Emergency Management Program

Suggested lines of inquiry and review approach

Performance Objective 1: Contractor Program Documentation

1.1 Operational Emergency Base Program

Suggested lines of inquiry and review approach

• Verify that the emergency plan and EPIPs describe the base level of emergency preparedness for the facility and how the facility will respond to serious incidents involving health and safety, the environment, and safeguards and security.
• Verify that the emergency plan and EPIPs integrate requirements of DOE regulations and directives, regulations developed by other Federal agencies, and, if applicable, State and local requirements addressing emergency issues, without duplication of emergency management effort.
• Verify that the emergency plan and EPIPs are based on the Hazards Survey (HS).

1.2 Hazards Survey

Suggested lines of inquiry and review approach

• Verify that the HS identifies the common emergency conditions that affect the facility.
• Ensure that the HS identifies specific hazardous materials and quantities that must be screened to determine if a release could produce consequences consistent with the definition of an Operational Emergency.
• Verify that that HS identifies the planning and preparedness requirements for each type of hazard listed.
• Verify that the HS includes a description of the screening process and the results of the application of the process to the hazardous materials in the facility.
• Ensure that all radioactive materials in the facility have been included in the screening process.
• Ensure that all chemicals with known or suspected toxic properties have been included in the screening process.
• Verify that all hazardous biological materials in a facility are reviewed to identify any biological Select Agents or Toxins (i.e., listed in 42 CFR 73, 7 CFR 331, or 9 CFR 121) in the inventory.
• Verify that the HS has been reviewed for classified information, Unclassified Controlled Nuclear Information (UCNI), and potentially exploitable information.
• Verify that the HS is reviewed at least every 3 years and updated prior to significant changes to the site/facility or hazardous material inventories.

1.3 Operational Emergency Hazardous Material Program

Suggested lines of inquiry and review approach

• Verify that the Operational Emergency Hazardous Material Program executes the general duty to identify the hazards that may result from an unplanned release of hazardous materials; strives to prevent unplanned releases of hazardous materials from DOE/NNSA facilities; takes any steps necessary to prevent releases; and uses feasible means to eliminate or materially reduce the hazard to workers and the public.
• Verify that the results of the Emergency Planning Hazards Assessment (EPHA) have been used to determine the necessary personnel, resources, and equipment for the Operational Emergency Hazardous Material Program.
• Verify that the Operational Emergency Hazardous Material Program ensures the development, implementation, documentation, and maintenance of an effective, integrated emergency management program that is "commensurate with the hazards" and that addresses the following program elements: program administration, training and drills, exercises, readiness assurance, emergency response organization, offsite response interfaces, emergency facilities and equipment, emergency categorization and classification, notifications and communications, consequence assessment, protective actions and reentry, emergency medical support, emergency public information, and termination and recovery.
• Verify that if the EPHA indicates that hazardous materials are present at the facility and that all events would be classified as less than an Alert, that the program encompasses all Operational Emergency Base Program requirements and the Hazardous Waste Operations and Emergency Response requirements found in 29 CFR 1910.120.
• Verify that closure site/facilities have adjusted their program to be commensurate with the hazards that remain as decontamination and decommissioning actions are completed.
• Verify that leased facilities are incorporated into the site emergency management program.

1.4 Emergency Planning Hazards Assessments (EPHAs)

Suggested lines of inquiry and review approach

• Verify that events identified in the HS and materials identified in the hazardous material screening process are incorporated into the EPHA for analysis.
• Ensure that the analysis includes hazards relevant to potential Operational Emergencies (OE) and consequences to workers, the public, and the environment.
• Verify that the EPHA uses the appropriate Protective Action Criteria for radiological and non-radiological events.
• Verify that the EPHA documents accident sequences, equipment or system failures, contributing events, source terms and release characteristics, model assumptions, exposure considerations, and time estimates for protective actions.
• Verify that a spectrum of potential emergency events/conditions are postulated and realistically analyzed, including a range of event probabilities and consequences, from low probability, high consequence to high probability, low consequence, including Beyond-Design-Basis events, and events exclusively affecting onsite personnel, as well as those affecting the offsite public.
• Verify that indicators of emergency events/conditions that can be used for recognition purposes in developing OE categorization criteria are identified and documented in the EPHA.
• Ensure that the EPHA addresses the determination of initiating events and indications for Emergency Action Levels (EALs) and default protective actions/Protective Action Recommendations (PARs) for each EAL.
• Verify that the EPHA considers potential sources outside facilities that may have an effect on maintaining controls on facility hazards, e.g., from other onsite or offsite facilities, from nearby industrial facilities, transportation (train, truck, barge), hostile attack, and natural phenomena events.
• Ensure that the EPHA includes Thresholds for Early Lethality (TELs) for use in determining the size of the Emergency Planning Zone (EPZ) and that the EPZ has been coordinated with local, State, and Tribal authorities.
• Verify that the method for tracking changes in operations, processes, or accident analyses that involve hazardous materials (e.g., introduction of new materials, new uses, significant changes in inventories, modification of material environments) accurately captures the changes before they are made, and provides sufficient time for emergency management personnel to review the EPHA and modify plans and procedures before the changes in operations are made.
• Verify that the EPHA has been reviewed for classified information, Unclassified Controlled Nuclear Information (UCNI), and potentially exploitable information.
• Verify that the EPHA is reviewed at least every 3 years, and updated prior to significant changes to the site/facility or hazardous material inventories.

1.5 Program Administration

Suggested lines of inquiry and review approach

• Verify that an individual is designated to administer the emergency management program.
• Ensure that selection criteria are established and that the designated individual meets the selection criteria for the position.
• Ensure that the individual designated has the authority, responsibility, and resources necessary to accomplish development and maintenance of the emergency plan, emergency plan implementing procedures (EPIPs), and coordination of emergency resources.
• Verify that the emergency plan and EPIPs are controlled and that changes are accomplished in a formal manner with management reviews and approvals.
• Ensure that an adequate review of the emergency plan and EPIPs is conducted annually.
• Ensure that formal review and approval processes are established and documented to ensure that the planning and development of components of the emergency management program (e.g., planning analyses, plans and procedures, supporting documentation) receive sufficient oversight by staff, management and DOE elements to ensure consistency, correctness, and completeness.
• Ensure that reasonable schedules (e.g., documentation submittals, reviews, and approvals; preparedness and readiness assurance activities) are established and enforced to ensure that program planning, preparedness, and readiness assurance activities are initiated, completed, and repeated in a timely and efficient manner.
• Ensure that the emergency management program at the facility or activity is a key element of work planning and execution in accordance with the Integrated Safety Management System (ISMS). Emergency management (like quality assurance, maintenance, personnel training, conduct of operations, fire protection, and waste management) must be a specific function addressed by the safety management program necessary to ensure the safe operation of a facility or activity.
• Verify that self-assessments of the emergency management program are conducted annually.
• Verify that if DOE/NNSA facilities that are generating classified information or Unclassified Controlled Nuclear Information (UCNI), or are conducting classified or UCNI operations, emergency management documentation is reviewed for classified information and UCNI. EPHAs that do not contain classified information or UCNI must be reviewed to determine if they contain potentially exploitable information.
• Verify that emergency management records are maintained in an auditable manner and that vital records are available.

Performance Objective 2: Contractor Program Implementation

2.1 Training and Drills

Suggested lines of inquiry and review approach

• Verify that the emergency plan and procedures require that employee training, typically referred to as General Employee Training (GET), is provided when they are employed, when their expected actions change, or when the emergency plan changes.
• Ensure that all personnel who have unescorted facility access have been trained initially, and annually thereafter, to recognize a hazardous material release and to notify proper authorities of the release.
• Verify that the emergency plan and EPIPs establish a formal training program for the instruction of all personnel comprising the facility ERO (i.e., primary and alternate), to include initial training and annual retraining for both onsite and offsite incidents, including transportation incidents.
• Verify that the emergency response training program includes a specific program of instruction for each position within the ERO, based on the responsibilities of each position. Ensure that the training program requires hands-on use of equipment, where appropriate, emphasizes training of teams, and includes facility-specific emergency response scenarios.
• Verify that all members of the ERO have demonstrated their proficiency in their assigned position annually.
• Ensure that annual retraining includes discussion of prior drill and exercise weaknesses, emergency plan and EPIP changes, equipment or facility changes, and lessons learned from other DOE sites and industrial facilities.
• Verify that the emergency plan and EPIPs provide for the conduct of an annual training program for offsite emergency response personnel and organizations, including Tribal, State, local, or private hospitals, public health, medical, or ambulance services, that are expected to support onsite response efforts. Ensure that the training provides facility- and site-specific emergency-related information, conditions, and hazards; and the opportunity to participate in training and drills validating procedures for response activities expected to involve integration of onsite and offsite response resources.
• Verify that the emergency plan and EPIPs provide a program of drills to develop and maintain personnel skills, expertise, and response capability.
• Ensure drills are of sufficient scope and frequency to support adequate response capability in all applicable areas.
• Verify that scheduled drills include scenario driven events that provide interface practice between the ERO and site medical and security organizations.
• Verify that the training program requirements are in accordance with the National Response Plan (NRP) and National Incident Management System (NIMS).

2.2 Exercises

Suggested lines of inquiry and review approach

• Verify that all DOE/NNSA facilities conduct building evacuation exercises at least annually.
• Verify that notification procedures and communications systems between the facility, offsite authorities and DOE HQ are tested at least annually.
• Ensure that Operational Emergency Hazardous Material Program facilities have established a formal exercise program that validates all elements of the emergency management program over a 5-year period.
• Verify that Hazardous Material program facilities conduct an annual exercise of their emergency program.
• Verify that each exercise is fully documented in an Exercise Plan and that the Exercise Plan was submitted to the Cognizant Field Element for approval.
• Verify that site level emergency response organization elements participate in at least one exercise annually. Ensure that, on multiple facility sites, this exercise is rotated among facilities.
• Verify that offsite response organizations are invited to participate in at least one exercise every 3 years to test and demonstrate an integrated emergency response capability.
• Ensure that, for each exercise, a control group is established to ensure that the exercise addresses the performance objectives of the exercise.
• Ensure that, for each exercise, an evaluation group is established to assess the performance of exercise participants against the exercise objectives.
• Ensure that a critique process is held to record initial impressions of accomplishments and shortcomings discovered during the exercise.
• Ensure that exercise evaluation reports are completed within 30-working days of the exercise.
• Ensure that Corrective Action Plans (CAPs) are completed within 30-working days of the receipt of the final exercise report.
• Verify that each of the Department's radiological emergency response assets have been exercised at least once every 3 years.
• Ensure corrective actions and lessons-learned identified as a result of facility and site exercise evaluation findings are addressed by the emergency management program.

2.3 Readiness Assurance

Suggested lines of inquiry and review approach

• Verify that all facilities have conducted an annual self-assessment of the emergency management program.
• Verify that standards and criteria used for program and exercise evaluations are those that have been issued by the Director, Office of Emergency Operations.
• Ensure that all facilities participate in the program of performance indicators to capture and track objective data regarding the performance of emergency management programs.
• Verify facility participation in the No-Notice Exercise Program conducted by the Director, Office of Emergency Operations.
• Ensure that evaluation reports are completed within 30-working days of the close of the evaluation.
• Ensure that CAPs are completed within 30-working days of the receipt of the final evaluation report. Verify that corrective actions are completed as soon as possible.
• Verify that completion of corrective actions includes a verification and validation process, independent of those who performed the corrective action, that verifies the corrective action has been put in place and that validates the corrective action has been effective in resolving the original finding.
• Verify that facilities have a system for incorporating and tracking lessons learned from training, drills, exercises, actual responses, and a site-wide lessons learned program.
• Verify that the facility participates in the DOE/NNSA Corporate Lessons Learned program.
• Verify that the facility submits an ERAP each year to the Cognizant Field Element by September 30th.

2.4 Emergency Response Organization

Suggested lines of inquiry and review approach

• Ensure that a single position has been identified to manage and control all aspects of the site/facility emergency response. Ensure that command and control functions are clearly defined and that other necessary management positions are prescribed.
• Verify that control at the event/incident scene is consistent with the National Incident Management System's (NIMS) Incident Command System (ICS) or that the ICS in use is compatible with local agencies and organizations if they have not yet converted to NIMS ICS.
• Verify that sufficient experienced and trained personnel are available for initial (on shift) and ongoing (augmented) response, including designated alternates, by name, title, or position; have been assigned to each functional area.
• Verify that emergency response responsibilities and tasks are clearly assigned to specific individuals identified by name, title, or position in the emergency plan and EPIPs.
• Verify that the emergency plan and EPIPs address the availability and potential employment of DOE radiological assets and other support groups.
• Ensure that primary responsibility for response activities that reduce the impact of an emergency are assigned among the DOE/NNSA, contractor, State, and local emergency response organizations.
• Verify that the facility emergency plan and EPIPs are integrated with those of the site, if applicable, and with the emergency plans of local, State, Tribal, and regional Federal response organizations.

2.5 Offsite Response Interfaces

Suggested lines of inquiry and review approach

• Verify that the facility (or site or Cognizant Field Element, if the responsibility is so assigned in the emergency plan) has performed sufficient interface with local officials to ensure that the administrative and physical means are in place to promptly notify the public of an emergency.
• Verify that the necessary agreements, training, security arrangements, and activation protocols are established with offsite support groups and are current.
• Ensure arrangements include identification of the specific official(s) (by name, position, or title), means of contact, agreement(s) that pertain to the use of Protective Action Recommendations (PARs) by local officials, provisions for communicating PARs to the public (equipment, methodology, or systems), and means for managing the resulting activities.
• Ensure the emergency plan and EPIPs include probable State, Tribal, and local emergency response activities if State, Tribal, or local governments refuse to participate in joint planning.

2.6 Facilities and Equipment

Suggested lines of inquiry and review approach

• Verify that the facility has the capability to notify employees of an emergency and that it possesses adequate facilities and equipment to support the range of emergency response scenarios identified in the HS.
• Verify that Operational Emergency Hazardous Material Program facilities have established a command center that is functionally capable of supporting the ERO, including assigned Federal, Tribal, State, and local emergency response personnel.
• Verify that an alternate location has been identified and provisions established for activating the alternate facility if the primary command center is not available.
• Ensure that ERO personnel can respond in a timely manner (typically 30 to 60 minutes) and that each assigned member has authorized access to the command center.
• Verify that the EOC has communications capabilities (primary and backup) with the incident scene, other site and DOE elements, and Federal, regional, Tribal, State, and local response organizations.
• Ensure that secure communications capabilities are available where necessary.
• Verify that adequate Personal Protective Equipment (PPE) and other equipment and supplies are available and operable to meet the needs determined by the results of the EPHA.

2.7 Categorization and Classification

Suggested lines of inquiry and review approach

• Verify that the facility has established criteria to quickly determine if an event is an Operational Emergency (OE).
• Ensure that EALs used to classify events are developed for the spectrum of potential emergencies identified in the EPHA, and initial protective actions are identified for each event.
• Verify that the authority and responsibility for categorizing an event/condition, and if necessary, determining the emergency classification, is clearly defined, recognized, and understood by ERO personnel.
• Verify that the emergency plan and EPIPs detail the method for categorization and classification, and specifically assign responsibility for categorization/classification to an individual by name, title, or position.
• Verify that the recognition/categorization/classification process of OEs is effectively integrated with existing operations, management, emergency response, reporting activities, and the security classification scheme.
• Ensure that facility OE criteria and EALs are reviewed with Tribal, State, and local emergency response authorities annually.
• Verify that the emergency plan and EPIPs provide procedures to ensure that an OE can be categorized within 15 minutes of event recognition/identification/discovery.
• Verify that a tool (i.e., an EAL-like tool) for recognizing and categorizing biological OEs, based on recognition factors identified in the EPHA, is part of the DOE/NNSA emergency management program for biosafety facilities. Biological OEs do not require classification. Initial protective actions are associated with each biological OE.

2.8 Notifications and Communications

Suggested lines of inquiry and review approach

• Verify that the facility can promptly notify workers of an emergency occurrence and the need to take protective actions and that backup systems are available.
• Verify that the facility can promptly notify local response organizations and the Cognizant Field Element and DOE Headquarters (HQ) after declaration of an OE, and, as necessary, after classification of an OE as an Alert, Site Area Emergency, or General Emergency.
• Ensure that Tribal, State, and local officials, the Cognizant Field Element EOC, and the Headquarters Operations Center are notified within 15 minutes of classification of an OE as an Alert, Site Area Emergency, or General Emergency; all other organizations are notified within 30 minutes.
• Ensure that the Cognizant Field Element EOC and the Headquarters Operations Center are notified within 30 minutes of the declaration of an OE that does not require classification; local, State, and Tribal, and all other organizations are notified within 30 minutes or as established in mutual agreements.
• Ensure that the facility has primary and backup means of communications with offsite emergency response officials and between control centers, Incident Command Posts, and field teams.
• Ensure that continuous, effective, and accurate communications among response components and/or organizations (e.g., event scene responders, emergency managers, response facilities, and workers who have taken protective actions) is reliably established and maintained throughout an OE.
• Verify that the emergency plan and EPIPs identify how all reports and releases will be reviewed for classified or UCNI information, before being provided to personnel without authorized access to such information, or before being entered into unclassified or non-secure communications systems.
• Verify that the emergency plan and EPIPs specify how emergency status reports are prepared, reviewed, approved and transmitted to the next higher Emergency Management Team until the emergency is terminated.
• Verify that final reports on emergency response have been submitted after an OE has been declared.

2.9 Consequence Assessment

Suggested lines of inquiry and review approach

• Verify that the emergency plan and EPIPs provide timely initial and ongoing methods, systems, staff, and equipment for assessing and monitoring the actual and potential onsite and offsite consequences of a hazardous material release.
• Ensure that hazardous material exposure release data is incorporated into the facility OE classification scheme.
• Ensure that meteorological data is available and pertinent to the facility hazards. Ensure methods for determining short- and long-term meteorological predictions are available.
• Verify that the consequence assessment process is integrated with processes for categorizing an event as an emergency, determining the appropriate emergency class, protective action decision-making, and locating and recovering materials.
• Ensure that all necessary data for consequence assessment calculations is available from reliable sources (e.g., stand or process flow rates, concentrations, tank volumes, meteorological data, and containment or process building leak rates.
• Ensure dose assessment models are consistent with DOE and industry standards and that differences in modeling methods are understood by onsite as well as offsite emergency response assessment personnel.
• Verify that the facility has the capability to perform backup consequence assessment if the primary equipment is not available.
• Verify that facilities have access to NARAC, or have procedures in place to activate or request NARAC capabilities.
• Verify that monitoring capability for consequence assessment is adequate. Ensure that field monitoring teams are trained and provided with adequate monitoring equipment and personal protective equipment to accomplish field monitoring and plume tracking within and beyond the EPZ.
• Ensure assessment capabilities include release assessment for receptor locations at the facility and site boundaries, at locations of special interest or needs population, and to or beyond the EPZ boundary.
• Verify that effective coordination is established with Federal, Tribal, State, and local organizations to estimate the impact of the release on the public and the environment, locate and track hazardous materials released, and locate and recover materials, especially those with national security implications.
• Ensure that field monitoring and data collection by facility and site teams, State and local teams and Federal teams is coordinated to facilitate exchanges and correlation of information.

2.10 Protective Actions

Suggested lines of inquiry and review approach

• Verify that the emergency plan and EPIPs use the appropriate Protective Action Criteria (PACs) for releases of radioactive and toxic chemical materials.
• Verify that for hazardous biological materials, PACs are considered exceeded and immediate protective actions are required for any actual or potential release of agents or toxins outside of secondary containment barriers. Long term PACs are specified by State or local public health officials.
• Verify that initial protective actions and/or PARs have been formulated for each EAL in the emergency plan and EPIPs.
• Verify that procedures are in place for emergency worker monitoring and for exposure control during emergencies.
• Ensure procedures and equipment are available for airborne and surface contamination monitoring.
• Verify that procedures are in place to implement the separate protective actions of evacuation and sheltering of employees, and to account for employees after emergency evacuation has been completed. Ensure that procedures include criteria for determining the most effective protective action.
• Ensure that EPIPs address methods for conducting search and rescue to assist with evacuation and accountability.
• Verify that the emergency plan and EPIPs specify the steps to be taken and identify (by name, position or title) who must approve reentry activities.
• Verify that reentry activities are performed safely and efficiently, with specific team composition (e.g., minimum of one medically trained member) and equipment that accomplishes the mission.
• Ensure that Personal Protective Equipment (PPE) is available to protect workers involved in emergency response, reentry, and clean up.
• Ensure that decontamination procedures are in place.
• Verify that responsible facility personnel can rapidly determine the extent of the area where protective actions are required and can formulate protective action recommendations.
• Verify that the notification and implementation of onsite Protective Actions (PAs) and notification of offsite Protective Action Recommendations (PARs) are made in a timely, efficient, and unambiguous manner confirmed and monitored by the ERO.
• Verify that the emergency plan and EPIPs require timely protective action recommendations to offsite authorities.
• Verify that the emergency plan and EPIPs address methods to coordinate the relaxation or termination of public protective actions.

2.11 Medical Support

Suggested lines of inquiry and review approach

• Verify that the facility has the capability to provide immediate onsite first aid and emergency medical treatment. Ensure that onsite first-aid stations are maintained at key location(s), as determined by the HS and EPHA, and recommendations by responsible fire, rescue and medical personnel.
• Ensure that medical treatment is provided for mass casualty situations (Cf. DOE O 440.1A).
• Verify that the facility has the capability to transport onsite injured and injured and contaminated patients to onsite or offsite medical facilities. Verify that procedures are in place to record the destination of transported patients and confirm their arrival.
• Verify that the facility has the necessary documentation (laws/regulations, contracts, written agreements, memoranda of understanding/memoranda of agreement) for the transport and medical treatment of injured and injured and contaminated patients using offsite resources and facilities.
• Ensure that treatment protocols are coordinated among onsite and offsite mutual aid response units, and their capabilities are effectively integrated.
• Ensure that the facility emergency medical procedures are integrated with the surrounding community emergency and disaster plans.

2.12 Emergency Public Information

Suggested lines of inquiry and review approach

• Verify that all facilities have prepared an Emergency Public Information Plan. The same plan can cover multiple facilities on a site.
• Verify that all facilities have provisions in place to establish a media center.
• Verify that the emergency plan and Emergency Public Information Plan provide methods for the timely release of accurate information regarding an emergency to the media. Verify that the plans provide for the initial press release to be provided to the media within 1 hour of the emergency being declared.
• Verify that the emergency plan and Emergency Public Information Plan address coordination of news release information with other Federal, Tribal, State, and local response organizations.
• Verify that the emergency plan and Emergency Public Information Plan provide a designated spokesperson (by name, title, or position) to provide periodic briefings and new releases to the media. Ensure that the spokesperson has access to emergency response management personnel to resolve or explain technical issues or misunderstanding.
• Verify that the emergency plan and Emergency Public Information Plan describe the process for assigning a Federal or contractor public information officer to the emergency public information response team involved in a significant offsite response deployment.
• Ensure that all facilities have established an emergency public information communications system among Headquarters, Cognizant Field Elements, and on-scene locations.
• Verify that Operational Emergency Hazardous Material Program facilities have provisions in place to establish a Joint Information Center (JIC).
• Verify that the emergency plan and Emergency Public Information Plan provide an ongoing program, coordinated with Tribal, State and local governments, for disseminating information to the news media and the public. Ensure that disseminated information describes the hazards present at the facility, protective measures information, contact telephone numbers, and addresses where additional information may be obtained and sources of protective action information.
• Ensure that procedures are in place in biosafety facilities that allow rapid and effective communications among public health officials, emergency rooms, law enforcement, and emergency management officials about unusual biological events.

2.13 Termination and Recovery

Suggested lines of inquiry and review approach

• Verify that the emergency plan and EPIPs describe the basis or criteria for terminating an emergency and initiating the recovery phase. Ensure that procedures address the methods to coordinate termination with offsite officials.
• Verify that the termination criteria for hazardous biological material release OE are similar to OEs involving the release of toxic chemical or radioactive materials that require classification.
• Ensure procedures specify the means for informing members of the ERO that an emergency has been terminated and that recovery has been initiated.
• Verify that the emergency plan and EPIPs provide methods for estimating the hazardous material exposures that may be encountered by facility personnel during recovery.
• Verify that the emergency plan and EPIPs provide for adequate protection of site workers and the general public during recovery efforts.
• Verify that the emergency plan and EPIPs include provisions for investigation of the root cause(s) of the emergency and corrective action(s) to prevent recurrence.

Performance Objective 3: DOE Line Management Oversight

Suggested lines of inquiry and review approach

• Verify that responsibilities of line management for emergency management are clearly defined, documented, and understood.
• Verify that resources needed for providing an adequate level of emergency management support are being communicated to the line management and that management is responsive to resource needs and concerns.
• Verify that the Cognizant Field Element has set expectations and communicated them to contractors through formal contract mechanisms and direct communication between Cognizant Field Element and contractor managers.
• Verify that the Cognizant Field Element has formal and documented oversight plans that include assessments, operational awareness activities, performance monitoring and improvement, and assessment of the contractor readiness assurance program.
• Ensure that deficiencies in programs or performance identified during operational awareness activities are communicated to the contractor for resolution through a structured issues management process (i.e., lessons learned program).
• Verify that findings are tracked and resolved through structured and formal processes, including provisions for review of corrective action plans.
• Ensure that line management reviews completion of corrective actions, which includes a verification and validation process, independent of those who performed the corrective action, to verify that the corrective action has been put in place and validate that the corrective action has been effective in resolving the original finding.
• Verify that line management periodically reviews established performance measures to ensure performance objectives and criteria are challenging and focused on improving performance in known areas of weakness.
• Ensure that the Cognizant Field Element monitors contractor performance and assesses whether performance expectations are met and that the contractor is assessing site activities adequately; self-identifying deficiencies; and taking timely and effective corrective actions.
• Verify that the Cognizant Field Element submits an ERAP each year, summarizing its programs and its facility and activity submissions, to the Program Secretarial Officer and the Director, Office of Emergency Operations, by November 30th.
• Verify that the Program Secretarial Officer has formal and documented oversight plans for the Cognizant Field Element.
• Ensure that the Program Secretarial Officer monitors Cognizant Field Element performance and assesses whether performance expectations are met and that the Cognizant Field Element is assessing site activities adequately.
• Ensure that the Program Secretarial Officer monitors Cognizant Field Element emergency management program performance. Verify that the Program Secretarial Officer assesses whether the Cognizant Field Element is self-identifying deficiencies in the Cognizant Field Element Emergency Management Program and is taking timely and effective corrective actions.

Review Approach

• Review technical planning bases documents (e.g., HS, EPHA, the hazards screening process) and the emergency plan, EPIPs, and associated analyses.
• Review documentation related to deficiencies (e.g., completed program assessments and exercise evaluations, causal analyses and corrective action plans, verification/validation records, and effectiveness determinations).
• Review training and qualification records and interview personnel to determine their familiarity with their responsibilities and with emergency plans, EPIPs, and other job aids.
• Observe individuals and teams in the performance of emergency management duties. Typical performance observations include annual facility/site exercises, training sessions; emergency equipment condition; tabletop exercises; facility walkthroughs; drills; survey, sample, and sample analysis; responder briefings; application of response capabilities; control of exercises; and exercise critiques.
• Interview DOE managers and staff to determine how assessments are planned and performed and how they are used to improve performance.
• Review trend analysis and performance indicator reports and evaluate the analyses, conclusions, and any related corrective actions.
• Conduct performance testing to determine whether personnel have the skills and abilities to perform their duties, whether procedures work, and whether systems and equipment are functional and appropriate.

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