West ValleyDemonstration Project

Transportation EmergencyManagement Program

IndependentOversight Reviewof the

Office of

Independent

Oversight and

Performance

Assurance

September 2000

OV

ER

SIG

HTTable of Contents

EXECUTIVE SUMMARY ................................................................... 1

1.0 INTRODUCTION........................................................................... 4

2.0 RESULTS ......................................................................................... 7Hazards Survey and Hazards Assessment .................................... 7Program Plans and Procedures ..................................................... 8Emergency Responder Performance .......................................... 10Feedback and Continuous Improvement.................................... 12National Transportation Program/TCEAP ................................ 13Offsite Interfaces ........................................................................... 15

3.0 CONCLUSIONS AND OVERALL RATING ............................ 17

4.0 OPPORTUNITIES FOR IMPROVEMENT.............................. 18

APPENDIX A - EVALUATION PROCESS AND TEAMCOMPOSITION .................................................................................. 21

APPENDIX B - FINDINGS FOR CORRECTIVE ACTIONAND FOLLOW-UP ............................................................................. 23

Abbreviations Used in This Report

CFR Code of Federal RegulationsDOE U.S. Department of EnergyDOT U.S. Department of TransportationEAL Emergency Action LevelEOC Emergency Operations CenterEPZ Emergency Planning ZoneERO Emergency Response OrganizationHA Hazards AssessmentHazMat Hazardous MaterialsMPOSS Main Plant Operations Shift SupervisorNRC U.S. Nuclear Regulatory CommissionNTP National Transportation ProgramNTP-A National Transportation Program – AlbuquerqueOH/WVDP Ohio Field Office/West Valley Demonstration ProjectTCEAP Transportation Compliance Evaluation/Assistance ProgramWVDP West Valley Demonstration ProjectWVNS West Valley Nuclear Services Company

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Executive Summary

EVALUATION: Independent Oversight Review ofthe West Valley DemonstrationProject Transportation EmergencyManagement Program

SITE: West Valley Demonstration Project

DATE: September 2000

Scope

The U.S. Department of Energy (DOE) Officeof Emergency Management Oversight, within theSecretary of Energy’s Office of IndependentOversight and Performance Assurance, conducteda transportation emergency management review ofthe West Valley Demonstration Project (WVDP)and National Transportation Program (NTP)/Transportation Compliance Evaluation/AssistanceProgram (TCEAP) in September 2000. Theprimary purpose of this review was to assess theeffectiveness of the WVDP emergencymanagement programs for transportation eventsinvolving hazardous materials (not related to nuclearweapons components), including the adequacy ofdirection provided by DOE line management tosites under their cognizance. This included theexamination of the effectiveness of the Ohio FieldOffice, the Ohio Field Office/West ValleyDemonstration Project (OH/WVDP), andcontractor feedback and continuous improvementprocesses as mechanisms for identifying, analyzing,and addressing program deficiencies, implementingcorrective actions, and demonstrating and verifyingthe effectiveness of those actions. The secondpurpose of this review was to observe and evaluatethe effectiveness of TCEAP as an evaluation/assistance process for line management.

Background

DOE Order 151.1, Comprehensive EmergencyManagement System, provides the framework fordeveloping, coordinating, controlling, and directingall emergency planning, preparedness, response,

and recovery functions for events at fixed facilitiesas well as for transportation activities. Effectivemanagement of the site’s emergency response toan onsite transportation event is contingent uponthe same levels of preparation, preparedness, andresponse capability as the response to an event ata fixed facility. Under DOE Order 460.2,Departmental Materials Transportation andPackaging Management, the Office ofEnvironmental Management is responsible forpolicy and guidance related to transportationactivities across the Department.

Offsite transportation emergency managementrequires high levels of integration and coordinationamong the Department, sites, and state, local, andtribal governments. Shipments may traversemultiple jurisdictions before reaching theirdestination. The initial offsite emergency responseto incidents involving shipments of non-weapons-related DOE hazardous materials is theresponsibility of local authorities. Therefore, DOEmust ensure that mechanisms are in place toprovide, in a timely manner, initial responders withthe information needed to safely and effectivelyrespond to a transportation incident involving thesematerials. The Office of EnvironmentalManagement, through the Albuquerque OperationsOffice, assesses field implementation effectivenessand provides technical assistance through theTCEAP under the requirements of DOE Order460.2.

Results

The WVDP has established effective programsto support a response to a wide range oftransportation emergencies on and off site. WestValley Nuclear Services Company (WVNS) hasdeveloped safety analysis reports for site facilitiesand activities, a hazards survey, and a hazardsassessment. These documents provide adequatetechnical basis for the development of sitewideemergency action levels, coupled with pre-determined protective actions, to effectively addresspotential transportation emergencies. A hierarchyof comprehensive policies, plans, and procedures

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implements the WVDP Transportation Emergency Plan,which is an appendix to the Site Emergency Plan. Rolesand responsibilities for implementing the plans andprocedures are clearly defined for operationalemergencies resulting from transportation accidents. Inaddition, the Ohio Field Office and OH/WVDPoversight activities have contributed to the effectivenessof the emergency management program. The self-assessment programs, along with a well documentedand managed corrective action process, continue toenhance the emergency management program. WVDPhas established an effective set of agreements withoffsite agencies to support an emergency response.

Nonetheless, some performance weaknesses wereidentified. Performance tests conducted during theevaluation demonstrated that not all initial decision-makers (Main Plant Operations Shift Supervisors) caninterpret the shipping manifests and guidancedocuments that provide the information needed for aneffective emergency response to protect the public andthe environment. In addition, procedural weaknesseswere noted in categorization, classification, notification,and formulation of protective actions.

The TCEAP transportation compliance evaluationsof WVDP conducted by the Ohio Field Office providedmeaningful site-level feedback. The TCEAP alsoprovides guidance that facilitates timely corrective actionfor areas that are not in compliance. This linemanagement evaluation/assistance program has directlyresulted in improvements in the transportationmanagement program and contributed to site compliancewith DOE orders and Department of Transportationregulations. In addition, for this evaluation the offsitetransportation performance test historically associatedwith TCEAP was expanded to include onsite capabilitiesfor responding to an offsite event, thereby moreeffectively testing performance in accordance with DOEOrder 151.1, Comprehensive Emergency ManagementSystem.

The results of the individual TCEAP evaluationsacross the Department are currently provided throughan annual report, the first of which was issued in March2000. The plan for fiscal year 2000 is to disseminatethese lessons learned more widely through posting ona Web site and to distribute results quarterly; this planhas not yet been fully implemented. Currently theTCEAP focuses only on site contractor performance.A program to expand the assessment to include theeffectiveness of DOE field elements is under review.

Conclusions

The WVDP emergency management programcontains the essential elements of a transportationemergency management program as required by DOEOrders 151.1 and 460.2. WVDP has plans, procedures,tools, and agreements in place to implement the programfor the postulated emergencies. However, improvementis needed in initial decision-makers’ familiarity with andproficiency in using available procedures and guidanceto make timely, accurate decisions for transportationevents affecting the site, and in their ability to assistoffsite responders in reacting to postulated transportationemergencies.

The line evaluation/assistance program activitiesassociated with TCEAP are effective in stimulatingprogram improvement. TCEAP provided acomprehensive evaluation of the WVDP transportationprogram to ensure that the requirements of DOE Order460.2 and the Department of Transportation are met.Recent enhancements in the scope and rigor ofperformance tests associated with onsite transportationemergencies will permit a more thorough assessmentof performance in meeting Departmental requirements.In addition, timely sharing of site data throughout theDOE complex could enhance the TCEAP feedbackand improvement process.

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FINDINGS

As directed by the Office of the Secretary of Energy, DOE has established a process for recording, tracking,addressing, and resolving findings identified by the Office of Independent Oversight and Performance Assuranceas defined by DOE Order 470.2A, Security and Emergency Management Independent Oversight and Perfor-mance Assurance Program. The DOE Assistant Secretary for Environmental Management, as the cognizantsecretarial officer, and the DOE field element (Ohio Field Office/WVDP/Albuquerque), as the cognizant linemanager, are required to develop a corrective action plan to address the findings identified in this report.

1. Portions of emergency plan implementing procedures for responding to transportation events do not provideadequate, prompt decision-making tools for initial decision-makers.

2. Deficiencies in WVDP initial decision-makers’ knowledge and proficiency resulted in failures to determineapplicable protective action criteria, declare accurate categorization and classification, and perform timelynotifications during transportation emergency response performance testing.

Low-level Waste Being Shipped Off Site

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1.0 Introduction

The Office of Emergency Man-agement Oversight reviewed thetransportation emergency man-agement program at the WestValley Demonstration Project inSeptember 2000.

The U.S. Department of Energy (DOE)Office of Emergency Management Oversight,within the Secretary of Energy’s Office ofIndependent Oversight and PerformanceAssurance, conducted a transportationemergency management review of the WestValley Demonstration Project (WVDP) inSeptember 2000. The purpose of this reviewwas twofold. One purpose was to assess theeffectiveness of the WVDP emergencymanagement programs in dealing withtransportation events involving hazardousmaterials (not related to nuclear weaponscomponents), since the site is transitioning froma production operation to a decommissioning anddecontamination site with increasedtransportation shipments off site, and todetermine the adequacy of direction provided byDOE line management to sites under theircognizance. The second purpose was to observeand evaluate the effectiveness of theTransportation Compliance Evaluation/Assistance Program (TCEAP) administrated byDOE Headquarters through the AlbuquerqueOperations Office.

In 1997, the Acting Secretary of Energyapproved the Office of EnvironmentalManagement Redeployment Initiative, splittingthe transportation program into three groups.The organization structure of the NationalTransportation Program (NTP) is shown inFigure 1. The NTP is responsible for ensuringthe availability of safe, secure, and economicaltransport services; consistency in regulatoryimplementation; and coordinated outreach forDOE programs. The NTP is managed by a teamhaving Departmental crosscutting responsibilities,

staffed by representatives from DOEHeadquarters, the Albuquerque OperationsOffice, and the Idaho Operations Office, andorganizationally reporting to the AssistantSecretary for Environmental Management (EM-1). The team makes joint decisions aboutactivities that are shared complex-wide, such aspolicy development, budget preparation, andresource allocation. However, Headquarters’primary responsibility is program policy,Albuquerque’s primary responsibility is ensuringefficient transportation operations, and Idaho’sprimary responsibility is systems engineering.

DOE Order 460.2, Departmental MaterialsTransportation and Packaging Management,establishes DOE complex-wide requirements toensure that transportation operations are fullycompliant with applicable regulatory drivers. TheNTP-Albuquerque (NTP-A) assignsimplementation responsibility to all DOE fieldoffices. TCEAP, an element of the NTP-A,provides a systematic approach for DOE(Headquarters, field offices, programs, andcontractors) to use as a management tool inevaluating and enhancing transportationregulatory and policy compliance.

The review included elements ofthe Transportation ComplianceEvaluation/Assistance Program.

An element of the TCEAP evaluationsincludes the Department of Transportationrequirements and responsibilities for shippers andcarriers of hazardous materials. In the event ofa transportation incident/accident involving DOEmaterials, the shipper is responsible for beingable to immediately provide detailed informationto local emergency responders regarding thehazards associated with the shipment. Theshipper is also responsible for providing a 24-hour emergency response telephone number

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where such information can be obtained. Becausethe management and operating contractor, WestValley Nuclear Services Company (WVNS), is theshipper for WVDP, WVNS is responsible forproviding the emergency response information. TheOversight team collaborated with the TCEAP teamin this aspect of the WVDP evaluation.

Under DOE Order 151.1, ComprehensiveEmergency Management System, the Office ofEnvironmental Management is responsible for allemergency management systems at WVDP,including transportation activities. The Office ofEnvironmental Management, as the lead programsecretarial office, is responsible for providingoverall program guidance and direction throughthe DOE Ohio Field Office to OH/WVDP andWVNS. The responsibilities of WVNS includethe site’s emergency management program. BurnsInternational Security Services is a subcontractorwith limited emergency management roles andresponsibilities.

The WVDP is located on approximately 200acres within an approximately 3,300 acre NewYork State-owned reservation. It is the site ofthe only commercial nuclear fuel reprocessingfacility ever to have operated in the United States,having operated from 1966 through 1972 under aU.S. Nuclear Regulatory Commission (NRC)license. In 1980, Congress enacted the WVDPAct (PL 96-368), which directed DOE to:

1. Develop containers suitable for the permanentdisposal of high- level radioact ive wastesolidified at the WVDP.

2. Solidify the high-level liquid waste at the WestValley site into a solid form suitable for transportand disposal.

3. Transport the solidified waste, as soon aspossible, to a Federal repository for permanentdisposal.

Figure 1. National Transportation Program Organization

NTP Management Team

DOE - HQProgram Policy

DOE - ALTransportation &

Packaging OperationsTCEAP

DOE - IDTransportation

System Engineering

DOE Field OfficesSite Transportation &

Packaging Management

Asst. SecretaryEnvironmental Management

Environmental ManagementDefense ProgramsNuclear Energy/Naval ReactorsCivilian Radioactive WasteNonproliferation & National SecurityField Offices

DOE Senior ExecutiveTransportation Forum

Secretary of EnergyDeputy Secretary of Energy

National Transportation Program Steering CommitteeDOE - Headquarters (HQ)DOE - Albuquerque (AL)

DOE - Idaho (ID)

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4. Dispose of WVDP-generated low-level andtransuranic wastes.

5. Decontaminate and decommission facilitiesused by the WVDP according to requirementsprescribed by the NRC.

The NRC license is held in abeyance whileDOE is conducting the project. Pursuant to theWVDP Act, DOE entered into a memorandum of

Platform for Upcoming Spent Fuel Rail Shipment

understanding with the NRC in 1981 to clarifythe roles of the parties with respect to the WVDP.

In addition, under a separate contractualarrangement with Nuclear Fuels Services (NFS),DOE took title to 125 spent fuel assemblies instorage in the Fuel Receiving and Storage facility.The spent fuel will be shipped to the IdahoNat ional Engineer ing and Envi ronmenta lLaboratory in 2001.

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2.0 Results

The evaluation addresses areas included in DOEOrder 151.1, review of emergency managementprograms, and corrective actions selected fromprevious WVDP self-assessments and the 1997TCEAP evaluation. Each section includes keyobservations, conclusions, and a rating ofSatisfactory, Marginal, or Unsatisfactory. Theseratings are used to communicate the effectivenessof program implementation and to provide aperspective on where line management attention iswarranted. Appendix A provides a more detailedexplanation of the rating system.

Hazards Survey and HazardsAssessment

The hazards survey and hazardsassessment provide anadequate basis for emergencymanagement planning.

DOE Order 151.1 requires that the scope andextent of emergency planning and preparedness at aDOE site be commensurate with the hazards. Inaccomplishing this graded approach, emergencymanagement planning efforts begin with the hazardssurvey, wherein site-specific hazards and associatedemergency conditions that may require response arequalitatively identified and assessed. If the qualitativeprocess identifies hazardous material in quantities thatpose a potential serious threat to workers or publichealth and safety, then a quantitative emergencyplanning hazards assessment (HA) is performed toestimate the severity of the impact. The assessmentresults should provide the technical basis fordetermining the scope of the site’s comprehensiveemergency management system. This reviewdetermined that the WVDP hazards survey and HAgenerally addressed the transportation attributesrequired by applicable requirements and guidance.However, some technical errors in assumptions andconclusions were noted that prevent the documentsfrom being fully consistent with DOE orders andguidance, but do not impact public safety; these arediscussed in the following paragraphs.

The WVDP hazards survey, last revised in May2000, includes a comprehensive list of facilities atthe site that may be the source of a potentialhazardous material release. General categories ofemergency events that could cause such a potentialrelease include natural phenomena, malevolent acts,and transportation activities. Offsite activitiesassociated with transportation arteries andcommercial facilities are also considered, but nohazards were identified that could adversely affectthe site. In addition to reviews of radiological andtoxicological databases to determine inventories ofmaterials requiring quantitative analysis, physicalwalk-downs of facilities were performed to confirmdatabase accuracy and the facility conditions thatwere used for performing the quantitative analysesin the HA. The hazards survey is based onchecklists of appropriate questions to achievecomprehensive survey information, uniformity ofobservations, and good documentation of results.The survey information is presented in tabular form,making the document a good emergency planningand response tool. The hazards survey is updatedannually to ensure its currency.

The WVDP HA, updated and revised in July2000, describes the assessment process, facilityoperations, processes, site demographics, andhazards. Also described are the administrativecontrols and engineered safety features that aid inthe identification of barriers to releases and theformulation of the HA output products, such asemergency action levels (EALs). The HA relies

Loading Low-level Waste for Transport

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the EPZ as, “the 200 acre fenced facility boundary,”an irregularly shaped rectangle. The EPZ computedand proposed by the HA should correspond to thedefined EPZ in the Emergency Plan.

The Oversight team reviewed the aboveinconsistencies with the DOE order and applicableguidance and determined that no impact on public safetyis incurred for the following reasons. The HA properlydefines the site boundary as approximately 1050 metersfrom the center of the secured area, even though apublic road runs along the west side of the facilityapproximately 200 meters from facility release pointsof interest. However, the road is not considered thenearest site boundary because available resources cancontrol access to it within one hour of an emergencydeclaration. This criterion is consistent with applicableguidance. Additionally, the extent of hazards iscontinually undergoing reduction, including near-termtermination of operations of the main plant. If the roadis promptly closed upon emergency declaration,members of the public will not receive a radiologicaldose approaching protective action criteria. TheOversight team therefore concluded that the public isprovided an adequate margin of safety, notwithstandingthe inconsistencies in assessment technical basis andresults, and that the EPZ defined in the EmergencyPlan is adequate.

In conclusion, with few exceptions the processfor developing and maintaining the hazards surveyand HA is effective, result ing in accurate,comprehensive documents to serve as the foundationof the transportation emergency managementprograms. The hazards survey and HA adequatelydescribe and assess activities, facilities, and processesthat could be affected by emergency conditions.Although inconsistencies with DOE orders and guidancewere noted, public safety is not compromised, and thedocuments provide an acceptable basis for emergencymanagement planning.

Rating: Satisfactory

Program Plans and Procedures

Overall plans and procedures areeffective.

An effective emergency management plan must bedocumented to define and convey top-level

heavily on process hazards analyses performed for anddocumented in the site safety analysis reports. Thoseanalyses provide technical basis information on facilityand activity hazards, accident scenarios, and mitigativefeatures, leading to identification of the accidents thatrepresent the greatest risk to onsite personnel and thepublic. Because the persons who are responsible forreviewing engineering modifications or other plantprocess changes are also responsible for preparing theHA, any changes that could increase the hazardsanalyzed in the HA are immediately known to theanalysts, and compensatory measures can be put inplace before the hazard is introduced.

In the area of transportation activities, most of thehazardous materials that the site has in amounts exceedingthreshold planning quantities are appropriately addressedby screening or quantitative assessment. However, nitricacid is delivered to the site in quantities exceeding thethreshold planning quantity, but has not been assessed orscreened in the HA. The Oversight team reviewed deliveryfrequencies and procedural controls on deliveries of nitricacid to the site. Only one more delivery will be made in2000, and there will be only a few more deliveries insubsequent years as facility operations cease.Administrative controls, such as security management oftraffic and strict procedural adherence, make an eventinvolving nitric acid less likely than the calculatedprobability. Thus, the Oversight team concluded that suchan event could be screened from the HA.

The Oversight team noted concerns about thedefinitions of the facility boundary and the emergencyplanning zone (EPZ). The “facility boundary” usedfor assigning emergency classes in the HA is 500meters—the shortest distance from the center of the220-acre WVDP site to the perimeter security fence.However, the center of the site does not represent apotential release point. DOE guidance suggests a facilityboundary of not less than 100 meters, or more than200 meters. Other criteria include consideration ofdefining the “facility” as the entire fenced security areaand using the minimum distance from a likely releasepoint to the closest perimeter fence as the analysis radiusfor all consequence calculations. At WVDP this distanceis approximately 125 meters, not 500 meters. The resultof the inappropriate selection of the facility boundary isthat several events are categorized as operationalemergencies not requiring classification when they maybe classifiable emergencies. In addition, whereas theHA states that, “Consistent with DOE guidance, theminimum EPZ radius for all Operational Emergenciesis 500 m (1640 ft),” the WVDP Emergency Plan defines

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management’s emergency management philosophy andpresent a program that complies with DOE Order 151.1for the facilities/programs within its purview. Specific,comprehensive implementing procedures must bedeveloped in conformance with the documentedprogram, and these implementing procedures must beusable by the personnel responsible for theirimplementation. The West Valley emergency plancontains the essential elements of an emergencymanagement program required by DOE Order 151.1,and WVDP has developed a series of procedures thatimplement the plan. The plan and implementingprocedures are appropriate for transportationemergencies postulated for WVDP activities.

The WVDP Transportation Emergency Plan, acomponent of the sitewide emergency plan, is primarilyintended to address offsite transportation accidents. Ifthe emergency operations center (EOC) were activatedfor an offsite transportation incident, a TransportationEmergency Management Organization, which is a subsetof the emergency response organization (ERO), wouldstaff the EOC. The Transportation EmergencyManagement Organization would also be available as atechnical resource in responding to an onsite spill ofhazardous material that is not severe enough to becomea classified emergency. Implementing procedures forthe Transportation Emergency Plan include emergencyinstructions for all WVDP employees, describing boththe tactical field response and the strategic commandresponse, and detailing the responsibilities of the ERO.

When a shipment leaves the WVDP site, a packageof shipping papers is provided to the Main PlantOperations Shift Supervisor (MPOSS) office. Inaddition to documentation required by the Departmentof Transportation (DOT), an EAL Shipping Notice isattached as a cover to the package, indicating whetherthe shipment includes containers of hazardous materialthat if released would constitute an operationalemergency. The Oversight team’s review of a sampleof shipping papers found that the information requiredby DOT regulations was present.

Typically, the initial notification of an offsitetransportation accident involving a WVDP shipmentcomes from the carrier or local response agency toWVDP Security. Security then transfers the call to theMPOSS. Onsite transportation accidents would also bereported to the MPOSS and, in accordance with plantprocedures, he would assume the role of incidentcommander and interim Emergency Director. TheMPOSS evaluates the situation using the WVDPshipping package and EALs for transportation eventsand categorizes the event.

When an operational emergency is declared due toa transportation incident/accident, the EOC is activatedand staffed by the Transportation EmergencyManagement Organization, Notification Officer, andPublic Information Director. The TransportationEmergency Management Organization assesses theevent, validates the event categorization, and providessupport to the on-scene response effort, if requested.A technical assistance group called the TransportationEmergency Response Organization would be availablefor field response or to provide information andconsultation to the on-scene incident commander. TheTransportation Emergency Plan also provides for, ifrequested, an on-scene public affairs presence (foroffsite events), if the event is expected to generate ahigh degree of public interest. However, this activity isnot addressed in the Emergency Public InformationPlan.

A hierarchy of site procedures, functionalorganization procedures, and individual proceduresimplement the site emergency plan. Emergencymanagement procedures include checklists to provideERO members with line-entry reminders of tasks tocomplete, together with references to other proceduresor sections.

Emergency categorization and classification areimplemented with a flowchart decision-making treedirecting the user to appropriate tables of thresholds foroperational emergencies not requiring classification andEALs for emergencies involving hazardous materialreleases requiring classification. Thresholds required bythe order, including criteria for offsite hazardous materialevents for both DOE and non-DOE shipments, areprovided in tabular listings. The site has also addressedother events not required by the order, such as loss ofplant annunciators and site power, to provide conservativedecision-making tools. Pre-determined protective actionsare included with the thresholds to promote promptdecision-making. However, several procedural weaknesseswere noted that contributed to MPOSS performanceproblems identified later in this report:

• Several emergency events are listed as Event Class“BELOW an ALERT.” DOE orders and guidance donot provide for such a declaration. Several of theseevents might be Alerts if the DOE guidance concerning“facility boundary” definition were followed asdiscussed in the previous section of this report.

• The tables of thresholds for operational emergenciesnot requiring classification (which include offsite

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emergencies) are footnoted with, “If the potentialexists for the emergency to escalate, consider takingthe conservative approach by classifying theemergency as an Alert.” Classification does not applyto offsite emergencies included in the table. Thisfootnote was inappropriately applied to offsite eventsduring two tabletop exercises, resulting in offsiteevents classified as an Alert.

• One Site Area Emergency EAL exists at WVDP:activation of main plant stack monitor alarms andlow differential pressure alarm, together with failureof plant ventilation high efficiency particulate air(HEPA) filters. The recommended protective actionsfor the EAL direct onsite actions only. Closure ofthe public road alongside the plant (Rock SpringsRoad) is not directed to establish control of the DOEsite as an anticipatory or mandatory action, eventhough the road is approximately 200 meters fromthe release point, and the projected dose is 1 rem at500 meters. Discretionary footnotes for all EALsand a procedural step in an EOC checklist addressroad closure but are not specifically related to thisEAL.

Concerns were also noted in procedures related tonotification processes. Formal mechanisms are not inplace to ensure prompt notifications of local and stategovernment under all circumstances. For example, amutual aid request processed through a centralized dispatchsystem, such as fire or medical, serves as the onlynotification to the county. At the state level, the site relieson the recall of the New York State Energy Research andDevlopment Authority (NYSERDA) representative forERO activation to constitute prompt notification to stateofficials. Documentation of the acceptability of thisarrangement in lieu of a formalized protocol was notavailable. Additionally, the form used to initially notifyDOE Headquarters of emergency conditions does notinclude items such as the affected facility/activity and abrief description of the event, including location, prognosis,and offsite support needed and requested.

FINDING: Portions of emergency planimplementing procedures for responding totransportation events do not provide adequate,prompt decision-making tools for initial decision-makers.

With some noted exceptions, WVDP hasimplemented a hierarchy of site plans and procedures,

flowing from the safety analysis report, that permiteffective management of transportation emergencyresponse activities. Site emergency plan implementingprocedures include many positive attributes, such ascomprehensive EAL thresholds and pre-determinedprotective actions for potential emergency conditions.Weaknesses that were noted in some procedures directlyrelated to transportation emergency event responsedetracted from responder performance (noted later inthis report), but overall program plans and proceduresare effective.

Rating: Satisfactory

Emergency Responder Performance

Initial decision-makers clearlyunderstand their roles andresponsibilities associated withtransportation events.

The MPOSS is the 24-hour-per-day initial decision-maker with responsibilities and authority for offsite andonsite transportation events involving hazardousmaterials. With the exception of the previously identifiedprocedural weaknesses, the MPOSS has decision-making tools available for providing emergency responseinformation to offsite authorities 24 hours a day.Similarly, tools are generally available to the MPOSSto initiate the response to site transportation events toeffectively mitigate consequences. However, in somecases expert knowledge and proficiency are requiredfor determining protective actions, categorizing andclassifying events, and making notifications with existingprocedures. Several instances were noted where theMPOSS could not provide expertise to offsiteresponders and could not implement all required actionsfor events on or affecting the site.

As part of the Department’s ongoing TCEAP, ateam composed of Ohio Field Office and DOE Officeof Environmental Management representatives evaluatedWVDP transportation activities coincident with theOversight assessment. TCEAP activities includedevaluation of the WVDP ERO’s ability to immediatelyprovide emergency response information required byDOT (49 CFR 172.602 – 604), and assessment ofWVDP’s transportation emergency response. TheTCEAP team developed hypothetical offsite scenariosfor transportation accidents that could reasonably occurfor WVDP activities. Performance-based evaluation

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objectives for the TCEAP and Oversight team weremutually addressed through conduct of the scenarios.These scenarios were presented to the five shiftsupervisors who could serve as the site’s initialEmergency Director.

Two exercises simulating a call from a remoteemergency scene involving a WVDP shipment wereperformed, one of which was conducted during theback-shift to confirm the immediate availability of aknowledgeable person with access to shipmentmanifests. Additionally, two tabletop exercises wereperformed for each of four supervisors, simulating atransportation event at a remote location, and atransportation event adjacent to and directly affectingthe site. The remote location scenario was designed torequire implementation of the site TransportationEmergency Plan, confirm supervisor knowledge of thehazardous material being shipped, and confirm thatcomprehensive emergency response and incidentmitigation information for an actual shipment manifestcould be provided. The second scenario (event nearthe site) required implementation of the site emergencyplan.

Both scenarios tested the supervisor’s ability toformulate and implement the time-urgent decisions thatare required in the initial stages of a transportationresponse effort. Shift supervisors were encouraged tomake use of all reference materials and resources thatwould normally be available to them in responding toan incident or emergency. A TCEAP team memberand an Oversight team member conducted eachperformance test. At least one individual from theWVDP emergency management staff was present toensure clear communications using site-specificterminology, and to help validate the observations ofthe evaluation teams.

The performance tests indicate that the WVDP shiftsupervisors clearly understand their roles andresponsibilities associated with being a site initialresponder and decision-maker during the early stagesof an event affecting the site. They also demonstratedgood knowledge of their roles and responsibilities ininterfacing with offsite initial responders to atransportation event involving WVNS as the shipper ofrecord.

For transportation emergencies affecting the site,all supervisors initiated actions to assess the sceneconditions and to determine event parameters to initiatethe correct response. However, shift supervisors wereunable to fully employ the 2000 Emergency ResponseGuide to determine the potential consequences of

hazardous material releases and the applicable protectiveaction criteria. Difficulties ranged from not being ableto access hazardous material data given its identificationnumber, to not being able to determine protective actioncriteria for various amounts of material released undervarious meteorological conditions. Notwithstandingdifficulties in interpreting the 2000 Emergency ResponseGuide, all supervisors promptly initiated appropriateprotective actions for site personnel to shelter in place.Some supervisors were not familiar with and did notmake good use of emergency implementing procedures,and consequently were slow to accomplish tasks or didnot complete tasks correctly. Most supervisors promptlyand properly activated the ERO, but one supervisorcould not locate the appropriate procedure, resulting inexcessive delay. Only one supervisor was able toaccurately categorize and classify both events correctly.Classification errors included:

• Emergency events not categorized as operationalemergencies

• Events not declared due to concern that site workersmight move around on the site upon emergencydeclaration, even when ordered to shelter in place

• Declaration of an event as an Alert even though theevent scene was remote from the site.

Most supervisors initiated notifications in a timelymanner, but one supervisor would not performnotifications without an Alert declaration. Anothersupervisor could not find the appropriate form and wasunsure of his responsibilities in providing the TimelyNotification Officer with information necessary tocomplete the notification process.

The following observations apply to responseactivities unique to scenarios involving the postulatedemergency event remote from the site. AlthoughSecurity Officers were proficient in immediatelyobtaining a callback number to use if the telephone weredisconnected, not all supervisors immediately confirmeda callback number with the scene incident commander.One shift supervisor purposely disconnected from thescene incident commander while re-locating to his officeto access shipping papers for the emergency event, apractice that was immediately corrected by plantmanagement. Supervisors have no standard format forrequesting and consistently documenting sceneinformation from the scene incident commander, suchas container integrity, time of day, and meteorologicalconditions, to ensure that field data are sufficient toprovide an appropriate response. Consequently, repeat

12

requests for additional information were frequent. Otherproblems included one supervisor experiencing difficultyin correlating the field information on shipping containeridentification with the correct manifest to allowdetermination of applicable emergency responseinformation.

FINDING: Deficiencies in WVDP initial decision-makers’ knowledge and proficiency resulted infailures to determine applicable protective actioncriteria, declare accurate categorization andclassification, and perform timely notificationsduring transportation emergency responseperformance testing.

In conclusion, tools in the form of procedures,equipment, and facilities are generally available to permitthe WVDP ERO to respond adequately to siteemergencies. Shift supervisors are able to implementpre-determined protective actions for plant workersimpacted by emergencies affecting the site. However,deficiencies in shift supervisor knowledge andproficiency in using tools specific to transportationemergencies kept them from adequately fulfilling theirroles and responsibilities under these circumstances.Weaknesses in initial decision-maker tasks, such asformulation of protective actions that have not beenpre-determined, categorization and classification ofemergencies, and performance of required notifications,require management attention.

Rating: Marginal

Feedback and Continuous Improvement

Feedback and continuousimprovement processes havecontributed to overall programeffectiveness.

The WVDP has implemented effective processesintended to support the goal of continuous improvementin the site’s emergency management program. TheWVDP emergency management program includescritical assessments of sitewide emergency preparednessand the subsequent preparation and implementation ofwell-conceived corrective action plans. The WVDPreceives feedback and corrective actions for theemergency management program from numeroussources, including the training and drills program,

exercises, the self-assessment program, and internal andexternal independent evaluations. Corrective actionsare effectively identified, assigned to responsibleindividuals, tracked to completion, and validated uponclosure.

WVNS has established a well documented self-assessment program that provides roles andresponsibilities, scheduling, conduct of the assessments,reporting, documentation of issues and concerns, andcorrective action tracking. Each organization isresponsible for conducting and reporting the results ofits self-assessment. The West Valley EmergencyManagement Department structures its self-assessmentsbased on the program elements embodied in theemergency management guides and verifies compliancewith DOE Order 151.1. The assessment program iscontinuous, with three or four elements formallyassessed each fiscal year. WVNS has developed a seriesof forms with documented lines of inquiry for eachprogram element. These forms cover the majorprogrammatic and evaluation criteria of DOE Guide151.1-1, Draft Volume VI, Emergency ManagementEvaluations. In general, the Oversight team found thatthe self-assessment documentation adequately addressedeach program element.

Once the self-assessment is completed, the reportis submitted to the organizational manager. Those thatrequire modification of plans, procedures, training, orperformance are assigned to the appropriate staffmember for action and are tracked in the Open ItemsTracking System, unless they were corrected on thespot. Actions items that are “not significant,” asdetermined by the responsible manager, are not requiredto be tracked. This review found one instance wherethe action to schedule meetings with offsite agenciesand conduct offsite plan reviews was not accomplishedand no follow-up action was initiated. Through thispractice, the site is missing the opportunity to track andtrend such items.

In addition to the self-assessment program, theWVDP site has been subject to operational readinessreviews, TCEAP evaluations, and the voluntaryprotection program process, as well as audits by OH/WVDP and the Ohio Field Office. Findings,recommendations, and opportunities for improvementhave been documented and evaluated, and, whenrequired, corrective action plans have been developed,tracked, and implemented. A representative sample ofcorrective actions (Ohio Field Office Surveillance ReportS99-035E) was reviewed by the Oversight team, and itwas determined that the actions were appropriate and

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tracked to completion in accordance with WVDP andOH/WVDP procedures. The WVDP SecurityDepartment has been proactive, using best practices, inconducting a security assessment in support of the spentfuel shipment project. Security has conducted theassessment, used the information to enhance the securityposture of the shipment, and proceduralized Securitysupport during the actual shipment process

Once the need for corrective action has beenidentified, a corrective action plan is developed andsubmitted to the appropriate OH/WVDP representativefor approval. It was noted that the three correctiveaction plans submitted by WVNS to OH/WVDP (inresponse to the triennial exercise, the TransportationEmergency Plan exercise, and an Ohio Field Officesurveillance report) were initially disapproved by OH/WVDP and required resubmission. This demonstratescritical analysis during the review and approval processconducted by OH/WVDP but may also indicate adisconnect in coordination between the contractor andOH/WVDP. Upon completion of the corrective actions,the responsible OH/WVDP manager closes out theproject task. Task closeout is validated by OH/WVDPQuality Assurance, unless closeout requires the conductof an exercise.

The WVNS system of tracking action items providesa series of checks and balances by assigning individualsto take responsibility for completing identified actionsand requiring signoffs by managers and supervisors toensure that the action has been completed. The systemprovides reports, which WVNS and the OH/WVDPpersonnel use to check on the status of any action item.The OH/WVDP Correspondence and CommitmentControl and Tracking program provides for a contractor-independent system to identify responsibilities, trackactions, and validate closure of site action items. BothOH/WVDP and WVNS have established effectiveprograms to manage the corrective action process.

The Oversight team reviewed the complete correctiveaction process as it was applied to the TransportationEmergency Plan exercise conducted on October 20, 1999.Although the field response elements met their exerciseobjectives and overall performance was good, multiplesignificant problems were identified in the site’smanagement of the response. OH/WVDP stated in itssurveillance report (S00-005, Transportation EmergencyPlan Exercise) that the exercise “failed to adequatelydemonstrate implementation of the WVDP TransportationEmergency Plan.” In response, a corrective action planwas prepared and submitted to OH/WVDP on November29, 1999. In subsequent discussion and review of

corrective actions between the OH/WVDP and WVNS,it was determined that an evaluation of the entire emergencymanagement program was needed because performanceindicators identified emergency management programmaticissues above the Transportation Emergency Plan issues.All corrective actions were tracked in the Open ItemTracking System and subsequently completed. Theseactions were independently reviewed by the Oversightteam and verified to be complete. The effectiveness ofthese corrective actions, as well as the TransportationEmergency Plan, will be validated by a TransportationEmergency Plan exercise (either field exercise or tabletopexercise). The schedule of this exercise will be determinedin conjunction with the preparation of the annual submittalof the Emergency Readiness Assurance Plan, dueSeptember 30, 2000.

In addition to site assessments, WVDP actively usesoutside source lessons-learned databases and reports,such as the DOE Occurrence Reporting and ProcessingSystem and the Society of Effective Lessons LearnedSharing, to identify enhancements to the emergencymanagement program. An individual is assigned toreview lessons learned, identify reports pertinent toWVDP, and forward them to the appropriate manager.Participation in industry conferences also effectivelycontributes to program enhancements.

In conclusion, Ohio Field Office and OH/WVDPoversight activities, as well as WVNS self-assessments,have contributed to the effectiveness of the emergencymanagement program. Additionally, WVNS and OH/WVDP have effective corrective-action and lessons-learned programs and consistently use the processeswithin these programs to implement corrections andenhancements to the emergency management program.Specifically, OH/WVDP and WVNS corrective actionplanning, task identification and tracking, andimplementation of corrective actions are welldocumented and managed.

Rating: Satisfactory

National Transportation Program/TCEAP

Thorough evaluations are beingconducted in accordance with theTransportation ComplianceEvaluation/Assistance Program.

The Office of Environmental Managementadministers the NTP. In 1997, the program was

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redeployed from DOE Headquarters to Albuquerqueand Idaho, with Headquarters maintaining responsibilityfor policy. The National Transportation Program Planissued by Albuquerque in July 1998 provides the rolesand responsibility for each of the Offices. DOE Order460.1, Packaging and Transportation Safety, DOEOrder 460.2, Departmental Materials Transportationand Packaging Management, and the DOEHeadquarters Functions, Responsibilities and AuthoritiesManual have not been updated to reflect theorganizational responsibilities implementing the NTP.

The primary goal of the NTP is to ensure safe,efficient, and timely transportation of DOE materials.Consistent with this goal, DOE Order 460.2 and theNational Transportation Program Plan require the DOEoperations and field offices to conduct complianceassessments at each DOE contractor facility, no lessthan every three years. This requirement has beenimplemented through the TCEAP, which has establisheda systematic approach for evaluating and enhancingtransportation and packaging regulatory and DOE policycompliance.

Coincident with the Oversight assessment, aTCEAP team composed of Ohio Field Office and Officeof Environmental Management representatives evaluatedWVDP transportation activities. TCEAP team activitiesincluded evaluation of the WVDP ERO’s ability toimmediately provide emergency response informationrequired by DOT (49 CFR 172.602 – 604) andassessment of WVDP’s initial response to transportationemergencies. The TCEAP team developed hypotheticaloffsite scenarios for transportation accidents that couldreasonably occur for WVDP activities.

The Oversight team evaluated TCEAP teamperformance in conducting performance-based tabletopexercises for the WVDP shift supervisors. The TCEAPexercise controller prepared challenging exercises thatfulfilled the objectives of both the TCEAP team and theOversight team, and provided the site with assistance indeveloping another meaningful training methodology. Theincreased scope of the TCEAP exercises to include bothnear-site and remote transportation events afforded thesite the opportunity to critically examine more elements oftheir program related to DOE Orders 460.2 and 151.1.The exercises were conducted in a professional manner,and included a 100 percent performance test of day-shiftand back-shift shift supervisors. Day-shift and back-shiftcalls from the “field” realistically exercised the WVDP24-hour telephone numbers.

During the WVDP evaluation, the TCEAP teamdemonstrated a thorough system for evaluating program

compliance through interviews and documentationvalidation. During their process, the TCEAP teammembers explained to site personnel the source ofrequirements that their program was being evaluatedagainst. When issues were identified, the TCEAP teammembers provided on-the-spot assistance and guidanceon how to correct the concern.

Also as part of their assessment, the TCEAP teamperformed a validation of corrective actions from their1997 TCEAP evaluation at WVDP and also evaluatedthe WVDP review of lessons learned from the Type Binvestigation report of the Fernald incident regarding aleaking low-level waste container. The TCEAP foundthat corrective actions for the 1997 TCEAP evaluationwere promptly completed. With respect to the Fernaldincident, WVDP performed an extensive review andresponded with a report providing the bases forconcluding that no action on their part was necessary.

A TCEAP report is developed for each facilityevaluation that if shared with the DOE complex wouldprovide valuable lessons learned. Other sources oftransportation-related lessons-learned information includethe DOE Packaging and Transportation MeasurementMethodology for Safety Metrics Indicator Program(SMIP) and the TCEAP annual report, both publishedby NTP. These reports provide summaries of eventsand lessons learned, as well as complex-wide statistics,on an annual basis. Also, there is currently a bi-monthlyconference call between TCEAP and complex-widetransportation managers to discuss issues, and the minutesare produced and distributed; however, the minutes area rollup summary without the necessary details oflessons learned. The first TCEAP annual report (March2, 2000) states, “For FY-2000, NTP-A will provide aquarterly status report or update for lessons learned.The lessons learned will be provided through the NTP-A web site and will be available to all DOE and contractortransportation managers.” These actions have not beenimplemented. The Office of EnvironmentalManagement has not established a formal mechanismfor sharing and trending lessons learned for programoffices responsible for onsite and offsite transportation.Additionally, DOT audit results at the various DOE sitesare not available for others sites to learn from. NeitherDOE Order 460.2 nor its associated implementingprocedures currently include a discussion of complex-wide sharing of assessment results that would facilitateprogram improvement.

In addition to TCEAP evaluations of facilitycontractors, as described above, DOE Order 460.2requires technical assessments of the DOE field

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elements. However, no minimum time frequency isspecified for the DOE field element assessments, andnone have been initiated. A draft plan for conductingDOE field element assessments (Field OfficeTransportation Evaluation Program Management Plan)has been developed; it has not yet been approved andis currently under review by the Field ManagementCouncil.

In conclusion, transportation compliance evaluationsof DOE facility contractors are being conducted inaccordance with the TCEAP procedure. The TCEAPteam demonstrated a thorough system for evaluatingprogram compliance through interviews anddocumentation validation. Their evaluations providemeaningful site-level feedback that results inimprovements to the transportation emergencymanagement program. Additionally, the TCEAPperformance-based testing offers a substantivecontribution to site readiness for transportationemergencies. The performance tests were challenging,fulfilled their objectives, and were conducted in aprofessional manner. However, the benefits of theTCEAP evaluations are generally limited to the site beingreviewed since TCEAP has not implemented its plansto distribute lessons learned. In addition, althoughTCEAP evaluations are implemented and effective,DOE Order 460.2 also requires evaluation of the DOEfield elements’ transportation and packagingmanagement to ensure compliance. This requirementhas not yet been implemented.

Rating: Satisfactory

Offsite Interfaces

Offsite interfaces are well understoodand documented.

WVDP has recognized its fundamental responsibilityto protect the public effectively in the event of atransportation emergency. This responsibility is sharedwith a range of external organizations and stakeholders.Among these stakeholders are other Federal agencies;state, county, and local governments; regulatoryagencies; law enforcement agencies; and hospitals.These relationships were individually and collectivelyfostered in a comprehensive program of planning,preparedness, and response to establish and sustain aneffective working partnership.

The WVDP Site Emergency Plan containsnumerous memoranda of agreement that have beenestablished with county and state law enforcementagencies; local fire department and hazardous material(HazMat) authorities; and local hospitals. Theseagreements are comprehensive and form a basis forcommunicating roles and responsibilities, dispatchingmutual aid, carrying out security operations, andproviding for treatment and care of patients, which maybe necessary in an emergency. WVDP has establisheda process designating accountability for ensuring thatthese agreements are routinely reviewed and updatedwhen necessary. The Oversight team reviewed thememoranda identified within the FY 2000 EmergencyReadiness Assurance Plan (ERAP) and found them alleffectively maintained.

Routine meetings are conducted to keepstakeholders apprised of emergency managementprogram activities. For example, the WVDP providesoffsite support agencies with emergency responsetraining courses to respond to an onsite event. Thistraining provides an overview of the current siteboundaries and site facilities, a briefing on the WVDPincident command system, WVDP emergency responseequipment, radiation safety, issuance and wearing ofdosimeters, types of contamination, biological effects,and the WVDP emergency medical response team. Thetraining includes a site tour that identifies the locationof hydrants, hazardous material storage locations, andradiological areas. In addition to presenting training,WVDP continually provides skills training courses(HazMat training and Street Smart Chemistry training– September 2000) and information to offsite agenciesconcerning DOE-sponsored training courses (REAC/TS courseware). This information is critical since WVDPdoes not have a fire department or medical transport

Offsite Emergency Response Exercise

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unit on site. During the planning process for the October1999 WVDP Transportation Emergency Plan exercise,an exercise design and development team was formedto discuss offsite interfaces as they developed andconducted the exercise. Offsite agencies were alsoincluded in the post-exercise critique and evaluationprocess.

Overall, offsite interfaces related to transportationemergency management are well understood andfounded on a comprehensive set of agreements. These

agreements form a basis for communicating roles andresponsibilities, dispatching mutual aid, carrying outsecurity operations, and providing for treatment andcare of patients, which may be necessary in anemergency. WVDP partnership with the stakeholdershas been interwoven with virtually every element ofthe Site Emergency Plan.

Rating: Satisfactory

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3.0 Conclusions and Overall Rating

The West Valley emergency managementprogram contains the essential elements of atransportation emergency management program asrequired by DOE Orders 151.1 and 460.2. Withfew exceptions, the hazards survey and HA areaccurate, comprehensive documents that serve asthe foundation of the transportation emergencymanagement programs. WVDP has implementeda hierarchy of site plans and procedures, flowingfrom the safety analysis report, that include manypositive attributes such as comprehensive EALthresholds and pre-determined protective actionsfor potential emergency conditions. Tools in theform of procedures, equipment, and facilities aregenerally available to permit the WVDP ERO toimplement an adequate response to emergencies.DOE Ohio Field Office and OH/WVDP oversightactivities, as well as WVNS self-assessments, havecontributed to the effectiveness of the emergencymanagement program. Additionally, WVNS andOH/WVDP have effective corrective-action andlessons-learned programs and consistently use theseprocesses to implement corrections andenhancements of the emergency managementprogram. However, improvement is needed ininitial decision-makers’ familiarity with and

proficiency in using available procedures andguidance to make timely, accurate decisions fortransportation events affecting the site, and assistingoffsite responders in reacting to postulatedtransportation emergencies.

Overall Rating: West Valley DemonstrationProject – Satisfactory

The NTP line evaluation/assistance programactivities associated with TCEAP are effective instimulating program improvement. TCEAPprovided a comprehensive evaluation of the WVDPtransportation program to ensure that therequirements of DOE Order 460.2 and DOT aremet. Recent enhancements in the rigor and scopeof performance testing associated with onsitetransportation emergency response provide a morethorough assessment of the site’s performance inmeeting Departmental requirements. Improvementin the timely sharing of site data throughout theDOE complex could further enhance the TCEAPfeedback and improvement process.

Overall Rating: National TransportationProgram/TCEAP – Satisfactory

WVDP Ratings by Report Element

Hazards Survey and Hazards Assessment Satisfactory

Program Plans and Procedures Satisfactory

Emergency Responder Performance Marginal

Feedback and Continuous Improvement Satisfactory

Offsite Interfaces Satisfactory

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4.0 Opportunities for Improvement

The emergency management review conductedby the Independent Oversight team identified severalopportunities for improvement. These potentialenhancements are not intended to be prescriptive.Rather, they are intended to be reviewed andevaluated by the responsible DOE and contractorline managers, and prioritized and modified asappropriate, in accordance with site-specificprogrammatic and emergency managementobjectives.

West Valley Demonstration Project

• In the next revision of the hazards assessment,document the rationale for screening outhazardous materials. This documentationensures accuracy during reviews and qualitychecks and is in accordance with DOE Order151.1-1, Volume II, Hazards Surveys andHazards Assessments.

• During the next annual review of the hazardsassessment, the site should use the DOE guidance(DOE Order 151.1-1, Volume II, HazardsSurveys and Hazards Assessments) for definingthe facility boundary and recalculate releaseconsequences based on this boundary. Thisrecalculation may result in changes to currentEALs, such as closing Rock Springs Road.

• The WVDP hazards assessment is the technicalbasis for the development of the EPZ. The EPZlisted in the hazards assessment is different fromwhat is reported in the WVDP Emergency Plan.It is recommended that the EPZ in the hazardsassessment be re-evaluated for consistency withDOE orders and guidance. Additionally, ensurethat the EPZ determined in the hazardsassessment is accurately reflected in the WVDPSite Emergency Plan.

• The current Timely Notification Form (WV-3322) documents categorization, classification,whether a release is in progress, and protective

actions but does not identify which facility isinvolved, type of release (radiological or non-radiological), type of event (HazMat, security,etc.) or other pertinent information. It isrecommended that WVDP coordinate with theDOE Headquarters EOC (watch office) toidentify the critical information that the watchofficers are trained to extract during initialnotification and include this information in theTimely Notification Form. Additionally, it isrecommended that the form be reviewed by thestate and associated counties to ensure that theirexpectations are met. It is also recommendedthat this form be transmitted to the state andlocal 24-hour notification points as a backup forinitial notification to the State members of theWVDP EOC cadre and requests for assistancefrom county response elements.

• At WVDP, copies of shipping papers related toshipments of material that exceed EALs are givento the MPOSS for response to an offsitetransportation incident, accompanied by a coversheet, “EAL Shipping Notice.” WVDP shouldconsider filing the EAL notice sheet along withthe shipping paper files required by DOT, forhistorical completeness.

• Onsite hazardous waste transport is controlledby detailed procedures. In contrast, onsitetransport of hazardous chemicals is not controlledby specific procedure, although trained andqualified fork truck operators perform thetransports. Consider proceduralizing hazardouschemical onsite transport in the same manner ashazardous waste transport.

• The Transportation Emergency Plan states that,if requested, Public Affairs should dispatchassistance to the offsite event scene. It isrecommended that an “away-box” containingbriefing materials, charts, and tables be pre-staged for use at the event scene. The contentsand a procedure for use should be documentedin either a checklist or procedure.

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• The self-assessment forms used to assessemergency management were developed andpublished prior to the latest draft of DOE Guide151.1-1, Draft Volume VI, EmergencyManagement Evaluation. Self-assessment formsshould be reviewed against the programmatic andevaluation criteria contained in Volume VI toensure both performance and compliance with theindividual emergency management programelements at the WVDP.

• A joint review for consistency of the WVDP SiteEmergency Plan with the emergency plans of thelocal and state governments should be conducted.This ensures meeting expectations in informationflow, decision-making authorit ies, andcommunications. Additionally, it is suggested thatall meetings with offsite officials be documentedas part of the emergency management program.

• WVDP has done an excellent job in enhancingtheir emergency management program based onthe results of the 1999 Transportation EmergencyPlan exercise. Due to the extensive nature of thechanges to the plan and associated procedures, itis recommended that a series of functional andintegrated drills and tabletop exercises be used totrain the ERO and test the elements of theTransportation Emergency Plan.

• Provide additional emphasis on basic emergencymanagement training and drills for initial decision-makers. This will increase proficiency in criticalinitial actions, information collection, andregulatory notifications.

National Transportation Program/TCEAP

• The TCEAP mission statement states that it provides asystematic approach for evaluating and enhancingtransportation and packaging regulatory and DOE policycompliance. To accomplish its mission to “enhance,”NTP-A should expedite its plan to utilize its Web siteto post TCEAP evaluation results. Consideration shouldalso be given to posting TCEAP reports and DOTfindings. The posted information should include atleast quarterly updates of significant observations,trends, and lessons learned. Consideration should alsobe given to establishing a tracking system to ensureappropriate follow-up actions for significanttransportation emergency issues.

• As part of this assessment, tabletop scenarios weredeveloped to test the shift supervisors’ ability toformulate and implement time-urgent decisions that arerequired in the initial stages of a transportation incident.Scenarios for this assessment were developed for eventsboth at a remote location, and adjacent to and directlyaffecting the site. The near-site scenario added theDOE Order 151.1 interface with the DOT requirements.NTP-A should consider standardizing the inclusion ofboth remote and near-site transportation accidentscenario tabletop exercises in the TCEAP.

• A draft of the Field Office Transportation Program(FOTEP) is currently under review by the FieldManagement Council. It is recommended that theprogram specify a minimum frequency for NTP-Aassessments of field elements and the elements ofSection 7 of the TCEAP. The program should alsoinclude target schedules for major activities of theassessment, such as final report issuance and correctiveaction plan development.

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APPENDIX AEVALUATION PROCESS AND TEAM COMPOSITION

The evaluation was conducted under the directionof the Secretary of Energy’s Office of IndependentOversight and Performance Assurance. The evaluationwas performed according to formal protocols andprocedures, including an Appraisal Process Guide,which provides the general procedures used byIndependent Oversight to conduct inspections andreviews, and the evaluation plan that was developedspecifically for this activity, which outlines the scopeand conduct of the process. Planning discussions wereconducted to ensure that all team members wereinformed of the review objectives, procedures, andmethods.

Explanation of Rating System

The Office of Independent Oversight andPerformance Assurance assigns an overall rating tothe emergency management program; ratings are alsoassigned to select individual elements of the program.The rating process involves the critical considerationof all evaluation results, particularly the identifiedstrengths and weaknesses. In the case ofweaknesses, the importance and impact of thoseconditions is analyzed both individually andcollectively, and balanced against any strengths andmitigating factors to determine their impact on theoverall goal of protecting emergency responders, siteworkers, and the public. The Office of IndependentOversight and Performance Assurance uses threerating categories—Satisfactory, Marginal, andUnsatisfactory—which are also depicted by colorsas Green, Yellow, and Red, respectively.

Satisfactory (Green): An overall rating ofSatisfactory is assigned when the emergencymanagement program being evaluated providesreasonable assurance that all of the site’semergency responders are ready to respondpromptly and effectively to an emergency eventor condition.

An emergency management element beingevaluated would normally be rated Satisfactory ifthe emergency management function were effectivelyimplemented. An element would also normally berated as Satisfactory if, for any applicable standardsthat are not met, other compensatory factors existthat provide equivalent protection to workers andthe public, or the impact is minimal and does notsignificantly degrade the response.

Marginal (Yellow): An overall rating ofMarginal is assigned when the emergencymanagement program being evaluatedprovides questionable assurance that siteworkers and the public can be protectedfollowing an emergency event or condition.

An emergency management element beingevaluated would normally be rated Marginal if oneor more applicable standards are not met and areonly partially compensated for by other measures,and the resulting deficiencies in the emergencymanagement function degrade the ability of theemergency responders to protect site workers andthe public.

Unsatisfactory (Red): An overall rating ofUnsatisfactory is assigned when the emergencymanagement program being evaluated does notprovide adequate assurance that site workersand the public can be protected following anemergency event or condition.

An emergency management element being evaluatedwould normally be rated Unsatisfactory if one or moreapplicable standards are not met, there are nocompensating factors, and the resulting deficiencies inthe emergency management function seriously degradethe ability of the emergency responders to protect siteworkers and the public.

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Team Composition

Director, Independent Oversight andPerformance Assurance

Glenn Podonsky

Deputy Director, Independent Oversightand Performance Assurance

Michael A. Kilpatrick

Director, Office of EmergencyManagement Oversight

Charles Lewis

Team Leader

Al Cerrone

Team Members

Bob MurawskiJeffrey RobertsonRoss ScaranoDavid Schultz

Quality Review Board

Michael A. KilpatrickCharles LewisDean HickmanDoug TroutTom DavisBob Nelson

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APPENDIX BFINDINGS FOR CORRECTIVE ACTION AND FOLLOW-UP

This appendix summarizes the significant findingsidentified during the Office of Independent Oversightand Performance Assurance review of the WVDPtransportation emergency management program. Thefindings identified in this appendix will be formallytracked in accordance with DOE Order 470.2A, Securityand Emergency Management Independent Oversightand Performance Assurance Program, and will require

a formal corrective action plan. The DOE AssistantSecretary for Environmental Management and the DOEfield element (Ohio Field Office, WVDP, and/orAlbuquerque) need to specifically address these findingsin the corrective action plan. Other weaknesses and/ordeficiencies identified in this report should be addressedby line management but need not be included in theformal corrective action plan.

FINDING STATEMENT

1. Portions of emergency plan implementing procedures for responding to transportationevents do not provide adequate, prompt decision-making tools for initial decision-makers.

2. Deficiencies in WVDP initial decision-makers’ knowledge and proficiency resulted infailures to determine applicable protective action criteria, declare accurate categorizationand classification, and perform timely notifications during transportation emergencyresponse performance testing.

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