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
or a
All nuclear power reactor facilities holding an operating license (OL)
construction permit (CP).
Purpose
the frequency
This notice is to alert licensees of revised requirements regarding
of participation by state and local governments in emergency preparedness will
exercises at nuclear power reactor sites. It is expected that addressees
review the information provided for applicability to their program. Suggestionsno
contained in this notice do not constitute NRC requirements; therefore, specific action or written response is required.
Description of Circumstances
FR 27733)
On July 6, 1984, the Commission published in the Federal Register (49 (Attachment 1) a revised rule effective August 6, 1984, relating to emergency
IV.F.
preparedness exercises. The revised 10 CFR Part 50, Appendix E, Section in emergency
relaxes the frequency of participation by state and local governments to
preparedness exercises from annually to biennially. This relaxation in theapplies
state and local governments that have fully participated (as defined
the new
revised rule) in a joint exercise since October 1, 1982. In addition, of its on- rule requires (1) each licensee at each site to conduct an exercise state and
site plan annually, (2) each licensee to provide an opportunity for
local governments to participate annually, (3) each state within the plume
exercise
exposure pathway EPZ of a given site to fully participate in an offsite
within any ingestion
for that site at least once every 7 years, (4) each state ingestion
exposure pathway EPZ to exercise its plans and preparedness related to
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.
be
This rule change also specifies that a full participation exercise shall "shall
held within 1 year before operation above 5 percent of rated power and
expo- include participation by each [s~tate and local government within the plume EPZ."
sure pathway EPZ and each [s]tate within the ingestion exposure pathway
in
(Note, however, that the United States Court of Appeals for the D.C. Circuit
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 operationalan
inspection process and not part of any operating license hearing. Therefore,
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=:
proviso that. if al major elements in the Public Commabta
emergency plan are performed in a The NRC proposed rile was published
satisfactory manner during the annual In the Federal Register with a 60-day
exercise, FEMA may recommend and comment period on July 21. S83 (48 FR
the NRC may find that another exercise 33307). Seventyone comment letters
with State and local government were received and evaluated by the
participation is not required for up to 2 NRC staf£
yearsm The proposed rule did not relax in Those commenters (55) favoring
any manner the annual requirement for relaxing the frequency of State and local
onsite e*ercises that each licensee is governmental participation In
required to conduct which include emergency preparedness exercises were
exercising the control room. technical utilities. consulting firms representing
support center, and emergency utilities. two State Governors. State and
operation facility functions. local governmental agencies. FLNIA and
Immediately after the Commission private citizens.
approved publication of the proposed Those commenters (14) opposing
rule, the Director of FEMAP ote to NRC relaxing the frequency of State and local
Chairman Palladino. urging the governmental peaticipation in
Commission to " '
- adopt biennial emergency preparedness exercises were
exercise frequency language * * *" in 10 an information service, environmental
CFR Part SO, Appendix E to assure gpoups, a State Governor. State and
consistency in the regulations. local governmental agencies, EPA and
FEMAvs final regulation. 44 CFR 350. private citizens.
published In the Federal Register on The comments raisedseveral
September 2B 1983 48 FR 44332), significant Issues, to which the
reduced State and local participation in Commission responds as follows:
emergency preparedness exercises to a Jssue No.
frequency of once every 2 years. The
FEMA final rule is not consistent with Should the Commission adopt a
the position taken by the Commission in biennial exercise frequency for State
-the NRC proposed rule (an annual and local government participation with
frequency with a specific NRC finding a proviso for remedial exercises for the
necessary for relaxation). This correction of serious deficiecies rather
NUCSLEAR REGULATORY difference was a source of some concern than the exercise frequency contained in
COMMISSION to both agencies and to some of the the proposed rule?
10 CFR Part 50
commenters on the NRC proposed rule. Discussion This issue was addressed
The FEMA regulation requires that a by many State and local governmental
Emergency Planning and State within the plume exposure comment letters whose concerns are
Preparedness
pathway EPZ fully participate in an generaly characterized by the following
exercise every 2 years with no quote from the FEMA comment letten
Aavsc'r Nuclear Regulatory requirement on the return frequency at a The NRC propol will be diicult to
Commission. specific site. Typically, therefore. a State administer. For example. objedtve critera
ACTIctw F-nal rule. with two sites might be expected to fully will need to be developed for use in
participate in an exercise at a specific determining whether State and local
SUIEAFr. The Commission is amending site at least every 4 years, a State with governments have perforned in a satisfactory
its rerulations to relax the frequency of three sites, every 6 years: four sites. enough manner to warrant an exemption
participation by State and local every 8 years: five sites, every 10 years. from the succeeding year's exercise. It will be
governmental authorities in emergency difficult to apply such criteria to the
etc. Whereas, the enclosed NRC rule satisfaction of State and local governments
preparedness exercises at nuclear change stipulates that a State within the The NRC proposal would create complex
power reactbr sites. This relaxation pltune exposure pathway EPZ fully situations such as what to dolif some
reflects experience gained in observing participate in an exercise every 2 years jurisdictions perfor in an unsatisfactory
and evaluating over 150 emergency with a retun frequency of at least once manner and the others in a satisfactory
preparedness exercises since 1980. every 7 years at a specific site. Both manner. Would all jurisdicions have to
EFFECTIVE DVA.T August 6.1984. rules require a multi-site State. when not exercise the next year or only the
fully participating in an exercise at a unsatisfactory ones? If only the
FOR FURTHER INFORMATION
CONTACT
- unsatisfactory ones. an unworkable condition
-Michael T. Jamgochian. Accident Source specific site, to partially participate would result wherinso=e jurisdictions
Term Program Office. Office of Nuclear every 2 years at that specific site in would be on annual and others on biennial
Regulatory Research. U.S. Nuclear order to support the participation of the frequency. Inequities would result Further.
Regulatory Comsniision. Washington. appropriate local governments. the time involved for evaluating exercise
DC 205S5. telephone (301) 443-7615. The Commission has selected a return results. including getting commitments from
frequency of 7 years because presently State and local gover:nents to take
SUPPLENEN-ARY INFORMAnON On July co-rective actions, has proved time
21. 983. the Commission published in no State has more than 7 operating and/ consuning in the past. If we add time for the
the Federal Register a proposed rule or planned reactors and Slates with that NRC to make a finding after FIA's
relating to emergency preparedness number of sites or less would not be recommendation. a good portion of a year
exercises (48 FR 33307). The proposed required to exercise in a full could be consumed This would cause
i.le retained the presently required participation mode more often than uncertainty and instability in State and local
arnnual. ill-participation exercise with a about once a year. 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- '. gove nt p rtlcipation .th- ...
Commisajon recoies the - ._ prepednes execises. Fk-A havtt
licensee's -=nual exercis A State or developed and norw uses a document.
implc=n~htild diffilties with thg local goverment may conidsr fts
propoQ
titled "Procecdral Policy onRadieodogice
MC zpproachlartnn response cqxbility to be less tha= Emergency Preparedness Plan RevIew.
freque yldth a find torelxa4 T:his optial becaus of art umsun:y Lage Exercise Observations and Evalusticn- was pointed but by the MRCemergency personnel turnover or because therc
preparedness regional fdspectors. a and Interim Findkngs.'I These
hare been limited responses to real procedures were forwarded to the
majority of the comment letters, the emergencies in the ccnmunity. The final FEcMA regions for ase on August S. is83.
general thrust in two petition's far rule requirs the licensee to provide for Having considered all comme-nts
rulemalng. I and theACRS. State or local govem=et participation received, experience gained since ISM.
issueNo2 if they indicate such a deskr. input from emergency preparedness
Will less frequent exercises result in Issue No. S regional inspectors, the general thrust of
=aking personnel and equipment less two petitions for rulemaking. and ACRS
Will the deletion of NUREG-OSI' as comiments. the Commission has
effective cr reliable and therefore a footnote adversely affect the interface concluded that the requirements for
reduce the level of safety? between ofisite emergency plans and
Discvssisn. A few comenters. frequency of participation by State and
the [;censee's emergency plans? local governmental authorities in
pr.marily citizens and gemamentaj Discussion The proposed rule
organizations. addressed thdi issue by emergency preparedness exercises
included a provision to delete references around nuclear power reactors should
pon-tin out that State aid local to NUREC-0654 throughout the
emergency response organizations must be relaxed.Te Commission therefore is
regulations. NWREG-4 provides promulating a final rule which.
frequently respond to various natural specific criteria for the evaluation of the
and man-made emergencies. 7Is 1. Contitues to require licensees to"
standards in I 5OM and is titled. conduct an armual onsite emergency
continuum of real life emergencies 'Criteria for Preparation and Evaluation
exercises personnel, equimte preparedness exercise.
of Radiological Emergency Response 2. Requires that State and local
communication networks and Plans and Preparedness i Support of
organizetronal strcctures on a requnt governments participate in emergency
Nuclear Plants. A few commenters. preparedness exercises every 2 years
basis. primarily a utility and a state with a provision-for remedial exercises
The following quote from a comment governmental official. felt that the.
letter set. ries this concern: to assure that deficiencies are corrected.
deletion of the NTJREC-o4d footnote in 3. Provides that at least once every 7 Wrile an emergency situation at a nuclear the regulations would preclude its use years. all States within the plume
power plant may call for some procedwres by reviewers in determining the exposure pathway EP"Z-o a given site
tEt are dIfferent from those used under other adequacy of emergency preparednessI. must fully participate in an offisite
emergency sicattors. many of the response CommissionResponse: The delegatlon
and evaceen meewres will be similar. If exercise for that 4s1 of a reference to NlUREG-054 w121 not 4. Requires licensees to provide a
not identicaL A :nyriad of maior and mince affect it use as a guidance document for
emergencies dermand the maintecance of a opportunity for State and local
force o personel viined in thee emergency planning. In the 1980 government participation in the
procedurec. By retpomding to other rulemaking. the Commission included licensees annual emergency
emergenzy a .atio= such as chemical spills. this reference as a means of formally preparedness exer ise. ard
the emergezcy response personnel will be approving the use of NIEMGS-54. See 5. Requires FEMA to determlne the
rehearsing many of the procedures they 45 FR 554eZ 55408 (August 19. 1980). need for and extent of remedial
would ue in theevetzof La energency NUilREC-ft is endorsed by Regzlatcry exercises.
situatien at a nucJear power plant Some Gtide S.lol,' end will-continue to be
examples ct these procedures wvu3d ici. used by reviewers in evaluating the The final rule is not totally consisten
not ifcatiou of approptiate local audfoities adequacy of emergency preparedness at with FEMA's final regulation (44 CFR
erablizhirg coaics tion tirks between nuclear power reactor sites. 350). This inconsistency lies in the res.
locaL regionzl iud state ergey repormw of retmrn frequency fcr Iltipledsite
persnneL zEu evacuating or Flnding helter Issuse No. i states as previously discussed. The
. .
fcr the aIleced pop :ltsce. FEMA pouition on reu frequncy isa
Do adequate procedures exist for NRC
Cozmission Respons: Because and FEiMA to evaluate wheteir major significant depammme from the NRC's
emergency response psonnel at the elements-are performed satisfactorily proposed regulation (48 FR 3;) dted.
State Lad local government kvel during an exercise? July 21. 193. The Commission belleves
continuously respoud to actoal DisciuiojrMany commnenters. that more study is needed before- emergemcis the Codion does not primarily State and local governmental deletion of the return frequency
consider that relaxing the frequency of authorities as well as utilitiepointed requirement can be lustified.
State and local govertment participation out that there is a need for uniform The Commission is adopting a
in ency preparedness exercises evaluation of exercise performance. biennial exercise frequency, for State
would adversely affect the heahth and Commission Resporne: The and local government participation with
safety of the public. Commission concurs with the a proviso for remedial exercises to
A provision has been added in the commenter In order to provide for assure the correction of serious
final rule to permit State or local uniform evaluation of emergency deficiencies. These changes to the
emergency preparedness regulations are
'On March . 2.= me Coi on reived a ' Copies of these documents are av&iLabLa at the being made because:
pet don for -wnakLm lPM-W-3Z from Natonua COMdIrSionS Public DcuMnent Roo. 1717 H a. Experience in observing and
Eme.Fency l tamew
AaaocauaaL On Aupnt 30, Stet NW_ Washingiona D.C. 3SS. Copies of evaluating over 150 exercises has shown
19e &.4Crc_--ma.oc n1ived a petition for these dociumeuts may be purchased from the that a disproportioaate amount of
ueaking (P SC 41 from the A4-utan Gcneral Goverunent Prntt~ Orfioe. Inhouom on cmvrert
of the Sihe of South CsmL-A. The reneral thrust of pnces may be obmatned by wnuns the US. Nudeu
bout pe-oow urgped be relaxuanutf ti frequency Reguiatory Commission. Washinglon. D.C. =S GuCdance for determicits the ceed for. sad
o! enne.n.,
. r;rcedn-se cx. .r.es. Anention: Publizauonn Sles W as e. extent o!. reumedisl exerxmses is beinr develope&
Attachment 1 IN 85-55 July 15, 10985 Federal Rk-ester /.Yl.L 49; -,No. 131:.I Friday, luly:fl. 1084-( 'Rides anvR u2a7os
Federal. State and local government and Fiding of No Sinificant Eaviro e6ntal T. JaMgochla Office of N cea- -,
licecsee resources are being expended Regulatory Research. US. Nuclear
in order to conduct and evaluate annual Regulatory Commission. Washington.-
The Commission has determined
eniergency preparedness exercises. As a under the Naticnal Environmental Policy DC 2=5, Telephone (3011 443-78.
result of the substantial expenditure of Act of 1989, as amended, and the
resources for these exercises. fewer Regulatory Flexibillty Certficatin
Commission's regulations in Subpart A
resources are available to establish and of 10 CFR Part 51. that this rule Is not a In accordance with the Regulatory
maintaLn the essential day-to-day major Federal action significantly Flexibility Act of 1S90 5 U.S.C. 605(
upgraded state of emergency affecting the quality of the human the Commission hereby certifies that
preparedness. environment and therefore an this final rule will not. if promulgated.
b. State and local governments envirrnmental impact statement is not have a significant economic impact an a
respond to a variety of actual required. See 10 CFR 51.20(a)(1). substantial number of small entities. The
emn-eencies on a contisaing basis. thus Moreover. the Commission has final rule clarifies certain elements and
frecuent~l exercising ther emergency determined. pursuant to 10 CFR 51.32, findings necessary for the Issuance of an
preparedness capabilities. that the final rule has no significant operating license for a nuclear power
c. The flexibility provided for in a environmental impact. This plant licensed pursuant to sections 103 biennial frequency will be an incentive determination has been made because and 104b of the Atomic Energy Act of
for State and local governments to the Commission eannot identify any 1954. as amended. 42 U.S.C. 2133. 2134b.
perform.in a satisfactory marmer in impact on the human environment The electric utility companies which
order to avoid conducting remedial associated with reducing the frequency own and operate nuclear power plants
of full participation of State and local are dominant in their service areas and
exercises.
And lastly. the Commission notes that governments in emergency preparedness do not fall within the definition of a
exercises from annually to biennially. small business found in Section 3 of the
MEMA has had aLmost 3 years of The alternative approaches that were Small Business Act. 15 U.S.C. 32 or
experience with evaluating State and considered in this rulemaking within the Small Business Size
local government radiological proceedings were: Standards set forth In 13 CFR Part In.
emergency planning and preparedness. 1. To retain the annual full Accordingly. there Is no significant
With few exceptions. this experience participation exercise with a provision economic Impact on a substantial
kas revealed a significant increase in to enable relaxation to every 2 years. number of small entities under the
the level cf State and local government Z.To incorporsteby reference into the Regulatory Flexibility tct of 190
radiological preparedness as NRC-s regulations, the FD
demcns rated in joint exercises. FEhiA List of Subjects In 10 CFR Part 50
regulations governg the frequency of
has evaluated approximately 150 full participation of State and local Antitrust Classified information. Fire
exercises. 1:i only five instances did governments in emergency preparedness prevention. Incorporation by reference.
FEMA determine that Stale and local exercises. Intergovernmental relations. Nuclear
govermr:en-s did not demonstrate 3. To relax the frequency of full power plants and reactors. Penalty.
adequate preparedness. The participation of State and local Radiation protection. Reactor siting
Commission believes that this enhanced governments in emergency preparedness criteria. Reporting and recordkeeping
level of preparedness should be exercises from annually to biennially. requirements.
recoFnized by allowing State and local There were no environmental impacts
governzients to exercise jointly with Pursuant to the Atomic Energy Act of
identified from any of the alternatives 954. as amended. the Energy
utilities or. a binenrial frequency. considered. Reorganization Act of 2374. as amende:;
On March 17. 1982. the Commission Because FEMA is directly involved in and section 552 and 553 of Title 5 of the
received a petition for rulemaking the evaluation of offsite emergency United States Code, notice is hereby
(PIRUM-5C-3) from National Emergency preparedness exercises and is affected given that the following amendment to
Management Association. On August 30. by the promulgation of these Title 10. Chapter L Code of Federal
198.7 the Coinm ission received a petition amendments. the NRC consulted Regulations, Part S is published as a
for nrlemaking (PRM-50-M3) from the extensively with FDA during the document subject to codification.
Adjutant General of the State of South development of this rule.
Carolina. The petition from the National Paperwocrk Reduction Act Statement PART 50-DOMESTIC UCEPSING OF
Emergency Management Association PRODUCTION AND UTILIZATI
requested the NRC to relax the The final rule contains no information FACILITIES
frequency of full participation by State collection requirements and therefore is
and local governments in emergency not subject to the requirements of the 1. The authority citation for Part 50
preparedness exercises from annually to Paperwork Reduction Act of 1980 (44 continues to read as follows:
bier.nia!yv. The petition from South U.S.C. 3501 et seq.). Authodtr.Secs_ Im3. 20" 181. 1t:. I83 Im
Carolkia requested that the NRC reduce Regulatory Analysis 188. 68 Stat. SS37.9 53.94.9S5.
V L. as
the frequency with which local amended. sec. Z34. 83 Stat. 1244. as amended
The Commission has prepared a 42 U.S.C 2233. :134. Z20L 2232. 233.228.'
governmoents must participate in a full regulatory analysis of this regulation. 2238. 2282) secs. 201. ;0: 20.868 Stat 12C4.
scale emergency preparedness exercise. The analysis examines the costs and 1244.124& as amended (42 U.S.C. 841.54S.
The promulgation of this final rule benefits of the rule as considered by the SW48). unless otherwise noted.
relaxes *he frequency of full Commission. A copy of the regulatory Sec. 50.7 also issued under Pub. L -.
participation by State and local analysis is available for inspection and ace. 10.92 Stat. 252 (42 U.S.C. 5851). Secs.
govermnnents in emergency preparedness copying. for a fee. at the NRC Public 50.57(d) 50.58. 50*1. and 50.S2 also isued
exercises from annually to biennially. under Pub. L 97-415.96 Stat. 2071.2073142 Document Room. 1717 H Street NW.. U.S.C. 2133. 2239). Sec. 50.78 also Issued
I his rule completes NRC action by Washington. DC. Single copies of the under sec. 12:.08 Stat. 139 (42 US.C. =52).
granting bcth petitions for rulemaking. analysis may be obtained from Michael 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)- eas isb roals ykhimble . CcnesctRLo Any weakneeaes se in~ce
Secs. 50.2 a2 aLo kse sft lase witout mandatory public particpationlL; that etd solW be c, -
U StL at as2 ULS.C.28 *-. be conducted for each site at which a power
For the purp*.at&Is of.. StL 958. as
SS reactor Islocated for wich the &frt aperat 4. In Appendix E footnotes 1 and 4 amended (42 U.S.C 2:J5- -i 5.10(a. (b). license for that sit frrued after MY 13. arm removedJfootnotes Z and 3 are .
and kc). BOtMS ML&& ad 5901"a) am. 182. This exercise shall be conductud withbi renumbered as fDctn otes 1 and.i and
isued nder sec. llb. t StaL 941 as l year be e ace th rst new footnotes 3, 4. and S are added to
amended (,2 U-S.C. ¢t. H 5010(b) and openating linene for hl power and prlor to read as follows:
(c) and 5S5 we kxued Knder let 1l1L W operation above 5%f rated power of the frst
Stat. 949. as ereede (42 U.S.C. Z(th and reactor, and sa e prticipatio by ' Use of site spedcf! simulatars or
I I SO5(4e), 505(b. 50-0.5071. £.72. 3073. eacr- State and local goverent within the computers is acceptable ror any exercis
and Sa8 are issued unda ac 181o, 68 Stat. plume expos pathway !M and each State ' 'Fuil participation' when used in
950. as aoended (42 USC. 2201o). within the ingestion expo rt re pathway EPZ conjunction with emergency prepaednesc
2. Each licensee at each srhe shall annually exercises for a particular site means
J 88.47 [Amended) exercise its Ce::-jency pla appropriate offKlte local and State auth:ties
3. Each licersee at each site shall ers and licens personnel physically and
2. In I 50.47. Footnote I Is removed.
3. in Appendix E. section IV.F Is with offsite authorities such that the State actively take part in testing their integrated
and local governsent emergency plans for capability to adequately access and respond
revised to read as follows: each operatir^g reactor site are exercised to an accident at a co:mercial nuclear power
biernially. with full or partial participation plant. 'Full particpation" Inchldes testing the
Appondlx E-Emergency Plannrng and by States and local governments. within the major observable portions of the onsite and
Prepa'edrres3 for Producton and plume exposnre pathway E State and offalte emergency plans and mobilization of
Utbfnt Faclifles local governments that have ly Sate local and licensee personnel and other
M . . .I particpated tm a joint exercise since October resources in sufficient muinbers to verify the
1. aM are eligible to fuly participate ta capability to respond to the scideact
emergency preparednm mxises on a scenario.
F. 7raining. biennial frequency. Tha level of participation
The program to provide for (1) the training ' Partial participatioan when used In
shall be as follows: conjunction With eCMerency preparedneSS
o! employees and exercistng. by periodic (a) A State shall at least partially
drills of radiatiom emergency phls= to ensure exercises for a particular site eans
participate in each offaits exercise at each appropriate offnite authorities shall actirely
that emolo'ees of the licensee are familiar -site.
with their specific emergency response take part in the exercise icient to test
(b) A State shall fally participate in at leest direction and contrl fhincons La. (a)
duties. and (2) the participatioan in the one offsite exercise every 2 years.
trzining and drcls by other persons whose protective action decision making related to
(c) At least oc every 7 year all States emergency action levmstaiand (b)!
assistance may be needed in the event of a within the plume exposure pathway EDZ fore
radiation emergency shall be described. This cormunication capabilities among azected
given site must fully participate in an offaite State and local authorities ad'the licensee.
shall include a description of specialized exercise for that sita. This exercise must also .0
- *
initial traLning and periodic retainirM involve full participation by local
proramas to be provided to each of the governments within tie plume exposure Dated at Washington. D.C. this 2th day ol
followy catrorier of emergency personnceb pathway EZ. June 1934.
a. Dire-cors and/or coordinatos of the (d) Partial participation by a local For the Nuclear Regulatory CommisLo&.
p'ant emergency oraniation: government during an offsite exercise for a
b. Personnel respaosible for accident Samuel J. Chilk
site is acceptable only when the local
assessment. including control room shift government is fully participa tng in a biennial Secretaryof the Commission
perso-nel: exercise at another site. R Doc 5-li7M rd
r -i-
& g of - -
c. Radloloical monitoring teamsa (el Each State within any ingestion 81+/-)9 CM w
L'Fure ccntrl teams (Firs brimadesk exposure pathway EPZ shall exercise its
e. P-epe and damage control tamm plans and preparedness related to ingestion
I. Fzs- aid and rescue teasa exponre pathway measures at leads once
S.Medical support personnel every S years.
Licensee's eadquazier support (f) Licensee, shall enable any State or local
persoarel government located within the plume
i. Secu.ty personneL exposure pathway EPZ to participated In
I- addition. a rzdiologcal orientation annual exmsea r-ihen requested by such
tr2alwg ;-*m=rn shall be made available to State or local government.
local servmas Monnek e4..local emergency 4. Remedial exercises will be required If
serices/CIvil Defense. local law the et=ency pla Isnot satisfactorily
enJforcee-et pevonneL local news eslia tested during the biennial exercise. such that
persons. NRC.tn consultation with FDMA. cannot find
rhe plan shall describe provisions for the reasocable assurance that adequate
condoct of emergency preparedness exercises protective meabares can be taken In the event
are follows: Exercise sha test the adsqcy to a radiological emergency. The extent of
of timing and coote-A of im.plementing State and local participation in remedal
procedures and metho~s. test emergency exercses must be sufficient to show that
equipr:ea and co-ica ons networks. appropriate corrective meascres have been
test the public nnsication system. and taken regardiog the element of the plan not
ensure that emergency organization properly tested in the previous exercis
personnel are familiar with their dutite.a 5. All train;1in including exercises, shall
1. A full participadn ' exercise which provide for formal critiques in order to
tests as much of the licernsee. State and local idectify weak or deficient areas that need
Attachment 1 INW15-55 July 15, 1985. i~el~
Attachment 2 IN 85-55
.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 IN 85-55 July 15, 1985 MILESTONES FOR MCERCISE OBSERVATZON AND CRITIQUES ge 3 of 3
- 75 days* State and licensee jointly suli;t exercise objective to
FMA and NRC Regional Offices.
- 60 days FMA and NRC Regional Offices discuss and meet with
licensee/State as necessary and prepare response.
- 45 days State and licensee scenario developers submit exercise
scenario to FE4A and NRC Regions for review.
- 35 days FEKA and NRC Regions notify State and licensee of scenario
acceptability.
- 30 days MA and NRC Regions develop specific post exercise critique
schedule with the State and advise FMA and NRC headquarters.
- 15 days 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).
- 1 day Meeting, in the exercise area, of all Federal observers both
onsite and offsite to f4nalize assigments, and give instructions.
E day Exer-ise
E day FM11A and RAC observers caucus to collate observations. NRC
observers also caucus to collate observations.
E day RAC Chairman and NRC team leader meet, as soon after their
respective caucuses as practical, to coordinate Federal
participation in critique.
E t0o 1 day 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 IN 85-55 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 IN 85-55
-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
-4- July 15, 1985 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 and preparedness for the
involved site under 44 CFR 350, FEMA may, in consultation with NRC,
require another remedial exercise and the NRC may consider enforcement
actions.
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 IN 85-55 July 15, 1985 LIST OF RECENTLY ISSUED
IE INFORMATION NOTICES
Information Date of
Notice No. Subject Issue Issued to
85-54 Teletheraphy Unit Malfunction 7/15/85 All NRC licensees
authorized to use
teletheraphy units
85-53 Performance Of NRC-Licensed 7/12/85 All power reactor
Individuals While On Duty facilities holding
85-52 Errors In Dose Assessment 7/10/85 All power reactor
Computer Codes And Reporting facilities holding
Requirements Under 10 CFR an OL or CP
Part 21
85-51 Inadvertent Loss Or Improper 7/10/85 All power reactor
Actuation Of Safety-Related facilities holding
85-50 Complete Loss Of Main And 7/8/85 All power reactor
Auxiliary Feedwater At A PWR facilities holding
Designed By Babcock & Wilcox an OL or CP
85-49 Relay Calibration Problem 7/1/85 All power reactor
facilities holding
85-48 Respirator Users Notice: 6/19/85 All power reactor
Defective Self-Contained facilities holding
Breathing Apparatus Air an OL or CP, research, Cylinders and test reactor, fuel cycle and
Priority 1 material
licensees
85-47 Potential Effect Of Line- 6/18/85 All power reactor
Induced Vibration On Certain facilities holding
Target Rock Solenoid-Operated an OL or CP
Valves
OL = Operating License
CP = Construction Permit