Information Notice 1985-55, Revised Emergency Exercise Frequency Rule
SSINS No.:
6835 IN 85-55
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C.
20555
July 15, 1985
IE INFORMATION NOTICE NO. 85-55:
REVISED EMERGENCY EXERCISE FREQUENCY RULE
Addressees
All nuclear power reactor facilities holding an operating license (OL) or a
construction permit (CP).
Purpose
This notice is to alert licensees of revised requirements regarding the frequency
of participation by state and local governments in emergency preparedness
exercises at nuclear power reactor sites.
It is expected that addressees will
review the information provided for applicability to their program.
Suggestions
contained in this notice do not constitute NRC requirements; therefore, no
specific action or written response is required.
Description of Circumstances
On July 6, 1984, the Commission published in the Federal Register (49 FR 27733)
(Attachment 1) a revised rule effective August 6, 1984, relating to emergency
preparedness exercises.
The revised 10 CFR Part 50, Appendix E, Section IV.F.
relaxes the frequency of participation by state and local governments in emergency
preparedness exercises from annually to biennially.
This relaxation applies to
state and local governments that have fully participated (as defined in the
revised rule) in a joint exercise since October 1, 1982.
In addition, the new
rule requires (1) each licensee at each site to conduct an exercise of its on- site plan annually, (2) each licensee to provide an opportunity for state and
local governments to participate annually, (3) each state within the plume
exposure pathway EPZ of a given site to fully participate in an offsite exercise
for that site at least once every 7 years, (4) each state within any ingestion
exposure pathway EPZ to exercise its plans and preparedness related to ingestion
exposure pathway measures every 5 years at some site, and (5) the NRC, in consul- tation with FEMA, to determine the need for and extent of state and local
participation in remedial exercises.
This rule change also specifies that a full participation exercise shall be
held within 1 year before operation above 5 percent of rated power and "shall
include participation by each [s~tate and local government within the plume expo- sure pathway EPZ and each [s]tate within the ingestion exposure pathway EPZ."
(Note, however, that the United States Court of Appeals for the D.C. Circuit in
UCS v. NRC, 735 F.2d 1437 vacated the 1982 amendment to the NRC's regulations
whiTch stated that emergency preparedness exercises were part of the operational
inspection process and not part of any operating license hearing.
Therefore, an
8507110068
IN 85-55 July 15, 1985 applicant should consider scheduling a full participation exercise to permit
litigation of issues concerning the implementation of emergency preparedness as
demonstrated by the exercise.)
To meet the intent of this revised regulation, the NRC staff has determined that
licensees should conduct exercises involving onsite participation at least once
each calendar year (annually) and joint exercises involving the participation of
offsite agencies, which meet the above requirements, at least once every second
calendar year (biennially).
The degree of participation of offsite agencies is specified in the regulation.
The licensees are expected to coordinate the scheduling of the participation of
offsite agencies with the appropriate state and local governments and with the
NRC and FEMA regional offices.
For example, a licensee holding a joint exercise
in November of 1985 would meet the biennial requirement by holding another joint
exercise during 1987, and would meet the annual requirement by holding an onsite
exercise during 1986.
The conduct of a remedial exercise does not alter annual
and biennial exercise requirements.
Licensees were previously requested by the respective NRC Regional Administrators
to use the milestones established in FEMA Guidance Memorandum #17, "Conducting
Pre-Exercise and Post-Exercise Activities," dated January 8, 1981, in submitting
exercise objectives and scenarios for FEMA and NRC review (Attachment 2).
Licensees should continue to adhere to these milestones for each exercise involving
offsite participation.
Guidance concerning the criteria to be used for determining
when remedial exercises will be required is contained in the attached FEMA
Guidance Memorandum EX-1 (Attachment 3).
No specific action or written response is required by this information notice.
If you need additional information regarding this matter, please contact the
Regional Administrator of the appropriate NRC regional office or this office.
od n, Director
Divi %on of Emergency Preparedness
a
Engineering Response
Office of Inspection and Enforcement
Technical Contact:
Edward M. Podolak, IE
(301) 492-7290
Attachments:
1. Federal Register Notice 49 FR 27733
2. FEMA Guidance Memorandum #17.
3. FEMA Guidance Memorandum EX-1
4. List of Recently Issued IE Information Notices
Federal Register / VoL 49. No.'131 / Friday. July a, 194 / Rules and Regulations
27=:
NUCSLEAR REGULATORY
COMMISSION
Emergency Planning and
Preparedness
Aavsc'r Nuclear Regulatory
Commission.
ACTIctw F-nal rule.
SUIEAFr. The Commission is amending
its rerulations to relax the frequency of
participation by State and local
governmental authorities in emergency
preparedness exercises at nuclear
power reactbr sites. This relaxation
reflects experience gained in observing
and evaluating over 150 emergency
preparedness exercises since 1980.
EFFECTIVE DVA.T August 6.1984.
FOR FURTHER INFORMATION
CONTACT
-Michael T. Jamgochian. Accident Source
Term Program Office. Office of Nuclear
Regulatory Research. U.S. Nuclear
Regulatory Comsniision. Washington.
DC 205S5. telephone (301) 443-7615.
SUPPLENEN-ARY INFORMAnON On July
21. 983. the Commission published in
the Federal Register a proposed rule
relating to emergency preparedness
exercises (48 FR 33307). The proposed
i.le retained the presently required
arnnual. ill-participation exercise with a
proviso that. if al major elements in the
emergency plan are performed in a
satisfactory manner during the annual
exercise, FEMA may recommend and
the NRC may find that another exercise
with State and local government
participation is not required for up to 2 yearsm The proposed rule did not relax in
any manner the annual requirement for
onsite e*ercises that each licensee is
required to conduct which include
exercising the control room. technical
support center, and emergency
operation facility functions.
Immediately after the Commission
approved publication of the proposed
rule, the Director of FEMAP ote to NRC
Chairman Palladino. urging the
Commission to "
'
- adopt biennial
exercise frequency language * * *" in 10
CFR Part SO, Appendix E to assure
consistency in the regulations.
FEMAvs final regulation. 44 CFR 350.
published In the Federal Register on
September 2B 1983 48 FR 44332),
reduced State and local participation in
emergency preparedness exercises to a
frequency of once every 2 years. The
FEMA final rule is not consistent with
the position taken by the Commission in
-the NRC proposed rule (an annual
frequency with a specific NRC finding
necessary for relaxation). This
difference was a source of some concern
to both agencies and to some of the
commenters on the NRC proposed rule.
The FEMA regulation requires that a
State within the plume exposure
pathway EPZ fully participate in an
exercise every 2 years with no
requirement on the return frequency at a
specific site. Typically, therefore. a State
with two sites might be expected to fully
participate in an exercise at a specific
site at least every 4 years, a State with
three sites, every 6 years: four sites.
every 8 years: five sites, every 10 years.
etc. Whereas, the enclosed NRC rule
change stipulates that a State within the
pltune exposure pathway EPZ fully
participate in an exercise every 2 years
with a retun frequency of at least once
every 7 years at a specific site. Both
rules require a multi-site State. when not
fully participating in an exercise at a
specific site, to partially participate
every 2 years at that specific site in
order to support the participation of the
appropriate local governments.
The Commission has selected a return
frequency of 7 years because presently
no State has more than 7 operating and/
or planned reactors and Slates with that
number of sites or less would not be
required to exercise in a full
participation mode more often than
about once a year.
Public Commabta
The NRC proposed rile was published
In the Federal Register with a 60-day
comment period on July 21. S83 (48 FR
33307). Seventyone comment letters
were received and evaluated by the
NRC staf£
Those commenters (55) favoring
relaxing the frequency of State and local
governmental participation In
emergency preparedness exercises were
utilities. consulting firms representing
utilities. two State Governors. State and
local governmental agencies. FLNIA and
private citizens.
Those commenters (14) opposing
relaxing the frequency of State and local
governmental peaticipation in
emergency preparedness exercises were
an information service, environmental
gpoups, a State Governor. State and
local governmental agencies, EPA and
private citizens.
The comments raisedseveral
significant Issues, to which the
Commission responds as follows:
Jssue No.
Should the Commission adopt a
biennial exercise frequency for State
and local government participation with
a proviso for remedial exercises for the
correction of serious deficiecies rather
than the exercise frequency contained in
the proposed rule?
Discussion This issue was addressed
by many State and local governmental
comment letters whose concerns are
generaly characterized by the following
quote from the FEMA comment letten
The NRC propol will be diicult to
administer. For example. objedtve critera
will need to be developed for use in
determining whether State and local
governments have perforned in a satisfactory
enough manner to warrant an exemption
from the succeeding year's exercise. It will be
difficult to apply such criteria to the
satisfaction of State and local governments
The NRC proposal would create complex
situations such as what to dol if some
jurisdictions perfor
in an unsatisfactory
manner and the others in a satisfactory
manner. Would all jurisdicions have to
exercise the next year or only the
unsatisfactory ones? If only the
unsatisfactory ones. an unworkable condition
would result wherinso=e jurisdictions
would be on annual and others on biennial
frequency. Inequities would result Further.
the time involved for evaluating exercise
results. including getting commitments from
State and local gover:nents to take
co-rective actions, has proved time
consuning in the past. If we add time for the
NRC to make a finding after FIA's
recommendation. a good portion of a year
could be consumed This would cause
uncertainty and instability in State and local
governents. which should be avoided
Attachment 1
IN 85-55 July 15, 1986 Fe14rterA
41Jo: n, Fr ddtl )
8,.*aq I.Uldi
j&
Commission Reponwc-..
z- '.
Commisajon recoies the -
._
implc=n~htild diffilties with thg
propoQ
MC zpproachlartnn
freque
yldth a find torelxa4 T:his
was pointed but by the MRCemergency
preparedness regional fdspectors. a
majority of the comment letters, the
general thrust in two petition's far
rulemalng. I and theACRS.
issue No2
Will less frequent exercises result in
=aking personnel and equipment less
effective cr reliable and therefore
reduce the level of safety?
Discvssisn. A few comenters.
pr.marily citizens and gemamentaj
organizations. addressed thdi issue by
pon-tin out that State aid local
emergency response organizations must
frequently respond to various natural
and man-made emergencies. 7Is
continuum of real life emergencies
exercises personnel, equimte
communication networks and
organizetronal strcctures on a requnt
basis.
The following quote from a comment
letter set.
ries this concern:
Wrile an emergency situation at a nuclear
power plant may call for some procedwres
tEt are dIfferent from those used under other
emergency sicattors. many of the response
and evaceen meewres will be similar. If
not identicaL A :nyriad of maior and mince
emergencies dermand the maintecance of a
force o personel viined in thee
procedurec. By retpomding to other
emergenzy a
.atio= such as chemical spills.
the emergezcy response personnel will be
rehearsing many of the procedures they
would ue in theevetzof La energency
situatien at a nucJear power plant Some
examples ct these procedures wvu3d ici.
not ifcatiou of approptiate local audfoities
erablizhirg coaics tion tirks between
locaL regionzl iud state ergey
repormw
persnneL zEu evacuating or Flnding helter
fcr the aIleced pop :ltsce.
Cozmission Respons: Because
emergency response psonnel at the
State Lad local government kvel
continuously respoud to actoal
emergemcis the Codion
does not
consider that relaxing the frequency of
State and local govertment
participation
in
ency preparedness exercises
would adversely affect the heahth and
safety of the public.
A provision has been added in the
final rule to permit State or local
' On March
. 2.= me Coi
on reived a
pet don for -wnakLm
lPM-W-3Z from Natonua
Eme.Fency l
tamew
AaaocauaaL On Aupnt 30,
19e &.4 Crc_--ma.oc n1ived a petition for
ueaking (P
SC 41 from the A4-utan Gcneral
of the Sihe of South CsmL-A. The reneral thrust of
bout pe-oow urgped be relaxuanutf ti frequency
o! en .
ne.n., r;rcedn-se cx. .r.es.
gove nt p rtlcipation
.th-
...
licensee's -=nual
exercis
A State or
local goverment may conidsr fts
response cqxbility to be less tha=
optial becaus of art umsun:y Lage
personnel turnover or because therc
hare been limited responses to real
emergencies in the ccnmunity. The final
rule requirs the licensee to provide for
State or local govem=et participation
if they indicate such a deskr.
Issue No. S
Will the deletion of NUREG-OSI' as
a footnote adversely affect the interface
between ofisite emergency plans and
the [;censee's emergency plans?
Discussion The proposed rule
included a provision to delete references
to NUREC-0654 throughout the
regulations. NWREG-4 provides
specific criteria for the evaluation of the
standards in I 5OM and is titled.
'Criteria for Preparation and Evaluation
of Radiological Emergency Response
Plans and Preparedness i Support of
Nuclear Plants. A few commenters.
primarily a utility and a state
governmental official. felt that the.
deletion of the NTJREC-o4d
footnote in
the regulations would preclude its use
by reviewers in determining the
adequacy of emergency preparednessI.
Commission Response: The delegatlon
of a reference to NlUREG-054 w121 not
affect it use as a guidance document for
emergency planning. In the 1980
rulemaking. the Commission included
this reference as a means of formally
approving the use of NIEMGS-54. See
45 FR 554eZ 55408 (August 19. 1980).
NUilREC-ft
is endorsed by Regzlatcry
Gtide S.lol,' end will- continue to be
used by reviewers in evaluating the
adequacy of emergency preparedness at
nuclear power reactor sites.
prepednes execises. Fk-A havtt
developed and norw uses a document.
titled "Procecdral Policy onRadieodogice
Emergency Preparedness Plan RevIew.
Exercise Observations and Evalusticn- and Interim Findkngs.'I These
procedures were forwarded to the
FEcMA regions for ase on August S. is83.
Having considered all comme-nts
received, experience gained since ISM.
input from emergency preparedness
regional inspectors, the general thrust of
two petitions for rulemaking. and ACRS
comiments. the Commission has
concluded that the requirements for
frequency of participation by State and
local governmental authorities in
emergency preparedness exercises
around nuclear power reactors should
be relaxed.Te Commission therefore is
promulating a final rule which.
1. Contitues to require licensees to"
conduct an armual onsite emergency
preparedness exercise.
2. Requires that State and local
governments participate in emergency
preparedness exercises every 2 years
with a provision-for remedial exercises
to assure that deficiencies are corrected.
3. Provides that at least once every 7 years. all States within the plume
exposure pathway EP"Z-o a given site
must fully participate in an offisite
exercise for that 4s1
4. Requires licensees to provide a
opportunity for State and local
government participation in the
licensees annual emergency
preparedness exer ise. ard
5. Requires FEMA to determlne the
need for and extent of remedial
exercises.
The final rule is not totally consisten
with FEMA's final regulation (44 CFR
350). This inconsistency lies in the res.
of retmrn frequency fcr Iltipledsite
states as previously discussed. The
FEMA pouition on reu
frequncy isa
significant depammme from the NRC's
proposed regulation (48 FR 3;)
dted.
July 21. 193. The Commission belleves
that more study is needed before- deletion of the return frequency
requirement can be lustified.
The Commission is adopting a
biennial exercise frequency, for State
and local government participation with
a proviso for remedial exercises to
assure the correction of serious
deficiencies. These changes to the
emergency preparedness regulations are
being made because:
a. Experience in observing and
evaluating over 150 exercises has shown
that a disproportioaate amount of
GuCdance for determicits the ceed for. sad
extent o!. reumedisl exerxmses is beinr develope&
Attachment 1
July 15, 10985 Issuse No. i
.
.
Do adequate procedures exist for NRC
and FEiMA to evaluate wheteir major
elements-are performed satisfactorily
during an exercise?
Disciuiojr Many commnenters.
primarily State and local governmental
authorities as well as utilitiepointed
out that there is a need for uniform
evaluation of exercise performance.
Commission Resporne: The
Commission concurs with the
commenter
In order to provide for
uniform evaluation of emergency
' Copies of these documents are av&iLabLa at the
COMdIrSionS Public DcuMnent Roo. 1717 H
Stet NW_ Washingiona D.C. 3SS. Copies of
these dociumeuts may be purchased from the
Goverunent Prntt~ Orfioe. Inhouom on cmvrert
pnces may be obmatned by wnuns the US. Nudeu
Reguiatory Commission. Washinglon. D.C. =S
Anention: Publizauonn
Sles
W
as e.
Federal Rk-ester /.Yl.L 49; -,No. 131:.I Friday, luly:fl. 1084-( 'Rides anvR u2a7os
Federal. State and local government and
licecsee resources are being expended
in order to conduct and evaluate annual
eniergency preparedness exercises. As a
result of the substantial expenditure of
resources for these exercises. fewer
resources are available to establish and
maintaLn the essential day-to-day
upgraded state of emergency
preparedness.
b. State and local governments
respond to a variety of actual
emn-eencies on a contisaing basis. thus
frecuent~l exercising ther emergency
preparedness capabilities.
c. The flexibility provided for in a
biennial frequency will be an incentive
for State and local governments to
perform.in a satisfactory marmer in
order to avoid conducting remedial
exercises.
And lastly. the Commission notes that
MEMA has had aLmost 3 years of
experience with evaluating State and
local government radiological
emergency planning and preparedness.
With few exceptions. this experience
kas revealed a significant increase in
the level cf State and local government
radiological preparedness as
demcns rated in joint exercises. FEhiA
has evaluated approximately 150
exercises. 1:i only five instances did
FEMA determine that Stale and local
govermr:en-s did not demonstrate
adequate preparedness. The
Commission believes that this enhanced
level of preparedness should be
recoFnized by allowing State and local
governzients to exercise jointly with
utilities or. a binenrial frequency.
On March 17. 1982. the Commission
received a petition for rulemaking
(PIRUM-5C-3) from National Emergency
Management Association. On August 30.
198.7 the Coinm ission received a petition
for nrlemaking (PRM-50-M3)
from the
Adjutant General of the State of South
Carolina. The petition from the National
Emergency Management Association
requested the NRC to relax the
frequency of full participation by State
and local governments in emergency
preparedness exercises from annually to
bier.nia!yv. The petition from South
Carolkia requested that the NRC reduce
the frequency with which local
governmoents must participate in a full
scale emergency preparedness exercise.
The promulgation of this final rule
relaxes *he frequency of full
participation by State and local
govermnnents in emergency preparedness
exercises from annually to biennially.
I his rule completes NRC action by
granting bcth petitions for rulemaking.
Fiding of No Sinificant Eaviro
e6ntal
The Commission has determined
under the Naticnal Environmental Policy
Act of 1989, as amended, and the
Commission's regulations in Subpart A
of 10 CFR Part 51. that this rule Is not a
major Federal action significantly
affecting the quality of the human
environment and therefore an
envirrnmental impact statement is not
required. See 10 CFR 51.20(a)(1).
Moreover. the Commission has
determined. pursuant to 10 CFR 51.32, that the final rule has no significant
environmental impact. This
determination has been made because
the Commission eannot identify any
impact on the human environment
associated with reducing the frequency
of full participation of State and local
governments in emergency preparedness
exercises from annually to biennially.
The alternative approaches that were
considered in this rulemaking
proceedings were:
1. To retain the annual full
participation exercise with a provision
to enable relaxation to every 2 years.
Z. To incorporsteby reference into the
NRC-s regulations, the
regulations governg the frequency of
full participation of State and local
governments in emergency preparedness
exercises.
3. To relax the frequency of full
participation of State and local
governments in emergency preparedness
exercises from annually to biennially.
There were no environmental impacts
identified from any of the alternatives
considered.
Because FEMA is directly involved in
the evaluation of offsite emergency
preparedness exercises and is affected
by the promulgation of these
amendments. the NRC consulted
extensively with FDA during the
development of this rule.
Paperwocrk Reduction Act Statement
The final rule contains no information
collection requirements and therefore is
not subject to the requirements of the
Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).
Regulatory Analysis
The Commission has prepared a
regulatory analysis of this regulation.
The analysis examines the costs and
benefits of the rule as considered by the
Commission. A copy of the regulatory
analysis is available for inspection and
copying. for a fee. at the NRC Public
Document Room. 1717 H Street NW..
Washington. DC. Single copies of the
analysis may be obtained from Michael
T. JaMgochla
Office of N cea-
-,
Regulatory Research. US. Nuclear
Regulatory Commission. Washington.-
DC 2=5, Telephone (3011 443-78.
Regulatory Flexibillty Certficatin
In accordance with the Regulatory
Flexibility Act of 1S90 5 U.S.C. 605(
the Commission hereby certifies that
this final rule will not. if promulgated.
have a significant economic impact an a
substantial number of small entities. The
final rule clarifies certain elements and
findings necessary for the Issuance of an
operating license for a nuclear power
plant licensed pursuant to sections 103 and 104b of the Atomic Energy Act of
1954. as amended. 42 U.S.C. 2133. 2134b.
The electric utility companies which
own and operate nuclear power plants
are dominant in their service areas and
do not fall within the definition of a
small business found in Section 3 of the
Small Business Act. 15 U.S.C. 32 or
within the Small Business Size
Standards set forth In 13 CFR Part In.
Accordingly. there Is no significant
economic Impact on a substantial
number of small entities under the
Regulatory Flexibility tct of 190
List of Subjects In 10 CFR Part 50
Antitrust Classified information. Fire
prevention. Incorporation by reference.
Intergovernmental relations. Nuclear
power plants and reactors. Penalty.
Radiation protection. Reactor siting
criteria. Reporting and recordkeeping
requirements.
Pursuant to the Atomic Energy Act of
954. as amended. the Energy
Reorganization Act of 2374. as amende:;
and section 552 and 553 of Title 5 of the
United States Code, notice is hereby
given that the following amendment to
Title 10. Chapter L Code of Federal
Regulations, Part S is published as a
document subject to codification.
PART 50-DOMESTIC UCEPSING OF
PRODUCTION AND UTILIZATI
FACILITIES
1. The authority citation for Part 50
continues to read as follows:
Authodtr. Secs_ Im3. 20" 181. 1t:. I83 Im
188. 68 Stat. SS37.9
53.94. 9S5.
V
L. as
amended. sec. Z34. 83 Stat. 1244. as amended
42 U.S.C 2233. :134. Z20L 2232. 233.228.'
2238. 2282) secs. 201. ;0: 20.868 Stat 12C4.
1244.124& as amended (42 U.S.C. 841.54S.
SW48). unless otherwise noted.
Sec. 50.7 also issued under Pub. L
-.
ace. 10.92 Stat. 252 (42 U.S.C. 5851). Secs.
50.57(d) 50.58. 50*1. and 50.S2 also isued
under Pub. L 97-415.96 Stat. 2071.2073142 U.S.C. 2133. 2239). Sec. 50.78 also Issued
under sec. 12:.08 Stat. 139 (42 US.C. =52).
Sacs. 50.80-SSI also issued under sec. 164.
Attachment 1
IN 85-55 July 15, 1985 2: eMw- Fedca-Re&ter t NnOE 49rWo. 13-1; f Ftidar,' W 4, 19W1
-
68 Stat. 85L as ended 1CUS5.CM
4)-
Secs. 50.2 a2 aLo kse
ft
s
lase
U StL
at
as2 ULS.C.28
- -.
For the purp*.at&Is
of..
StL 958. as
amended (42 U.S.C 2:J5- -i 5.10(a. (b).
and kc). BOtMS ML&& ad 5901"a) am.
isued nder sec. llb.
t StaL 941 as
amended (,2 U-S.C .
¢t.
H 5010(b) and
(c) and 5S5 we kxued Knder let 1l1L W
Stat. 949. as ereede (42 U.S.C. Z(th and
I I SO5(4e), 505(b. 50-0 .5071. £.72. 3073.
and Sa8 are issued unda ac 181o, 68 Stat.
950. as aoended (42 USC. 2201o).
J 88.47
[Amended)
2. In I 50.47. Footnote I Is removed.
3. in Appendix E. section IV.F Is
revised to read as follows:
Appondlx E-Emergency Plannrng and
Prepa'edrres3 for Producton and
Utbfnt
Faclifles
M
.
.
.I
F. 7raining.
The program to provide for (1) the training
o! employees and exercistng. by periodic
drills of radiatiom emergency phls= to ensure
that emolo'ees of the licensee are familiar
with their specific emergency response
duties. and (2) the participatioan in the
trzining and drcls by other persons whose
assistance may be needed in the event of a
radiation emergency shall be described. This
shall include a description of specialized
initial traLning and periodic retainirM
proramas to be provided to each of the
followy catrorier of emergency personnceb
a. Dire-cors and/or coordinatos of the
p'ant emergency oraniation:
b. Personnel respaosible for accident
assessment. including control room shift
perso-nel:
c. Radloloical monitoring teamsa
L'Fure ccntrl teams (Firs brimadesk
e. P-epe and damage control tamm
I. Fzs- aid and rescue teasa
S. Medical support personnel
Licensee's eadquazier support
persoarel
i. Secu.ty personneL
I- addition. a rzdiologcal orientation
tr2alwg ;-*m=rn shall be made available to
local servmas Monnek e4..local emergency
serices/CIvil Defense. local law
enJforcee-et pevonneL local news eslia
persons.
rhe plan shall describe provisions for the
condoct of emergency preparedness exercises
are follows: Exercise sha test the adsqcy
of timing and coote-A of im.plementing
procedures and metho~s. test emergency
equipr:ea and co-ica
ons networks.
test the public nnsication system. and
ensure that emergency organization
personnel are familiar with their dutite.a
1. A full participadn ' exercise which
tests as much of the licernsee. State and local
eas
is b roals
ykhimble .
witout mandatory public particpationlL;
be conducted for each site at which a power
reactor Is located for wich the &frt
aperat
license for that sit
frrued after MY 13.
182. This exercise shall be conductud withbi
l year
be
e ace
th rst
openating linene for hl power and prlor to
operation above 5%f rat ed power of the frst
reactor, and sa
e prticipatio by
eacr- State and local goverent within the
plume expos
pathway !M and each State
within the ingestion expo rt re pathway EPZ
2. Each licensee at each srhe shall annually
exercise its Ce::-jency pla
3. Each licersee at each site shall ers
with offsite authorities such that the State
and local governsent emergency plans for
each operatir^g reactor site are exercised
biernially. with full or partial participation
by States and local governments. within the
plume exposnre pathway E State and
local governments that have
ly
particpated tm a joint exercise since October
1. aM are eligible to fuly participate ta
emergency preparednm mxises on a
biennial frequency. Tha level of participation
shall be as follows:
(a) A State shall at least partially
participate in each offaits exercise at each
-site.
(b) A State shall fally participate in at leest
one offsite exercise every 2 years.
(c) At least oc
every 7 year all States
within the plume exposure pathway EDZ for e
given site must fully participate in an offaite
exercise for that sita. This exercise must also
involve full participation by local
governments within tie plume exposure
pathway EZ.
(d) Partial participation by a local
government during an offsite exercise for a
site is acceptable only when the local
government is fully participa tng in a biennial
exercise at another site.
(el Each State within any ingestion
exposure pathway EPZ shall exercise its
plans and preparedness related to ingestion
exponre pathway measures at leads once
every S years.
(f) Licensee, shall enable any State or local
government located within the plume
exposure pathway EPZ to participated In
annual exmsea r-ihen requested by such
State or local government.
4. Remedial exercises will be required If
the et=ency pla Is not satisfactorily
tested during the biennial exercise. such that
NRC.tn consultation with FDMA. cannot find
reasocable assurance that adequate
protective meabares can be taken In the event
to a radiological emergency. The extent of
State and local participation in remedal
exercses must be sufficient to show that
appropriate corrective meascres have been
taken regardiog the element of the plan not
properly tested in the previous exercis
5. All train;1in
including exercises, shall
provide for formal critiques in order to
idectify weak or deficient areas that need
CcnesctRLo
Any weakneeaes se in~ce
that etd
solW be
c, -
4. In Appendix E footnotes 1 and 4 arm removedJfootnotes Z and 3 are .
renumbered as fDctn otes 1 and.i and
new footnotes 3, 4. and S are added to
read as follows:
' Use of site spedcf! simulatars or
computers is acceptable ror any exercis
' 'Fuil participation' when used in
conjunction with emergency prepaednesc
exercises for a particular site means
appropriate offKlte local and State auth: ties
and licens personnel physically and
actively take part in testing their integrated
capability to adequately access and respond
to an accident at a co:mercial nuclear power
plant. 'Full particpation" Inchldes testing the
major observable portions of the onsite and
offalte emergency plans and mobilization of
Sate local and licensee personnel and other
resources in sufficient muinbers to verify the
capability to respond to the scideact
scenario.
' Partial participatioan when used In
conjunction With eCMerency preparedneSS
exercises for a particular site
eans
appropriate offnite authorities shall actirely
take part in the exercise
icient to test
direction and contrl fhincons La. (a)
protective action decision making related to
emergency action levmstaiand (b)!
cormunication capabilities among azected
State and local authorities ad'the licensee.
.0
Dated at Washington. D.C. this 2th day ol
June 1934.
For the Nuclear Regulatory CommisLo&.
Samuel J. Chilk
Secretary of the Commission
R Doc 5-li7M rd
r
-i-
&
g of
-
-
81+/-)9 CM
w
Attachment 1
INW15-55 July 15, 1985. i~el~
Attachment 2
.Guidknce K4emorandum
17
July 15, 1985
Radeological Emergency Preparedness Division JOIN'? EXERCISE PROCEDURES
In the interest of assuring that the health and safety of the public
is protected in the event of an accident at a nuclear power plant, it
is necessary 'or the licensee (applicant), to conduct an emergency
preparedness exercise jointly with appropriate State and local agencies.
The role of the Federal government at such exercises is to evaluate the
capability of the utility and the State and local governments to protect
the public health and safety in the event of an accident at the facility.
The FSMA official responsible for this activity is the appropriate Regional
Di-ector.
over the last few months there have been several joint exercises where EZMA
and NRC have made reviews both orally in an open meeting, and in written
form.
We find however, significant variation among regions in the procedures
used for providing the evaluation.
The need for a standardized approach
is evident and the following is a guide for both FDLA and NRC personnel
involved in exercise evaluation.
Assicrnents for offsite observers will-be made by the RAC Chairman
- Onsite
observers will be assigned locations by the NRC: Team Leader.
A meeting of
all pa-ties should be conducted prior to the exercise to assure that all
observer locations are staffed by an evaluator, as well as to make whatever
last minute changes are necessary based c f'eld conditions, number of
evaluators available, etc.
The exercise should be followed as soon as possible by a critique.
The
car;itue
is a worklng session for preliminary review of the exercise between
the par4icipants (State and local officials and utility representatives and
the Federal observer teams headed by TA
and the NRC).
It should be open
to the public and the media.
They should, however, attend as observers, and
not par-tcinate in the discussions. *
I
local circmstances dictate that a
private session be held with the State authorities, it must be scheduled in
advznce and the information provided by the RAC Chairman at the private
=ee=iLn
should be repeated in the open session.
-2- Attachment 2.
IN 85-55 July. 15, 1985 It is desirable to conduct the critique with all the principal parties
aresent, (e. g. the RAC, the involved State and local authorities, the
licenses and NRC).
There may be situations where such a joint critique
is not feasible and separate sessions (one related to licensee participation
and one related to State and local participation) ar necessary due to
log4stical or funding constraints.
These situations are to be cleared in
advance thru the FMA/NRC Steering Committee.
In such cases the RAC
Cha4-7zan should be available for both critiques.
The joint critique should be chaired by the RAC chairmen and should be
wih in or near the 10
ile EPZ.
As part of the overall Iforat the RAC-
Chaia-=n will discuss observations of the offsits response and the NRC
will discass observations of the onsite response.
The State, local
governments and utility should be present at this meeting to make pre- sentations.
For the joint critique to be effective, it
should take
place within the 24-hour period immediately following the exercise.
'Thers should also be opportunity for clarification, questions or c =ts
by licensee, State and local officials.
The RAC Cha' =an's overview statement should be based on comments from
RAC members and other FMA observers as well as his own observation.
It
should include the strcng points as well as a general statement on the
deficiencies noted.
Under no circumstances will the RAC Chairman's
c-e=nts indicate that the State or local plans passed or faied.
He/she
should indicate that the comments are preliminary to be followed by a
comprehensIve evaluation within 14 days.
The final F"MA findings and
determination, as well as approval of a State and/or local plan, sutbitted
acording to 44 CFR 350 of which the exercise is a part, is reserved to the
Associate Director for Plans and Preparedness in Washington.
The mrlnc43al milestones for FMiA and NRC exercise observation and critique
are g ven in Enclosure L
These milestones are for planning purposes and
actual schedules may need to be different because cf local circ=ustances.
.
Enclosure No. i
Attachment 2
July 15, 1985
MILESTONES FOR MCERCISE OBSERVATZON AND CRITIQUES
ge 3 of 3
-
75 days*
-
60 days
-
45 days
-
35 days
-
30 days
-
15 days
-
1 day
E day
E day
E day
E t0o
1 day
State and licensee jointly suli;t exercise objective to
FMA and NRC Regional Offices.
FMA and NRC Regional Offices discuss and meet with
licensee/State as necessary and prepare response.
State and licensee scenario developers submit exercise
scenario to FE4A and NRC Regions for review.
FEKA and NRC Regions notify State and licensee of scenario
acceptability.
MA and NRC Regions develop specific post exercise critique
schedule with the State and advise FMA and NRC headquarters.
The RAC Cha4i-rn and NRC team leader will meet to develop
observer action plan (where stationed, how many fr=n each
organization, what to look for).
Meeting, in the exercise area, of all Federal observers both
onsite and offsite to f4nalize assigments, and give instructions.
Exer-ise
FM11A and RAC observers caucus to collate observations.
observers also caucus to collate observations.
NRC
RAC Chairman and NRC team leader meet, as soon after their
respective caucuses as practical, to coordinate Federal
participation in critique.
Joint RAC/NRC critique
General Acenda
.
State, locals and licensee present their views.
B. Critique of offsite actions, by RAC Cha4i-an.
C.
Crtique of onsite actions, by NRC.
D. Critique of Federal response (if
applicable), by
RAC Ch%4iman.
E.
Opporiunity for clarification questions or cr-ents by
licensee, State and locals (press and public questions
will
not be entertained during the critique).
4 15 days
Written critiques by FEMA Region to State, with copies to FM.A
headquarters and NRC and by NRC Region to license- with copies
to NRC headcuarters and FMA.
- (Recc-manded Suspense Dates)
Attachment 3
July 15, 1985 Federal Emergency Management Agency
Washington, D.C. 20472
July 1, 1985
GUIDANCE MEMORANDUM EX-1
REMEDIAL EXERCISES
Pu rpose
This Guidance Memorandum provides criteria and procedures for requiring and
scheduling remedial exercises and other remedial actions to correct deficiencies
identified in exercises to test State and local radiological emergency response
plans.
It also provides guidance for determining the extent of participation in
remedial exercises.
Background
The Federal Emergency Management Agency (FEMA) rule, 44 CFR 350, and the
Nuclear Regulatory Commission (NRC) rule, 10 CFR 50, Appendix E, require
that State and local goveriments participate in periodic, joint exercises
with utilities. These rules require remedial exercises and other corrective
measures if the results of these exercises do not give reasonable assurance
that adequate protective measures can be taken in the event of a radiological
emergency or the deficiencies identified are significant enough to impact
on the public health and safety.
The NRC rule (10 CFR 50, Appendix E,
IV.f.4.) calls for NRC-FEMA consultation in making a determination as to
whether a remedial exercise is needed.
The FEMA rule (44 CFR 350.9.c.5)
leaves the determination of the participation required from State and local
governments to the appropriate FEMA Regional Director.
For the purpose of exercise assessment, FEMA uses an evaluation method to apply
the criteria of NUREG-0654/FEMA-REP-1.*
FEMA classifies exercise inadequacies
as deficiencies or areas requiring corrective actions. Deficiencies are
demonstrated and observed Inadequacies that would cause a finding that offsite
emergency preparedness was not adequate to provide reasonable assurance that
appropriate protective measures can be taken to protect the health and safety
of the public living in the vicinity of a nuclear power facility in the event
of radiological emergency. Because of the potential impact of deficiencies
on emergency preparedness, they are required to be promptly corrected through
appropriate remedial actions including remedial exercises, drills or other
actions. Areas requiring corrective actions are demonstrated and observed
inadequacies of State and local government performance, and although their
correction is required during the next scheduled biennial exercise, they are
not considered, by themselves, to adversely impact public health and safety.
In addition to these inadequacies, FEMA identifies areas recommended for
- The method currently in use is incorporated in the August 5, 1983, memorandum
from the FEMA Deputy Associate Director of State and Local Programs and
Support to the .FEMA Regional Directors, subject: "Procedural Policy on
Radiological Emergency Preparedness, Plan Reviews, Exercise Observations and
Evaluation, and Interim Findings."
Attachment 3
-2- July 15,'1985 improvement, which are problem areas observed during an exercise that are
not considered to adversely impact public health and safety.
While not
required, correction of these would enhance an organization's level of
Guidance on Determining the Need for a Remedial Exercise
The following criteria shall be used in determining the need for requiring a
remedial exercise.
1. A deficiency in one or more of the following planning standards of
NLREG-0654/FEMA-REP-1 will require a remedial exercise.
Exceptions
to this requirement may be made when correction of deficiencies can
be demonstrated by other remedial actions.
o
Assignment of Responsibility (Organization Control) (A);
o
Alert and Notification Methods and Procedures (E);
o Emergency Communications (F);
o Public Education and Information (areas related to emergency
public information) (G);
o Accident Assessment (including field monitoring and radiological
assessment) (I);
o Protective Response (including evacuation and other protection
responses and decisionmaking) (J);
o Radiological Exposure Control (K); and
o Medical and Public Health Support and Services (L).
2. Remedial exercise action may be required when areas requiring corrective
actions collectively raise doubts as to whether adequate protective
measures can be taken in the event of an emergency.
Procedures for Reporting on the Need for and Scheduling of Remedial Actions
When evaluation of a joint exercise indicates that there is the potential
or need for remedial action, the following procedures will be followed.
1. The FEMA Regional Office will immediately notify FEMA Headquarters, by
telephone, of the nature of exercise inadequacies. FEMA Headquarters
will, in turn, notify and discuss these inadequacies with NRC Headquarters.
2. The FEMA Regional Office will promptly initiate a consultation process
with the members of the Regional Assistance Committee(s) (RAC), the
State(s) and FEMA Headquarters for these purposes: (a) To classify
all exercise inadequacies, (b) to specify appropriate remedial actions, including remedial exercises, drills, or other actions, for both
deficiencies and areas requiring corrective actions and (c) to determine
which organizations are to be involved in remedial actions.
During
this period, FEMA Headquarters will continue to consult with NRC Headquarters.
Attachment 3
IN 85-55 July 15, 1985 -3-
3. Within 30 days of the exercise, the FEMA Region will transmit a letter
and draft report consisting of, at least, a summary table of the
exercise inadequacies to the State(s) with a copy to FEMA Headquarters
and the RAC(s).
The letter and summary table will confirm the results
of the consultations with the State(s). The State will be asked to
use this letter and summary table of exercise Inadequacies as a basis
for working with the FEMA Region in accomplishing the remedial actions.
4. Within 60 days from the exercise, the FEMA Region will prepare and.
transmit copies of the exercise report to the State(s), RAC(s) and FEMA
Headquarters.
If the remedial exercise or other remedial actions
have been taken and evaluated prior to the end of the 60 day period, the
FEMA Region will incorporate its evaluation of these actions within the
exercise report. (In this case, the report will be completed and forwarded
within 30 days of the remedial exercise or other remedial actions.)
5. FEMA Headquarters will forward a copy of the exercise report to NRC
Headquarters within 10 days of receipt from the FEMA Regional Office.
6. If the remedial exercise or other remedial actions are not conducted
prior to the preparation and forwarding of the exercise report, they
should be completed as soon as possible but not later than 60 days after
the report is forwarded to FEMA Headquarters.
7.
If the evaluation of the remedial exercise or other remedial actions
are not incorporated into the exercise report, the FEMA Regional Office
will prepare and forward an evaluation report of these remedial actions
to the State(s), RAC(s) and FEMA Headquarters within 30 days of the
conduct of their completion.
8. FEMA Headquarters will forward a copy of the remedial action evaluation
report to NRC Headquarters within 10 days of receipt from the FEMA Regional
Office.
Extent of Participation
The extent of State and local government participation in a remedial exercise
shall be determined by the FEMA Regional Director.
Some factors to consider in
this determination include:
1. The remedial exercise should address only those activities that are necessary
to demonstrate correction of the identified deficiencies.
2.. To
the extent possible, the remedial exercise participation should be
limited to organizations having the deficiency(ies).
3. When the corrective action by one organization cannot be demonstrated
without involvement of other organizations, their participation should
be at a level necessary to confirm the corrective action.
This includes
participation by utilities which should be arranged through the
appropriate NRC Regional Administrator.
p
Attachment 3
IN 85-55 July 15, 1985 -4-
Action on Inadequately Performed Remedial Exercises
When evaluation of a remedial exercise Indicates that an organization did not
adequately demonstrate correction of identified deficiencies, one of the
following actions are to be taken.
-
1. If FEMA has not approved offsite planning
involved site under 44 CFR 350, FEMA may, require another remedial exercise and the
actions.
and preparedness for the
in consultation with NRC,
NRC may consider enforcement
2. If FEMA has approved offsite planning and preparedness for the involved
site under 44 CFR 350, FEMA may initiate steps to withdraw the 350
approval or schedule another remedial exercise under the provision of
350.13 and the NRC may consider enforcement actions.
Coordination with NRC
This Guidance Memorandum has been prepared in coordination with the NRC staff.
Attachment 4
July 15, 1985
LIST OF RECENTLY ISSUED
IE INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issue
Issued to
85-54
85-53 Teletheraphy Unit Malfunction 7/15/85
85-52
85-51
85-50
Performance Of NRC-Licensed
Individuals While On Duty
Errors In Dose Assessment
Computer Codes And Reporting
Requirements Under 10 CFR
Part 21
Inadvertent Loss Or Improper
Actuation Of Safety-Related
Equipment
Complete Loss Of Main And
Auxiliary Feedwater At A PWR
Designed By Babcock & Wilcox
Relay Calibration Problem
Respirator Users Notice:
Defective Self-Contained
Breathing Apparatus Air
Cylinders
Potential Effect Of Line-
Induced Vibration On Certain
Target Rock Solenoid-Operated
Valves
7/12/85
7/10/85
7/10/85
7/8/85
7/1/85
6/19/85
6/18/85
All NRC licensees
authorized to use
teletheraphy units
All power reactor
facilities holding
All power reactor
facilities holding
All power reactor
facilities holding
All power reactor
facilities holding
All power reactor
facilities holding
All power reactor
facilities holding
an OL or CP, research, and test reactor, fuel cycle and
Priority 1 material
licensees
All power reactor
facilities holding
85-49
85-48
85-47 OL = Operating License
CP = Construction Permit