Information Notice 2009-19, Hostile Action-Based Emergency Preparedness Drills
| ML092250360 | |
| Person / Time | |
|---|---|
| Issue date: | 11/24/2009 |
| From: | Dan Dorman, Mcginty T, Tracy G NRC/NMSS/FCSS, Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking |
| To: | |
| David Beaulieu | |
| References | |
| IN-09-019 | |
| Download: ML092250360 (5) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
OFFICE OF NEW REACTORS
WASHINGTON, DC 20555-0001 November 24, 2009 NRC INFORMATION NOTICE 2009-19: HOSTILE ACTION-BASED EMERGENCY
PREPAREDNESS DRILLS
ADDRESSEES
All holders of operating licenses or construction permits for nuclear power reactors, except
those who have permanently ceased operations and have certified that fuel has been
permanently removed from the reactor vessel. All licensees and potential applicants for new
fuel cycle facilities under Title 10 of the Code of Federal Regulations (10 CFR) Part 70,
Domestic Licensing of Special Nuclear Material. All current and potential applicants for an
early site permit, combined license, or standard design certification for a nuclear power plant
under the provisions of 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear
Power Plants.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to
provide a summary of the NRC staffs observations of hostile action-based emergency
preparedness (EP) drills at power reactor licensees over the previous 3 years. The NRC
expects recipients to review the information for applicability to their facilities and to consider
actions, as appropriate, to incorporate lessons learned from these unique drills. Suggestions
contained in this IN are not NRC requirements; therefore, no specific action or written response
is required.
DESCRIPTION OF CIRCUMSTANCES
This IN provides summary information related to hostile action drills that licensees conducted
using the guidelines in Nuclear Energy Institute (NEI) 06-04, Conducting a Hostile Action- Based Emergency Response Drill, Revision 1, dated October 30, 2007 (Agencywide
Documents Access and Management System (ADAMS) Accession No. ML073100460). Hostile
action scenarios are initiated by hostile or terrorist actions that lead to simulated plant damage, which is a primary difference from traditional scenarios These scenarios require a coordinated
Federal, State, and local response to mitigate the event while simultaneously addressing the
security situation. NRC observations were generally made in coordination with NEI and the
Federal Emergency Management Agency but were not part of any formal evaluation or
inspection process. The following summary of NRC staff observations of hostile action drills
provides generic information on key challenges, lessons learned, and good practices.
Scenario Development
(1) Licensees engagement of offsite response organizations (OROs) early in the scenario
development process provided the opportunity to define and discuss the unique
challenges posed by a hostile action event. Specifically, early engagement facilitated
discussion of ORO response onsite and licensee coordination with the OROs incident
command structure. Licensees that had an understanding of how OROs would respond
to their site under the National Incident Management System/Incident Command System
and that clearly worked with their OROs to identify extent of play and scenario elements
had greater success in effectively demonstrating the required functional demonstrations
outlined in NEI 06-04 during the conduct of their hostile action drills. Incorporation of
offsite responder capabilities into the scenario development led to fewer discrepancies
between the sites (and drill controllers) expectations and the reality of players actions.
(2) Use of lessons learned from previous hostile action drills was an effective tool in
planning, scenario development, and outreach to OROs. This helped to address the
unique challenges associated with these scenarios and resulted in scenarios that more
effectively demonstrate the capabilities and response to such an event. A current listing
of hostile action drill lessons learned, identified by licensees in coordination with OROs, is available on the NEI members Web site (http://www.nei.org/members) and the U.S.
Department of Homeland Security Lessons Learned Information Sharing Web site
(3) For aircraft threat scenarios, licensees should ensure that the scenario reflects realistic
timelines and notification procedures. This should preclude negative training and should
convey more realistic implementation of response actions. Licensees should continue
consulting Regulatory Guide 1.214, Response Strategies for Potential Aircraft Threats, dated July 2009 (ADAMS Accession No. ML091740646). The staff also noted that it
was advantageous for licensees to engage the NRC staff during scenario development
and when possible have staff support initial communications between the licensee
control room and the NRC Headquarters Operations Officer.
(4) While NEI 06-04 scenarios must present conditions leading to core damage with a
potential radiological release, the guidance does allow for a success path to prevent a
radiological release if drill players take appropriate and timely mitigative actions. A good
practice was scenarios that clearly reflect and communicate the potential for a
radiological release, regardless of ultimate scenario outcomes. These types of
scenarios necessitate decisions about the possible relocation of the Incident Command
Post and the need for additional protective measures or equipment for ORO resources
onsite.
(5) NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security- Based Events, dated July 18, 2005 (ADAMS Accession No. ML051740058) addressed
the establishment of an alternate facility for the assembly of licensee emergency
response organization (ERO) personnel. NEI 06-04 identifies activation of this alternate
facility as dependent on the scenario. The initial conditions of some licensee scenarios
identify that the drill commences during nonworking hours or weekends to allow for the
staffing of the alternate facility. The NRC staff has identified this as a good practice for evaluating the effectiveness of facility utilization as outlined in NRC Bulletin 2005-02.
While this is a good practice for demonstrating the ability to staff alternate facilities, it
does preclude demonstration of the coordination that would be required if ERO
personnel were onsite at the initiation of the event. Scenario developers should consider
which demonstration best fits the needs of their drill when determining initial conditions.
Predrill Tabletop
(1) NEI 06-04 provides guidance on conducting a predrill tabletop. Conducting tabletops is
a good practice for providing key licensee ERO personnel and OROs with opportunities
to review and discuss their respective roles, priorities, and response actions during a
hostile action event. In particular, the tabletops permitted diverse organizations to gain
an understanding of each others immediate priorities and concerns during a hostile
action event. The NRC staff identified the following specific good practices that led to a
successful tabletop:
- Tabletops were most effective when they were well planned, facilitated by
experienced personnel, included all key OROs, and exercised the interfaces
among facilities (e.g., Incident Command Post, Technical Support Center, Joint
Information Center, etc.) and their liaison personnel.
- Tabletops were most instructive when they highlighted how stresses on the
various players during a hostile action scenario were different from those of
traditional EP drills. Tabletops are most valuable when used in a constructive, continuous learning culture with a focus on scenario and drill improvement.
- Tabletops have the most positive impact when licensees allotted sufficient time
between the tabletop and the actual drill to allow incorporation of lessons learned
before conducting the drill.
(2) A good practice was licensees inviting offsite responders, specifically local law
enforcement agencies (LLEAs), to observe control room simulator activities in response
to a postulated hostile action scenario during licensed operator training and to walk
down plant areas to gain familiarity with the layout of the site and a better understanding
of the physical and industrial aspects of the facility. NRC staff discussions with offsite
responders revealed that these activities provided important insights to ORO personnel
and fostered good coordination between licensees and OROs.
Integrated Response
(1) Unlike a typical radiological EP exercise, a key objective of NEI 06-04 hostile action
scenarios is to require offsite support and licensee coordination with offsite responders
to mitigate the events onsite. This coordination should occur via the Incident
Commander. The following good practices involving this coordination were identified:
- The identification and designation of capable and experienced liaisons from the
licensee to the Incident Commander for key plant disciplines (i.e., security, operations, health physics) and early discussions with OROs on how licensee
liaisons would be integrated into Incident Command operations;
- The training of licensee liaisons and other appropriate ERO personnel by their
cognizant OROs on basic National Incident Management System/Incident
Command System (NIMS/ICS) concepts and terminology to facilitate better
liaison integration into Incident Command Post operations;
- The identification and availability (staging) of appropriate communications
equipment to support liaison functions; and
- The prestaging of user aids (e.g., site maps) to support the liaison briefing of
Incident Command personnel and to display significant plant information.
(2) Although the prestaging of ORO personnel and equipment may be necessary to ensure
their availability because of the short duration of the drill, good practices identified to
minimize the impact of prestaging were:
- The use of actual communication methods, rather than inject messages, to notify
and communicate with OROs;
- The timed integration of responders to simulate delays in response (i.e., 10-
15 minutes equals 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of actual response) to allow for the effective use of a
time compression while ensuring a realistic demonstration of response
capabilities;
- Strict segregation of prestaged elements from active drill players and
communications until their introduction into the scenario at the appropriate time;
and
- The transition of the responsibilities of the Incident Commander based on the
scenario and the arrival of various response organizations.
(3) Negative training may occur by locating the Incident Command Post to support drill
accessibility vice realistically reflecting the expected location based on an actual hostile
action event. This may have masked challenges to logistics, communications, and
security or by precluding the need for important discussions (e.g., how to respond when
an Incident Command Post is located within an area that must be evacuated). The use
of real-world staging areas and Incident Command Post locations was a good practice
that helped to effectively train response personnel and verify the adequacy of locations
to support these functions.
(4) A good practice was the staffing of key interface positions at the Incident Command Post
and emergency operations center to facilitate communication between the two types of
facilities and to ensure that each was informed of the others actions and decisions in a
timely fashion. NEI 06-04 guidance does not require the staffing of State and local
emergency operations centers. However, actions directed by the Incident Commander, such as road closures, evacuation of the public located near the site, and augmentation
of resources, could have a significant impact on decisionmaking at the respective
emergency operations centers.
Coordination with Security and Law Enforcement
(1) NEI 06-04 provides guidance to facilitate a functional demonstration of the ability of the
ERO to coordinate in-plant and onsite response actions with security and the offsite
Incident Command. Hostile Action drills are not intended to require the use of an actual
adversary force or demonstrate the tactical ability of site security and LLEA responders
to neutralize a postulated adversary or regain control of occupied areas. Hostile actions
drills are intended to create a scenario in which the site is simulated to be in an
unsecured status following an initial attack. The following were identified with this aspect
of hostile action drills:
- A good practice was the use of scenarios that provided for discussion among
control room staff, site security, and the Incident Commander to address
appropriate strategies for securing or allowing access to plant areas in support of
initial mitigative actions (e.g., fire suppression, assessment and repair activities, the staffing of onsite emergency facilities, and the relocation of personnel to
offsite locations) while the site remained unsecured and in a threat environment.
- Negative training could occur from use of a scenario time jump or declaration of
the site as being all clear of adversaries, which preempts the demonstration of
this criterion. Scenarios that provide for an all clear message also do not
consider that threats to site personnel and responders may still exist (e.g.,
unidentified adversaries, unexploded ordnance, etc.) or that all or parts of the site
would be controlled as a crime scene by the Federal Bureau of Investigation or
LLEAs. Some drills, while their scenarios did not provide an explicit all clear, were allowed to deteriorate into effective all clear situations due to lack of
controller sensitivity and timely injects to reinforce that the possibility of physical
threats still existed.
- A good practice was the actual staffing of an exercise security supervisor and
security lieutenant position at the central alarm station and secondary alarm
station to realistically demonstrate the timing and content of communications and
the use of applicable site procedures. The staffing of these positions, rather than
their simulation by a control cell, improved coordination with the control room, Incident Command, and responding law enforcement.
- A good practice included the use of control cells to mimic the actions and
communications of security officers in the field with the central alarm station and
secondary alarm station and the use of photographs and other reference
materials to more accurately reflect indications available to security officers in the
central alarm station or secondary alarm station. Coordination of Public Information
The coordination of public information during a hostile action event provides challenges
because of the potential sensitivity and availability of information.
- A good practice identified as addressing these challenges was licensee
engagement of LLEA and the Federal Bureau of Investigation before the hostile
action drill to clarify the intended roles and responsibilities in presenting
information to the public. Specifically, this dealt with the sensitivities that LLEA
and the Federal Bureau of Investigation would most likely concern themselves
with, and how these additional entities would integrate into current processes for
public information dissemination.
- A good practice was also the use of separate tabletop between the licensee and
respective agency public information officers to define specific communication
protocols.
Communications
Communications were routinely a challenge to the conduct of hostile action drills. For most
licensees, the need for the plant to communicate with the Incident Command, whether through
its own liaisons or otherwise, was a new concept. The hostile action drill scenarios were some
licensees first introduction to response using principles of NIMS/ICS. The task of conveying
threat information rapidly to plant employees and doing so continually over the course of several
hours using plant page announcements was also relatively new. Some sites made protective
action announcements to plant personnel very rapidly, while some delayed more than fifteen
minutes. The most successful hostile action drills addressed these communication obstacles
early, either in the scenario development or at the tabletop, by answering the questions: (1)
Who do I need to communicate with? and (2) How am I going to do it in this situation? The
NRC staff observed the following common challenges:
- Lack of compatible communications equipment between site personnel and
offsite responders required them to trade radios with one another at the scene in
order to communicate directly. The security situations created by the scenarios
may have precluded these trades.
- Radios did not work because of the lack of sufficient repeaters, terrain between
the site property and Incident Command Post location, or weather conditions.
- Cellular phones did not receive a signal because of signal dead areas around the
remote location of the Incident Command Post or site property.
- Cellular phone batteries did not have sufficient duration, and replacement
batteries were not readily available.
- There were not enough telephone land lines available at the Incident Command
Post location to accommodate all parties. Some licensees addressed many of these challenges during their planning and scenario
development, but nearly all hostile action drills encountered some form of unanticipated
communication challenge.
A good practice was the deployment and use of designated ORO communications vehicles
during drills to provide and validate communications interoperability and to provide training to
responders. Further information on how some licensees have improved their communications is
located in IN 2007-12, Tactical Communications Interoperability between Nuclear Power
Reactor Licensees and First Responders, dated March 15, 2007 (ADAMS Accession
No. ML070710233).
A good practice was that some licensees tested their alternate means of communication (e.g.,
simulating a loss of cellular phone service) at some point well into the drill. Whether the
licensee simulated the loss of service as being the result of hostile action or the result of
overwhelming traffic in response to the event, it prompted players to think about how they would
continue with their response to an actual hostile action.
BACKGROUND
The following documents are related NRC generic communications:
- NRC Bulletin 2005-02 requests licensees to provide information to the NRC on
actions that they have taken or plan to take to address how current EP drill and
exercise programs prepare or evaluate responders for security-based events
commensurate with established EP standards.
- Regulatory Issue Summary (RIS) 2006-12, Endorsement of Nuclear Energy
Institute Guidance, Enhancement to Emergency Preparedness Programs for
Hostile Actions, dated July 19, 2006 (ADAMS Accession No. ML061530290),
endorses an NEI white paper issued on May 2005 and revised on November 18,
2005 (ADAMS Accession No. ML053290326), that proposes a phased approach
to incorporating a hostile action scenario as part of the existing biennial exercise
cycle in which each licensee would conduct a hostile action drill within a 3-year
period as a voluntary, unevaluated initiative.
- RIS 2008-08, Endorsement of Revision 1 to Nuclear Energy Institute Guidance
Document NEI 06-04, Conducting a Hostile Action-Based Emergency Response
Drill, dated March 19, 2008 (ADAMS Accession No. ML080110116), endorses, with noted clarifications, NEI 06-04, Revision 1, for use during the voluntary
industry initiative.
DISCUSSION
The current regulations at 10 CFR 50.47(b) and Appendix E, Emergency Planning and
Preparedness for Production and Utilization Facilities, to 10 CFR Part 50, Domestic Licensing
of Production and Utilization Facilities, do not explicitly require licensees to incorporate a
hostile action scenario as part of periodic EP drills and exercises. Bulletin 2005-02 describes the NRC staff position on conducting a hostile action drill. RIS 2008-08 endorses NEI 06-04, Revision 1, as an acceptable methodology for use in developing and conducting a hostile action
drill as part of the industry initiative in response to the potential program enhancements
discussed in NRC Bulletin 2005-02. This IN does not contain specific solutions to the wide
range of current challenges that a hostile action scenario presents or to the coordination
challenges between licensees and Federal, State, and local first responders. This IN does not
endorse specific tools, scenarios, methods, or equipment that licensees may use to enhance
their response to a hostile action event.
CONTACT
This IN requires no specific action or written response. Please direct any questions about this
matter to the technical contacts listed below or to the appropriate Office of Nuclear Reactor
Regulation project manager.
/RA/ /RA/
Daniel H. Dorman, Director Timothy J. McGinty
Division of Fuel Cycle Safety Division of Policy and Rulemaking
and Safeguards Office of Nuclear Reactor Regulation
Office of Nuclear Material Safety
and Safeguards
/RA/
Glenn Tracy, Director
Division of Construction Inspection
and Operational Programs
Office of New Reactors
Technical Contacts: James R. Anderson, NSIR Rollie Berry, NSIR
301-415-6615 301-415-6119 E-mail: James.Anderson@nrc.gov E-mail: Rollie.Berry@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
CONTACT
This IN requires no specific action or written response. Please direct any questions about this
matter to the technical contacts listed below or to the appropriate Office of Nuclear Reactor
Regulation project manager.
/RA/ /RA/
Daniel H. Dorman, Director Timothy J. McGinty
Division of Fuel Cycle Safety Division of Policy and Rulemaking
and Safeguards Office of Nuclear Reactor Regulation
Office of Nuclear Material Safety
and Safeguards
/RA/
Glenn Tracy, Director
Division of Construction Inspection
and Operational Programs
Office of New Reactors
Technical Contacts: James R. Anderson, NSIR Rollie Berry, NSIR
301-415-6615 301-415-6119 E-mail: James.Anderson@nrc.gov E-mail: Rollie.Berry@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
ADAMS Accession Number: ML092250360 ME1692 OFFICE EP/DPR TECH EDITOR BC/DPR DD/EP/DPR D/DPR/NSIR
NAME James Anderson KAzariah-Kribbs Joseph Anderson CMiller MLeach
DATE 8/14/09 8/19/09 email 8/17/09 8/24/09 9/3/09 OFFICE D:DSO/NSIR D:DSP/NSIR PGCB:DPR PGCB:DPR BC:PGCB:DPR
NAME PHolahan CErlanger DBeaulieu CHawes MMurphy
DATE 9/14/09 9/16/09 9/17/09 9/22/09 11/03/09 OFFICE D:DCIP/NRO D:DFCSS/NMSS D:DPR/NRR
NAME GTracy DDorman TMcGinty
DATE 11/13/09 11/23/09 11/24/09 OFFICIAL RECORD COPY