Evaluation of the U.S. Nuclear Regulatory Commission’s Policies and Procedures for Emergency Evacuation of Disabled Personnel

Agency Response Dated October 24, 2024: Agree. The Office of Administration (ADM) acknowledges and agrees with the importance of communication at areas of refuge. ADM has conducted a thorough assessment of the locations and functionality of telephones in all areas of<br />
refuge. A comprehensive list of the identified deficiencies was provided to the Office of the Chief Information Officer which has been remedied. The remaining floors without working telephones are active construction sites. Moving forward, this assessment will be conducted annually. As a temporary compensatory measure, a responder will be immediately dispatched if an individual is observed in an area of refuge without a functioning telephone. As a standard practice, all areas of refuge are monitored via visual surveillance system in the Central Alarm Station during building emergencies.<br />
OIG Analysis: The OIG checked the areas of refuge for working two-way communication systems (phones) and confirmed the implementation of the recommendation as stated. This recommendation is now closed.

Agency Response Dated June 18, 2025: Agree. The Office of Administration (ADM) acknowledged and agreed with the importance of consistent conspicuous signage. Compliant signage was installed in exit stairwells for each floor in each building (Appendix A). ADM complies with NFPA Code 101 section 7.10 for “Markings of Means of Egress”, section 7.9.3 requirements for monthly functional testing and section 7.10.9 for annual testing requirements. Annual inspections will be continued, and incorrect or outdated information is checked for in those inspections. Additional inspections and updates will be performed as needed due to construction or changes in workplace conditions.<br />
Completion Date: December 2024<br />
OIG Analysis: The OIG confirmed that area refuge signage was posted, where applicable, and the outdated emergency information was removed. NRC personnel stated that subterranean garage levels of One White Flint North and Two White Flint North buildings previously identified as areas of refuge could not be brought to code; however, the agency believed an exception in the building code allowed for removal of the areas of refuge for those levels. The OIG reviewed International Building Code Section 1009.3.3 and National Fire Protection Association 13 to determine if an exception applied to the subterranean garage levels of One White Flint North and Two White Flint North buildings. The OIG noted that International Building Code Section 1009.3.3 exception 2 applied, eliminating subterranean areas of refuge. This recommendation is now closed.<br />
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Agency Response Dated October 24, 2024: Agree. ADM acknowledges and agrees with the importance of consistent conspicuous signage. ADM will conduct annual inspections of all areas of refuge, removing outdated or incorrect signage and installing compliant signs. Additional<br />
inspections and updates will be performed as needed due to construction or changes in workplace conditions. Target Completion Date: December 27, 2024<br />
OIG Analysis: The proposed action meets the intent of this recommendation. The OIG will close this recommendation upon verifying that the area of refuge signage has been updated as needed to show correct information and comply with NFPA 101 standards.

Agency Response Dated June 18, 2025: Agree. ADM acknowledged and agreed with the recommendation to assess the force required to open fire doors. ADM has assessed and adjusted the force required to open fire doors under normal and pressurization conditions per NFPA Building Fire Codes. Additionally, ADM complies with NFPA 101 section 7.2.1.4.5, “Door Unlatching and Operating Forces on testing and assessing force requirements monthly during inspections of the building fire systems. This assessment will be performed on all newly installed doors.<br />
Completion Date: Most recent inspection conducted on May 3, 2025<br />
OIG Analysis: The OIG reviewed the agency’s assessment documentation for the fire doors and determined that it met the intent of the recommendation. This recommendation is now closed.<br />
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Agency Response Dated October 24, 2024: Agree. ADM acknowledges and agrees with the recommendation to assess the force required to<br />
open fire doors. ADM will assess the force required to open fire doors under normal and pressurization conditions and make prudent adjustments within applicable building code requirements. Additionally, this assessment will be performed on all newly installed doors.<br />
Target Completion Date: December 27, 2024 <br />
OIG Analysis: The proposed action meets the intent of this recommendation. The OIG will close this recommendation after reviewing the proposed assessment and verifying adjustments made to fire doors based on this assessment.

Agency Response Dated June 18, 2025: Agree. ADM and the Office of the Chief Human Capital Officer (OCHCO) acknowledged and agreed with the importance of frequent drills and training opportunities. The Occupancy Emergency Plan and responder team have conducted several tabletop (Appendix A) and in-person exercises with considerations specific to disabled individuals. The scopes of these and future drills include employee responses to Mass Notification System messages, building specific evacuations, evacuation actions for those with specific needs, and responder actions for disabled personnel. ADM will continue offering one-on-one exercises as an expansion to these resources for anyone, at their request. Completion Date: Most recent exercises conducted on April 24, 2025. Additional exercises planned through the summer of 2025.<br />
OIG Analysis: The OIG reviewed the agency’s documentation on the tabletop fire drill exercises and determined that it met the intent of the recommendation. This recommendation is now closed.<br />
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Agency Response Dated October 24, 2024: Agree. ADM and the Office of the Chief Human Capital Officer acknowledges and agrees with the importance of frequent drills and training opportunities and intends to conduct more frequent limited-scope drills. The scopes of<br />
these drills will include employee responses to Mass Notification System messages, building-specific evacuations, evacuation actions for those with specific needs, and responder actions for disabled personnel. ADM regularly engages the Advisory Committee for Employees with<br />
Disabilities to provide refresher training, present an opportunity for question-and-answer sessions, and offer availability to discuss individual plans and needs. ADM will continue offering one-on-one exercises as an expansion to these resources for anyone, at their request. Occupant<br />
Emergency Plan procedures will be updated to require these activities on a recurring basis.<br />
Target Completion Date: December 27, 2024.<br />
OIG Analysis: The proposed action meets the intent of this recommendation. The OIG will close this recommendation upon verifying that the updated Occupant Emergency Plan procedures include the new required activities, and after verifying the completion of at least one limited-scope drill.