Federal Register / Vol. 79, No. 184 / Tuesday, September 23, 2014 / Notices 56779 

B. Aftermarket Seats 

Aftermarket seats generally attach to 

cargo racks and are generally marketed 

as being intended for use when the ATV 

is not moving. 

• What, if any, data are available 

regarding use of aftermarket seats by 

passengers when the ATV is moving? 

• What, if any, data are available 

regarding injury or risk of injury 

associated with the use of aftermarket 

seats? 

C. Feasibility 

• Can design modifications be made 

to ATVs to prevent passengers? 

• If design modifications are feasible, 

please describe possible design changes 

that could prevent passengers. How 

could such modifications affect the 

usability or utility of the ATV? 

Although CPSC cannot mandate a 

specific design, information regarding 

proof-of-concept designs can inform 

decision making regarding the 

feasibility of a performance 

requirement. 

• Would it be feasible to establish a 

performance standard that would 

prevent consumers from carrying 

passengers or installing aftermarket 

seats capable of carrying passengers 

without significantly adversely affecting 

the usability or utility of the ATV for 

purposes other than carrying 

passengers? 

• How would a performance 

requirement to prevent passenger use of 

ATVs affect two-rider ATVs, also called 

Tandem, 2-Up, or Type II ATVs? Should 

such a requirement apply to two-rider 

ATVs? 

Dated: September 18, 2014. 

Todd A. Stevenson, 

Secretary, Consumer Product Safety 

Commission. 

[FR Doc. 2014–22556 Filed 9–22–14; 8:45 am] 

BILLING CODE 6355–01–P 

DEFENSE NUCLEAR FACILITIES 

SAFETY BOARD 

[Recommendation 2014–1] 

Emergency Preparedness and 

Response 

AGENCY: Defense Nuclear Facilities 

Safety Board. 

ACTION: Notice, recommendation. 

SUMMARY: Pursuant to 42 U.S.C. 

2286a(b)(5), the Defense Nuclear 

Facilities Safety Board has made a 

recommendation to the Secretary of 

Energy concerning the need to take 

actions to improve the emergency 

preparedness and response capability at 

the Department of Energy’s (DOE) 

defense nuclear facilities. 

DATES: Comments, data, views, or 

arguments concerning the 

recommendation are due on or before 

October 23, 2014. 

ADDRESSES: Send comments concerning 

this notice to: Defense Nuclear Facilities 

Safety Board, 625 Indiana Avenue NW., 

Suite 700, Washington, DC 20004–2001. 

FOR FURTHER INFORMATION CONTACT: 

Andrew L. Thibadeau at the address 

above or telephone number (202) 694– 

7000. 

Dated: September 17, 2014. 

Peter S. Winokur, Ph.D., 

Chairman. 

Recommendation 2014–1 to the 

Secretary of Energy 

Emergency Preparedness and Response 

Pursuant to 42 U.S.C. § 2286d(a)(3) 

Atomic Energy Act of 1954, As 

Amended 

Dated: September 2, 2014 

The need for a strong emergency 

preparedness and response program to 

protect the public and workers at the 

Department of Energy’s (DOE) defense 

nuclear facilities is self-evident. Design 

basis accidents resulting from natural 

phenomena hazards and operational 

events do occur and must be addressed. 

Consequently, emergency preparedness 

and response is a key component of the 

safety bases for defense nuclear 

facilities, as evidenced by its inclusion 

as a safety management program in the 

technical safety requirements for these 

facilities and in specific administrative 

controls that reference individual 

elements of emergency response. It is 

the last line of defense to prevent public 

and worker exposure to hazardous 

materials. One of the objectives of DOE’s 

order on emergency preparedness and 

response (Order 151.1C, Emergency 

Management System) is to ‘‘ensure that 

the DOE Emergency Management 

System is ready to respond promptly, 

efficiently, and effectively to any 

emergency involving DOE/[National 

Nuclear Security Administration 

(NNSA)] facilities, activities, or 

operations, or requiring DOE/NNSA 

assistance.’’ The Defense Nuclear 

Facilities Safety Board (Board) believes 

that the requirements in this order that 

establish the basis for emergency 

preparedness and response at DOE sites 

with defense nuclear facilities, as well 

as the current implementation of these 

requirements, must be strengthened to 

ensure the continued protection of 

workers and the public. 

Problems with emergency 

preparedness and response have been 

discussed at Board public hearings and 

meetings over the past three years, as 

well as in Board site representative 

weekly reports and other reviews by 

members of the Board’s technical staff. 

At its hearings, Board members have 

stressed the need for DOE to conduct 

meaningful training and exercises to 

demonstrate site-wide and regional 

coordination in response to 

emergencies. Board members have also 

encouraged DOE to demonstrate its 

ability to respond to events that involve 

multiple facilities at a site and the 

potential for several ‘‘connected’’ 

events, e.g., an earthquake and a 

wildland fire at Los Alamos. 

On March 21, 2014, and March 28, 

2014, the Board communicated to the 

Secretary of Energy its concerns 

regarding shortcomings in the responses 

to a truck fire and radioactive material 

release event at the Waste Isolation Pilot 

Plant (WIPP) in Carlsbad, New Mexico. 

The DOE Accident Investigation Board 

explored and documented these 

shortcomings in its reports. Many of the 

site-specific issues noted at WIPP are 

prevalent at other sites with defense 

nuclear facilities, as documented in the 

attached report. 

The Board has observed that these 

problems can be attributed to the 

inability of sites with defense nuclear 

facilities to consistently demonstrate 

fundamental attributes of a sound 

emergency preparedness and response 

program, e.g., adequately resourced 

emergency preparedness and response 

programs and proper planning and 

training for emergencies. DOE has noted 

these types of problems in reports 

documenting independent assessments 

of its sites and in its annual reports on 

the status of its emergency management 

system. The annual reports also noted a 

lack of progress in addressing these 

problems. 

The Board is concerned that these 

problems stem from DOE’s failure to 

implement existing emergency 

management requirements and to 

periodically update these requirements. 

DOE has not effectively overseen and 

enforced compliance with these 

requirements, which establish the 

baseline for emergency preparedness 

and response at its sites with defense 

nuclear facilities. These requirements 

need to be revised periodically to 

address lessons learned, needed 

improvements to site programs, new 

information from accidents such as 

those at the Deepwater Horizon drilling 

rig and the Fukushima Dai-ichi Nuclear 

Power Plant, and inconsistent 

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56780 Federal Register / Vol. 79, No. 184 / Tuesday, September 23, 2014 / Notices 

1Severe events include design basis and beyond 

design basis events. They also include operational 

and natural phenomena events. 

interpretation and implementation of 

the requirements. 

Through its participation in DOE 

nuclear safety workshops in response to 

the events at the Fukushima Dai-ichi 

Nuclear Power Plant and its lines of 

inquiry regarding emergency 

preparedness and response at recent 

public hearings and meetings, Board 

members have been supportive of DOE’s 

efforts to improve its response to both 

design basis and beyond design basis 

events. However, the Board believes 

DOE’s efforts to adequately address 

emergency preparedness and response 

at its sites with defense nuclear facilities 

have fallen short as clearly evidenced by 

the truck fire and radioactive material 

release events at WIPP. 

Background 

Technical planning establishes the 

basis for emergency preparedness and 

response at DOE sites with defense 

nuclear facilities. Technical planning 

includes the development of emergency 

preparedness hazards assessments, 

identification of conditions to recognize 

and categorize an emergency, and 

identification of needed protective 

actions. This basis is used to develop 

emergency response procedures, 

training, and drills for emergency 

response personnel. This basis leads to 

identification of resource requirements 

for emergency response, including 

facilities and equipment. Technical 

planning is also the basis for 

determining the scope and scenario of 

exercises and other assessments used to 

verify and validate readiness and 

effectiveness of emergency response 

capabilities at DOE sites with defense 

nuclear facilities. 

Hazards assessments form the 

foundation of the technical planning 

basis for emergency preparedness and 

response and provide the basis for the 

preparation of the procedures and 

resources used as personnel respond to 

emergencies. As cited in the attached 

report, the Board has observed that 

hazards assessments at many DOE sites 

with defense nuclear facilities do not (1) 

address all the hazards and potential 

accident scenarios, (2) contain complete 

consequence analyses, (3) develop the 

emergency action levels for recognizing 

indicators and the severity of an 

emergency, and (4) contain sufficiently 

descriptive protective actions. One 

example of incomplete hazards analysis 

that is endemic to the complex is the 

lack of consideration of severe events 

that could impact multiple facilities, 

overwhelm emergency response 

capabilities, and/or have regional 

impacts.1 This was a topic of discussion 

at the Board’s public meeting and 

hearing on the Pantex Plant in Amarillo, 

Texas, on March 14, 2013, and on the 

Y–12 National Security Complex in 

Knoxville, Tennessee, on December 10, 

2013. 

At many DOE sites with defense 

nuclear facilities, the Board has 

observed, as cited in the attached report, 

that training on the use of emergency 

response procedures, facilities, and 

equipment is not adequate to fully 

prepare facility personnel and members 

of the emergency response organization. 

Similarly, drill programs are not 

adequately developed and implemented 

to augment this training. 

As part of their preparedness for 

emergencies, DOE sites with defense 

nuclear facilities have emergency 

response facilities such as Emergency 

Operations Centers and firehouses, and 

associated support equipment. The 

Board has observed that some 

emergency response facilities at DOE 

sites with defense nuclear facilities will 

not survive all potential accidents and 

natural phenomena events and, 

consequently, will be unable to perform 

their vital function of coordinating 

emergency response. As discussed in 

the attached report, many of these 

facilities will not be habitable during 

radiological or hazardous material 

releases. Equipment that is used to 

support operations of these facilities is 

frequently poorly maintained and may 

not be reliable during an emergency. 

The Board has also observed problems 

with DOE efforts to demonstrate the 

effectiveness of its planning and 

preparation for emergencies and its 

response capabilities. Exercises are used 

to demonstrate a site’s capability to 

respond, and assessments are used to 

verify adequacy of planning and 

preparedness. As discussed in the 

attached report, exercises conducted at 

many DOE sites with defense nuclear 

facilities do not adequately encompass 

the scope of potential scenarios (i.e., 

various hazards and accidents) that 

responders may encounter. Some sites 

do not conduct exercises frequently 

enough or do not develop challenging 

scenarios. Many sites are not effective at 

critiquing their performance, developing 

corrective actions that address 

identified problems, and measuring the 

effectiveness of these corrective actions. 

DOE oversight is a mechanism for 

continuous improvement and is used to 

verify the adequacy of emergency 

preparedness and response capabilities 

at its sites with defense nuclear 

facilities. As cited in the attached 

report, the Board has observed that 

many DOE line oversight assessments 

are incomplete and ineffective, and do 

not address the effectiveness of 

contractor corrective actions. In 

addition, the Board has noted that the 

current scope of DOE independent 

oversight is not adequate to identify 

needed improvements and to ensure 

effectiveness of federal and contractor 

corrective actions. 

As observed recently with the 

emergency responses to the truck fire 

and radioactive material release events 

at WIPP, there can be fundamental 

problems with a site’s emergency 

preparedness and response capability 

that will only be identified by more 

comprehensive assessments that address 

the overall effectiveness of a site’s 

emergency management program. For 

example, emergencies can occur during 

off-shift hours, such as the radioactive 

material release event at WIPP that 

happened at approximately 11:00 p.m. 

on Friday, February 14, 2014. Overall 

effectiveness was the scope of DOE’s 

independent assessments conducted 

prior to 2010. These assessments 

consistently identified problems with 

site emergency preparedness and 

response, and also sought continuous 

improvement of these programs. In 

2010, DOE independent oversight 

transitioned to assist visits and did not 

conduct independent assessments. In 

2012, DOE independent oversight 

returned to conducting independent 

assessments. However, these 

assessments are targeted reviews, 

currently only focused on the ability of 

the sites to prepare and respond to 

severe events. As a result, these 

independent assessments do not 

encompass all elements of emergency 

management programs and will not 

identify many fundamental problems. 

Causes of Problems 

Based on an evaluation of the 

problems observed with emergency 

preparedness and response at DOE sites 

with defense nuclear facilities, the most 

important underlying root causes of 

these problems are ineffective 

implementation of existing 

requirements, inadequate revision of 

requirements to address lessons learned 

and needed improvements to site 

programs, and weaknesses in DOE 

verification and validation of readiness 

of its sites with defense nuclear 

facilities. 

The Board has observed at various 

DOE sites with defense nuclear facilities 

that implementation of DOE’s 

requirements for emergency 

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Federal Register / Vol. 79, No. 184 / Tuesday, September 23, 2014 / Notices 56781 

2Lessons learned from this event that are 

applicable to DOE sites and facilities were 

discussed by DOE during its June 2011 Nuclear 

Safety Workshop and published in its August 16, 

2011 report, A Report to the Secretary of Energy: 

Review of Requirements and Capabilities for 

Analyzing and Responding to BDBEs, and its 

January 2013 report, A Report to the Secretary of 

Energy: Beyond Design Basis Event Pilot 

Evaluations, Results and Recommendations for 

Improvements to Enhance Nuclear Safety at DOE 

Nuclear Facilities. 

1Severe events include design basis and beyond 

design basis events. They also include operational 

and natural phenomena events. 

preparedness and response programs 

varies widely. Therefore, the Board 

concluded that some requirements do 

not have the specificity to ensure 

effective implementation. For example, 

existing requirements for hazards 

assessments lack detail on addressing 

severe events. Requirements do not 

address the reliability of emergency 

response facilities and equipment. 

Requirements for training and drills do 

not address expectations for the 

objectives, scope, frequency, and 

reviews of effectiveness of these 

programs. Requirements for exercises do 

not include expectations for the 

complexity of scenarios, scope of 

participation, and corrective actions. 

Guidance and direction that address 

many of the deficiencies in these 

requirements are included in the 

Emergency Management Guides that 

accompany DOE Order 151.1C; 

however, many sites with defense 

nuclear facilities do not implement the 

practices described in these guides. DOE 

has not updated its directive to address 

the problem with inconsistent 

implementation. In addition, DOE has 

not incorporated the lessons learned 

from the March 11, 2011, earthquake 

and tsunami at the Fukushima Dai-ichi 

Nuclear Power Plant in its directive.2

These lessons learned need to be more 

effectively integrated into DOE’s 

directive and guidance on emergency 

preparedness and response. 

The Board also observed that DOE has 

not effectively conducted oversight and 

enforcement of its existing 

requirements. DOE oversight does not 

consistently identify the needed 

improvements to site emergency 

preparedness and response called for in 

its directive. When problems are 

identified, their resolution often lacks 

adequate causal analysis and 

appropriate corrective actions. When 

corrective actions are developed and 

implemented, contractors and federal 

entities frequently do not measure the 

effectiveness of these actions. 

Conclusions 

The Board and DOE oversight entities 

have identified problems with 

implementation of emergency 

preparedness and response 

requirements at various DOE sites with 

defense nuclear facilities. The Board has 

also identified problems with specific 

emergency preparedness and response 

requirements. These deficiencies lead to 

failures to identify and prepare for the 

suite of plausible emergency scenarios 

and to demonstrate proficiency in 

emergency preparedness and response. 

Such deficiencies can ultimately result 

in the failure to recognize and respond 

appropriately to indications of an 

emergency, as was seen in the recent 

radioactive material release event at 

WIPP. Therefore, the Board believes that 

DOE has not comprehensively and 

consistently demonstrated its ability to 

adequately protect workers and the 

public in the event of an emergency. 

Recommendations 

To address the deficiencies 

summarized above, the Board 

recommends that DOE take the 

following actions: 

1. In its role as a regulator, by the end 

of 2016, standardize and improve 

implementation of its criteria and 

review approach to confirm that all sites 

with defense nuclear facilities: 

a. Have a robust emergency response 

infrastructure that is survivable, 

habitable, and maintained to function 

during emergencies, including severe 

events that can impact multiple 

facilities and potentially overwhelm 

emergency response resources. 

b. Have a training and drill program 

that ensures that emergency response 

personnel are fully competent in 

accordance with the expectations 

delineated in DOE’s directive and 

associated guidance. 

c. Are conducting exercises that fully 

demonstrate their emergency response 

is capable of responding to scenarios 

that challenge existing capability, 

including their response during severe 

events. 

d. Are identifying deficiencies with 

emergency preparedness and response, 

conducting causal analysis, developing 

and implementing effective corrective 

actions to address these deficiencies, 

and evaluating the effectiveness of these 

actions. 

e. Have an effective Readiness 

Assurance Program consistent with DOE 

Order 151.1C, Comprehensive 

Emergency Management System, 

Chapter X. 

2. Update its emergency management 

directive to address: 

a. Severe events, including 

requirements that address hazards 

assessments and exercises, and ‘‘beyond 

design basis’’ operational and natural 

phenomena events. 

b. Reliability and habitability of 

emergency response facilities and 

support equipment. 

c. Criteria for training and drills, 

including requirements that address 

facility conduct of operations drill 

programs and the interface with 

emergency response organization team 

drills. 

d. Criteria for exercises to ensure that 

they are an adequate demonstration of 

proficiency. 

e. Vulnerabilities identified during 

independent assessments. 

Peter S. Winokur, Ph.D., 

Chairman 

Recommendation 2014–1 to the 

Secretary of Energy 

Emergency Preparedness and Response 

—Findings, supporting data, and 

analysis— 

Introduction. In recent years, multiple 

high-visibility, high-consequence 

accidents have occurred. On April 20, 

2010, the Deepwater Horizon oil rig 

exploded and sank, resulting in a sea 

floor oil gusher flowing for 87 days and 

releasing about 210 million gallons of 

oil in the Gulf of Mexico. On March 11, 

2011, an earthquake and tsunami struck 

the Fukushima Dai-ichi Nuclear Power 

Plant, resulting in equipment failures, 

and a subsequent loss of coolant 

accident, nuclear meltdowns, and 

releases of radioactive materials. Both 

accidents are examples of an initial 

event that cascaded into subsequent 

events. In both cases the facility 

operators, institutional managers, and 

emergency responders were not 

adequately prepared. 

The Defense Nuclear Facilities Safety 

Board (Board) has been concerned about 

whether (1) the Department of Energy 

(DOE) has provided adequate direction 

and guidance for emergency 

preparedness and response to severe 

events 1 that could affect multiple 

facilities, lead to cascading effects, 

cause loss of necessary utilities and 

supporting infrastructure, and require 

coordination for offsite support; (2) DOE 

sites and facilities have implemented 

DOE requirements for emergency 

preparedness and response; (3) DOE, in 

its role as a regulator, has provided 

adequate oversight of site and facility 

emergency preparedness and response; 

and (4) DOE and its contractors are 

adequately trained and qualified, and 

are using drills and exercises effectively 

and as required. In general, the Board 

has been concerned about a culture of 

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56782 Federal Register / Vol. 79, No. 184 / Tuesday, September 23, 2014 / Notices 

complacency with respect to emergency 

preparedness and response. 

These concerns about the emergency 

preparedness and response capabilities 

of DOE sites have been topics during 

recent Board public meetings and 

hearings at the Savannah River Site [1], 

Los Alamos National Laboratory [2], 

Pantex Plant [3], and Y–12 National 

Security Complex (Y–12) [4]. To address 

these concerns, members of the Board’s 

staff conducted a review (1) to ensure 

DOE site emergency preparedness and 

response capabilities provide adequate 

protection of the public and workers; 

and (2) to provide feedback to DOE 

Headquarters and sites about 

improvements to complex-wide 

emergency management programs and 

site emergency preparedness and 

response. The objectives for the review 

included: 

• Assessing individual DOE site 

emergency preparedness and response 

capabilities. 

• Assessing DOE Headquarters efforts 

to provide comprehensive requirements 

and guidance, and to provide oversight 

and enforcement for conducting 

emergency management; specifically, 

recent efforts to improve site 

preparedness for severe events. 

As part of an effort to assess the 

overall ‘‘health’’ of emergency 

preparedness and response at DOE 

defense nuclear facilities, members of 

the Board’s staff conducted 

programmatic reviews at DOE’s National 

Nuclear Security Administration 

(NNSA) and Environmental 

Management sites, representing the 

various elements of the nuclear 

weapons complex (i.e., weapons design 

laboratories, production sites, and 

cleanup sites). These assessments 

included reviews of emergency 

management program documents 

(including policy documents, plans, 

hazard assessments, and procedures; 

findings and opportunities for 

improvement (OFIs) resulting from 

federal and contractor assessments; 

corrective actions to address findings 

and OFIs; exercise and drill packages, 

with their associated after-action 

reports; etc.); onsite programmatic 

reviews; reviews conducted using video 

conferencing facilities; reviews to follow 

up on the results of previous reviews; 

and observation of drills and exercises. 

In addition to reviewing emergency 

preparedness and response in general, 

the staff reviews also addressed the 

ability to prepare and respond to severe 

events (e.g., events that can affect 

multiple facilities, can cascade into 

additional events, and can overwhelm 

site resources). 

Historical Background. The Board has 

had a long-standing interest in the state 

of emergency preparedness and 

response at DOE sites that predates 

Deepwater Horizon and Fukushima. In 

the late 1990s, the Board issued a 

Technical Report [5] and a 

Recommendation [6] that led to 

improvements in emergency 

preparedness and response. However, 

the Board observed in the past several 

years that the momentum for 

continuous improvement has faded and 

that some sites have lost ground, failing 

to institutionalize improvements they 

had begun. The following section 

summarizes the Board’s earlier 

engagement in improving emergency 

preparedness and response at DOE sites, 

and the fate of the resulting 

improvements. 

DNFSB Technical Report—In March 

1999, the Board published Technical 

Report-21, Status of Emergency 

Management at Defense Nuclear 

Facilities of the Department of Energy. 

The reviews documented in that report 

were based on objective evaluation 

guidance promulgated by both DOE [7] 

and the Federal Emergency Management 

Agency [8]. Although the evaluations 

were based on observations at several 

facilities with widely diverse missions 

and operating characteristics, and the 

observations were made over an 

extended time, there were a number of 

observations that recurred. The 

following bulleted list is a direct quote 

of the Board’s general conclusions 

regarding the status of emergency 

management in a DOE-wide context: 

• Top-level requirements and 

guidance for DOE and contractor 

organizations involved in emergency 

management functions are well founded 

and clearly set forth in appropriate 

documents. 

• Applicable requirements and 

guidance are applied selectively. In 

some cases, noncompliance is condoned 

on the basis of a faulty conclusion— 

either that a requirement ‘‘doesn’t apply 

here,’’ or that a particular guidance 

element ‘‘isn’t mandatory.’’ 

• A potentially serious problem exists 

at the DOE level, involving apparent 

misperceptions and questionable 

interpretations regarding the division of 

responsibility for: (1) Development and 

promulgation of emergency 

management requirements and 

guidance; (2) establishment, conduct, 

and supervision of emergency 

management programs; and (3) oversight 

and evaluation of performance. 

Responsibilities are set forth clearly 

enough in DOE Order 151.1, 

Comprehensive Emergency Management 

System (dated September 25, 1995) [9], 

but implementation could be made 

more effective with better cooperation 

among senior and mid-level managers in 

programmatic and staff offices [at DOE 

Headquarters] involved with emergency 

management matters. These conflicts, 

which also exist between DOE 

Headquarters and field elements, have 

been observed in other DOE contexts as 

well. All the involved organizations 

bear some degree of responsibility for 

these problems. This matter merits 

attention at the highest levels of DOE 

management. 

• Deficiencies exist in emergency 

hazard analyses in one or more of the 

following areas: 

—Thoroughness of hazard assessments 

performed as elements of emergency 

planning at defense nuclear facilities, 

particularly in addressing all nuclear 

and nonnuclear hazards with 

potential impact on ongoing nuclear 

operations. 

—Verification and independent review 

processes used to ensure the 

completeness and accuracy of the 

parameters and analytical tools 

employed in hazard and consequence 

analyses, and identification of 

Emergency Classifications, Emergency 

Planning Zones, and Protective 

Action Recommendations. 

—Integration of emergency hazard 

assessments with related 

authorization basis activities for 

identification and implementation of 

the controls necessary for effective 

accident response. 

• In general, consequence assessment 

is weak all across the DOE complex. 

Observations have included use of 

inapplicable computational models and/ 

or software that is limited with regard 

to the hazards and accident scenarios 

that can be simulated. There are too few 

qualified responders assigned to execute 

sophisticated computer modeling 

programs for downwind plots of likely 

radiation levels and/or contamination; 

at some sites this responsibility is 

vested in a single individual. 

• At some sites and facilities, 

Emergency Action Levels are 

insufficiently developed and poorly 

implemented. Response procedures 

occasionally fail to address reasonably 

postulated incidents that could lead to 

an operational emergency, sometimes 

because hazard assessments were not 

sufficiently comprehensive or 

penetrating. In some cases, initiating 

conditions have not been recognized in 

sufficient detail to permit timely 

initiation of the appropriate emergency 

action. 

• Responders are slow to classify 

emergencies and to disseminate 

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2HSS was recently reorganized into two new 

offices, the Office of Independent Enterprise 

Assessments and the Office of Environment, Health, 

Safety and Security; however, the rest of this paper 

will reference HSS since that was its designation 

when the reviews referenced in this paper were 

conducted. Also note that the Office of Emergency 

Management Oversight, which subsequently 

became part of the Office of Safety and Emergency 

Evaluations, has become the Office of Emergency 

Management Assessments and is located in the 

Office of Independent Enterprise Assessments as 

part of this reorganization. 

appropriate Protective Action 

Recommendations, both in drills and 

exercises, and in actual events. In some 

cases, recommended actions have been 

inconsistent with the prevailing 

conditions; in others, communication of 

the recommendations has been confused 

and unclear, leading either to failure to 

implement suitable protective measures 

or to implementation of unnecessary 

measures. 

• Members of emergency response 

organizations whose emergency 

response duties are in addition to their 

routine day-to-day responsibilities are 

generally provided only minimal 

training regarding the infrastructure, 

equipment, and procedures involved in 

emergency response. Most of the 

training they do receive is imparted on 

the job during periodic drills and 

exercises; little formal classroom 

training or one-on-one tutoring is 

conducted for this group of responders. 

• Tracking of the resolution of 

weaknesses disclosed during drills and 

exercises, as well as those experienced 

during actual emergencies, is poor. 

Closure of these issues is, at best, 

informal, with almost no attention from 

senior DOE managers. As a result, many 

weaknesses do not get satisfactorily 

resolved, and repetition tends to ingrain 

them groundlessly as inevitable 

characteristics of emergency response 

that cannot be corrected. 

DNFSB Recommendation 98–1—On 

September 28, 1998, the Board issued 

Recommendation 98–1, Resolution of 

Issues Identified by Department of 

Energy (DOE) Internal Oversight [6]. 

Under this recommendation, the Board 

cited the need to establish a clear, 

comprehensive, and systematic process 

to address and effectively resolve the 

environment, safety, and health issues 

identified by independent oversight 

during the conduct of assessment 

activities. As a result, DOE established 

a disciplined process, clarifying roles 

and responsibilities for the 

identification of, and response to, safety 

issues; established clearer direction on 

elevating any disputed issues for 

resolution to the Office of the Secretary, 

if necessary; and established a tracking 

and reporting system to effectively 

manage completion of corrective 

actions, known as the ‘‘Corrective 

Actions Tracking System.’’ 

DOE sent the Implementation Plan 

[10] for Recommendation 98–1 to the 

Board, which accepted the 

Implementation Plan in March 1999. As 

part of its implementation of this plan, 

DOE developed corrective actions to 

address the issues identified in 

Technical Report-21 and during DOE’s 

assessments of emergency management 

programs. DOE used these corrective 

actions as case studies to demonstrate 

execution of its Implementation Plan. 

Initially, the Corrective Actions 

Tracking System addressed only 

emergency management issues. 

Evolution of DOE Oversight—After 

DOE identified serious problems in its 

security practices, the Secretary of 

Energy created the Office of 

Independent Oversight and Performance 

Assurance in early 1999 to consolidate 

security-related Department-wide 

independent oversight into a single 

office reporting directly to the Office of 

the Secretary of Energy. As a result of 

significant concerns with emergency 

management programs throughout the 

DOE complex, DOE created the Office of 

Emergency Management Oversight 

within the new organization. DOE 

incorporated the Office of Independent 

Oversight (which included the Office of 

Emergency Management Oversight) into 

the new Office of Security and Safety 

Performance Assurance in 2004, and 

then into the Office of Health, Safety 

and Security in 2006. The Office of 

Emergency Management Oversight 

began conducting oversight inspections 

in 2000. 

The Office of Emergency Management 

Oversight conducted evaluations of the 

emergency management programs at 

DOE’s sites about every three years, in 

accordance with DOE Order 470.2A, 

Security and Emergency Management 

Independent Oversight and Performance 

Assurance Program [11], and DOE Order 

470.2B, Independent Oversight and 

Performance Assurance Program [12]. 

Initially, the evaluations focused on 

critical planning and preparedness of 

sites to classify the severity of 

emergency conditions and to initiate 

appropriate protective actions. The 

evaluations addressed the identification 

and analysis of hazards, consequence 

analysis, emergency action levels used 

to determine the classification of an 

emergency, and protective actions for 

the workers and public. The evaluations 

included limited scope performance 

tests to demonstrate effectiveness of the 

emergency response organization to 

execute these essential response actions. 

As the Office of Emergency Management 

Oversight observed improvement with 

the ability to determine and implement 

protective actions, it iteratively 

expanded the scope of the evaluations 

to include other elements of emergency 

preparedness, such as the adequacy of 

plans, procedures, emergency response 

organization, training, drill and exercise 

programs, and readiness assurance. 

The Office of Emergency Management 

Oversight documented the results of the 

evaluations, reviewed corrective action 

plans, and then followed up with an 

evaluation of the effectiveness of the 

corrective actions in the next year. The 

oversight resulted in progressive 

improvement in the emergency 

management programs at the DOE sites. 

The Board’s staff limited its oversight of 

DOE’s emergency management 

programs as a result of the rigor and 

effectiveness of the Office of Emergency 

Management Oversight. 

In 2009, in compliance with the new 

vision for the Office of Health, Safety 

and Security (HSS) [13], the Office of 

Emergency Management Oversight 

focused on assisting DOE line 

management with solving problems in 

the area of emergency management, 

versus independent oversight.2 In short, 

this focus included: 

• Providing mission support activities 

only at the request of DOE line 

managers. 

• Defining activities in a collaborative 

fashion with cognizant site and 

Headquarters managers and staff, 

tailoring the activities to best meet 

identified needs. 

• Developing mission support activity 

reports and similar products that have 

been specifically designed to provide 

the information requested by line 

management, and that do not include 

ratings or findings. 

In addition to moving from an 

independent oversight mode to an assist 

mode, the Office of Emergency 

Management Oversight no longer 

tracked corrective actions. 

DOE began to consider its 

preparedness for beyond design basis 

accidents after the 2011 Fukushima 

accident. As a result, evaluation of 

emergency preparedness and response 

at DOE’s sites and facilities received 

attention again. However, DOE limited 

its reviews to evaluations of severe 

events. 

DOE Response to Fukushima—In 

response to the March 11, 2011, 

earthquake and tsunami at the 

Fukushima Dai-ichi nuclear power 

plant, the Secretary of Energy issued a 

safety bulletin, Events Beyond Design 

Safety Basis Analysis, on March 23, 

2011 [14]. This safety bulletin identified 

actions ‘‘to evaluate facility 

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vulnerabilities to beyond design basis 

events at [DOE] nuclear facilities and to 

ensure appropriate provisions are in 

place to address them.’’ The safety 

bulletin directed that these actions were 

to be completed for Hazard Category 1 

nuclear facilities by April 14, 2011, and 

for Hazard Category 2 nuclear facilities 

by May 13, 2011. 

During June 6–7, 2011, DOE held a 

two-day workshop addressing 

preliminary lessons learned from 

Fukushima. This workshop included 

presentations from representatives of 

government agencies and private 

industry, plus breakout sessions to 

identify vulnerabilities associated with 

beyond design basis events, natural 

phenomena hazards, emergency 

management, and actions to address 

these vulnerabilities. Results from this 

workshop and the responses to the 

Secretary of Energy’s safety bulletin 

were published by DOE in the August 

2011 Nuclear Safety Workshop Report, 

Review of Requirements and 

Capabilities for Analyzing and 

Responding to BDBEs [15]. This report 

identified recommendations for nearterm and long-term actions to improve 

DOE’s nuclear safety. A September 16, 

2011, memorandum [16] from the 

Deputy Secretary ‘‘directed the Office of 

Health, Safety and Security (HSS) to 

work with DOE’s Nuclear Safety and 

Security Coordinating Council, and the 

Program and Field Offices of both DOE 

and the National Nuclear Security 

Administration, to develop a strategy to 

implement the recommended actions 

and report back to [the Deputy 

Secretary] by the end of September 

2011.’’ The memorandum also stated 

that the Deputy Secretary ‘‘expect[ed] 

all short-term actions identified in 

section 8.1 of the attached report [to] be 

completed by March 31, 2012, and all 

recommendations to be completed by 

December 31, 2012.’’ 

HSS issued an implementation 

strategy, Strategy for Implementing 

Beyond Design Basis Event Report 

Recommendation, in February 2012 

[17]. The implementation strategy 

addressed all the recommendations in 

the August 2011 Workshop Report and 

proposed that guidance and criteria be 

piloted at several nuclear facilities prior 

to revising safety basis and emergency 

management directives. HSS conducted 

pilot studies at the High Flux Isotope 

Reactor at the Oak Ridge National 

Laboratory, the Waste Encapsulation 

Storage Facility (WESF) at the Hanford 

Site, the H-Area Tank Farms at the 

Savannah River Site, and the Tritium 

Facility at the Savannah River Site [18, 

19]. 

One of the recommendations in the 

August 2011 Nuclear Safety Workshop 

Report was to update the emergency 

management directives by December 

2012 with a focus on incorporating 

requirements and guidance for 

addressing severe accidents. The DOE 

Office of Emergency Operations, which 

is responsible for the development and 

maintenance of DOE requirements for 

emergency preparedness and response 

at its sites, developed draft guidance for 

planning and preparing for severe 

events as part of its response to lessons 

learned from Fukushima; however, it 

has not been able to incorporate this 

guidance in the emergency management 

directives. To date, none of these 

directives have been updated to reflect 

the lessons learned from the earthquake 

and tsunami at the Fukushima Dai-ichi 

nuclear power plant. In fact, the Office 

of Emergency Operations has not been 

able to update either the emergency 

management order (last revised in 2005) 

or the supporting guides (last revised in 

2007) as part of its normal update and 

revision cycle. The Operating 

Experience Level 1 Document, 

Improving Department of Energy 

Capabilities for Mitigating Beyond 

Design Basis Events (OE–1), issued in 

April 2013 [20] does contain a summary 

of this guidance, but it does not drive 

action to implement this guidance. 

Review Approach. To address the 

Board’s objectives, members of the 

Board’s staff developed three questions 

that formed the foundation of its review 

of the state of emergency preparedness 

and response at DOE defense nuclear 

facilities: 

1. Does DOE provide facility workers, 

response personnel, and emergency 

management decision makers with 

adequate direction and guidance to 

make timely, conservative emergency 

response decisions and take actions that 

focus on protection of the public and 

workers? 

2. Does DOE provide adequate 

equipment and hardened facilities that 

enable emergency response personnel 

and emergency management decision 

makers to effectively respond to 

emergencies and protect the public and 

workers? 

3. Do the contractor assurance 

systems and DOE oversight provide an 

effective performance assurance 

evaluation of emergency preparedness 

and response? 

The staff review was supplemented by 

reviews of relevant DOE independent 

oversight assessments. Members of the 

Board’s staff also made observations 

regarding the ability of various site 

emergency management programs to 

address severe events, and included 

observations of the response to the truck 

fire and radioactive material release 

events at the Waste Isolation Pilot Plant 

(WIPP). 

Observations. The following sections 

discuss observations made by members 

of the Board’s staff as part of their 

review. Although the staff team made 

observations in numerous areas of 

emergency preparedness and response, 

the following sections address staff team 

observations that will have the most 

impact on improvements to emergency 

preparedness and response at DOE sites. 

The Technical Planning Documents, 

Training and Drills, and Exercises 

sections address the first review 

question. The Facilities and Equipment 

section addresses the second question. 

The Oversight and Assessments section 

addresses the third question. Some 

observations reflect problems with 

emergency management program 

requirements and guidance, including 

observations addressing: Problems with 

specific requirements, problems with 

implementation of guidance, and 

problems with oversight and 

enforcement of compliance with these 

requirements. 

Technical Planning Documents— 

Planning is a key element in developing 

and maintaining effective emergency 

preparedness and response. As required 

by DOE Order 151.1C [21], ‘‘emergency 

planning must include identification 

and analysis of hazards and threats, 

hazard mitigation, development and 

preparation of emergency plans and 

procedures, and identification of 

personnel and resources needed for an 

effective response.’’ DOE Guide 151.1– 

2, Technical Planning Basis [22], 

provides further clarification, 

highlighting in section 2.1 the need to 

document the technical planning basis 

used to determine ‘‘the necessary plans/ 

procedures, personnel, resources, 

equipment, and analyses [e.g., 

determination of an Emergency 

Planning Zone] that comprise’’ an 

emergency management program. 

Hazard Assessments: Development of 

planning documents begins with 

identification and analysis of hazards 

and threats, which is then followed by 

the development of actions to mitigate 

the effects of these hazards and threats 

during an emergency. The Board’s staff 

team observed that the quality of these 

documents varied widely among the 

DOE sites, also varying among 

contractors at a site. Specifically, the 

staff team observed that hazards 

assessments at many DOE sites do not 

address all the hazards and potential 

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3An EPHA does not have to analyze all the 

scenarios, but it does have to identify all possible 

initiating events and their impacts and analyze the 

results of all potential impacts (such as breaching 

a confinement barrier or causing an explosion or 

fire). 

4Although the SNL EALs do consider different 

quantities of material at risk for various activities, 

they represent the maximum quantities that could 

be used for those activities and thus do not consider 

the use of lesser quantities. 

5For example, in the Weapons Engineering 

Tritium Facility (WETF) and Chemistry & 

Metallurgy Research Facility EPHAs [34, 35], the 

material at risk (MAR) for each scenario is the 

bounding limit in the technical safety requirements. 

As a result, none of WETF EALs are less than 

general emergencies when the ventilation is not 

intact and none of the Chemistry & Metallurgy 

Research EALs are less than a site area emergency. 

6 If the hazard from an emergency is an internal 

exposure hazard, then sheltering-in-place would be 

appropriate; however, if the release leads to an 

external exposure hazard, then sheltering-in-place 

may not be acceptable and it may be important to 

evacuate personnel as soon as possible. Similarly, 

if the release is of short duration, sheltering-inplace may be appropriate; whereas, a long duration 

release with significant consequences might require 

early evacuation. 

7For example, the LANL protective action guide 

only addresses sheltering as a ‘‘strategy to reduce 

exposure to airborne materials.’’ 

accident scenarios,3 contain incomplete 

consequence analyses, do not develop 

the emergency actions levels (EALs) for 

recognizing indications and the severity 

of an emergency, and contain incorrect 

emergency planning zones. In addition, 

a few sites limited their hazards 

assessments to the bounding analysis in 

their documented safety analysis; as a 

result, the hazard assessments do not 

address less severe events warranting 

protective actions for the workforce, and 

do not address beyond design basis 

accidents. 

For example, during its 2013 review 

of the emergency planning hazard 

assessments (EPHAs) for facilities at the 

Sandia National Laboratories (SNL) in 

New Mexico, the Board’s staff team 

found that the EPHAs were incomplete. 

The EPHAs for SNL defense nuclear 

facilities included input parameters for 

consequence analyses, but did not 

include documentation of the 

calculation or the results [23–25]. 

Further, the SNL EPHAs did not 

document the derivation of, or basis for, 

the EALs [23–25]. The EPHA for the 

Pantex Plant did not address flooding as 

a potential operational emergency, even 

though flooding occurred on July 7, 

2010 [26–29]. The emergency 

responders for the radioactive material 

release at WIPP were unable to classify 

the event to identify needed protective 

actions because the hazard assessment 

did not evaluate a radiological release 

when the mine was unoccupied or 

when operations underground were not 

ongoing [30]. Although some sites have 

addressed natural phenomena events in 

their EPHAs, others have not. Overall, 

the sites do not address ‘‘severe’’ events 

that would affect multiple facilities or 

regional areas. 

Emergency Action Levels: During its 

review of EALs for various sites, 

members of the Board’s staff found that 

EALs and protective actions in the 

EPHAs for defense nuclear facilities 

were often based only on the worst case 

design basis accidents and were too 

generic to be effective. When decision 

makers know that the release is less 

severe than the worst case accident, 

they may be reluctant to implement 

conservative protective actions, 

particularly those that involve the 

public. Therefore, it is important to 

analyze less severe accidents so that less 

extreme responses can be developed for 

use by decision makers. EALs were 

often event-based rather than conditionbased (i.e., based on observable criteria 

or triggers). As a result, emergency 

response personnel would not be able to 

identify emergency conditions of 

various degrees of severity and, 

therefore, would not be able to select 

appropriate protective actions. In 

addition, many of the EPHAs did not 

contain specific observable criteria or 

triggers to determine the severity of a 

radiological or hazardous material 

release when a release is occurring. 

For example, the EALs for SNL were 

based on ‘‘worst case events’’ 4 and were 

event-based only [23, 24, 25, 30]. As a 

result, emergency response personnel 

would be unable to classify emergencies 

at different degrees of severity (Alert, 

Site Area Emergency, and General 

Emergency), determine the required 

response, and determine the needed 

protective actions for the workers and 

public. The EALs lacked observable 

criteria or triggers such as stack monitor 

readings, the quantity of material 

involved, the degree that containment or 

confinement is compromised, and 

whether ventilation is operating. This 

failure to include measurable triggers in 

EALs was also observed by HSS in 

oversight reviews at other sites such as 

the Hanford Site [31]. 

In contrast, the staff observed that the 

WIPP EALs reference conditions, but 

only after observing an event (such as a 

vehicle accident or a fire on a vehicle). 

Thus, if a condition occurs that is not 

associated with an observable event that 

was analyzed in the EPHA (such as 

occurred during the February 14, 2014, 

radioactive material release), emergency 

response personnel would be unable to 

categorize and classify the event, and 

then implement appropriate protective 

actions [29, 32]. 

Similarly, members of the Board’s 

staff observed a wide variety of 

problems with EALs at other DOE sites. 

For example, at the Pantex Plant, EALs 

were predominantly event-based [33]. 

At Los Alamos National Laboratory 

(LANL), some EALs were based on 

bounding conditions similar to those in 

the documented safety analysis, and 

would not lead to the initiation of 

protective actions for accidents of a 

lesser degree [34, 35]; while EALs that 

were condition-based assume that 

personnel are at work in the facility to 

observe the indicators [36].5 Similarly, 

at Lawrence Livermore National 

Laboratory (LLNL), EALs were also 

event-based [37–39]. Some use 

indicators that were limited to 

consideration of the initiating event and 

did not consider the results of the event 

or the follow-on indicators (e.g., a 

confinement barrier is defeated, alarms 

are activated, and monitors indicate a 

release). 

Protective Actions: Some sites default 

to a protective action of shelter-in-place 

no matter what the emergency may be. 

The Pantex Plant [33] and Savannah 

River Site [40–45] are two sites that use 

this default protective action 

extensively.6 There are some events in 

which the potential exposures would 

require an evacuation; however, some 

sites are sheltering-in-place initially 

until they recognize that conditions 

warrant evacuations. Therefore, a 

necessary evacuation could be delayed 

and result in unnecessary exposures. 

For emergencies with the potential for 

exposures requiring evacuation, sites 

may need to consider a more timely 

conservative protective action rather 

than wait for additional direction from 

decision makers. 

Other sites do not provide sufficient 

description in their protective actions. 

Some sites implement shelter-in-place 

when the need is to take shelter in a 

structurally sound facility for a natural 

phenomenon hazard (such as an 

earthquake or tornado). Sites should 

have separate protective actions in 

response to a radioactive or hazardous 

material release versus protection from 

physical harm (e.g., falling debris, 

collapsing buildings, and missiles). 

Some sites have identified shelter (or 

take cover) and shelter-in-place (or 

remain indoors) to address these two 

categories of protective needs. This 

problem has been corrected in 

protective actions at the Savannah River 

and Hanford sites [46], but is still 

evident in protective actions at WIPP 

[32, 47] and LANL [48].7

Severe Events: During Board public 

hearings and meetings at the Savannah 

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River Site [1], LANL [2], Pantex Plant 

[3], and Y–12 [4], the Board discussed 

weaknesses in the ability of DOE sites 

to respond to severe events. In addition, 

as part of its reviews of the overall state 

of emergency preparedness and 

response at DOE sites, members of the 

Board’s staff reviewed the preparedness 

for, and the ability to respond to, severe 

events. During these reviews, the staff 

team identified weaknesses in existing 

programs, as well as elicited input from 

the sites on gaps in the existing 

requirements and guidance. Many sites 

have not completed a hazard assessment 

for severe events; particularly events 

that can affect multiple facilities and 

events that can affect a regional area [15, 

20]. As a result, they have not 

developed EALs and protective actions 

commensurate with the unique hazards 

and complexity of these events. 

Technical planning requirements are 

focused on individual facilities without 

consideration of the impact of collective 

facilities with additional and varied 

hazards. 

Specific gaps in requirements and 

guidance that were identified by the 

sites during the reviews by members of 

the Board’s staff or through the staff’s 

review of their existing programs 

include: 

• The need for clarification of the 

definition of a severe event, and the 

actions that sites are expected to take to 

prepare for such events, particularly 

addressing the question of ‘‘how much 

preparation is enough for severe 

events.’’ 

• The focus of existing requirements 

on individual facilities with no current 

direction on evaluating multi-facility 

events. 

• The need to develop a methodology 

for prioritizing response to multi-facility 

events, including the development of 

prioritization strategies for response, 

mitigation, and reentry. 

• The need to incorporate self-help 

and basic preparedness training into 

workforce refresher training. 

• The need to develop a logistical 

process for providing food, water, and 

other essentials to responders if they are 

required to stay on site for an extended 

period of time. 

Although DOE’s OE–1 highlights the 

need to incorporate some of these 

considerations in site emergency 

management programs, it does not 

provide explicit guidance on how to do 

so. 

Members of the Board’s staff also had 

the opportunity to observe pilot studies 

at WESF at the Hanford Site, and at the 

tank farms and Tritium Facility at the 

Savannah River Site. The studies were 

conducted by HSS in tandem with the 

Office of Emergency Operations to 

develop guidance on how to address 

beyond design basis events in 

documented safety analyses and how to 

address severe events in emergency 

management programs [18, 19]. One 

major gap identified by the staff team 

during its reviews, as well as by the 

pilot study group at both the Hanford 

and Savannah River sites, is related to 

the actions to be taken by facility 

personnel in the immediate aftermath of 

a severe event (i.e., actions taken by 

facility personnel that will put the 

facility into a safe and stable condition). 

Although the pilot study report, BDBE 

Pilot Evaluations, Results and 

Recommendations for Improvements to 

Enhance Nuclear Safety at DOE Nuclear 

Facilities [18], highlights this gap, it 

does not identify who will develop 

guidance to address the gap. DOE’s OE– 

1 does not mention this issue. 

In general, members of the Board’s 

staff observed problems associated with 

requirements (or lack of requirements) 

addressing severe events, specifically 

those addressing the scope of hazards 

assessments, EALs, and protective 

actions that address the complexity of 

events that could cascade or affect 

multiple facilities. The staff team also 

observed problems with identification 

and development of actions to be taken 

by workers in the immediate aftermath 

of an event and in situations where 

outside response is delayed. 

Training and Drills—With respect to 

preparation for emergencies, DOE Order 

151.1C, Chapter IV, 4.a requires that: 

A coordinated program of training 

and drills for developing and/or 

maintaining specific emergency 

response capabilities must be an integral 

part of the emergency management 

program. The program must apply to 

emergency response personnel and 

organizations that the site/facility 

expects to respond to onsite 

emergencies. 

The associated emergency 

management guide [7] contains detail on 

meeting this requirement. Members of 

the Board’s staff submitted comments 

pertaining to training requirements in 

the order and guides during the last 

order revision cycle in 2005. At the 

conclusion of the RevCom process, DOE 

personnel responded to these comments 

with a commitment to address them 

during the next revision cycle [49]. 

These comments focused on the need to 

include requirements for the 

effectiveness of training and drills, and 

for responsibilities to ensure the 

adequacy and consistency of training 

and drills. These comments were based 

on the staff team’s observation that 

implementation of training and drill 

programs was inconsistent among the 

DOE sites, and that more specificity was 

needed in the requirements. 

During its recent reviews, members of 

the Board’s staff continued to observe 

that the implementation of training and 

drill programs at DOE sites is variable; 

these programs were also addressed 

during Board public meetings and 

hearings [1, 3]. At some sites such as Y– 

12, Savannah River Site, and Hanford 

Site, the training of emergency response 

personnel is well developed and 

executed. At some sites, a task analysis 

of individual positions was completed, 

and training was developed and 

executed to address these tasks. Drills 

were scheduled to practice these tasks, 

and the basis for qualification was 

determined and confirmed. As part of 

the training program, some sites 

identified continuing training and the 

need for retraining based on feedback 

from performance on drills and 

exercises. 

However, at other sites, the quality of 

training varied significantly, sometimes 

to the point of being perfunctory and 

limited to only participation of the 

emergency response organization. Some 

sites schedule drills, but rarely perform 

them, while other sites do not have a 

drill program that meets the 

expectations of the guidance. In general, 

the training and drills conducted at 

some sites frequently do not reflect 

lessons learned and feedback from 

performance of exercises. For example, 

the Pantex Plant has a drill program, but 

conducts few of the scheduled drills. 

SNL conducts drills; however, the drills 

involving facility personnel are only 

evacuation drills and are essentially the 

equivalent of fire drills. 

The staff also observed issues with the 

training and qualification of emergency 

management program staff at various 

sites. Some sites, such as the contractors 

at Y–12, Savannah River Site, and 

Hanford Site, have established 

qualification programs for these 

personnel and hire experienced 

personnel or train personnel to fill these 

positions. Other sites, such as the 

Pantex Plant, have not established 

training qualification requirements for 

their emergency management program 

staff. 

Exercises—As part of a site’s 

preparedness for responding to 

emergencies, DOE Order 151.1C 

requires that ‘‘[a] formal exercise 

program must be established to validate 

all elements of the emergency 

management program over a five-year 

period.’’ The Order also stipulates that 

‘‘[e]ach exercise must have specific 

objectives and must be fully 

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documented (e.g., by scenario packages 

that include objectives, scope, timelines, 

injects, controller instructions, and 

evaluation criteria).’’ In addition, 

Chapter 4, 4.b(1) of the Order requires 

that: 

(a) Each DOE/NNSA facility subject to 

this chapter must exercise its emergency 

response capability annually and 

include at least facility-level evaluation 

and critique. 

(b) Site-level emergency response 

organization elements and resources 

must participate in a minimum of one 

exercise annually. This site exercise 

must be designed to test and 

demonstrate the site’s integrated 

emergency response capability. For 

multiple facility sites, the basis for the 

exercise must be rotated among 

facilities. 

This requirement to conduct exercises 

is further clarified in section 3.1 of the 

DOE Emergency Management Guide 

151.1–3, Programmatic Elements, which 

provides guidance for DOE sites to: 

* * * establish a formal exercise program 

that validates all elements of a facility/site or 

activity emergency management program 

over a 5-year period. The exercise program 

should validate both facility- and site-level 

emergency management program elements by 

initiating a response to simulated, realistic 

emergency events or conditions in a manner 

that, as nearly as possible, replicates an 

integrated emergency response to an actual 

event. 

Members of the Board’s staff reviewed 

exercise programs at various DOE sites 

as part of its programmatic reviews of 

emergency management programs, as 

well as through observations of 

exercises conducted at DOE sites. The 

staff team observed a wide variability in 

the quality of the scenarios. Some sites 

had challenging scenarios and a few 

recent site exercises involved severe 

events, including multiple facilities and 

cascading events. However, other sites 

had scenarios that were not challenging 

and did not fully test the capabilities of 

the site. Some sites do not have a 5-year 

plan for exercises that involves all of the 

hazards and accidents at their facilities 

with EPHAs. In addition, some sites do 

not exercise all of their facilities with 

EPHAs and all of their response 

elements on an annual basis. 

Exercises are intended to be a 

demonstration of performance and, 

therefore, addressing all the elements of 

emergency response on an annual basis 

is important. The staff team observed 

specific problems with planning and 

scheduling of exercises at various sites. 

Some sites, such as the Pantex Plant, 

did not conduct an annual site-wide 

exercise in 2013 [50]; while other sites, 

such as SNL, are not conducting annual 

exercises (or appropriately tailored 

drills to test emergency preparedness 

and response) for each facility that has 

an EPHA [51–53]. In addition, some of 

these sites, such as the Pantex Plant [23, 

54, 55], do not conduct exercises to 

‘‘validate all elements of an emergency 

management program over a 5-year 

period.’’ At SNL, the staff team was 

particularly concerned that emergency 

management personnel are not 

scheduling drills and exercises that 

address the different types of hazards 

and accident scenarios possible at its 

nuclear facilities. The drills and 

exercises should train and test the 

various elements of their capability for 

responding to radiological hazards and 

scenarios. In addition, the staff team 

observed that few if any of the sites have 

scheduled exercises to be conducted 

during swing and night shifts. 

As part of its observations of exercises 

and review of exercise packages, 

members of the Board’s staff observed 

several examples of exercise scenarios 

that were not challenging enough to 

demonstrate proficiency. For example, 

the 2013 annual exercise at the 

Savannah River Site [56] involved the 

drop of a 55-gallon drum of radioactive 

waste during a repackaging operation at 

the Solid Waste Management Facility. 

The exercise assumed that the dropped 

drum injured an employee and resulted 

in contamination in the immediate area 

of the drum. Similarly, the 2013 

exercise at the Pantex Plant [50], which 

was conducted in January 2014, also 

involved a simplistic scenario involving 

a liquid nitrogen truck in a vehicular 

accident. The hazardous release was 

limited and required little protective 

action to be taken by the plant 

population. In contrast to these 

simplistic scenarios, the 2013 site-wide 

exercise at the Hanford Site [57] 

involved an earthquake that led to 

problems at multiple facilities, 

including a tunnel collapse at PUREX 

and a release of contamination and a fire 

at WESF, that were compounded 

initially by problems with 

communications. 

In addition to the use of simplistic 

scenarios, another problem observed by 

the staff team was the failure of most 

sites to adequately incorporate recovery 

actions into the exercise. Due to the 

hazardous nature of operations at DOE 

sites, planning and implementing 

recovery and reentry actions will be 

extremely complex, as evidenced by the 

current recovery activities at WIPP. 

Recovery at other DOE sites could be 

more difficult due to the more 

hazardous and complex nature of 

operations at those sites. Planning and 

implementing recovery actions are 

typically not demonstrated in detail 

during the normal scope of annual 

emergency exercises at DOE sites, or in 

follow-on exercises [3, 4, 58]. For 

example, the 2013 Savannah River Site 

annual site-wide exercise demonstrated 

the importance of more fully exercising 

recovery planning. The exercise team 

did not appear to understand the level 

of detail required for developing a 

recovery plan outline and had a difficult 

time completing the outline for recovery 

planning that is included in the 

Savannah River Site emergency 

procedures [59]. 

Members of the Board’s staff also 

observed problems with the preparation 

and conduct of exercises. Problems 

associated with preparation for 

exercises have involved both the 

content and timing. Specifically, the 

staff team observed that some sites use 

identical scenarios in the drills 

preparing for exercises, and some sites 

often schedule the majority of their 

drills immediately prior (i.e., within 

days) to the exercise [60, 61]. Although 

it is appropriate to use drills to train and 

practice, these strategies can lead to a 

false impression of a site’s preparedness 

and response capability (i.e., ‘‘cramming 

for the exam’’). The graded exercise 

becomes a snapshot of proficiency 

rather than being a true representation 

of long-term proficiency. For example, 

at the Savannah River Site, the staff 

team observed that the scenarios used in 

preparation for the 2013 evaluated 

exercise for Building 235–F addressing 

concerns raised in Board 

Recommendation 2012–1 were identical 

to the scenario planned for the actual 

exercise. Based on feedback from the 

Board’s Savannah River site 

representatives, the scenario was 

changed [61]. The Board’s site 

representatives raised similar concerns 

with scenarios used to prepare for other 

exercises at the Savannah River Site, 

and this practice appears to have been 

changed. The staff team observed that at 

some sites, such as the Hanford Site, 

these preparatory drills are conducted 

immediately prior to the actual 

performance of the exercise, ensuring 

that the participants can perform 

adequately during the actual exercise, 

but not addressing the need for making 

sustained improvements in emergency 

preparedness and response capabilities 

by conducting preparation activities 

throughout the course of the year. 

As part of its observation of exercises 

at various sites, members of the Board’s 

staff had the opportunity to observe 

after-exercise critiques, as well as to 

review the after action reports for the 

exercises. During many exercises, the 

staff team observed that evaluators 

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failed to document needed 

improvements identified during the 

course of the exercise. The staff team 

also observed that the critiques were 

often not adequate to identify the 

underlying causes of problems during 

the exercise and that subsequent 

assessments and evaluations did not 

ensure the effectiveness of corrective 

actions to address these problems. One 

example of a flawed critique system was 

observed at the Pantex Plant, where the 

2011 exercise was originally graded as 

‘‘satisfactory’’ and the 2012 exercise was 

originally graded as ‘‘successful.’’ After 

Board Member questions during the 

public meeting and hearing on the 

Pantex Plant and subsequent staff 

questions, Babcock & Wilcox Technical 

Services Pantex, LLC (B&W Pantex) 

regraded the 2011 exercise as 

‘‘unsatisfactory’’ and the 2012 exercise 

as ‘‘marginal’’ [3, 62]. 

Members of the Board’s staff also 

observed that some sites incorporated 

severe event scenarios into their drill 

and exercise programs. Some sites have 

conducted exercises that include severe 

event scenarios that encompass multiple 

facilities; however, some sites such as 

the Pantex Plant and Y–12 have yet to 

do so [3, 4]. It is important to practice 

and demonstrate proficiency in 

responding to severe event scenarios 

due to the complexity of response, the 

need to prioritize limited resources, the 

need to make decisions about protective 

actions when multiple facilities are 

involved, the potential need to respond 

without the assistance of mutual aid, 

and the potential loss of infrastructure 

(e.g., power, communications, mobility). 

The current DOE directives do not 

contain requirements or expectations to 

conduct these types of challenging 

exercises. While DOE’s OE–1 contains 

guidance on the scope of severe event 

scenarios that should be conducted by 

the sites, it does not explicitly require 

that the sites conduct these types of 

exercises. 

Facilities and Equipment—DOE Order 

151.1C requires a site’s emergency 

program to address the ‘‘provision of 

facilities and equipment adequate to 

support emergency response, including 

the capability to notify employees of an 

emergency to facilitate the safe 

evacuation of employees from the work 

place, immediate work area, or both.’’ 

Facilities include an emergency 

operations center (EOC) and an 

alternate, and the Order stipulates that 

these facilities must be ‘‘available, 

operable, and maintained.’’ 

Maintenance and appropriate upgrading 

of emergency response facilities and 

equipment are an important part of 

ensuring that the emergency 

preparedness and response capabilities 

of a site are sustainable. 

Communications and notification 

systems are necessary to initiate 

protective actions and enable safe 

evacuation of employees. Chapter 4 of 

the Order requires ‘‘[p]rompt initial 

notification of workers, emergency 

response personnel, and response 

organizations, including DOE/NNSA 

elements and State, Tribal, and local 

organizations, and continuing effective 

communication among response 

organizations throughout an 

emergency.’’ 

The staff team observed some 

problems with the survivability, 

habitability, and maintenance of 

emergency response facilities and 

equipment, as well as communications 

and notification systems [63, 64] that 

the staff believes are due to the lack of 

explicit requirements or expectations in 

the DOE Order and Guides. Specifically, 

members of the Board’s staff observed 

that many of the emergency response 

facilities may not be habitable in the 

aftermath of a hazardous or radiological 

material release event, or survivable in 

the aftermath of a severe natural 

phenomena event. These facilities were 

not designed to survive an earthquake, 

and many do not have ventilation 

systems that will filter radiological and 

toxicological materials. Examples of 

such facilities include the Emergency 

Control Center (ECC), the Technical 

Support Center (TSC), and the fire 

house at Y–12 [4, 66]; the EOC at the 

Hanford Site [67]; the EOC and alternate 

EOC, the Department Operations 

Centers, and the Emergency 

Communications Center at LLNL [68]; 

and the EOC and Central Monitoring 

Room at WIPP [69]. 

Some facilities were designed with 

filtered air systems that would enable 

them to remain habitable in the event of 

a hazardous release in proximity to the 

facility. However, members of the 

Board’s staff observed that some of these 

systems were not being properly 

maintained [63, 64, 68–71]. Habitability 

of these facilities could also be 

compromised by failures of their 

emergency backup systems. Many of the 

facilities have backup systems that are 

general service and do not have a 

pedigree for an expectation of 

reliability. In general, the staff team 

observed problems with the lack of 

established maintenance programs for 

these facilities and support equipment, 

such as backup generators and fuel 

tanks [63, 64, 67–69, 71]. It should be 

noted that some of these facilities are 

scheduled to be replaced. For example, 

Babcock and Wilcox Technical Services 

Y–12, LLC (B&W Y–12) has a new 

project planned to replace the ECC and 

the TSC, with funding beginning in 

fiscal year 2015 and project completion 

scheduled in fiscal year 2017, and B&W 

Y–12 is preparing for Critical Decision– 

0 for a new fire house [4]. Similarly, 

there are plans to replace the LLNL 

EOC. 

Members of the Board’s staff also 

observed problems with systems used to 

support emergency communications 

and notifications. For example, the staff 

observed problems with the systems 

used to notify workers and visitors 

about an emergency and protective 

actions that are to be taken, such as was 

observed recently at WIPP during the 

underground truck fire [72]. Some 

systems have experienced failures to 

broadcast due to failures of sirens, 

overriding signals, and incomplete 

coverage, or have provided workers 

with garbled messages [73–78]. The staff 

team also observed potential problems 

with the method by which remote 

workers, such as those at the Hanford 

Site, are notified of emergencies via 

portable alerting systems, and the 

process by which they are refreshed on 

hazards and responses (e.g., pre-job 

briefings). 

In addition to the vulnerabilities of 

some of these facilities during an 

emergency, the Board’s staff team also 

observed, based on its review of site 

exercise schedules across DOE sites, 

that alternate emergency response 

facilities were not being exercised on a 

periodic basis. In general, many of the 

alternate response facilities have 

limited, older, less-effective 

communications systems and support 

equipment, which could dramatically 

hamper on-site emergency response. 

Their locations are sometimes so close 

to the primary facilities that they will 

suffer the same habitability problems. 

Conversely, sometimes they are so 

distant that it will be difficult for 

personnel to travel to the alternate 

facilities. Therefore, it is important for 

emergency response personnel to 

practice using the less-effective 

equipment and understand the 

challenges of using alternate facilities. 

Oversight and Assessment—As part of 

its readiness assurance requirements, 

DOE Order 151.1C stipulates the need 

for assessments of emergency 

management programs and capabilities 

by the contractor and oversight of these 

programs and capabilities by DOE 

program and field (site) offices. 

Additionally, in the general 

requirements sections of the Order, the 

HSS Office of Security and Safety 

Performance is tasked with 

responsibility for independent oversight 

of emergency management programs at 

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8The Office of Independent Enterprise 

Assessments now has this responsibility. See 

Footnote 2. 9The Office of Emergency Management 

Assessments now has this responsibility. See 

Footnote 2. 

DOE sites.8 Members of the Board’s staff 

have observed problems with oversight 

of emergency management programs 

overseen by DOE Headquarters and site 

office personnel, and with assessments 

and self-assessments conducted by the 

contractors. These failures are 

contributing to the problems with the 

emergency management programs at the 

various sites that have been observed by 

the staff team, particularly problems 

that are long-standing or recurrent. 

Federal Independent Oversight: The 

Office of Safety and Emergency 

Management Evaluations in HSS was 

responsible for oversight of emergency 

management programs at DOE sites.9

The Office of Emergency Operations is 

responsible for the development and 

maintenance of emergency management 

requirements for programs at all DOE 

sites, and is also responsible for 

providing interpretations of these 

requirements. The Office of Emergency 

Operations also has responsibility for 

NNSA emergency management 

programmatic support to NNSA sites. 

The Office of Emergency Operations 

does not conduct assessments of 

emergency management programs at 

DOE (or NNSA) sites. However, when 

requested, it provides assistance to sites 

and subject matter experts to support 

reviews, such as readiness reviews and 

biennial reviews by the NNSA Chief of 

Defense Nuclear Safety (CDNS). 

After operating in an assistance mode 

since 2010, HSS returned in 2012 to 

conducting independent assessments. 

These assessments are targeted reviews, 

currently focused on the ability of the 

sites to prepare and respond to severe 

events, and do not encompass all 

elements of emergency management 

programs. In 2012, HSS focused on five 

elements (Emergency Response 

Organization, Equipment and Facilities, 

Technical Planning Basis, EPHAs, and 

Off-site Interfaces) for severe event 

preparedness in its reviews at five sites 

and one facility (Y–12 [70], LANL [71], 

Idaho National Laboratory [79], WIPP 

[69], Paducah Gaseous Diffusion Plant 

[80], and the Tritium Facilities at the 

Savannah River Site [81]). In 2013, HSS 

focused on three new elements, while 

retaining three elements from its 2012 

reviews (Off-site Interfaces, Equipment 

and Facilities, EPHAs, Medical 

Response, Training and Drills, and 

Termination and Recovery) at four sites 

(LLNL [68], Portsmouth Gaseous 

Diffusion Plant [82], Hanford Site [67], 

and the Nevada National Security Site 

(NNSS) [83]). After each of its reviews, 

HSS produced a document summarizing 

the results of the review and identifying 

findings and OFIs. HSS also issues a 

year-end report that highlights common 

issues, lessons learned, and 

recommended actions [63, 64]. Unlike 

the independent assessments conducted 

previously in the 2000–2009 timeframe, 

adjudication of findings is left to site 

offices. HSS does not review corrective 

actions or their effectiveness, although it 

may review the resolution of findings 

from previous assessments as part of its 

follow-up review. 

As part of its review of the efficacy of 

federal oversight, members of the 

Board’s staff reviewed the reports issued 

by HSS in 2012 and 2013, and observed 

its targeted assessments at LLNL, 

Hanford Site, and NNSS conducted in 

2013. The staff team observed that these 

assessments were effective in 

identifying issues associated with a 

site’s preparedness to respond to severe 

events. The HSS assessment team does 

not assess the site’s capability to 

respond to less severe events that are 

more likely to occur. Although the 

assessment team does identify 

fundamental program weaknesses as 

part of its assessment, it does not 

document these weaknesses. As a result, 

the assessments do not evaluate the 

overall effectiveness of a site’s 

emergency preparedness and response 

capability. As observed recently with 

the emergency responses to the truck 

fire and radioactive release events at 

WIPP, there can be fundamental 

problems with a site’s emergency 

preparedness and response capability 

that will only be identified by more 

comprehensive assessments designed to 

evaluate the overall effectiveness of a 

site’s emergency management program. 

Independent assessments conducted 

prior to 2010 focused on overall 

effectiveness. These assessments 

consistently identified problems with 

site emergency preparedness and 

response, and HSS sought to ensure 

continuous improvement of these 

programs by conducting follow up 

assessments. 

The HSS targeted assessments did not 

include an observation of drills or 

exercises. Drills and exercises are 

representative of a site’s broader 

response capability. While the HSS 

team observed a drill during its 

assessment at LLNL, this exercise was 

outside the scope of the assessment and 

was not incorporated into the potential 

findings and OFIs of their report. During 

2014, HSS is observing severe event 

exercises as part of its assessments. 

Members of the Board’s staff found 

that many of the HSS findings from its 

independent assessments conducted 

prior to 2010, as well as findings from 

the HSS targeted assessments, were not 

effectively addressed. Specifically, 

based on its review of numerous federal 

and contractor assessments and 

associated corrective action plans, the 

staff team found that many of the 

corrective actions did not adequately 

address the specifics of the findings or 

did not result in long-term resolution of 

the issue. In many cases, there was not 

adequate causal analysis and there was 

no review of the effectiveness of the 

corrective actions. As a result, findings 

have gone uncorrected, sometimes for 

many years, and are found again in 

subsequent assessments. 

For example, members of the Board’s 

staff reviewed the 2009 HSS report [30] 

as part of the staff’s 2013 assessment at 

SNL. Several of the findings in the 

report addressed the inability of 

emergency response personnel to 

effectively use emergency plans and 

procedures to implement protective 

actions. In addition, as part of their 

discussions of program weaknesses and 

items requiring attention, the HSS 

assessors identified problems with using 

EALs due to their complexity and the 

overly conservative nature of the 

protective actions. The staff team 

reviewed the EALs [23–25] and 

protective actions [84–97], as well as 

other technical planning documents 

such as EPHAs [23–25]. The staff team 

found them to be of poor quality and 

difficult to implement. When the staff 

team discussed the HSS findings with 

Sandia Field Office and SNL emergency 

management personnel, the SNL 

personnel indicated that they developed 

corrective actions to address the 

findings in the HSS report and all 

corrective actions had been completed. 

However, based on its 2013 assessment, 

the staff team found that the original 

problems identified by HSS still existed. 

SNL did not address the implications of 

the systemic program weaknesses 

identified by HSS regarding the entire 

suite of SNL technical planning 

documents, not just EALs. Thus, the 

original findings identified by HSS were 

not effectively addressed by SNL. 

Similarly, during the HSS targeted 

assessment conducted at the Hanford 

Site in 2013 that was observed by 

members of the Board’s staff, HSS team 

members noted that the same issues had 

been identified during the team’s assist 

visit to the Hanford Site in 2010 [67]. 

HSS team members also noted that 

recommendations from the 2010 visit 

had been entered and closed in the site’s 

corrective active tracking system but 

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56790 Federal Register / Vol. 79, No. 184 / Tuesday, September 23, 2014 / Notices 

were observed again during the 2013 

assessment. 

Federal Line Oversight: In addition to 

oversight conducted by DOE 

Headquarters personnel, members of the 

Board’s staff also reviewed oversight by 

site office personnel of contractor 

emergency management programs. The 

scope of this review included numerous 

federal assessment reports and 

associated contractor corrective action 

plans. The level and type of oversight 

conducted by site office personnel 

varied widely across DOE sites. At some 

sites, the federal employee responsible 

for emergency management did not have 

any other responsibilities; at other sites, 

such as Y–12, emergency management 

was a collateral duty. At some sites, this 

position rotated frequently and there 

was a long period of time before the 

individual responsible for oversight of 

the contractor’s emergency management 

program was qualified as an emergency 

management specialist per the DOE 

qualification standard [98, 99]. 

The type of oversight conducted by 

site office personnel varied widely, 

ranging from independent assessments 

to shadow assessments of contractor 

reviews to reviews of data provided by 

contractor assurance systems. Sole 

reliance on data provided by the 

contractor assurance system without 

confirmatory independent reviews can 

be problematic. For example, the Y–12 

emergency management program 

manager relied heavily on the results of 

B&W Y–12 management selfassessments of its emergency 

management program against the 15 

assessment criteria suggested by the 

DOE Emergency Management guides, 

with the exception of direct observation 

of Y–12 exercises by the program 

manager, assisted by other personnel. 

Although the general health of the Y–12 

emergency management program 

appeared to be consistent with DOE 

requirements and guidance, the 

oversight strategy employed by the 

NNSA Production Office may not be 

able to identify a reduction in 

effectiveness of the program. While this 

has not been a problem at Y–12, the 

programs at SNL and WIPP demonstrate 

that this is a problem at sites that do not 

have a strong contractor emergency 

management program. 

Contractor Assessments: Most of the 

sites reviewed by members of the 

Board’s staff were conducting annual 

assessments of their emergency 

management programs using the 15 

criteria suggested by the DOE 

Emergency Management Guides. 

However, based on its review of 

numerous contractor assessment 

reports, the staff team observed that 

many of the assessments were not 

effective at identifying problems and 

weaknesses with their programs. For 

example, many of the observations 

identified by HSS were not identified by 

the contractor assessments. As already 

discussed, SNL did not identify 

problems with its technical planning 

documents or its failure to conduct 

required exercises, and B&W Pantex did 

not identify problems with its training 

and drill and exercise programs. 

Similarly, LANL did not identify 

problems with the membership of its 

emergency response organization [100]. 

Members of the Board’s staff also 

observed that while most sites 

developed corrective actions to address 

issues identified in their assessments, as 

well as independent assessments, and 

tracked actions to closure, few sites 

were evaluating the effectiveness of 

these corrective actions. As already 

discussed, many of the sites, such as the 

Hanford Site and SNL, were not 

effectively addressing the findings and 

OFIs identified by external reviewers 

such as HSS and CDNS. Specifically, 

they were performing poor root cause 

analyses and were not performing 

reviews of the effectiveness of these 

corrective actions to address the issues 

and prevent their recurrence. 

Another area of weakness noted by 

members of the Board’s staff during its 

review of assessments and corrective 

actions, and observation of exercises 

was exercise assessment and critique. 

The staff team reviewed numerous 

exercise packages, after action reports, 

and corrective action plans, and 

observed many annual site exercises. 

The staff team observed that the 

critiques were often superficial, were 

not self-critical, and downplayed the 

significance of findings while conveying 

an aura of success. Most critiques failed 

to identify the root causes of problems, 

thus these problems recurred. For 

example, several significant findings of 

critical response capabilities, such as 

delayed notifications and lack of 

communication within the response 

organization, were identified during 

exercises at the Pantex Plant, yet the 

results of the exercises were graded as 

satisfactory [3]. The need for critical 

review of exercises has now been 

recognized by the NNSA Production 

Office and B&W Pantex, and corrective 

actions are now being implemented. 

Summary of Observations. The 

following table summarizes the Board’s 

staff team’s observations of the three 

questions that formed the foundation of 

its review of the state of emergency 

preparedness and response at DOE sites 

with defense nuclear facilities: 

Review Question 1: Review Question 2: Review Question 3: 

Does DOE provide facility workers, response 

personnel, and emergency management decision makers with adequate direction and 

guidance to make timely, conservative emergency response decisions and take actions 

that focus on protection of the public and 

workers? 

Does DOE provide adequate equipment and 

hardened facilities that enable emergency 

response personnel and emergency management decision makers to effectively respond to emergencies and protect the public and workers? 

Do the contractor assurance systems and 

DOE oversight provide an effective performance assurance evaluation of emergency 

preparedness and response? 

Many EPHAs did not adequately cover plausible emergency scenarios, including severe 

events.

Many emergency facilities will not be survivable or habitable during an emergency.Many contractor assurance systems were not 

effective at sustainably correcting identified 

emergency preparedness and response 

issues. 

Many EALs did not provide a clear method to 

identify the severity of events in order to categorize and classify an emergency and select protective actions.

Many emergency facilities and their alternates 

did not have reliable support systems, including an adequate maintenance program.

Many communications and notification systems were not adequate to ensure notification of workers and the public.

DOE Headquarters and local site personnel 

were not providing effective oversight to ensure emergency preparedness and response issues are identified and corrected. 

Many emergency protective actions did not 

have the clarity to ensure the protection of 

workers and the public during an emergency.

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Review Question 1: Review Question 2: Review Question 3: 

Many facility worker, initial responder, and 

EOC personnel training and drills were not 

adequate to prepare and qualify personnel to 

ensure timely, effective response during an 

emergency.

Many site emergency exercise programs did 

not demonstrate proficiency and did not 

identify weaknesses that will allow management to effectively drive improvements in 

emergency preparedness and response.

In general, the staff team observed 

that implementation of DOE’s 

requirements for emergency 

preparedness and response programs 

varies widely at various DOE sites with 

defense nuclear facilities. DOE has 

noted these types of problems in the 

HSS reports documenting independent 

assessments of its sites and in its annual 

reports on the status of its emergency 

management system. The annual reports 

also noted a lack of progress in 

addressing these problems [101–103]. 

Based on an evaluation of these 

observations, the staff team determined 

that the most important underlying root 

causes of these problems were 

inadequate implementation and revision 

of requirements, and ineffective 

contractor and federal verification and 

validation of readiness for responding to 

emergencies. 

Conclusions. In the aftermath of 

DOE’s implementation of corrective 

actions addressing Board 

Recommendation 98–1, members of the 

Board’s staff observed considerable 

improvement in emergency 

preparedness and response at many 

DOE sites across the complex. However, 

during this review of emergency 

preparedness and response, the staff 

team found that many sites had not 

continued to improve their programs, 

and in some cases, there had been 

degradation in these programs. One of 

the contributing factors in this lack of 

sustained continuous improvement was 

the failure of DOE as a regulator of 

emergency management programs at its 

sites. Although the problems observed 

by the Board’s staff team were largely 

associated with a failure to implement 

existing requirements and guidance, the 

Office of Emergency Operations has 

failed to maintain and improve the 

requirements and guidance in its 

directives, particularly in response to 

addressing lessons learned, needed 

improvements to site programs, and 

inconsistent interpretation and 

implementation of the requirements. 

The Office of Emergency Operations has 

also failed to revise its requirements to 

address lessons learned from 

Fukushima and use feedback from its 

sites on the type of guidance needed to 

effectively prepare and respond to 

severe events. 

Many problems result from 

inconsistent implementation of existing 

requirements by the various DOE sites; 

therefore, the staff team concluded that 

some requirements do not have the level 

of specificity to ensure effective 

implementation. Requirements for 

hazards assessments lack detail on 

addressing severe events. Requirements 

do not address reliability of emergency 

response facilities and equipment. 

Requirements for training and drills do 

not address expectations for the 

objectives, scope, frequency, and 

reviews of effectiveness. Requirements 

for exercises do not include 

expectations for the complexity of 

scenarios, scope of participation, 

grading of proficiency, and corrective 

actions. Some of the additional detail 

that addresses the deficiencies in these 

requirements is already included in the 

Emergency Guides that accompany DOE 

Order 151.1C. However, many sites have 

not implemented the practices 

described in the guides. 

Contractor assessment and federal 

oversight often did not identify needed 

improvements to site emergency 

preparedness and response, which 

compounded the observed problems 

with the implementation of 

requirements. When problems were 

identified, they often lacked adequate 

causal analysis and appropriate 

corrective actions. When corrective 

actions were developed and 

implemented, sites (contractors and 

federal entities) frequently did not 

measure the effectiveness of these 

actions. 

During its period of focus on 

conducting assist visits rather than 

independent assessments, HSS failed to 

conduct effective oversight of 

emergency management programs and 

enforcement of existing requirements at 

DOE sites, and did not ensure that the 

sites adequately responded to its 

findings and OFIs. HSS has made 

progress on reengaging in its role of 

independent oversight of emergency 

management programs at DOE sites with 

its recent transition back to independent 

oversight. The effectiveness of this 

oversight has been constrained by both 

the limited scope of the assessments 

currently being conducted by HSS and 

by the lack enforcement to ensure that 

its findings and OFIs are effectively 

addressed by the sites. The HSS focus 

on targeted assessments of a site’s 

ability to respond to severe events can 

lead to a failure to identify fundamental 

weaknesses in a site’s emergency 

management program. The HSS failure 

to engage in the resolution of its 

findings and OFIs is similar to the 

problem that was the genesis of Board 

Recommendation 98–1. 

These deficiencies in implementation 

and oversight have led to failures to 

identify and prepare for the suite of 

potential emergency scenarios and to 

demonstrate proficiency, and ultimately 

to the failure to recognize and respond 

appropriately to indications of an 

emergency, as was seen in the recent 

radioactive material release event at 

WIPP. Therefore, the Board’s staff 

review team believes that DOE has not 

comprehensively and consistently 

demonstrated its ability to protect the 

worker and the public in the event of an 

emergency. 

DOE Headquarters can address many 

of these problems by conducting more 

rigorous and comprehensive 

independent oversight and by revising 

its directives to address lessons learned, 

needed improvements to site programs, 

and inconsistent interpretation and 

implementation of the requirements. 

Technical and Economic Feasibility of 

Recommendation. The results of this 

review by members of the Board’s staff 

were used to support the development 

of Recommendation 2014–1, Emergency 

Preparedness and Response. The 

deficiencies identified in this review 

relate to problems with DOE’s safety 

management framework. The 

recommendation is technically feasible 

because it can be addressed using 

known scientific and engineering 

principles. The recommendation is 

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56792 Federal Register / Vol. 79, No. 184 / Tuesday, September 23, 2014 / Notices 

economically feasible because it has 

been structured to allow DOE to identify 

short-term and long-term enhancements 

to its emergency management programs. 

Several of these enhancements may 

involve improvements in infrastructure, 

while other improvements require the 

revision and strengthening of directives 

and guidance, as well as strengthening 

DOE oversight. Revising its directives is 

part of its normal process for 

maintaining the currency of its 

directives as codified in DOE Order 

251.1C, Departmental Directives 

Program [104]. Much of the detail 

needed to resolve problems of 

variability of implementation of 

requirements is already addressed in 

existing Emergency Management 

Guides. In addition, improvements to 

oversight would simply return the type 

of Headquarters oversight to the levels 

in which it was previously engaged and 

is an expectation in its directives on 

oversight (DOE Order 226.1B, 

Implementation of Department of 

Energy Policy [105] and DOE Order 

227.1, Independent Oversight Program 

[106]). Members of the Board’s staff are 

confident that DOE can identify 

solutions to address these deficiencies 

that are technically and economically 

feasible. 

References 

[1] Defense Nuclear Facilities Safety Board, 

Public Meeting and Hearing for Public 

Health and Safety, Including That of the 

Workers, Savannah River Site, Augusta, 

GA, June 16, 2011. 

[2] Defense Nuclear Facilities Safety Board, 

Public Meeting and Hearing for Seismic 

Safety of the Plutonium Facility, Los 

Alamos National Laboratory, Santa Fe, 

NM, November 17, 2011. 

[3] Defense Nuclear Facilities Safety Board, 

Public Meeting and Hearing for Safety 

Culture, Emergency Preparedness, and 

Nuclear Explosive Operations at Pantex, 

Amarillo, TX, March 14, 2013. 

[4] Defense Nuclear Facilities Safety Board, 

Public Meeting and Hearing for Safety in 

Design, Operations, and Emergency 

Preparedness at the Y–12 National 

Security Complex, Knoxville, TN, 

December 10, 2013. 

[5] Defense Nuclear Facilities Safety Board, 

Status of Emergency Management at 

Defense Nuclear Facilities of the 

Department of Energy, Technical Report21, March 1999. 

[6] Defense Nuclear Facilities Safety Board, 

Recommendation 98–1: Resolution of 

Issues Identified by Department of 

Energy (DOE) Internal Oversight, 

September 28, 1998. 

[7] Department of Energy, Programmatic 

Elements: Emergency Management 

Guide, DOE G 151.1–3, July 11, 2007. 

[8] Federal Emergency Management Agency, 

Radiological Emergency Preparedness 

Exercise Evaluation Methodology, 

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56794 Federal Register / Vol. 79, No. 184 / Tuesday, September 23, 2014 / Notices 

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30, 2011. 

Risk Assessment for Recommendation 

2014–01 

Emergency Preparedness & Response 

The recommendation addresses 

vulnerabilities in the Department of 

Energy’s (DOE) safety framework for 

defense nuclear facilities resulting from 

deficiencies in the content and 

implementation of DOE’s requirements 

for emergency preparedness and 

response. In accordance with the 

Defense Nuclear Facilities Safety 

Board’s (Board) Policy Statement 5 (PS– 

5), Policy Statement on Assessing Risk, 

this risk assessment was conducted to 

support the Board’s recommendation on 

Emergency Preparedness and Response. 

As stated in PS–5, 

The Board’s assessment of risk may 

involve quantitative information 

showing that the order of magnitude of 

the risk is inconsistent with adequate 

protection of the health and safety of the 

workers and the public . . . the Board 

will explicitly document its assessment 

of risk when drafting recommendations 

to the Secretary of Energy in those cases 

where sufficient data exists to perform 

a quantitative risk assessment. 

DOE’s hazards assessments address 

initiating events, preventive and 

mitigative controls, and consequences. 

Initiating events in these assessments 

include operational and natural 

phenomena events. Preventive and 

mitigative controls are design basis 

controls identified in safety analysis 

documents. Consequences cover a wide 

spectrum, ranging from insignificant to 

catastrophic effects. 

Emergency preparedness and 

response programs exist at DOE sites 

with defense nuclear facilities because 

the risk associated with those facilities 

is acknowledged by DOE and is required 

by law. Therefore, emergency 

preparedness and response programs 

need to function effectively to protect 

the workers and the public. 

This recommendation is focused on 

improving the effectiveness of DOE’s 

emergency preparedness and response 

programs. A quantitative risk 

assessment on the effectiveness of these 

programs requires data on probability 

and consequences. However, data do 

not exist on the probability of failure of 

elements of the emergency preparedness 

and response programs. Therefore, it is 

not possible to do a quantitative 

assessment of the risk of these elements 

to provide adequate protection of the 

workers and the public. 

CORRESPONDENCE FROM THE 

SECRETARY 

August 5, 2014. 

The Honorable Peter S. Winokur, Chairman 

Defense Nuclear Facilities Safety Board 

625 Indiana Avenue NW., Suite 700 

Washington, DC 20004 

Dear Mr. Chairman: Thank you for the 

opportunity to review the Defense Nuclear 

Facilities Safety Board (DNFSB) Draft 

Recommendation 2014–01, Emergency 

Preparedness and Response. DOE agrees that 

actions are needed to improve emergency 

preparedness and response capabilities at its 

defense nuclear facilities. The Department’s 

emergency preparedness and response 

infrastructure, capabilities, and resources are 

of great importance to me and DOE’s senior 

leadership. Recommendation 2014–01 will 

complement actions that the Department has 

already initiated to improve emergency 

management. 

Following my review of the Draft 

Recommendation with my leadership team, it 

appears the document establishes a timeline 

for accomplishing the recommended actions. 

I recommend the DNFSB remove the specific 

time for completing responsive actions. It is 

the Department’s responsibility to determine 

the necessary resources, including the 

requisite timeline to accomplish the actions 

in our implementation plan to address 

DNSFB recommendations. I share your intent 

to improve emergency management in the 

Department and I assure you that the 

Department takes this situation seriously. We 

will prioritize efforts and plan to consult 

with you. I have already directed my staff to 

expeditiously proceed with improvements 

which we identified separately, 

accomplishing the highest priorities within a 

one year period. 

In addition to the wording change 

identified above, I offer suggested language 

that may help clarify the DNFSB’s intent in 

the Draft Recommendation. These changes 

are included as an enclosure for your 

consideration. 

We appreciate the DNFSB’s perspective 

and look forward to continued positive 

interactions. If you have any questions, 

please contact me or Mr. Joseph J. Krol, 

Associate Administrator for Emergency 

Operations, at 202–586–9892. 

Sincerely, 

Ernest J. Moniz 

Enclosure 

Specific DOE Comments on 

Draft DNFSB Recommendation 2014– 

01, 

Emergency Preparedness and Response 

1. The formal process for developing 

an implementation plan for an accepted 

recommendation will establish a 

schedule commensurate with careful 

consideration of scope, capabilities, and 

resources, subject to the expectations for 

timeliness found in the DNFSB enabling 

legislation. The Department 

recommends changing the phrase at the 

beginning of the Draft Recommendation, 

striking the words, ‘‘. . . during each 

site’s 2015 annual emergency response 

exercise’’, which would change the 

statement to read, ‘‘To address the 

deficiencies summarized above, the 

Board recommends that DOE take the 

following actions:’’ 

2. Regarding Action 1, the 

Departmental management model 

currently uses criteria and review 

approaches. The current wording, 

‘‘develop and initiate’’, could lead the 

public to believe that the Department 

does not have a criteria and review 

approach, whereas your staff recognizes 

that such approaches exist and are in 

use. The use of this terminology 

‘‘criteria and review approach’’ also 

seems to focus narrowly on a particular 

solution when other parts of the 

mstockstill on DSK4VPTVN1PROD with NOTICES

Federal Register / Vol. 79, No. 184 / Tuesday, September 23, 2014 / Notices 56795 

DNFSB’s Draft Recommendation appear 

to imply that systemic changes are 

needed in the overall DOE oversight and 

continuous improvement processes. 

DOE recommends changing Action 1 to 

read, ‘‘In its role as a regulator, 

standardize and improve 

implementation of its criteria and 

review approach to confirm . . . .’’ 

3. Regarding Action 2c, as written, it 

is not clear that you may have intended 

for ‘‘facility specific drill programs’’ to 

mean drill programs for facility 

operators, who, as part of conduct of 

operations, take actions under abnormal 

and emergency operating procedures to 

mitigate conditions or that bring 

facilities into safe shut-down, separate 

from actions taken by the emergency 

response organization. DOE 

recommends changing this action to 

read, ‘‘. . . including requirements that 

address facility conduct of operations 

drill programs and the interface with 

emergency response organization team 

drills.’’ 

4. Regarding Action 2e, the intent of 

this element is unclear since the 

Department already has continuous 

improvement processes in place and 

processes for including lessons learned 

during implementation of DOE 

directives into future directive 

revisions. In addition, Action 2e appears 

to imply that improvements should be 

made to the emergency management 

directive on a one-time basis and that 

the directive should not be changed 

until after program reviews called for in 

Action 1 are completed. The 

Department recommends a clarification 

of the intent of this action. 

DISPOSITION OF DOE COMMENTS ON DRAFT RECOMMENDATION 2014–1 

DOE comment Board response Revised wording 

The formal process for developing an implementation plan for an accepted recommendation will establish a schedule commensurate with careful consideration of 

scope, capabilities, and resources, subject to 

the expectations for timeliness found in the 

DNFSB enabling legislation. The Department 

recommends changing the phrase at the beginning of the Draft Recommendation, striking the words, ‘‘during each site’s 2015 annual emergency response exercise’’, which 

would change the statement to read, ‘‘To address the deficiencies summarized above, 

the Board recommends that DOE take the 

following actions:’’ 

The Board understands the DOE rationale for 

removing the time constraint from the Recommendation. However, the Board’s enabling legislation states that ‘‘not later than 

one year after the date on which the Secretary of Energy transmits an implementation plan with respect to a Recommendation 

(or part thereof) under subsection (f), the 

Secretary shall carry out and complete the 

implementation plan.’’ The Board believes 

that the actions in the first sub- Recommendation can be accomplished by the 

end of 2016 and has revised the wording of 

the Recommendation accordingly.

To address the deficiencies summarized 

above, the Board recommends that DOE 

take the following actions: 

1. In its role as a regulator, by the end of 

2016, standardize and improve implementation of its criteria and review approach to 

confirm that all sites with defense nuclear 

facilities: 

Regarding Action 1, the Departmental management model currently uses criteria and review approaches. The current wording, ‘‘develop and initiate’’, could lead the public to 

believe that the Department does not have a 

criteria and review approach, whereas your 

staff recognizes that such approaches exist 

and are in use. The use of this terminology 

‘‘criteria and review approach’’ also seems to 

focus narrowly on a particular solution when 

other parts of the DNFSB’s Draft Recommendation appear to imply that systemic 

changes are needed in the overall DOE 

oversight and continuous improvement processes. DOE recommends changing Action 1 

to read, ‘‘In its role as a regulator, standardize and improve implementation of its criteria and review approach to confirm ’’ 

The Board acknowledges that DOE uses criteria and review approaches in its current 

oversight of the emergency preparedness 

and response capabilities of its sites. However, as discussed in the Recommendation, 

’’ the current scope of DOE independent 

oversight is not adequate to identify needed 

improvements and to ensure effectiveness 

of federal and contractor corrective actions.’’ 

In addition, the Recommendation notes 

‘‘that DOE has not effectively conducted 

oversight and enforcement of its existing requirements.’’ Therefore, the scope and implementation of the existing criteria and review approaches should be standardized 

and improved. The Board believes that 

DOE’s suggested rewording addresses this 

issue and is appropriate.

1. In its role as a regulator, by the end of 

2016, standardize and improve implementation of its criteria and review approach to 

confirm that all sites with defense nuclear 

facilities: 

Regarding Action 2c, as written, it is not clear 

that you may have intended for ‘‘facility-specific drill programs’’ to mean drill programs 

for facility operators, who, as part of conduct 

of operations, take actions under abnormal 

and emergency operating procedures to mitigate conditions or that bring facilities into 

safe shut-down, separate from actions taken 

by the emergency response organization. 

DOE recommends changing this action to 

read, ‘‘including requirements that address 

facility conduct of operations drill programs 

and the interface with emergency response 

organization team drills.’’ 

The Board acknowledges that the meaning of 

‘‘facility-specific drill programs’’ needs to be 

clarified. The use of this term was intended 

to address the response of facility operators 

during emergency events and their interactions with emergency response personnel. The Board believes that DOE’s suggested rewording addresses this need for 

clarification and is appropriate.

2.c Criteria for training and drills, including requirements that address facility conduct of 

operations drill programs and the interface 

with emergency response organization team 

drills. 

mstockstill on DSK4VPTVN1PROD with NOTICES

56796 Federal Register / Vol. 79, No. 184 / Tuesday, September 23, 2014 / Notices 

DISPOSITION OF DOE COMMENTS ON DRAFT RECOMMENDATION 2014–1—Continued 

DOE comment Board response Revised wording 

Regarding Action 2e, the intent of this element 

is unclear since the Department already has 

continuous improvement processes in place 

and processes for including lessons learned 

during implementation of DOE directives into 

future directive revisions. In addition, Action 

2e appears to imply that improvement should 

be made to the emergency management directive on a one-time basis and that the directive should not be changed until after program reviews called for in Action 1 are completed. The Department recommends a clarification of the intent of this action. 

Based on DOE’s comment, the Board acknowledges that clarification of the intent of 

this element is necessary. The clarification 

that DOE requested can be accomplished 

by phrasing the required element more simply as ‘‘Vulnerabilities identified during independent assessments’’.

2.e Vulnerabilities identified during independent assessments. 

[FR Doc. 2014–22510 Filed 9–22–14; 8:45 am] 

BILLING CODE P 

DEPARTMENT OF ENERGY 

Federal Energy Regulatory 

Commission 

Combined Notice of Filings #1 

Take notice that the Commission 

received the following electric corporate 

filings: 

Docket Numbers: EC14–144–000. 

Applicants: Broken Bow Wind II, 

LLC. 

Description: Joint Application for 

Order Authorizing Acquisition and 

Disposition of Jurisdictional Facilities 

Under Section 203 of the Federal Power 

Act Broken Bow Wind II, LLC, et al. 

Filed Date: 9/15/14. 

Accession Number: 20140915–5218. 

Comments Due: 5 p.m. ET 10/6/14. 

Take notice that the Commission 

received the following exempt 

wholesale generator filings: 

Docket Numbers: EG14–104–000. 

Applicants: Solar Star California XIII, 

LLC. 

Description: Notice of SelfCertification of Exempt Wholesale 

Generator Status of Solar Star California 

XIII, LLC. 

Filed Date: 9/15/14. 

Accession Number: 20140915–5203. 

Comments Due: 5 p.m. ET 10/6/14. 

Take notice that the Commission 

received the following electric rate 

filings: 

Docket Numbers: ER09–1224–007. 

Applicants: Entergy Operating 

Companies. 

Description: Entergy Operating 

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Bandwidth Formula Comprehensive 

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Filed Date: 9/15/14. 

Accession Number: 20140915–5223. 

Comments Due: 5 p.m. ET 10/6/14. 

Docket Numbers: ER10–3184–002; 

ER10–2805–002; ER10–2564–004; ER10– 

2600–004; ER10–2289–004 

Applicants: FortisUS Energy 

Corporation, Central Hudson Gas & 

Electric Corporation, Tucson Electric 

Power Company, UNS Electric, Inc., 

UniSource Energy Development 

Company. 

Description: Notice of Non-Material 

Change in Status of FortisUS Energy 

Corporation, et al. 

Filed Date: 9/15/14. 

Accession Number: 20140915–5219. 

Comments Due: 5 p.m. ET 10/6/14. 

Docket Numbers: ER14–2882–000. 

Applicants: The Empire District 

Electric Company. 

Description: Compliance filing per 35: 

Revised Protocols to be effective 4/1/

2015. 

Filed Date: 9/15/14. 

Accession Number: 20140915–5174. 

Comments Due: 5 p.m. ET 10/6/14. 

Docket Numbers: ER14–2883–000. 

Applicants: PJM Interconnection, 

L.L.C. 

Description: § 205(d) rate filing per 

35.13(a)(2)(iii): Revisions to OATT 

Sched 6A Modify Black Start Comp and 

Add Black Start Backstop to be effective 

11/15/2014. 

Filed Date: 9/15/14. 

Accession Number: 20140915–5175. 

Comments Due: 5 p.m. ET 10/6/14. 

Docket Numbers: ER14–2884–000. 

Applicants: KCP&L Greater Missouri 

Operations Company. 

Description: § 205(d) rate filing per 

35.13(a)(2)(iii): Formula Rate Protocols 

Filing to be effective 3/1/2015. 

Filed Date: 9/15/14. 

Accession Number: 20140915–5176. 

Comments Due: 5 p.m. ET 10/6/14. 

Docket Numbers: ER14–2885–000. 

Applicants: Seiling Wind 

Interconnection Services, LLC. 

Description: Baseline eTariff Filing 

per 35.1: Seiling Interconnection, 

Seiling I and Seiling II Shared Facilities 

Agreement to be effective 10/1/2014. 

Filed Date: 9/16/14. 

Accession Number: 20140916–5056. 

Comments Due: 5 p.m. ET 10/7/14. 

Docket Numbers: ER14–2886–000. 

Applicants: GDF SUEZ Energy 

Marketing NA, Inc. 

Description: Request of GDF SUEZ 

Energy Marketing NA, Inc. for Limited 

Waiver of the ISO New England, Inc. 

Tariff. 

Filed Date: 9/15/14. 

Accession Number: 20140915–5224. 

Comments Due: 5 p.m. ET 10/6/14. 

Docket Numbers: ER14–2887–000. 

Applicants: Southwest Power Pool, 

Inc. 

Description: § 205(d) rate filing per 

35.13(a)(2)(iii): Section 2.2 and 

Attachment F Revisions to be effective 

12/1/2014. 

Filed Date: 9/16/14. 

Accession Number: 20140916–5093. 

Comments Due: 5 p.m. ET 10/7/14. 

Take notice that the Commission 

received the following electric 

reliability filings: 

Docket Numbers: RD14–13–000. 

Applicants: North American Electric 

Reliability Corporation. 

Description: Petition of the North 

American Electric Reliability 

Corporation for Approval of Proposed 

Reliability Standard NUC–001–3. 

Filed Date: 9/15/14. 

Accession Number: 20140915–5206. 

Comments Due: 5 p.m. ET 10/15/14. 

Docket Numbers: RR14–7–000. 

Applicants: North American Electric 

Reliability Corporation. 

Description: Petition of the North 

American Electric Reliability 

Corporation for Approval of 

Amendments to Regional Reliability 

Standards Development Procedure of 

the Northeast Power Coordinating 

Council, Inc. 

Filed Date: 9/15/14. 

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