ML080110116
| ML080110116 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/2008 |
| From: | Michael Case NRC/NRR/ADRA/DPR |
| To: | |
| References | |
| NEI 06-04, Rev 1 RIS-08-008 | |
| Download: ML080110116 (6) | |
See also: RIS 2008-08
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
March 19, 2008
NRC REGULATORY ISSUE SUMMARY 2008-08
ENDORSEMENT OF REVISION 1 TO NUCLEAR ENERGY
INSTITUTE GUIDANCE DOCUMENT NEI 06-04, CONDUCTING A
HOSTILE ACTION-BASED EMERGENCY RESPONSE DRILL
ADDRESSEES
All holders of operating licenses for nuclear power reactors, except those who have
permanently ceased operations and have certified that fuel has been permanently removed
from the reactor vessel.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
to endorse Revision 1 to Nuclear Energy Institute (NEI) guidance document NEI 06-04,
Conducting a Hostile Action-Based Emergency Response Drill, dated October 30, 2007. The
NRC finds this document, with the staff clarifications noted, presents an acceptable
methodology for licensees to conduct industry-wide, baseline, hostile action-based emergency
preparedness (EP) drills. Specifically, drills that fall under Phase 3 of the industry initiative
described in Attachment 5 to NEI guidance document, Enhancements to Emergency
Preparedness Programs for Hostile Action, May 2005 (revised November 18, 2005)
(Agencywide Document Access and Management System (ADAMS) Accession No.
ML053290326); hereafter, referred to as 2005 NEI guidance. This RIS requires no action or
written response by addressees.
BACKGROUND INFORMATION
Current regulations in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.47(b)
and 10 CFR Part 50, Appendix E,Section IV.F.2 do not explicitly require licensees to conduct a
hostile action-based scenario as part of periodic EP drills and exercises. However, following the
events of September 11, 2001, the NRC issued Bulletin 2005-02, Emergency Preparedness
and Response Actions for Security-Based Events. The bulletin requested licensees to provide
information to the NRC regarding action taken or planned to be taken associated with
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security-based EP drills and exercises. Additionally, Attachment 6 of the Bulletin outlined an
acceptable methodology for use by each site to voluntarily conduct a hostile action-based
scenario as an "off-year" EP drill over a 3-year period. The industry responded to the bulletin
with the 2005 NEI guidance, which clarified proposed enhancements to emergency plans that
were provided in Bulletin 2005-02 and provided implementation guidance for those
enhancements. In addition, Attachment 5 of the 2005 NEI guidance provided a phased
approach to support the final implementation of conducting a hostile action-based scenario as
part of the existing biennial exercise cycle. Phase 3 specifically described an industry initiative;
whereby, each nuclear power plant site conducts a hostile action-based EP drill within a 3-year
period. The NRC subsequently endorsed this 2005 NEI guidance in RIS 2006-12,
Endorsement of Nuclear Energy Institute Guidance: Enhancement to Emergency
Preparedness Programs for Hostile Actions, dated July 19, 2006.
In a letter dated August 30, 2006, NEI requested NRC endorsement of Revision 0 to NEI 06-04,
Guideline for the Development of EP Drill and Exercise Threat-Based Scenarios, dated August
2006 (ADAMS Accession No. ML062490557). This document provided specific guidelines to
industry, State, and local response organizations on the conduct of hostile action-based EP
drills under phase 3 of the industry initiative. The NRC subsequently responded in a letter to
NEI dated October 23, 2006 (ADAMS Accession No. ML062480473), stating that:
NRC endorsement is not required for licensees to conduct a security event-based
scenario during an off-year exercise or drill. However, the NRC considers that the use of
Revision 0 to NEI 06-04 is appropriate for developing and conducting a security event-
based EP drill or exercise during this phase and encourages the industry to proceed with
efforts to schedule and conduct these drills and exercises.
As such, hostile action-based EP drills, also referred to as Phase 3 Drills, will not be evaluated
by either the NRC or the Federal Emergency Management Agency (FEMA). This provides a
no fault opportunity for licensees to demonstrate responses to the unique challenges security
events pose to existing EP programs. Lessons learned from these drills will support formal
implementation of hostile action-based event scenarios as part of biennial exercises.
During Calendar Year (CY) 2007, nine hostile action-based EP drills were conducted using the
proposed industry guidelines contained in Revision 0 to NEI 06-04. These drills identified
valuable lessons learned and aided in clarifying the unique challenges a hostile action-based
event poses to existing EP programs. Based on these lessons learned, Revision 1 to NEI 0604,
Conducting a Hostile Action-Based Emergency Response Drill, dated October 30, 2007
(ADAMS Accession No. ML073100460), was developed by the industry to ensure consistency
in the conduct of remaining hostile action-based EP drills through CY2009.
SUMMARY OF ISSUE
Revision 1 to NEI 06-04 clarifies the intended scope and methods for demonstration of key
objectives of hostile action-based EP drills. This document is intended for use in conducting the
remaining hostile action-based EP drills under Phase 3 of the industry initiative as outlined in
the 2005 NEI guidance. The NRC staff finds that Revision 1 to NEI 06-04 is consistent with the
intent of Bulletin 2005-02. As such, the staff endorses Revision 1 to NEI 06-04 with the
following clarifications:
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a. Overview, Section 1, states, The periodic implementation of a hostile action-based
emergency response drill has replaced the practice of conducting a tabletop drill during
each force-on-force (FOF) exercise. Although hostile action-based drills encompass
many of the objectives demonstrated during previously conducted FOF tabletops, the
demonstration of key control room EP actions is still expected under IP 71114.07,
Emergency Preparedness Component of the Force-On-Force (FOF) Exercise
Evaluation and has not been superseded by the conduct of a hostile action-based drill.
b. Overview, Section 1, last paragraph, discusses licensees incorporating into their drill
program one hostile action-based scenario in a six-year cycle. The NRC is currently
working in concert with FEMA to address the use of hostile action-based scenarios
during biennial exercises under the rulemaking process; however, the frequency,
scenario objectives, and specific guidelines have not yet been determined for conducting
a hostile action-based scenario as part of a biennial exercise.
c. Objective Development, Section 2, states, Once the ERO is activated and integrated
into the stations response to the event, it is expected that the following key capabilities
will be demonstrated:. It should be noted that some hostile action-based scenarios
may be developed to demonstrate key capabilities prior to or in parallel with activating
the ERO.
d. Scenario Development, Section 4, implies that access restrictions may develop due to
the impact of an aircraft; however, it should be noted that access restrictions should not
be dictated only by possible aircraft damage. Access restrictions based on possible
damage from land- and water-based attacks should also be considered as part of these
scenarios. Any likely equipment and building damage for any scenario should be
included to provide realism, such that the response actions necessary to mitigate the
event are appropriate.
e. Scenario Development, Section 4, encourages that drills be conducted in real time, or
as near real time as possible. NRC encourages that the use of a time jump or time
compression be minimized or eliminated when possible. Applicable State and local
response organizations should be included in scenario development activities so that
demonstration of significant off-site decisions and response actions are included and the
impact of any time jump or time compression is fully understood.
f. Appendix A, Functional Demonstration Criteria No. 3, explains that licensees should
demonstrate the ability to make accelerated NRC notifications. Additional opportunities
to practice other communications between the licensee and NRC may be possible by
coordinating aspects of participation with NRC staff. These activities could include the
use of authentication codes and communications with the NRC headquarters operations
officer (HOO) regarding a postulated ground-based, waterborne, or airborne threat.
g. Appendix A, Functional Demonstration Criteria No. 5, should address the coordination
of the control room staff and site security to perform initial accident assessment and
mitigation prior to the site being secured and ERO mobilization. Following a hostile
action, there may be delays in staffing emergency facilities and in securing the site.
Therefore, the scenario should include the demonstration of appropriate prompt actions
that can be taken by available on-shift staff prior to the site being secured, in
coordination with site security and initial offsite responders, to safely coordinate the
dispatching of damage control (repair) personnel to implement applicable coping
Page 4 of 5
strategies. This may require the prioritization of site security and initial law enforcement
resources to perform sweeps of designated plant areas to allow prompt access by
damage control (repair) personnel in the period after known adversaries have been
neutralized.
h. Appendix A, Functional Demonstration Criteria No. 9, discusses the ability of the ERO
to activate alternate facilities. Licensees are encouraged to use this drill as an
opportunity to test continuity of operations capabilities and challenge processes and
procedures associated with these alternate facilities.
i.
Additional Clarifications: Use of the National Incident Management System (NIMS)
and definitions from the National Response Plan (NRP) are referenced throughout
Revision 1 to NEI 06-04. However, the NRP was superseded by the National Response
Framework, dated January 2008. Therefore, the latest revision of such referenced
documents should be used for conduct and development of drills and scenarios.
Additionally, the use of the Incident Command System (ICS) and Incident Command
Post (ICP), as described in NIMS, are also consistently referenced throughout Revision
1 to NEI 06-04; however, the use of a Unified Command (UC) or Unified Area Command
(UAC) is not. In keeping with the NIMS structure, licensees are encouraged to
demonstrate key decision-making and communication interface activities with the
UC/UAC, as applicable, to adequately demonstrate the effective prioritization of activities
and coordination of resources with the licensee and State/local emergency operations
facilities.
BACKFIT DISCUSSION
Bulletin 2005-02 identifies the staff position regarding conduct of a hostile action-based EP drill.
This RIS endorses Revision 1 to NEI 06-04 as an adequate methodology for the development
and conduct of a hostile action-based EP drill as part of the industry initiative in response to
potential program enhancements discussed in Bulletin 2005-02. This RIS neither imposes any
new or modified NRC staff requirements, nor prescribes a unique way to comply with the
regulations or requires any action or written response. Any action on the part of the licensee to
use the guidance endorsed by this RIS is strictly voluntary. Therefore, this RIS is not a backfit
under 10 CFR 50.109 and the NRC staff did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS was not published in the Federal Register
because it is informational and pertains to a staff position that does not represent a departure
from current regulatory requirements and practice. NRC intends to work with NEI, industry
representatives, FEMA, State and local response organizations, members of the public, and
other stakeholders in developing both final guidance and modifying related guidance
documents. This action will be done in support of the rulemaking to update emergency
preparedness regulations.
CONGRESSIONAL REVIEW ACT
The NRC has determined that this RIS is not a rule as designated by the Congressional Review
Act (5 U.S.C. §§801-808) and, therefore, is not subject to the Act.
Page 5 of 5
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not contain any information collections and, therefore, is not subject to the
requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
Public Protection Notification
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for
information or an information collection requirement unless the requesting document displays a
currently valid OMB control number.
CONTACT
Please direct any questions about this matter to one of the technical contacts listed below.
/RA/
Michael J. Case, Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Technical Contacts: Michael D. McCoppin,
Joseph D. Anderson,
NSIR/DPR NSIR/DPR
(301) 415-2737
(301) 415-4114
E-mail: mdm2@nrc.gov
E-mail: jda1@nrc.gov
Enclosure: Revision 1 to NEI 06-04, Conducting a Hostile Action-Based Emergency Response
Dril, October 30, 2007 (ADAMS Accession No. ML073100460)
Note: NRC generic communications may be found on the NRC public Web site,
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
Note: NRC generic communications may be found on the NRC public Web site,
http://www.nrc.gov, under Electronic Reading Room/Document Collections.
DISTRIBUTION:
RIS File
ADAMS ACCESSION NUMBERS:
PACKAGE: ML080110111, RIS: ML080110116, ENCLOSURE: ML073100460 (TAC MC7511)
OFFICE
DPR:NSIR
Tech Editor
TL:DPR:NSIR
BC:DPR:NSIR
DD:DPR:NSIR
D:DPR:NSIR
NAME
MMcCoppin
HChang
JAnderson
AMcMurtray
CMiller
MLeach
DATE
1/14/2008
1/23/2008
1/14/2008
1/31/2008
1/31/2008
2/4/2008
OFFICE
BC:ITSB:DIRS
D:DORL
D:DSP:NSIR
OGC (CRA)
NAME
GWaig
CHaney
PHolahan
NHilton
CLazar
BJones
DATE
2/7/2008
2/15/2008
2/7/2008
2/7/2008
3/3/2008
3/1/2008
OFFICE
PMDA
OIS
LA:PGCB:DPR:NRR
PGCB:DPR:NRR
BC:PGCB:DPR:NRR
D:DPR:NRR
NAME
VHuth
G Trussell
CHawes
AWMarkley
MMurphy
MCase
DATE
3/11/2008
3/10/2008
3/12/2008
03/12/2008
03/19/2008
03/19/2008