit3: 4111

Are controlled copies of the SAMG

located in the technical support center

(rsc)? (Y/N) Yes

Are controlled copies of the SAMG

located in the emergency operations

facility (EOF)? (Y/N) Yes

Are controlled copies of the SAMG

located in the control room? (Y/N)

Yes

b Are SAMGs covered by the licensee's

procedure control and document

management system, including the

requirements for periodic review and

revision? (Y/N)

Yes

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)

Yes

d Perform a high-level comparison of the

site's SAMGs with available industry

guidance (e.9., 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/com ments)?

Yes

Both units'SAMG's are consistenl

with owner's grouP guidance.

e How is training conducted on the

SAMGs?

Who is trained on the SAMGs?

What is the periodicity of training?

Training is provided by slide based

classroom presentations followed up

with a table toP.

Site ERO members and licensed

operators

The training is Provided once Per

license cycle (every other Year).

f

Interview 4 licensed operators (2 reactor

operators and 2 senior reactor

operators), 2 TSC staff, and 2 TSC

manaqers assiqned to apply the SAMGs
Letter or

Number

Inspection ltem Yes No Response/Comments

during an emergency to determine:

(1) Did they receive initial training on

the SAMGs? (Y/N)

Yes

Did they receive periodic training

(Y/N/document periodicity) on the

SAMGs and how they relate to

their assigned duties?

Yes

Every other year

(2) Can they articulate their

responsibilities with respect to the

use of SAMGs (Y/Nldocument

who would actually implement the

licensee's SAMGs)?

Yes

g Have there been periodic exercises on

the use of SAMGs by individuals who

would implement them during an

emergency (Y/N/document period icity)?

No
EXHIBIT 1

TABLE OF RESULTS

NINE MILE POINT

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last uPdated? a

a

a

a

N1-SAP-1 411512011

N1-SAP-2 411512011

N2-SAP-1 911912008

N2-SAP-2 412712011

Are controlled copies of the SAMG

located in the technical support center

osc)? ff/N)

Yes

Are controlled coPies of the SAMG

located in the emergency operations

facilitv (EOF)? ff/N)

Yes

Are controlled copies of the SAMG

located in the control room? (Y/N) 

-

Yes

b Are SAMGs covered by the licensee's

procedure control and document

management sYstem, including the

requirements for periodic review and

revision? (Y/N)

No, with

comment

Procedure S-ODP-PRO-0301, Rev

00400. 'EOP Revisions' is the

governing document for EmergencY

Operating Procedures (EOPS) and

Severe Accident Procedure (SAP)

changes. The procedure does not

mandate a periodic review of

EOPs/SAPs.

c Does the licensee's configuration

control and change management

systems cause the licensee to update

SAMGs to reflect design changes?

(Y/N/Partial ly-descri be )

Yes Procedure CNG-FES-007, Rev

00010, 'Preparation of Design

Inputs and Change lmPact Screen'

which is implemented bY CNG-CM1.01-1003, Rev 00400, 'Design

Engineering and Configuration

Control' requires engineers to

update SAMGs when necessary to

suooort desiqn chanqes.

d Perform a high-levelcomparison of

the site's SAMGs with available

industry guidance (e.9., 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/com ments)?

Yes The procedure format and content

follows the generic industrY

guidance.

e How is training conducted on the

SAMGS?

Who is trained on the SAMGs?

What is the periodicity of training?

Licensed operators (LO)s receive

SAMG training as part of their initial

training program. LOs receive

refresher training on a four Year

periodicity. The LO initialand

requalification training consists of

simulator and classroom

instruction.

f Interview 4 licensed oPerators (2

reactor operators and 2 senior reactor

operators), 2 TSC staff, and 2 TSC

Nine Mile Point

Page 1
Letter or

Number

lnspection ltem Yes No Response/Comments

managers assigned to apply the

SAMGs during an emergency to

determine:

(1) Did they receive initial training

on the SAMGs? (Y/N)

No, with

comment

LOs receive SAMG training as Part

of their initial training program.

At NMP, responsibility for

implementing the SAMGs resides

with the control room. As such,

TSC personnel do not receive

SAMG training as part of their TSC

oual ification oroqram.

Did they receive periodic

training (Y/N/document

periodicity) on the SAMGs and

how they relate to their

assioned duties?

No, with

comment

LOs receive refresher training on a

four year periodicity. As discussed

above, TSC personnel do not

receive SAMGs 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)?

Yes The SAMGs would be implemented

by LOs. During interviews LOs

were able to articulate their roles

and responsibitities implementing

the SAMGS.

o Have there been periodic exercises on

the use of SAMGs by individuals who

would implement them during an

emergency (Y/N/docu ment

oeriodicitv)?

Yes There have been three emergencY

preparedness exercises since 2005

that have required site personnelto

imolement the SAMGs

Nine Mile Point

Page 2
EXHIBIT 1

TABLE OF RESULTS

OYSTER CREEK

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last

updated?

The SAMGs were last updated in 2000.

ln2007, the SAMG procedure number

was changed and reissued as revision 0.

No substantive changes were made, only

typographical errors were corrected.

There is one expedited (pen and ink)

change that was made in 2007 and will

be incorporated in the next change.

Are controlled copies of the

SAMG located in the technical

support center (TSC)? (Y/N)

Yes

Are controlled copies of the

SAMG located in the

emergency operations facilitY

(EOF)? (Y/N)

No

Are controlled copies of the

SAMG located in the control

room? (Y/N)

Yes

b Are SAMGs covered by the

licensee's procedure control

and document management

system, including the

requirements for periodic

review and revision? (Y/N)

No, with

comment

The SAMGs have their own procedure for

document control, AD-OC-1 03,

"EOP/SAM PROGRAM CONTROL.'

Exelon's nuclear oversight group (NOS)

identified that although there is a

requirement for a routine biennial review,

there is no guidance regarding what

topics are to be covered during the

review or how the review should be

tracked and documented. NOS

documented this deficiency in issue

report (lR) 1214497. The licensee

provided a verbal response that the

biennial reviews have been completed.

No documentation for these reviews

exists.

c Does the licensee's

configuration control and

change management sYstems

cause the licensee to uPdate

SAMGs to reflect design

changes? (Y/N/Partiallydescribe)

Yes

Screening criteria is contained in CC-AA102, "Design Input and Configuration

Change lmpact Screening."

d Perform a high-level

comparison of the site's

SAMGs with available industrY

guidance (e.9., owner's grouP

guidance document and other

industry standards as

applicable). Are the SAMGs

consistent with the owners

Yes

Exelon Procedure AD-OC-1 03,

"EOP/SAM PROGRAM CONTROL",

contains the requirements for Oyster

Creek's EOP and SAMG develoPment

and maintenance. Oyster Creek's

SAMGs are based upon the BWR

Owner's Group Emergency Procedure

and Severe Accident Guidelines,

Oyster Creek

Page 1
Letter or

Number

Inspection ltem Yes No Resoonse/Comments

group guidance (if any) having

been incorporated

(Y/N/comments)?

Revision 2, dated March 2001. Oyster

Creek's SAMGs are contained in three

site procedures. AD-OC-103 requires that

any deviations from the BWROG

EPG/SAMGs be documented and

technically justified and shall be

contained in a controlled document

entitled, "Appendix A to the PSTGs -

Justification for Deviations of the Severe

Accident Management Guidelines from

the BWR Owner's Group Severe

Accident Guidelines", which is identified

as Oyster Creek procedure 2000-GLN3200.04. The licensee cannot locate this

document and it is not in their controlled

records management sYstem. The

licensee has entered this issue into the

corrective action program as lR

1219591. The licensee further identified

that the deviations from the BWROG

guidance for the SAMGs were previously

included with the deviations for the

Emergency Operating Procedures in

procedure 2000-GLN-3200.03.

In lieu of reviewing the Appendix A to the

PSTG document, the insPector

performed a high level review of the

BWROG guidance to the SAMG

flowcharts. There is a strong correlation

between the two documents, but

differences and justification between the

two are not documented.

e How is training conducted on

the SAMGs?

Who is trained on the SAMGs?

What is the periodicity of

training?

Training for SAMGs is a combination of

classroom and read and sign training.

SAMG training is given to licensed

operators (Senior Reactor Operators,

Reactor Operators) and select

emergency response organization (ERO)

members (Site Emergency Directors,

TSC Operations Managers, TSC

Technical (engineering) Managers and

TSC Core/Hydraulic Engineers).

Licensed operators receive SAMG

classroom training as part of their initial

licensing training. Initial training for ERO

members is an instructor led, classroom

course. Annual refresher training is given

to the licensed operators as part of their

continuing training program. Annual

refresher training for ERO members is

either a classroom course or a read and

sign document.

Oyster Creek

Page 2
Letter or

Number

Inspection ltem Yes No Response/Comments

t 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

emerqencv to determine:

Did they receive initial training

on the SAMGs? (Y/N) Yes

Did they receive periodic

train ing (Y/N/document

periodicity)on the SAMGs and

how they relate to their

assiqned duties?

Yes

Can they articulate their

responsibilities with respect to

the use of SAMGs

(Y/N/document who would

actually implement the

licensee's SAMGs)?

Yes

g Have there been periodic

exercises on the use of

SAMGs by individuals who

would implement them during

an emergency (Y/N/document

oeriodicitv)?

Yesr

Exelon procedure EP -AA-122-1001

contains the requirements for exercising

the SAMGs. The SAMGs are exercised

on a 6-year frequency. The first exercise

was completed on November 11, 2009.

Oyster Creek

Page 3
EXHIBIT 1

TABLE OF RESULTS

PEACH BOTTOM

Letter

or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last

updated?

SAMP-1, Sheet 1 10105110

SAMP-1, Sheet 2 10105110

SAMP-1, Sheet 3 05104107

SAMP-1, Sheet 4 1OlO5l10

SAMP-1, Sheet 5 10/05/10

SAMP-1, Sheet 6 1 0/05/10

SAMP-1, Sheet 7 10lO5l1O

SAMP-1, Bases, 10/05/10

SAMP-2, Sheet 1 O5l04lO7

SAMP-2, Sheet 2 05104107

SAMP-2, Sheet 3 03123111

SAMP-2, Bases 05104107

TSG-1 .105108107

TSG-1 .212115104

TSG-1 .3 05lO4lO7

TSG-2.1 10123198

TSG-2.2 01125111

TSG-3.1 10123198

TSG-3.2 02105103

TSG-3.3 02105103

TSG-4.1 02117111

TSG-4.2 12110110

PSSMG-SAMP-1 10/05/10

PSSMG, App.A, SAMP-1 10/05/10

PSSMG, App.B, SAMP-1 10/05/10

PSSMG- SAMP-2 O5IO4IO7

PSSMG, App.A, SAMP-2 05104107

PSSMG, App. B, SAMP-2 05104107

Are controlled copies of the

SAMG located in the technical

support center (TSC)? (Y/N)

Yes Information provided by the licensee.

SAMPs, SAMPs' Bases, and TSGs

Are controlled copies of the

SAMG located in the

emergency operations facil itY

(EOF)? (Y/N)

Yes lnformation provided by the licensee.

SAMP-1, Sheets 1-7 and SAMP-2,

Sheets 1-3 are in the EOF, but the SAMP

Bases and TSGs are not in the EOF.

Are controlled copies of the

SAMG located in the control

room? (Y/N)

Yes The resident inspectors verified that a

copy of the current revision of the

SAMPs, SAMPs' Bases, and TSGs are in

both the Unit 2 and Unit 3 side of the

main control room.

Peach Bottom

Page 1
Letter

or

Number

lnspection ltem 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)

No, with

comment

The SAMPs and TSGs are in the

licensees controlled procedure and

document management sYstem ;

however, the licensee does not have a

requirement for periodic review and

revision of any procedure.

c Does the licensee's

configuration control and

change management sYstems

cause the licensee to uPdate

SAMGs to reflect design

changes? (Y/N/PartiallYdescribe)

Yes CC-AA-1 02, Step 4.1.21.3

d Perform a high-level

comparison of the site's

SAMGs with available

industry guidance (e.9.,

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)?

Yes Comparison with BWROG SAG,

Revision 2, March 2001, and basis for

any deviations documented in the

PSSMGS.

e How is training conducted

the SAMGs?

Operators: Based on discussion with the

Operations Training Manager, initial

classroom training is provided per PLOT1562 and PLOT-1695 during "gaP"

training after their NRC exam. Simulator

scenarios are limited to recognizing when

to "transition" from TRIPS (EOPs) to

SAMPS (SAMGS).

(ERO): Based on discussion with the

site EP Manager, InitialClassroom

Training with an ILT class and an Annual

"Read and Sign" package as required by

TQ-AA-113. PLOT-1562 and PLOT1695 are used to provide the initial

training.

Peach Bottom

Page 2
Letter

or

Number

Inspection ltem Yes No Resoonse/Comments

Who is trained on the

SAMGs?

Operators: Senior Reactor Operators

(SROs), Reactor Operators (ROs) and,

to a lesser extent, Equipment Operators

(Eos)

Emerqencv Response Oroanization

(ERO): Shift Emergency Directors (all

SROs), Station Emergency Directors

(TSC), TSC Operations Managers, and

TSC Technical Managers

What is the periodicity of

training?

Ooerators: While there is a commitment

to conduct operator requalification

training on B.5.b mitigation strategies,

there is no commitment to perform requal

training on SAMPs and non-B.S.b TSGs.

However, the Ops Training Manager

demonstrated that SAMP gl Severe

Accident Overview Training was provided

during each of the last three 2-year

licensed operator requalification training

cycles.

As a member of the ERO, SROs must

complete the annual "Read and Sign"

package.

Emeroencv Response Oroanization

(ERO): Based on discussion with the

site EP Manager, InitialClassroom

Training with an ILT class and an Annual

"Read and Sign" package as required by

TQ-AA-113.

t lnterview 4 licensed oPerators

(2 reactor operators and 2

senior reactor operators), 2

TSC staff, and 2 TSC

managers assigned to aPPIY

the SAMGs during an

emergency to determine:

(1) Did they receive initial

training on the

SAMGs? (Y/N)

Yes RO: Yes, when the SAMPs were initially

issued or in Initial License Training (lLT).

SRO/Shift Emeroencv Director: Yes,

when the SAMPs were initially issued or

in lLT.

Peach Bottom

Page 3
Letter

or

Number

Inspection ltem Yes No Response/Comments

TSC/Station Emeroency Director: Yes,

when the SAMPs were initially issued or

in lLT.

Did they receive

periodic training

(Y/N/document

periodicity) on the

SAMGs and how they

relate to their assigned

duties?

Yes RO: Yes, as part of licensed operator

requalification training (LORT) but do not

remember how often.

SRO/Shift Emergencv Director: Yes, as

part of LORT but do not remember how

often.

Yes, for their ERO role in the form of an

Annual"Read and Sign" package

TSC/Station Emerqencv Director:

Annual"Read and Sign" package

TSC Operations and Technical

Manaqers: Annual"Read and Sign"

package

(2) Can they articulate

their responsi bilities

with respect to the use

of SAMGs

(Y/N/document who

would actually

implement the

licensee's SAMGs)?

No, with

comment

RO: Yes, they recognized that they

would be implementers that would carry

out direction from SROs and make plant

manipulations.

SRO/Shift Emerqency Director: Yes,

generally recognized that they could be

either a decision maker or

evaluator/implementer depending on

whether the MCR or the TSC has control

of the event.

TSC/Station Emerqency Director: Both

SEDs interviewed recognized that they

would be the decision makers for the

SAMPs and TSGs once the TSC is

activated and has accepted event

control. This is consistent with initial

training provided per PLOT-1562.

TSC Operations and Technical

Manaqers: Some confusion about their

roles. Believe that they would be

decision makers versus evaluators as

described in PLOT-1 562.

Peach Bottom

Page 4
Letter

or

Number

Inspection ltem Yes No Resoonse/Comments

TSC Operations and Technical

Manaqers: Some confusion about their

roles. Believe that they would be

decision makers versus evaluators as

described in PLOT-1 562.

g Have there been periodic

exercises on the use of

SAMGs by individuals who

would implement them during

an emergency (Y/N/document

periodicity)?

Yes As required by EP-AA-122-1001, Peach

Bottom has an EP objective to

demonstrate the use of their SAMPs

once every six years. Exelon procedure

states that this is consistent with NUREG

0654. This exercise would involve one of

five Emergency Response Organization

(ERO) teams. Licensee reports that this

drill objective was last evaluated on

111912009.

Peach Bottom

Page 5
EXHIBIT 1

TABLE OF RESULTS

PILGRIM

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last

updated?

l

SAG-01 and SAG-02 were

updated 12121110 due to EAL

update. Technical Support

Guideline (TSG)-1 00, Functional

Status Assessment Guideline, was

updated 519111 due to a

oermanent modification to the

Safety Relief Valves.

Are controlled copies of the

SAMG located in the

technical support center

(TSC)? (Y/N)

Yes All SAMG documents are available

in Merlin (on-line document

revision control and retrieval

system) and in the emergency

response facilities. Additionally,

SAMGs are located in the

Alternate TSC in Chiltonville.

Are controlled copies of the

SAMG located in the

emergency operations facilitY

(EOF)? (Y/N)

Yes

Are controlled copies of the

SAMG located in the control

room? (Y/N)

Yes

b Are SAMGs covered by the

I icensee's procedure control

and document management

system, including the

requirements for periodic

review and revision? (Y/N)

No, with

comment

All SAMG documents are available

in Merlin and Document Control

Center (DCC). There is, however,

no requirement for 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/Partial I v-descri be)

Yes Plant modification changes are

made in accordance with the

Design Inputs Process and design

change processes and SAMGs

would be revised if they were

affected.

d Perform a high-level

comparison of the site's

SAMGs with available

industry guidance (e.9.,

owner's group guidance

document and other industry

Yes It appears that the licensee utilized

the NEI guidance to conduct a risk

based evaluation of what events

might require additional guidance

in the form of SAMGs. Some

events evaluated under this

Pilgrim

Page 1
Letter or

Number

lnspection ltem Yes No Resoonse/Comments

standards as applicable). Are

the SAMGs consistent with

the owners group guidance (if

any) having been

incorporated

(Y/Nicomments)?

guidance refer to SAG-01 and

SAG-02 which were developed by

the licensee to implement the

industry SAMG expectations.

e How is training conducted

the SAMGs?

Who is trained on the

SAMGS?

What is the periodicity of

training?

Training on SAMGs (or SAGs at

Pilgrim) is given addressing the

SAGs themselves, Severe

Accident Management

Phenomenology (RPV and

Containment phenomena are

analyzed for corrective action

consideration), and Technical

Support Guidelines procedures.

After an SRO receives their

license, SAMG training

(approximately 3 days) is included

in the approximately 2 weeks of

miscellaneous training

(ad m inistrative procedures

probabilistic risk analysis, etc)

provided to the SRO. Technical

Support Center (TSC) Managers

and staff and Emergency

Operations Facility (EOF)

Managers and staff are also

provided initial SAMG training.

Requalification training on SAMGs

for SROs is required everY two (2)

years.

Emergency Response Team

Manager and staff periodic training

is everv two (2) vears.

f Interview 4 licensed operators

(2 reactor operators and 2

senior reactor operators), 2

TSC staff, and 2 TSC

managers assigned to aPPIY

the SAMGs during an

emergency to determine:

Pilgrim

Page2
Letter or

Number

Inspection ltem Yes No Response/Comments

(1) Did they receive initial

training on the SAMGs?

(Y/N)

Yes, with

comment

SRO - Yes

SRO - Yes

TSC Mgr - Yes

TSC Mgr - Yes

TSC Staff - Yes

TSC Staff - Yes

RO's - Do not receive training on

SAMGs. They are trained on tasks

which are required during

emergencies and which may be

undertaken under EOPs or

SAMGs but are not specificallY

trained on the SAMGs themselves.

Did they receive

periodic training (Y/N/

document periodicity) on

the SAMGs and how

they relate to their

assigned duties?

Yes, with

comment

SRO - Yes, every 2years

SRO - Yes, every 2years

RO - see above

TSC Mgr - Not yet (took initial

SAMG training last year), everY 2

years

TSC Mgr - Yes, every 2 Years

TSC Staff - Not yet (took initial

SAMG training last year), everY 2

years

TSC Staff - Not yet (took initial

SAMG training last year), everY 2

VCATS

(2) Can they articulate their

responsibilities with

respect to the use of

SAMGs (Y/N/ document

who would actuallY

implement the licensee's

SAMGs)?

Yes SRO - Yes, recommendations

made to Operations Manager in

control room.

SRO - Yes, same.

RO - see above

TSC Mgr - Yes, recommendations

made to EmergencY ResPonse

Manager.

TSC Mgr - Yes, same.

TSC Staff - Yes, same.

TSC Staff - Yes, same.

g Have there been periodic

exercises on the use of

SAMGs by individuals who

would implement them during

an emergency (Y/N/document

oeriodicitv)?

No There was one exercise when the

SAMGs were first imPlemented.

Per the licensee, a future EP Drill

where SAMGs will be required to

be utilized is being Planned

Pilgrim

Page 3
EXHIBIT 1

TABLE OF RESULTS

SALEM

Letter or

Number

Inspection ltem Yes No Resoonse/Comments

a When were the SAMGs last updated? 1211811998. Guidance has not been

updated for Revision 1 of the

Westinghouse Owners Group (WOG)

guidance which was issued in October

2001.

Are controlled copies of the SAMG

located in the technical support center

ffsc)? ry/N)

Yes

Are controlled copies of the SAMG

located in the emergency operations

facilitv (EOF)? ff/N)

No

Are controlled copies of the SAMG

located in the control room? (Y/N) Yes

o Are SAMGs covered by the licensee's

procedure control and document

management system, including the

requirements for periodic review and

revision? (Y/N)

Yes

c Does the licensee's configuration control

and change management systems cause

the licensee to update SAMGs to reflect

desion chanoes? (Y/N/Partiallv-describe)

Yes

d Perform a high-level comparison of the

site's SAMGs with available industry

guidance (e.9., owner's group guidance

document and other industry standards

as applicable). Are the SAMGs

consistent with the owners grouP

guidance (if any) having been

incoroorated (Y/N/com ments)?

Yes

Salem's SAMGs are consistent with

WOG guidance but have not been

updated for Revision 1 of the WOG

guidance which was issued in October

2001.

e How is training conducted on the

SAMGs?

Who is trained on the SAMGs?

What is the periodicity of training?

Classroom training is conducted.

Licensed operators are trained every

2 years and TSC staff are trained

every 6 years.

t Interview 4 licensed operators (2 reactor

operators and 2 senior reactor

operators), 2 TSC staff, and 2 TSC

managers assigned to apply the SAMGs

durinq an emerqency to determine:

(1) Did they receive initial training on

the SAMGs? (Y/N) Yes

Did they receive periodic training

(Y/N/document periodicity) on the

SAMGs and how they relate to

their assiqned duties?

Yes
Letter or

Number

Inspection ltem 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)?

Yes

The Shift Manager (SM)would

implement the SAMGs using shift

oersonnel until the TSC is manned.

When TSC is manned, the TSC

technical support supervisor would

give guidance to the SM to implement

the SAMGS.

g Have there been periodic exercises on

the use of SAMGs by individuals who

would implement them during an

em erqency (Y/N/document periodicity)?

Yes Periodic exercises that use the

SAMGs are conducted at least every

6 vears.

Salem

Page2
EXHIBIT 1

TABLE OF RESULTS

SEABROOK

Letter or

Number Inspection ltem Yes No Response/Comments

a When were the SAMGs last

updated?

1998. They have not been updated with

2001 WOG quidance.

Are controlled copies of the

SAMG located in the

technical support center

(TSC)? (Y/N)

Yes

Are controlled copies of the

SAMG located in the

emergency operations

facility (EOF)? (Y/N)

Yes, with

comment

A complete set was not available at the

EOF. Specifically, SACRG-1 and

SACRG-2 were missing. The station will

be adding the two procedures, but

considers the addition an enhancement

and noted that it was not required for EOF

responders. The licensee entered this

into the corrective action program as

AR1651436.

Are controlled copies of the

SAMG located in the control

room? (Y/N)

Yes

b Are SAMGs covered by the

licensee's procedure control

and document management

system, including the

requirements for periodic

review and revision? (Y/N)

Yes Seabrook SAMGs are controlled and

maintained by administrative procedure

NM1 7750, Severe Accident Management.

However, it was not until November 2003

(NM 1 1750, Revision 2) that a 3-year

period review was implemented for

SAMGS.

The last review, per NM11750, was

completed in November 2007 by the PRA

engineering group. Operations, who

assumed ownership of the SAMGs in

2008, failed to perform the subsequent

three-year review in November 2010. The

licensee entered this into the CAP as AR

1652093. The station did however

perform a review of the SAMGs during

their review of IER '1 1-1, but not

specifically to satisfy the three-year

review.

Additional info:

FPL-1, Quality Assurance Topical Report,

Revision 9, Appendix B, "Procedures"

states, in part, that "Seabrook is

committed to the use of Appendix A of

Regulatory guide 1.33 as guidance for

establishing the types of procedures that

are necessary to control and support plant

operations." ,

Several oeneric procedure tvpes are

Seabrook

Page 1
Letter or

Number Inspection ltem Yes No Response/Comments

defined with a broad description of the

activities to be included (e.9., calibration

and test, chemical-radiochemical control,

emergency plan implementing, and

emergency procedures). However, no

specific procedure type describes beyond

design basis mitigation procedures.

The current QATR does not recognize

SAMGs nor does it require periodic

review.

Does the licensee's

configuration control and

change management

systems cause the licensee

to update SAMGs to reflect

design changes?

(Y/N/Pa rtial ly-d escri be)

No, with

comment

Although not explicitly addressed in the

configuration control and change

management systems, Seabrook

procedure NMI 1 750, Severe Accident

Management, section 4.3.4.3, states,

"updates to the SAMGs and their training

materials shall be published on as asneeded basis considering the following:

. NRC requirements published as

regulations, issues and

resolutions, audit findings or drill

observations

. Feedback from the Emergency

Response Organization and the

Station staff performing periodic

tabletop and / or inter-facility mini

drills

o Additional insights from the

Probabi listic Safety Assessment

o Scientific and technical advances

in the understanding of severe

accidents, and

o Plant modifications and procedure

changes."

d Perform a high-level

comparison of the site's

SAMGs with available

industry guidance (e.9.,

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)?

Yes, with

comment

Seabrook SAMGs were determined to be

consistent with the guidelines established

forWOG SAMG Revision 0. The SAMGs

have not been updated with 2001 WOG

guidance (Rev.1).

Seabrook plans to transition to Revision 1.

However, they will not know the specific

impact of any required changes to

Revision 1 until their engineering analysis

is completed at a time stillto be

determined.

The WOG published revision 1 of the

SAMGs in October 2001. In 2003 (CR 03-

2379) Seabrook oversight identified that

changes to SAMGs were warranted. At

that time, only minor enhancements were

incorporated and noted that the SAMGs

would work as written.

Seabrook

Page2
Letter or

Number lnspection ltem Yes No Response/Comments

In March 201'1, Seabrook identified the

need to incorporate changes indentified in

WOG SAMGs Revision 1 (AR 1635016),

Further, Seabrook identified that ERP98004, SAMG set point basis document

had not been revised since initial issuance

in 1998 and may have been impacted by

subsequent power up rate in 2005. (AR

1 6351 80)

e How is training conducted on

the SAMGs?

Who is trained on the

SAMGs?

What is the periodicity of

training?

Training for SAMGs is conducted using

traditional classroom, tabletop, and job

performance measure walkdowns. No

emergency preparedness drills or

operations simulator drills include SAMGS.

Training is provided to licensed operators,

non-licensed operators, and technical

support staff (TSC)

Training is conducted on a two year cycle

for SAMGS.

f lnterview 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

emeroencv to determine:

(1) Did they receive

initial training on the

SAMGs? (Y/N)

Yes

Did they receive

periodic training

(Y/N/document

periodicity) on the

SAMGs and how they

relate to their

assiqned duties?

Yes Training is conducted on a two year cycle

for 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)?

Yes

Following guidance provided in SACRG-1,

Severe Accident Control Room Guideline

Initial Response, those interviewed

denoted that the Shift Manager (Site

Temporary Emergency Director) would

have the responsibility for implementing

the SAMGs if the emergency response

facilities were not activated or available.

Otherwise, the SM would imPlement

accident mitigation strategies as directed

by the SED [Site Emergency Director].

Per NM 11750, Severe Accident

Manaqement; implementers are all

Seabrook

Page 3
Letter or

Number lnsoection ltem Yes No Response/Comments

license holders, decision makers are

SED, evaluators are emergency

operations technician, reactor engineers,

engineering coordinators, and nuclear

safety evaluators.

Following guidance provided in SACRG-2,

Severe Accident Control Room Guideline

for Transients After the TSC is Activated

those interviewed denoted that the SED

would have the responsibilitY for

implementing the SAMGs, if the

emergency response facilities were not

activated or available.

g Have there been periodic

exercises on the use of

SAMGs by individuals who

would implement them

during an emergency

(Y/N/document periodicitY)?

No, with

comment

SAMG events are not integrated into the

stations combined functional drills.

However, the station Provides the

opportunity for participants to conduct

SAMG activities during training and

tabletop events. This type of training /

tabletop is provided for selected ERO

positions (e.9., Operations Technician,

Reactor Engineer, Engineering

Coordinator, and Site EmergencY

Directors).

Seabrook

Page 4
EXHIBIT 1

TABLE OF RESULTS

SUSQUEHANNA

Letter

or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last

updated?

l

PSTG Rev 9 was issued in April2005 to

upgrade EOPs to BWROG EPG/SAG Rev.2

guidance.

Site EOPs are based on BWROG Rev.2

and site SAGs are based on BWROG Rev.1

guidance. PPL chose not to update the

SAMG procedures (EP-DS series) to Rev.2

guidance.

. EP-DS-001 1012012010

. EP-DS-O02 412712011

. EP-DS-004112612010

. EP-DS-003 412912011

o EP-DS-O05 412712011

r EP-DS-0061012612010

Are controlled copies of the

SAMG located in the

technical support center

(TSC)? ry/N)

Yes (1) copy of the EP-DS procedures.

(2) copy of the EP-DS hard cards.

Are controlled copies of the

SAMG located in the

emergency operations

facilitv (EOF)? ry/N)

Yes (2) copies of the EP-DS procedures

(2) copies of the EP-DS hard cards.

Are controlled cooies of the

SAMG located in the control

room? (Y/N)

No (0) copies of the EP-DS procedures.

(1) copy of the EP-DS hard cards. The

inspectors noted there were to be three

hard card sets in the TSC but could only

identify two. The third copy of the hard

cards was actually misplaced to the control

room and should have been located in the

TSC. Procedurally, no controlled copies of

the EP-DS procedures or hard cards are to

be in the control room. This issue was

entered in PPL's corrective action program

(CAP) (ARs 1406627, 1 405215).

b Are SAMGs covered by the

licensee's procedure control

and document management

system, including the

requirements for periodic

review and revision? (Y/N)

Yes PSTG control is established by NDAP-QA0330 and requires changes prior to or in

parallel with procedural changes. The

SAMG procedures (EP-DS series) are

covered by periodic review via NDAP-QA0002.

c Does the licensee's

configuration control and

change management

systems cause the licensee

to update SAMGs to reflect

design changes?

ff/N/Partial lv-d escri be)

Yes Plant changes that affect the SAMGs arba

covered by NDAP-Q A-1220 and NDAP-QA0330. Deviations from the BWROG

EPG/SAG shall be documented by 10 CFR

50.59 per NDAP-QA-0330.

Susquehanna

Page 1
Letter

or

Number

lnspection ltem Yes No Response/Comments

d Perform a high-level

comparison of the site's

SAMGs with available

industry guidance (e.9.,

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)?

Yes Site SAGs are based on BWROG

EPG/SAG Rev.1 guidance. PPL has not

updated the SAMG procedures (EP-DS

series) to BWROG EPG/SAG Rev.2

guidance.

e How is training conducted

on the SAMGs?

Who is trained on the

SAMGs?

What is the periodicity of

training?

l

l

The courses below are broken down by

course number/title/method of

delivery/assessmenUperiodicity and a list of

the Emergency Response Organization

positions that receive the training.

EP076/"Severe Accident Management

(SAM) Overview and Transition"/Read

and Sign/Not assessed/Single

Performance: Dose Assessment

Supervisor, Emergency Director-TSC,

Emergency Director/Control Room(Shift

Manager), Engineering Support Supervisor,

HPN Communicator-EOF, Liaison Support

Supervisor-EOF, Operations Coordinator -

TSC, Public Information Manager, Public

lnformation Technical Briefers, Radiation

Protection Coord inator/HPN Communicator,

Recovery Manager, Severe Accident

Management Coordinator, Technical

Support Coordinator-TSC, TSC Lead

Engineer, Unit Supervisor.

EP077 l "severe Accident Progression

and Phenomena"/Classroom/Not

Assessed/Single Performance:

Emergency Director-TSC, Emergency

Director/Control Room(Shift Manager),

Operations Coordinator -TSC, Severe

Accident Management Coordinator.

Licensed operators and STAs also receive

this training during initial licensing

coursework.

EP078Ef'Damage SuPPort

Proced u res"/Self-Study/Assignment but

not testable/Single Performance; Annual

Performance only for the SAM

Coord inator: Emergency Director/Control

Room(Shift Manager), OPerations

Coordinator -TSC, Severe Accident

Management Coordinator.

lnsoectors noted that PPL has a designated

Susquehanna

Page2
Letter

or

Number

Inspection ltem Yes No Response/Comments

position called the SAM Coordinator as an

element of the Emergency Response

Organization in the TSC. Inspectors also

noted during this Tl that the STA is

expected to act as the SAM Coordinator

until the TSC is staffed in the case that an

accident evolves to the point that the SAMG

entry criteria are met. The inspectors

identified that the while the STAs receive

initialtraining on the SAMGS, they do not

receive periodic refresher training. This

issue was entered in PPL's CAP as AR

1406734.

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

emerqencv to determine: I

(1) Did they receive

initial training on the

SAMGs? (Y/N)

Yes All licensed operators receive initial training

on the SAMG procedures. While some

licensed operators could not recall if they

had received initial training on the SAMG

procedures, inspectors verified that those

interviewed had received training. TSC

staff received initial training based on

position-specific requirements (see e.

above).

Did they receive

periodic training

(Y/N/document

periodicity)on the

SAMGs and how

they relate to their

assiqned duties?

No, with

comment

Periodic training on the SAMG procedures

is position-specific and is only received by

the Severe Accident Management

Coordinator.

(2) Can they articulate

their responsibilities

with respect to the

use of SAMGs

(Y/N/document who

would actually

implement the

licensee's SAMGs)?

Yes

g Have there been periodic

exercises on the use of

SAMGs by individuals who

would implement them

during an emergency

(Y/N/docu ment period icity)?

No, with

comment

EP exercises/drills have periodically

incorporated entry in the SAMG procedures

(EP-DS series) but these scenarios were

developed to support ERO declaration of a

General Emergency as required by EP drill

regulations. The SAMG procedures were

not oerformed to completion or recoverv.

Susquehanna

Page 3
EXHIBIT 1

TABLE OF RESULTS

THREE MILE ISLAND UNIT 1

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs last

updated? l

May 12,2010

Are controlled copies of the SAMG

located in the technical support

center (TSC)? (Y/N)

Yes Verified directly by inspector.

Are controlled copies of the SAMG

located in the emergency

operations facilitv (EOF)? (Y/N)

Yes Inspector verified by interview of

Exelon staff responsible for EOF

orocedures.

Are controlled copies of the SAMG

located in the control room? (Y/N)

Yes Verified directly by inspector.

b Are SAMGs covered by the

licensee's procedure control and

document management system,

including the requirements for

periodic review and revision? (Y/N)

No, with

comment

SAMGs are developed, verified,

approved, and revised using the

licensee process AD-AA-1 01,

Processing of Procedures and

T&RMs, Rev.22. SAMGs are

considered Training & Reference

Material (T&RM) instead of an actual

procedure. Their use category is

Level 3, which is informational use.

Many station procedures are also

Level 3. T&RMs (such as the

SAMGs) are not subject to 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)

Yes CC-AA-102, Design Input and

Configuration Change lmpact

Screening, Rev. 20 sections 4.1.17,

4.1.22.3, and Attachment 8 address

updating SAMGs when affected by

desiqn or confiquration chanqes.

d Perform a high-levelcomparison of

the site's SAMGs with available

industry guidance (e.9., 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)?

Yes TMI SAMGs (ER-TM-TSC-0010, TMI1 Severe Accident Management

Guidelines, Rev. 2 is consistent with

the B&WOG guidelines - Generic

Severe Accident Guideline (GSAG)

and Generic Severe Accident

Guideline Technical Basies Document

(GSAGTBD) document 69-1224353-

02 dated March 1997.

e How is training conducted on the

SAMGs?

Who is trained on the SAMGs?

What is the periodicity of training?

Initial instructor-led classroom training

is conducted for all licensed operators

(RO, SRO), and members of the

emergency response organization

(ERO) staff assigned SAMG

responsibilities as Evaluators,

Decision-Makers, and lmplementers.

Most of these ERO members fill the

TSC staff positions of Emergency

Director, Operations Manager,

Technical Manager, Core/Thermal

Hydraulic engineer, Mechanical

Enqineer, or Electrical Engineer.

Three Mile lsland

Page 1
Letter or

Number

Inspection ltem Yes No Response/Comments

Hydraulic engineer, Mechanical

Engineer, or Electrical Engineer.

Refresher training is required

annually. The refresher training is

shorter and can be done as a read &

sign or as classroom 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:

In addition to the 8 personnel

interviewed, the inspectors selected 4

additional SAMG-qualified individuals

at random and verified their

oualification status was current.

(1) Did they receive initial

training on the SAMGs?

(Y/N)

Yes No comments.

Did they receive periodic

training (Y/N/docu ment

periodicity) on the SAMGs

and how they relate to their

assigned duties?

Yes They each receive periodic refresher

trarning. The periodic refresher

training for ERO members is a

general read & sign of the SAMG

procedures. lt is not customized to

the individual's duties

Most of the ERO has also received

SAMG training during table-toP

exercises.

(2) Can they articulate their

responsibilities with resPect

to the use of SAMGs

(Y/N/document who would

actually implement the

licensee's SAMGs)?

Yes The licensed operators (RO, SRO),

and members of the emergency

response organization (ERO) staff

assigned SAMG responsibilities as

Evaluators, Decision-Makers, and

lmplementers each could articulate

their responsibilities with respect to

SAMG evaluation, decision making,

and implementation. The associated

ERO members fill the TSC staff

positions of Emergency Director,

Operations Manager, Technical

Manager, Coreffhermal Hydraulic

engineer, Mechanical Engineer, or

Electrical Engineer.

g Have there been periodic exercises

on the use of SAMGs by

individuals who would imPlement

them during an emergency

(Y/N/docu ment period icity)?

Yes An EP Exercise requiring SAMG

implementation was conducted on

September 22,2009. NRC DEP Pls

were counted during this exercise.

Additionally, each ERO team (5

teams) performed a SAMG table-toP

exercise in the mid-2009 timeframe.

There is no periodic requirement.

Three Mile lsland

Page2
EXHIBIT 1

SUMMARY OF RESULTS

VERMONT YANKEE

Letter or

Number

Inspection ltem Yes No Response/Comments

a When were the SAMGs

last updated?

RPV & Containment EOP/SAG 

I

Reference and Action Levels - |

03/05/07

Appendix A, Vermont Yankee Severe

Accident Guidelines lmplementation

Guide - 03/16/06

Appendix B, SAG Design Notes -

12t29198

Appendix C, Plant-SPecific

Mod ification s - 1 2129198

Attachment D SAG-1 - 02101106

Attachment D SAG-2 -09114109

Appendix E, Technical SuPPort

Guidelines (TSG): Foreword and

Figure 2 - 10111101

Appendix E, Section 1, Introduction -

10111101

Appendix E, Section 2, General

lnformation - 10111101

Appendix E, Section 3, Control

Parameter Assessment Guideline -

03/08/07

Appendix E, Section 4, Plant Status

Assessment Guideline - 04114111

Appendix E, Section 4, Attachment 1,

Core Damage Assessment

Methodology - 02116106

Appendix E, Section 5, SYstem Status

Assessment Guideline - 10111101

Appendix E, Section 6, EOP/SAG

Action Assessment Guideline -

03/08/07

Appendix E, Section 7, Containment

Venting Guideline - 03/08/07

Appendix F, Validation Program -

12129198

Appendix G, Loss of Large Areas of

the Plant Due to Fire or ExPlosion -

04114111

Appendix H, EMG-|, EmergencY

Manaqement Guideline - 02126109-

Are controlled copies of

the SAMG located in

the technical suPPort

center (TSC)? (Y/N)

Yes The inspectors verified that there are two

controlled copies of the SAMGs in the

technical support center. The inspectors

identified an extra uncontrolled copy of

App. E, Sec. 4, Att. 1 - Core Dqrne€eVermont Yankee

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Letter or

Number

Inspection ltem Yes No Response/Comments

Assessment Methodology with an outdated

revision. Entergy entered the issue into

their corrective action program, and

immediatelv corrected the deficiency.

Are controlled copies of

the SAMG located in

the emergency

operations facility

(EOF)? (YiN)

Yes The inspectors verified that there is one

controlled copy in the EOF.

Are controlled copies of

the SAMG located in

the control room? (Y/N)

Yes The inspectors verified that there is one

controlled copy 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)

No, with

comment

The SAMG manual is a controlled

document, so periodic audits are

conducted to verify the correct revisions

are in place in hard copy. VY is not

required to do periodic reviews of their

procedures, per the current revision of the

QA Manual. The QA master audit plan for

the operations department includes

emergency operation procedures (EOPs),

but does not specifically mention the

SAMGS.

c Does the licensee's

configuration control

and change

management systems

cause the licensee to

update SAMGs to

reflect design changes?

(Y/N/Partial lv-describe)

Yes EN-DC-115, the corporate procedure for

engineering changes, includes screening

questions to determine if a review is

needed to assess the change for impacts

to the SAMGs. The review, if needed, is

performed by the senior reactor operator

(SRO) responsible for the SAMGS.

d Perform a high-level

comparison of the site's

SAMGs with available

industry guidance (e.9.,

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)?

Yes The inspectors performed a high level

review and verified that the SAMGs are

consistent with the BWR owners'group

recommendations. The inspectors also

verified that Entergy added plant specific

information where appropriate. Entergy's

10 CFR 50.54(hh) information is included

in Appendix G to the SAMG manual.

Appendix H to the SAMG manualcontains

information on severe accident

management, including considerations of

offsite power availability, spent fuel pool

level, security concerns and medical

concerns.

e How is training

conducted on the

SAMGs?

Who is trained on the

SAMGs?

What is the periodicity

of training?

Entergy conducts classroom training for

licensed operators on the Severe Accident

Guidelines (SAGs), the Technical Support

Guidelines (TSGs), Severe Accident

Management, and Primary Containment

Venting. Licensed operators are trained on

all four, initially and once every two years.

Non-licensed operators are trained on the

Vermont Yankee

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Letter or

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Inspection ltem Yes No Response/Comments

SAGs and Primary Containment Venting,

initially and once every two years. Nonlicensed operators are trained on Severe

Accident Management in requalification

only. The emergency plant manager, who

directs personnel in the TSC and the OSC,

attends classroom training with the

licensed operators, initially and then every

three years, for alltopics but primary

containment venting. The Emergency

Operations Facility (EOF) Emergency

Director attends Severe Accident

Management with the licensed operators

initially and every three years.

Once every two years licensed operators

are given a simulator scenario that requires

SAG entry. The operators proceed through

the SAGs in a tabletop discussion, due to

limitations on severe accident simulation.

Licensed and non-licensed operators

perform in-plant walkdowns during initial

and requalification training that involves the

EOPs and SAGs.

Engineering staff members are given a

brief overview of the SAGs during initial

enqineerinq traininq.

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 performed all of the

required interviews.

(1) Did they receive initial training

on the SAMGs?

ry/N)

Yes

Did they receive

periodic training

(Y/N/document

periodicity) on

the SAMGs and

how they relate

to their assigned

duties?

Yes Those who had been qualified in their

position long enough to need

requalification training have received it.

See periodicity listed in question "e" above.

(2) Can they

articulate their

responsibilities

with respect to

the use of

Yes The Control Room Supervisor (CRS) is

responsible for recognizing the entry

criteria into the SAGs (along with the TSC),

has command and control of the SAGs,

and makes decisions with TSC input if

Vermont Yankee
Letter or

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Inspection ltem Yes No Response/Comments

SAMGs

(Y/N/document

who would

actually

implement the

licensee's

SAMGs)?

available.

The reactor operators (ROs) implement

SAMG actions as directed by the control

room supervisor, and based on their

training can provide for a second check for

the control room supervisor (CRS).

The shift technical advisor (STA) is

responsible for monitoring entry criteria into

the SAGs. The STA also tracks control

room priorities based on those listed in

each "leg" (procedure section).

The TSC operations coordinator (an active

SRO) is the SAG decision maker in the

TSC. The operations coordinator assesses

plant conditions to determine if there has

been a core breach. TheY determine

priorities based on the leg in use,

coordinate with the OSC to take actions

and keep the control room informed. They

also use App H to monitor longer term

concerns.

The emergency plant manager directs

actions in the TSC/OSC, and provides a

second check for the ops coordinator. The

emergency plant manager is not

considered to be an SAG decision maker.

g Have there been

periodic exercises on

the use of SAMGs by

individuals who would

implement them during

an emergency

(Y/N/document

oeriodicitv)?

Yes Entergy conducts an emergency drill which

includes an entrance into the SAGs via the

EOPs every three years. Additionally, VY

has conducted one emergencY drill

involving SAMG entry for a plane crash on

site. Of the eight individuals interviewed,

two could remember participating in a drill

reouirino the SAMGS.

Vermont Yankee

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