Information Notice 1989-46, Confidentiality of Exercise Scenarios

Confidentiality of Exercise Scenarios

ML031190361
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	05/11/1989
From:	Cunningham R NRC/NMSS/IMNS
To:
References
IN-89-046, NUDOCS 8905080009
Download: ML031190361 (10)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555 May 11, 1989 NRC INFORMATION NOTICE NO. 89-46: CONFIDENTIALITY OF EXERCISE SCENARIOS

Addressees

All holders of licenses for fuel cycle facilities and byproduct material

licensees having an approved emergency response plan.

Purpose

This information notice is being provided to alert fuel facility and certain

byproduct material licensees of the unacceptable practice of conducting the

required annual radiological emergency response exercises using 'players who

are familiar with the details of the exercise scenarios. It is expected that

recipients will review the information for applicability to their programs, distribute the notice to responsible radiation protection and emergency response

staff, and consider actions, if appropriate, to ensure that emergency response

exercises fulfill their intended purpose. However, suggestions contained in

this information notice do not constitute new U.S. Nuclear Regulatory Commission

(NRC) requirements, and no written response is required.

Description of Circumstances

During NRC's observation and evaluation of a recent radiological emergency

exercise at a fuel facility in NRC Region II, the inspectors learned that

the licensee was planning to use a scenario that was familiar to the exercise

players. The inspectors also learned that a training handout was provided to

members of the emergency organization which intentionally included the actual

scenario to be used for the exercise. The scenario and the various players'

anticipated roles were apparently discussed and "rehearsed." The handout

also offered applicable emergency procedures (or portions thereof) for use

by players during the exercise. Subsequent inspections at other fuel cycle

facilities have revealed that this situation is not unique. Failure to

conduct a radiological emergency exercise in a manner that adequately tests

a licensee's ability to implement the Radiological Contingency Plan could

result in an NRC request to conduct a remedial exercise, as occurred in the

case discussed above.

Discussion:

Fuel facility and major byproduct materials licensees were ordered under a

Generic Order published in the Federal Register (Vol. 46, No. 31, February 17,

1981) to submit radiological contingencyplans to the NRC licensing staff for

incorporation into their licenses. The emergency response plans submitted in

508000 Z I"191

IN 89-46 May 11, 1989 response to this order have been incorporated as license conditions for a

number of years. These plans include requirements for periodic training, drills, and exercises. The purpose of training and drills is to familiarize

participants with the contents of the contingency plan, procedures, and the

types of events that would take place in the facility.

However, for exercises, it was the NRC's intention that participants not have

prior knowledge of the specific exercise scenario. Exercises are conducted

to test response capabilities and ensure that radiological emergency personnel

are familiar with their duties. Observers of exercises cannot evaluate the

effectiveness of personnel actions if the personnel have been briefed on the

scenarios prior to the exercise.

The new final rule, effective April 7, 1990 (Federal Register Vol. 54, No. 66, published April 7, 1989) states, "Exercises must use accident scenarios postu- lated as most probable for the specific site and the scenarios shall not be

known to most exercise participants. The licensee shall critique each exer- cise using individuals not having direct implementation responsibility for

the plan. Critiques of exercises must evaluate the appropriateness of the

plan, emergency procedures, facilities, equipment, training of personnel, and

overall effectiveness of the response. Deficiencies found by the critiques

must be corrected."

No specific action or written response is required by this information notice.

If y-o-u -ave

any questions -aboudtthisMatte, pea~se direct them to the technical

contact listed below, or to the Regional Administrator of the appropriate NRC

Regional Office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical Contacts: Edwin D. Flack, NMSS

(301) 492-0405 Douglas M. Collins, Region II

(404) 242-5586 Attachments:

1. List of Recently issued NMSS Information Notices

2. List of All Recently Issued NRC Information Notices

Attachment 1 IN 89-46 May 11, 1989 LIST OF RECENTLY ISSUED

NMSS INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

89-37 Proposed Amendments to 40 04/04/89 All U.S. NRC

CFR Part 61, Air Emission licensees

Standards for Radionuclides

89-35 Loss and Theft of Unsecured 03/30/89 All U.S. NRC byproduct, Licensed Material source and special

nuclear material licensees

89-34. Disposal of Americium 03/30/89 All holders of U.S.

Well-Logging Sources NRC specific licenses

authorizing well-logging

activities.

89-25 Unauthorized Transfer of 03/07/89 All NRC source, Ownership or Control of byproduct, and special

Licensed Activities nuclear material

licensees.

89-24 Nuclear Criticality Safety 03/06/89 All fuel cycle

licensees and other

licensees possessing

more than critical mass

quantities of special

nuclear material.

89-13 Alternative Waste Management 02/08/89 All holders of NRC

Procedures in Case of Denial specific licenses.

of Access to Low-Level Waste

Disposal Sites

89-12 Dose Calibrator Quality 02/09/89 All NRC medical

Control licensees.

89-03 Potential Electrical 01/11/89 All fuel cycle and

Equipment Problems major nuclear materials

licensees.

Attachment 2

1. 81-48 May 11, 1989 Pag 1 of 1 LIST OF RECEIITY ISSUED

NRCINFORRATIUON NOTICES

Lftcrrition ,ace or

Notice No. Suebect Issuance Issued to

89.45 Metalclad. Low-Voltage 5/8/89 All holders of OLs

Power Circuit 3reakors or CPs for nuclear

Refurbisheo with Sub- power reactors.

stanoard Parts

89-44 Hydrogen Storage an tne 4/27/89 All rolders of OLs

Roof of the Control Room or CPs for ruclear

power reactors.

28-82. Torus Stells with Corrosion Si2/89 All holders of OLs

Supp. I ane Cegraded Coatings in or CPs for 864s.

Ild Containments

89-43 Permanent Deformation of 5/1/89 All holders of OLs

Torque Switch Helfical or CPs for nuclear

Springs in Lizitorque power reactors.

SA-Type Motor Operators

88-97. Potentially Substandard 4/28/89 All holders of OLS

Supp. I Valve Replacerent Parts or CPs for nuclear

power reactors.

89-42 Failure of Rosemount 4/21/89 All holders of OL5 Focels 1153 ano 1:54 or CPs for nuclear

Transi tters power reactors.

89-41 Operator hesponse to 4/2,089 All holvers of OLs

Pressurization of Low- or CPS for nuclear

Pressure Interfacing power reactors.

Systems

a8-75, Disabling of 01esel 4/1689 All holders of OLs

Supplement I Generator Cut;ut Circuit or CPs for nuclear

Sreakers by Anti-;Pwm power reactors.

Cfrcuitry

-- ------- 8t.4C: - ffsattsfc:ory1:orar rettT/I4/1s~9 All hoieers ofCLs~

Results ano Their Etfdct on or CPS for nuclear

the Requalificat1on Program power reactors.

89-i9 Cist of Pertles Excluoed 4/5/89 All holders of CLs

from Federal Procurement or CPs for nuclear

or Rlon-Procurement Programs ;ower reattors.

CL

• Coerating Licenic

C?

• Construction Permit

UNITED STATES FIRST CLASS MAIL

NUCLEAR REGULATORY COMMISSION POSTAGE 1 FEES PAID

WASHINGTON, D.C. 20555 USNARC

PERMIT No. 0.67 OFFICIAL BUSINESS

PENALTY FOR PRIVATE USE, $300

IN 89-46 May 11, 1989 response to this order have been incorporated as license conditions for a

number of years. These plans include requirements for periodic training, drills, and exercises. The purpose of training and drills is to familiarize

participants with the contents of the contingency plan, procedures, and the

types of events that would take place in the facility.

However, for exercises, it was the NRC's intention that participants not have

prior knowledge of the specific exercise scenario. Exercises are conducted

to test response capabilities and ensure that radiological emergency personnel

are familiar with their duties. Observers of exercises cannot evaluate the

effectiveness of personnel actions if the personnel have been briefed on the

scenarios prior to the exercise.

The new final rule, effective April 7, 1990 (Federal Register Vol. 54, No. 66, published April 7, 1989) states, Exercises must use acient scenarios postu- lated as most probable for the specific site and the scenarios shall not be

known to most exercise participants. The licensee shall critique each exer- cise using individuals not having direct implementation responsibility for

the plan. Critiques of exercises must evaluate the appropriateness of the

plan, emergency procedures, facilities, equipment, training of personnel, and

overall effectiveness of the response. Deficiencies found by the critiques

must be corrected."

No specific action or written response isrequired by this information notice.

Ifyou have any questions about this matter, please direct them to the technical

contact listed below, or to the Regional Administrator of the appropriate NRC

Regional Office.

PriinaI Signed by

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical Contacts: Edwin D. Flack, NMSS

(301) 492-0405 Douglas M. Collins, Region II

(404) 242-5586 Attachments:

1. List of Recently issued NMSS Information Notices

2. List of All Recently Issued NRC Information Notices

Editor *IMNS

EKraus RECunningham

4/6 /89 5/7/89

• See previous concurrence

OFC: IMOB* :IMSB* :IMOB* :OGC* :RII* :IMOB* :IMSB* : IMNS*

---

for tel.-------------------------

NAME:JMetzger/ll:GBidinger:JLyash :RFonner :DCollins :DCool :LRouse :GSjoblom

DATE:4/20 /89 :4/26/89 :4 /g§sLi j046S82n:5cQZ/89 :5/4/89: 4/27/89: 5/5/89

IN 89- May , 1989 Page 2 of

However, for exercises, it was the NRC's intention that participants not have

prior knowledge of the specific exercise scenario. Exercises are conducted to

test response capabilities and ensure that radiological emergency personnel

are familiar with their duties. Observers of exercises cannot evaluate the

effectiveness of personnel actions if the personnel have been briefed on the

scenarios prior to the exercise.

The new final rule, effective April 7, 1990 (Federal Register Vol. 54, No. 66, published April 7, 1989) states, "Exercises mus use accident scenarios

postulated as most probable for the specific site and the scenarios shall not

be known to most exercise participants. The licensee shall critique each

exercise using individuals not having direct implementation responsibility for

the plan. Critiques of exercises must evaluate the appropriateness of the

plan, emergency procedures, facilities, equipment, training of personnel, and

overall effectiveness of the response. Deficiencies found by the critiques

must be corrected."

No specific action or written response is required by this Information

Notice. If you have any questions about this matter, please direct them to

the technical contact listed below, or to the Regional Administrator of the

appropriate NRC Regional Office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety, NMSS

Technical Contacts: Edwin D. Flack, NMSS

(301) 492-0405 Douglas M. Collins, Region II

(404) 242-5586 Attachments:

1. List of recently issued NMSS Information Notices

2. List of all recently issued NRC Information Notices

Editor

EKrausiha

4/6 /89 5/9F/89

• See previous concurrence

OFC: IMOB* :IMSB* :IMOB* :OGC* :RII* :IMOSB  ;.MSB* : Imqh

---

for tel.--- ---------

NAME:JMetzger/ll:GBidinger:JLyash :RFonner :DCollins " :LRouse :GwMb m

DATE:4/20 /89 :4/26/89 -4/2618 404 29:51089- :5/q /89:5/27/89:5/\ /89 LPLL RECORDU CUYI

OFFI

IN 89- Vw Apri4- , 1989 Page 2 of

However, for exercises, it was the NRC's intention that participants not have

prior knowledge of the specific exercise scenario. Exercises are conducted to

test response capabilities and ensure that radiological emergency personnel

are'familiar with their duties. Observers of exercises cannot evaluate the

effectiveness of personnel actions if the personnel have been briefed on the

scenarios prior to the exercise.

The new final rule, effective April 7, 1990 (Federal Register Vol. 54, No. 66, published April 7, 1989) states, "Exercises must use accident scenarios

postulated as most probable for the specific site and the scenarios shall not

be known to most exercise participants. The licensee shall critique each

exercise using individuals not having direct implementation responsibility for

the plan. Critiques of exercises must evaluate the appropriateness of the

plan, emergency procedures, facilities, equipment, training of personnel, and

overall effectiveness of the response. Deficiencies found by the critiques

must be corrected." X

No specific action or written response is required by this Information

Notice. If you have any 4uestions about this matter, please direct them to

the technical contact listed below, or to the Regional Administrator of the

appropriate NRC Regional Office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety, NMSS

Douglas M. Collins, Region II

(404) 242-5586 Attachments:

1. List of recently issued NMSS Information Notices

2. List of all recently issued NRC Information Notices

Editor IMNS

EKraus RECunningham

4/6 /89 4/ /89

• See previous concurrence

OFC: IMOB* :IMSB* :IMOB* :OGC* :RIIJfl  : IMOB : IM5B* : IMNS

_________---------------------- -------------------------

NAME:JMetzger/ll:GBidinger:JLyash :RFonner: D-flinw DCool: LRouse: GSjoblon

DATE:4/20 /89 :4/26/89 4 /89:4?27/89:A/ /89

IN 89- April 1989 Page 2 of

However, for exercises, it was the NRC's intention that participants not have

prior, knowledge of the specific exercise scenario. Exercises are conducted to

test response capabilities and ensure that radiological emergency personnel

are famIliar with their duties. Observers of exercises cannot evaluate the

effectiveness of personnel actions if the personnel have been briefed on the

scenarios prior to the exercise.

The new final rjle, effective April 7, 1990 (Federal Register Vol. 54, No. 66, published April '7,1989) states, "Exercises must use accident scenarios

postulated as most probable for the specific site and the scenarios shall not

be known to most exercise participants. The licensee shall critique each

exercise using individuals not having direct implementation responsibility for

the plan. Critiques of exercises must evaluate the appropriateness of the

plan, emergency procedures, facilities, equipment, training of personnel, and

overall effectiveness of the response. Deficiencies found by the critiques

must be corrected."

No specific action or written response is required by this Information

Notice. If you have any questions about this matter, please direct them to

the technical contact listed below, or to the Regional Administrator of the

appropriate NRC Regional Office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety, NMSS

Douglas M. Collins, Region II

(404) 242-5586 Attachments:

1. List of recently issued NMSS Information Notices

2. List of all recently issued NRC Information Notices

Editor IMNS

EKraus RECunningham

4/6 /89 4/ /89

• See previous concurrence

oFC: IMOB* :IMSB*  :,M OGC* l IMOB :IM, :IMNS

NAME:JMetzger/ll:GBidingertyash :RFonner :DCool :GSjoblom

DATE:4/20 /89 :4/26/89 :4l66l2 4Q42j 690j /89 :4Z/,89 :4/ /89

IN 89- April , 1989 Page 2 of

Conduct of drills and exercises are to ensure that radiological emergency

personnel are familiar with their duties. Observers of drills and exercises

can t evaluate the effectiveness of personnel actions if the personnel have

been xposed to the scenarios during training.

The new inal rule, effective April 7, 1990 (Federal Register Vol. 54, No. 66, published April 7, 1989) states, "Exercises must use accident scenarios

postulated as most probable for the specific site and the scenarios shall not

be known to most exercise participants. The licensee shall critique each

exercise using individuals not having direct implementation responsibility for

the plan. Critiques of exercises must evaluate the appropriateness of the

plan, emergency procedures, facilities, equipment, training of personnel, and

overall effectiveness of the response. Deficiencies found by the critiques

must be corrected."

No specific action or written response is required by this Information

Notice. If you have any questions about this matter, please direct them to

the technical contact listed below, or to the Regional Administrator of the

appropriate NRC Regional Office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety, NMSS

Douglas M. Collins, Region II

(404) 242-5586 Attachments:

1. List of recently issued NMSS Information Notices

2. List of all recently issued NRC Information Notices

Editor ,EjIK INNS

EKraus RECunningham

4/6 /89 4/ /89 OFC: IOA :MISBW J9 IM / i

0GC,4 :IMOB :MISB :IMNS

---

---- f/'---- g-

---

-----------------

NAME 1Ietzger/ll:GBidinger: gash :RFo9r :DCool :LRouse :GSjoblom

DATE:4/20 /89 :4/<P/89 :4/6&/89 :4/04 /89 :4/ /89 :4/ /89 :4/ /89 OFFICIAL RECORD COPY

IN 89- April , 1989 Page 2 of

7 Conduct of drills and exercises are to ensure that radiologi emergency

personnel are familiar with their duties. observerse of d us and exercises

cannot evaluate the effectiveness of personnel actions i the personnel have

been exposed to the scenarios during training.

The new final rule, effective April 7, 1990 (Feder Register Vol. 54, No. 66, published April 7, 1989) states, "Exercises imust se accident scenarios

postulated as uost probable for the specific si and the scenarios shall not

be known to most exercise participants. The censee shall critique each

exercise using individuals not having direct mplementation responsibility for

the plan. Critiques of exercises must eva ate the appropriateness of the

plan, emergency procedures, facilities, uipment, training of personnel, and

overall effectiveness of the response. eficiencies found by the critiques

must be corrected."

No specific action or written resp se is required by this Information

Notice. If you have any question about this matter, please direct them to

the technical contact listed be w, or to the Regional Administrator of the

appropriate NRC Regional Offic

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety, NMSS

Technical Cont t: Douglas M. Collins, Region II

(404) 242-5586 Attachment:

1. List f recently issued NMSS Information Notices

2. List of all recently issued NRC Information Notices

Editor IMNS

EKraus RECunningham

4/G /89 4/ /89 UF1: :MISB :IMOB :OG W :IMOB :MISB :IMNS

____.Ac ----------------------------- --------------------------------____

NAME Jtzger/ll:GBidinger:JLyash :RFd'niIr :DCool :LRouse :GSjoblom

__ _ ----------------------------------

_

DATE:4/QP/89 :4/ /89 :4/ /89 :4/'//89 :4/ /89 :4/ /89 :4/ /89 OFFICIAL RECORD CUPY