ML062620341

IR 05000334-06-009, 05000412-06-009; on 06/26/2006 - 08/22/2006; Beaver Valley Nuclear Power Station, Units 1 and 2; Exercise Evaluation

ML062620341
Person / Time
Site:	Beaver Valley
Issue date:	09/18/2006
From:	Blough A Division of Reactor Safety I
To:	Lash J FirstEnergy Nuclear Operating Co
References
EA-06-215 IR-06-009
Download: ML062620341 (15)

See also: IR 05000334/2006009

Text

September 18, 2006

EA-06-215

Mr. James Lash

Site Vice President, Beaver Valley Power Station

FirstEnergy Nuclear Operating Company

Post Office Box 4

Shippingport, Pennsylvania 15077

SUBJECT:

BEAVER VALLEY POWER STATION - NRC EVALUATED EMERGENCY

PREPAREDNESS EXERCISE INSPECTION REPORT 05000334/2006009 AND

05000412/2006009

Dear Mr. Lash:

On August 22, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Beaver Valley Power Station (BVPS), which evaluated the performance of your

emergency response organization during the June 27, 2006, exercise and the post-exercise

critique conducted on June 29, 2006. The inspectors briefed your staff regarding the

preliminary results of this inspection on June 29, 2006. Subsequent to the onsite portion of this

inspection, the team conducted additional interviews and discussions with your staff and

examined additional documents. The NRC conducted the exit meeting for this inspection with

you and members of your staff via telephone conference on August 22, 2006.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed emergency plan procedures and previous drill reports, observed the

exercise activities, and interviewed selected emergency preparedness personnel from your

staff.

This report documents one finding concerning the performance of your staff related to the dose

projections and protective action recommendations made during the exercise. Specifically, the

NRC inspection team noted that your dose assessment team made dose projections without a

sound technical basis for some of the inputs, in that the technical support center staff was not

relied on to characterize the source of the release nor to determine a projected release

duration. This deficiency is similar to an NRC-identified weakness in your May 2004 exercise,

which was detailed in NRC Inspection Report Numbers 05000334/2004008 and

05000412/2004008. Facility licensees, such as BVPS, are required by 10 CFR 50, Appendix E,

Section IV.F.2.g, to correct all exercise critique weaknesses, including those identified by the

NRC. The 2006 NRC team reviewed your staffs corrective actions for the 2004 exercise

weakness and determined that those corrective actions had not been effective in that a similar

weakness recurred in the 2006 exercise.

2

J. Lash

This finding was assessed using the emergency preparedness Significance Determination

Process (SDP) and was preliminarily determined to be White (i.e., a finding with some

increased importance to safety, which may require additional NRC inspection). The finding

appears to have low to moderate safety significance because not adequately correcting the

BVPS process for dose projection may adversely impact the timeliness and adequacy of PARs

made in the event of a radiological release from BVPS.

This finding is an apparent violation of NRC requirements specified in 10 CFR 50, Appendix E,

Section IV.F.2.g, and is being considered for escalated enforcement action in accordance with

the NRC Enforcement Policy. The current policy is included on the NRC's website at

http://www.nrc.gov; select What We Do, Enforcement, then Enforcement Policy.

We believe that we have sufficient information to make our final risk determination for the

performance issue involving the inadequate corrective actions for a previously-identified

emergency preparedness exercise weakness. However, before the NRC makes a final

decision on this matter, we are providing you an opportunity to: (1) present to the NRC your

perspective on the facts and assumptions used by the NRC to arrive at the finding and its

significance at a Regulatory Conference, or (2) submit your position on the finding to the NRC

in writing. If you request a Regulatory Conference, it should be held within 30 days of receipt of

this letter and we encourage you to submit supporting documentation at least one week prior to

the conference in an effort to make the conference more efficient and effective. If a Regulatory

Conference is held, it will be open for public observation and a press release will be issued to

announce it. If you decide to provide a written response in lieu of the Regulatory Conference,

the submittal should be sent to the NRC within 30 days of the receipt of this letter.

Please contact Mr. Raymond Lorson at (610) 337-5282 within 10 business days of the date of

this letter to notify the NRC of your intentions. If we have not heard from you within that time,

we will continue with our significance determination and enforcement decision, and you will be

advised by separate correspondence of the results of our deliberations on this matter. Since

the NRC has not made a final determination in this matter, no Notice of Violation is being issued

for the inspection finding at this time. In addition, please be advised that the characterization of

the apparent violation described in this letter may change as a result of further NRC review.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,

its enclosure, and your response (if any) will be available electronically for public inspection in

the NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

A. Randolph Blough, Director

Division of Reactor Safety

Docket Nos. 50-334, 50-412

License Nos. DPR-66, NPF-73

3

J. Lash

Enclosure:

Inspection Report 05000334/2006009 and 05000412/2006009

w/Attachments: Supplemental Information

cc w/encl:

G. Leidich, President and Chief Nuclear Officer

J. Hagan, Senior Vice President of Operations and Chief Operating Officer

D. Pace, Senior Vice President, Fleet Engineering

J. Rinckel, Vice President, Fleet Oversight

L. Myers, Executive Vice President, Special Projects

R. Anderson, Vice President, FirstEnergy Nuclear Operating Company

Manager, Fleet Licensing, FirstEnergy Nuclear Operating Company

R. Mende, Director, Site Operations

T. Cosgrove, Director, Maintenance

P. Sena, Director, Engineering

L. Freeland, Director, Site Performance Improvement and Manager, Regulatory Compliance

D. Jenkins, Attorney, FENOC

B. Sepelak, Supervisor, Nuclear Compliance

M. Clancy, Mayor, Shippingport, PA

D. Allard, PADEP

C. OClaire, State Liaison to the NRC, State of Ohio

Z. Clayton, EPA-DERR, State of Ohio

Director, Utilities Department, Public Utilities Commission, State of Ohio

D. Hill, Chief, Radiological Health Program, State of West Virginia

J. Lewis, Commissioner, Division of Labor, State of West Virginia

W. Hill, Beaver County Emergency Management Agency

J. Johnsrud, National Energy Committee, Sierra Club

A. King, PA Emergency Management Agency (PEMA)

Darrell Hammons, RAC Chair, DHS Region III

4

J. Lash

Distribution w/encl:

S. Collins, RA

M. Dapas, DRA

R. Bellamy, DRP

R. Fuhrmeister, DRP

B. Sosa, OEDO

R. Laufer, NRR

T. Colburn, PM, NRR

R. Guzman, NRR

P. Cataldo - Senior Resident Inspector

P. Garrett - Resident OA

M. Satorius, DRS-RIII

ROPreports@nrc.gov

Region I Docket Room (with concurrences)

SECY

OCA

OEMAIL

OEWEB

L. Reyes, EDO

W. Kane, DEDR

L. Lopez, OE

O. Samuel, OE

L. Chandler, OGC

B. Jones, OGC

M. Elwood, OGC

J. Schlueter, OSTP

J. Dyer, NRR

M. Weber, NRR

B. Boger, NRR

Enforcement Coordinators RII, RIII, RIV

E. Hayden, OPA

H. Bell, OIG

G. Caputo, OI

L. Tremper, OC

D. Screnci/N. Sheehan, PAO, RI

D. Holody, EO, RI

K. Farrar, ORA

R. Summers, ORA, RI

R1DRP_Mail

R. Kahler, NSIR/EPD

S. LaVie, NSIR/EPD

A. Blough, DRS

M. Gamberoni, DRS

R. Lorson, DRS

S. Barr, DRS

Region I OE Files (w/concurrences)

4

J. Lash

Distribution w/encl:

S. Collins, RA

M. Dapas, DRA

R. Bellamy, DRP

R. Fuhrmeister, DRP

B. Sosa, OEDO

R. Laufer, NRR

T. Colburn, PM, NRR

R. Guzman, NRR

P. Cataldo - Senior Resident Inspector

P. Garrett - Resident OA

M. Satorius, DRS-RIII

ROPreports@nrc.gov

Region I Docket Room (with concurrences)

SECY

OCA

OEMAIL

OEWEB

L. Reyes, EDO

W. Kane, DEDR

L. Lopez, OE

O. Samuel, OE

L. Chandler, OGC

B. Jones, OGC

M. Elwood, OGC

J. Schlueter, OSTP

J. Dyer, NRR

M. Weber, NRR

B. Boger, NRR

Enforcement Coordinators RII, RIII, RIV

E. Hayden, OPA

H. Bell, OIG

G. Caputo, OI

L. Tremper, OC

D. Screnci/N. Sheehan, PAO, RI

D. Holody, EO, RI

K. Farrar, ORA

R. Summers, ORA, RI

R1DRP_Mail

R. Kahler, NSIR/EPD

S. LaVie, NSIR/EPD

A. Blough, DRS

M. Gamberoni, DRS

R. Lorson, DRS

S. Barr, DRS

Region I OE Files (w/concurrences)

SUNSI Review Complete: STB (Reviewers Initials)

DOCUMENT NAME: E:\\Filenet\\ML062620341.wpd

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

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy

OFFICE

RI/DRS

RI/DRS

RI/DRS/SRA

RI/ORA

RI/DRS

NAME

SBarr/STB

RLorson/NSP for

WCook/WAC

DHolody/RJS for

ABlough/ARB

DATE

09/15/06

09/15/06

09/15/06

09/18/06

09/18/06

OFFICE

NAME

DATE

OFFICIAL RECORD COPY

Enclosure

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket Nos:

50-334, 50-412

License Nos:

DPR-66, NPF-73

Report Nos:

05000334/2006009, 05000412/2006009

Licensee:

FirstEnergy Nuclear Operating Company

Facility:

Beaver Valley Power Station, Units 1 and 2

Location:

Shippingport, Pennsylvania 15077

Dates:

June 26 - August 22, 2006

Inspectors:

S. Barr, Senior Emergency Preparedness Inspector (Lead)

S. LaVie, Senior Emergency Preparedness Specialist (NSIR)

P. Cataldo, Senior Resident Inspector

D. Werkheiser, Resident Inspector

M. Brown, Operations Engineer

Approved by:

Raymond K. Lorson, Chief

Plant Support Branch 1

Division of Reactor Safety

ii

Enclosure

SUMMARY OF FINDINGS

IR 05000334/2006009, 05000412/2006009; 06/26/2006 - 08/22/2006; Beaver Valley Nuclear

Power Station, Units 1 and 2; Exercise Evaluation.

The report documents an inspection of the Beaver Valley emergency preparedness exercise

conducted on June 27, 2006. The inspection was conducted by NRC regional and

headquarters inspectors. One apparent violation (AV) with potential low to moderate safety

significance was identified (Preliminary White). The significance of most findings is indicated by

their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,

Significance Determination Process (SDP). Findings for which the SDP does not apply may

be Green or be assigned a severity level after NRC management review. The NRC's program

for overseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

A.

NRC-Identified and Self-Revealing Findings

Cornerstone: Emergency Preparedness

Preliminary White. The inspector identified an apparent violation for the

licensees failure to provide adequate corrective actions to a previously-identified

emergency preparedness exercise weakness. 10 CFR 50, Appendix E, Section

IV.F.2.g, requires that any emergency preparedness weakness or deficiency that

is identified shall be corrected. An apparent violation of that requirement was

identified involving the licensees failure to adequately correct a performance

deficiency in the area of Protective Action Recommendation development

identified by the NRC in the May 2004 evaluated exercise. Specifically, in the

2006 exercise, the licensee dose assessment team did not adequately consider

plant-specific situational information to develop the best dose projection estimate

achievable at the time, which was an apparent repeat of a problem exhibited in

the 2004 exercise. The licensees 2006 performance regarding the development

of a dose projection without a sound technical basis demonstrated that the

licensee had implemented ineffective corrective actions for the 2004 inspection

finding.

This finding is greater than minor because it is associated with the Emergency

Response Organization Performance attribute and affected the objective of the

Emergency Preparedness Cornerstone to ensure that the licensee is capable of

implementing adequate measures to protect the health and safety of the public in

the event of a radiological emergency. The Emergency Preparedness SDP,

Section 5.3, Failure to Correct Drill or Exercise Weaknesses, was used to

evaluate the significance of this finding. Because the licensees corrective

actions were not adequate and the weakness involved a Risk Significant

Planning Standard area that is not covered by performance indicators (i.e.,

10 CFR 50.47(b)(9)), a loss of planning standard function was assessed,

resulting in a White finding. (Section 1EP1)

Enclosure

Report Details

1.

REACTOR SAFETY

Cornerstone: Emergency Preparedness (EP)

1EP1 Exercise Evaluation (71114.01 - 1 Sample)

a.

Inspection Scope

Prior to the exercise, an in-office review was conducted of the exercise objectives and

scenario submitted to the NRC to determine if the exercise would test major elements of

the emergency plan as required by 10 CFR 50.47(b)(14). The evaluation of the

licensees performance during the exercise is described below. Overall, this inspection

activity represents the completion of one sample on a biennial cycle.

The exercise evaluation consisted of the following review and assessment:

The adequacy of Beaver Valleys performance in the biennial full-participation

exercise regarding the implementation of the risk-significant planning standards

(RSPS) in 10 CFR 50.47(b)(4), (5), (9) & (10) which are emergency

classification, offsite notification, radiological assessment, and protective action

recommendations, respectively.

The overall adequacy of Beaver Valleys emergency response facilities with

regard to NUREG-0696, Functional Criteria for Emergency Response Facilities,

and Emergency Plan commitments. The facilities assessed were the control

room simulator, the Technical Support Center (TSC), the Operations Support

Center (OSC), and the Emergency Operations Facility (EOF).

Other performance areas, such as the emergency response organizations

(EROs) recognition of abnormal plant conditions, command and control, intra-

and inter-facility communications, prioritization of mitigation activities, utilization

of repair and field monitoring teams, interface with offsite agencies, staffing and

procedure adequacy, and the overall implementation of the emergency plan and

its implementing procedures.

Past performance issues from the last NRC exercise report and Beaver Valleys

drill reports to determine effectiveness of corrective actions as demonstrated

during this exercise to ensure compliance with 10 CFR 50.47(b)(14).

The post-exercise critique to evaluate Beaver Valleys self-assessment of its

ERO performance during the exercise and to ensure compliance with 10 CFR 50, Appendix E.IV.F.2.g.

The inspectors reviewed the documents listed in the Attachment to this report.

2

Enclosure

b.

Findings

Introduction. The inspectors identified an apparent violation of 10 CFR 50 Appendix E,

Section IV.F.2.g, for failure to correct a previously identified exercise weakness.

Specifically, the inspectors identified a performance deficiency in the licensees method

of dose projection, potentially affecting their ability to make the proper protective action

recommendation (PAR). This performance issue appeared to be similar to a weakness

that the licensee failed to critique in the May 2004 exercise, which was documented in

NRC Inspection Report 50-334 & 412/2004008.

Description The 2006 exercise scenario involved a containment bypass event, where

the offsite dose occurred primarily due to an exothermic reaction in the charcoal filter

beds, releasing the accumulated radiological particulates into the atmosphere. The

licensee Environmental Assessment and Dose Projection (EA&DP) team did dose

calculations assuming a one-hour release, not as a default number, but because they

believed the duration of the release could not be estimated. This assumption was

clearly recognized by the remainder of the EA&DP team. When the plant conditions

indicated the release would last greater than one hour, the EA&DP team performed an

additional dose assessment and suggested to the states that the second assessment be

added to the first. These activities were performed in accordance with site procedures

(e.g., Procedure 1/2-EPP-IP-2.6.3, Step 8.1.2.4.1), which state that, if the duration of

the release cannot be estimated, then use 1.0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> and repeat the projection as better

data become available. The NRC team observed that the EA&DP team did not

estimate the release duration, nor did they confer with the technical support center

(TSC) staff to develop a technically-sound release duration estimate. The EA&DP team

used this non-default one-hour release duration, rather than making a dose projection

based on the actual current plant conditions.

In the 2004 evaluated exercise, the licensee EA&DP team performed dose projection

calculations using the default one-hour release time. The use of the default release

duration was invalid during this exercise because less than one full train of containment

spray was available. The one-hour release projection is based in part on a design

assumption that the operation of the containment spray will restore the containment to

sub-atmospheric pressure within an hour. The EA&DP team was not aware of the

degraded containment spray capability and used the default one hour release duration.

The NRC team noted that licensee players in the TSC were aware that less than one full

train of containment spray was available, yet they did not provide any technical input for

the estimation of a projected release duration. The 2004 inspection concluded that,

although EA&DP personnel were aware throughout the exercise of releases and release

rates via the radiation monitors, the licensee used an invalid release duration time in the

dose projections and that they also did not know the basis for the one hour release time.

The NRC issued a Green Finding for the failure of the licensee exercise critique to

identify an invalid radiological release duration time.

3

Enclosure

In both the 2004 and 2006 exercises, the licensee used a one-hour release duration

after they did not obtain a release duration from the TSC. In both cases, since the

exercise scenarios involved events which challenged the basis for the default one-hour

release duration, the EA&DP team should have recognized that a projected release

duration of greater than one hour would have been appropriate. As stated in the 2004

inspection report and as observed by the 2006 inspection team, this practice can

reasonably be seen to adversely affect the PAR if the dose from subsequent hours

results in a significant dose to the public. The lack of communication and technical

analysis was not identified by the licensee as a contributing cause in their followup of the

2004 NRC finding, and no corrective actions were implemented in this regard. Similarly

in the 2006 exercise, the EA&DP personnel did not obtain a release duration estimate

from the TSC and resorted to the one-hour non-default release time. The licensees

reliance on using a one-hour release duration, and then repeating an analysis when

better data became available, did not ensure the accurate assessment of the magnitude

of the offsite release based on best-available information.

The NRC reviewed the licensee corrective actions implemented in response to the 2004

finding. Corrective actions included a review of: the Final Safety Analysis Report basis

for the one hour duration; dose assessment processes and procedures; and associated

training. The licensee concluded, in Condition Report (CR) 04-04232-01 and -04, that

the one hour default release time is appropriate for Beaver Valley Power Station and

revision to the procedures referenced in this CA are not necessary. Further, CR 04-

04966-01 concluded that CR 04-04966 and CR 04-04232 were reviewed at Rad-Pro

TAC Meeting 04-09" and no further actions are required by RP training on these CRs

because the conditions described in the CRs are addressed in the applicable

Emergency Response training lessons.

The inspectors determined that the corrective actions had been narrowly focused on

establishing the validity of the one-hour default release duration, and did not address the

potential non-conservative impact of this default value on protective action

recommendations. The licensee performed a review of the BVPS design basis accident

release durations (ranging from 15 minutes to 30 days) and also considered default

durations obtained from other sites. Although the licensee determined that one hour

was valid, the basis of how the disparate release durations were reduced to a generally

applicable one-hour default was not evident. Since the licensee determined the one-

hour default as being adequate, corrective actions were largely limited to adding a

precaution requiring users to consider the bases of the default duration, with an explicit

example of ...one full train of containment sprays, etc... The inspectors determined

that the dose assessment procedure emphasis remained focused on the one-hour

default, rather than on developing an estimated release duration based on plant-specific

information. Changes to licensee emergency response organization computer-based

training were apparently limited to cross-referencing the added precautions. Based on

the observation of the 2006 exercise, the NRC inspectors determined that the

corrective actions had been ineffective. Specifically, the EA&DP personnel did not

request nor receive any technical assessment of the radiation release duration from the

TSC and used the non-default one-hour duration when it was not supported by the

plant condition. The licensee continued to make dose projections without a sound

4

Enclosure

technical basis, which had the potential to adversely impact the timeliness and accuracy

of the PARs.

Analysis. The inspectors determined that the licensee did not take adequate corrective

actions (e.g., proper procedure changes) to prevent recurrence of the weakness

identified in the 2004 evaluated exercise, which was the failure to determine a sound

technical basis for the release projection time used in the formulation of PARs.

Therefore, the performance deficiency in the 2006 exercise was the failure to correct an

exercise weakness, as required by 10CFR50.47(b)(14). The observed weakness

directly related to the licensees ability to provide adequate methods for assessing actual

or potential offsite consequences of a radiological emergency condition, as required by

10 CFR 50.47(b)(9). NRC Manual Chapter 0609, Appendix B, Emergency

Preparedness Significance Determination Process, states, under Section 5.3, Failure to

Correct Drill or Exercise Weakness:

If corrective actions are not adequate and the WEAKNESS involves a Risk

Significant Planning Standard (RSPS) area that is not covered by the DEP PI

(e.g., 10 CFR 50.47(b)(9)), the NRC staff should assess a LOSS OF PS

FUNCTION (i.e., a White finding). All non-RSPS areas would be Green.

In this case, the planning standard function lost was 10CFR50.47(b)(14), which requires

licensees to correct deficiencies identified as a result of exercises and drills. The

licensees failure to comply with this standard is the entry point in Sheet 1 of the EP

SDP. The specific problem was a planning standard problem, but not a risk significant

planning standard problem. The Sheet 1 logic shows that a planning standard problem

that results in a planning standard function failure (as the above citation from the SDP

Section 5.3 defines) is a White finding.

Enforcement. 10 CFR 50 Appendix E, Section IV.F.2.g requires , in part, that any

weaknesses or deficiencies that are identified in an emergency preparedness exercise

shall be corrected. Contrary to that requirement, FENOC failed to adequately correct a

performance deficiency in the area of PAR development identified by the NRC in the

May 2004 evaluated exercise. Specifically, in the 2006 exercise the licensee dose

assessment team failed to consider plant-specific situational information to develop the

best dose projection estimate achievable at the time, which was a repeat of the

deficiency exhibited in the 2004 exercise. This finding is identified as an apparent

violation in accordance with Section VI.A.5.b of the NRC Enforcement Policy. (AV

05000334/2006009-01, 05000412/2006009-01)

5

Enclosure

4.

OTHER ACTIVITIES (OA)

4OA1 Performance Indicator (PI) Verification (71151- 3 Samples)

a.

Inspection Scope

The inspectors reviewed data for the EP PIs which are: (1) Drill and Exercise

Performance (DEP); (2) ERO Drill Participation; and (3) Alert and Notification System

(ANS) Reliability. The inspectors reviewed supporting documentation from drills and

tests from all four quarters of 2005, and the first quarter of 2006, to verify the accuracy

of the reported data. The review of these performance indicators was conducted in

accordance with NRC Inspection Procedure 71151. The acceptance criteria used for

the review were 10 CFR 50.9 and NEI 99-02, Revision 2, Regulatory Assessment

Performance Indicator Guidelines. This inspection activity represented the completion

of three samples on an annual cycle.

b.

Findings

No findings of significance were identified.

40A6

Meetings, including Exit

The inspectors presented the preliminary inspection results to Mr. James Lash, Beaver

Valley Power Station Vice President, and other members of the licensees staff, at the

conclusion of the onsite inspection on June 29, 2006. Due to the preliminary nature of

those results, the NRC inspection team subsequently conducted additional in-office

inspection activities, including interviews and discussions with BVPS staff and the

examination of additional documentation. The NRC conducted an exit meeting via

telephone conference call with Mr. Lash and other members of his staff on August 22,

2006. No proprietary information was provided to the inspectors during this inspection.

A-1

Attachment

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Lash, Vice President, Beaver Valley Power Station

G. Halnon, Director, FENOC Fleet Regulatory Affairs

S. Vicinie, Manager, Beaver Valley Emergency Preparedness

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000334/2006009-01, 05000412/2006009-01

AV

Failure to provide adequate

corrective actions to a previously-

identified emergency preparedness

exercise weakness.

Closed

None.

Discussed

None.

LIST OF DOCUMENTS REVIEWED

Section 1EP1: Exercise Evaluation

BVPS Emergency Plan

BVPS Emergency Plan Implementing Procedures

BVPS Evaluated Exercise Executive Summary

BVPS Evaluated Exercise Scope and Objectives

BVPS Evaluated Exercise Scenario and Radiological Release Data

BVPS Evaluated Exercise Event Logs

Procedure 1/2-EPP-I-5, General Emergency (Revision 22)

Procedure 1/2-EPP-IP-2.6, Environmental Assessment and Dose Projection Controlling

Procedure (Revision 17)

Procedure 1/2-EPP-IP-2.6.1, Dose Projection - Backup Methods (Revisions 13)

A-2

Attachment

Procedure 1/2-EPP-IP-2.6.2, Dose Projection - ARERAS/MIDAS With FSAR Defaults

(Revision 13)

Procedure 1/2-EPP-IP-2.6.3, Dose Projection - ARERAS/MIDAS With Real Time Inputs

(Revisions 11, 12, and 13)

Procedure 1/2-EPP-IP-2.6.4, Dose Projection - ARERAS/MIDAS With Manual Inputs

(Revisions 12, 13, and 14)

Procedure 1/2-EPP-IP-2.6.5, Alternate Meteorological Parameters (Revision 11)

Procedure 1/2-EPP-IP-2.6.6, Dose Projection By hand Calculation Known Isotopic Release

(Revision 7)

Procedure 1/2-EPP-IP-2.6.7, Release Source Term Determination Based On Field

Measurements (Revision 9)

Procedure 1/2-EPP-IP-2.6.8, Dose Assessment Based On Environmental Measurements and

Samples (Revision 7)

Procedure 1/2-EPP-IP-2.6.9, Integrated Dose Assessment (Revision 7)

Procedure 1/2-EPP-IP-2.6.10, Ground Contamination Assessment and Protective Actions

(Revision 8)

Procedure 1/2-EPP-IP-2.6.11, Dose Projections Miscellaneous Data (Revision 12)

Procedure 1/2-EPP-IP-2.6.12, Dose Projections - ARERAS/MIDAS With Severe Accident

Assessment (Revision 10)

Procedure 1/2-EPP-IP-4.1, Offsite Protective Actions (Revisions 17, 18, 19, 20, 21 and 22)

CR 04-04063, ERO Evaluated Exercise Recognition of Equipment Failure

CR 04-04071, Evaluated Exercise: Improve Methods for Determining Release Duration

CR 04-04081, Logic in Initial PAR Did Not Meet Procedural Requirements

CR 04-04232, Evaluated Exercise Potential Green Finding for Critique Failure

Supplemental Information from the BVPS Evaluated Exercise (dated July 10, 2006)

Additional Information from the BVPS Evaluated Exercise (dated July 12, 2006)

Additional Information from the BVPS Evaluated Exercise (dated August 3, 2006)

Emergency Recovery Manager Training Material

EA&DP and Environmental Personnel Training Material

Section 4OA1:Performance Indicator Verification

Procedure 1/2-ADM-1111, NRC EPP Performance Indicator Instructions

Drill and Exercise Performance PI Data, January 2005 - March 2006

ERO Drill Participation PI Data, January 2005 - March 2006

Alert and Notification System Reliability PI Data, January 2005 - March 2006

A-3

Attachment

LIST OF ACRONYMS

ANS

Alert and Notification System

CFR

Code of Federal Regulations

CR

Condition Report

DEP

Drill and Exercise Performance

EA&DP

Environmental Assessment and Dose Projection

ERO

Emergency Response Organization

EOF

Emergency Operations Facility

EP

Emergency Preparedness

ERO

Emergency Response Organization

FSAR

Final Safety Analysis Report

NRC

Nuclear Regulatory Commission

OSC

Operations Support Center

PAR

Protective Action Recommendation

PI

Performance Indicator

RSPS

Risk Significant Planning Standard

TSC

Technical Support Center