ML111920188
| ML111920188 | |
| Person / Time | |
|---|---|
| Issue date: | 07/11/2011 |
| From: | Office of Nuclear Security and Incident Response |
| To: | Nuclear Energy Institute |
| Murray, Charles, NSIR/DPR (301) 415-8007 | |
| References | |
| NEI 06-04, Rev 2 | |
| Download: ML111920188 (8) | |
Text
NEI 06-04, Revision 2, Conducting a Hostile Action Based Emergency Response Drill NRC Review Comments 1
Section Comment General Comment The document as written encompasses activities that are outside the scope of exercise evaluations performed by the NRC. For the document to receive NRC consideration the document should be revised to include only those items pertaining to an NRC Evaluated HAB Exercise. (Incident Command Post, pre-drill tabletop, pre-drill briefings, offsite activities evaluated by other government agencies, and lessons learned are some examples of items to consider for revision removal). The following comments are included for discussion.
General Comment The document should clearly state applicability to NPP licensees and OROs: The NEI Hostile Action-Based (HAB)
Drill Task Group has developed this document to establish guidance for nuclear power plant (NPP) licensees, to be used in coordination with offsite response organizations (OROs), for the development, conduct, and evaluation of HAB emergency response drills and exercises.
General Comment Define Emergency Response Organization (ERO) vs. Offsite Response Organization (ORO) to clearly distinguish between organizations.
1.0 Revise 5th bullet to address ISG: in a post-attack environment. Mitigative measures in hostile action scenarios should commence after the simulated active attack has ceased, but before LLEA have swept the site for safe entry or declared the site secure.
1.0 Add bullet to address Interim Staff Guidance (ISG): Use of alternate facilities to stage the ERO for rapid activation during hostile action 1.0
[2nd paragraph, 2nd sentence] Revise sentence to clearly identify where key attributes where developed from (i.e.,
1.0 Third bullet; Additional participation by Security personnel will be necessary to simulate security facilities and functions(e.g., the Central Alarm Station) and on-shift security supervision, including simulating communications with on-shift security positions (e.g., BREs, guard posts) required to demonstrate a realistic response.
1.0
[4th paragraph] Statement HAB drill scenarios do not reflect on the content of site physical security plans implies that scenario is not an accurate demonstration of EP-Security interfaces. Rather guidance should state, HAB scenarios shall provide for the adequate demonstration of EP-Security interface. However, scenarios should not and need not contain safeguards information that would unintentionally compromise site security plan.
1.0
[Last paragraph] Include reference to NRC information Notice 2009-19, Hostile Action-Based Emergency Preparedness Drills, as a source of lessons-learned leading to the development of this document.
NEI 06-04, Revision 2, Conducting a Hostile Action Based Emergency Response Drill NRC Review Comments 2
2.0 HAB Objectives, revise first paragraph as follows; Expectations concerning demonstration of these objectives are contained in guidance documents and inspection procedures issued by the US Nuclear Regulatory Commission (NRC). The reason being that expectations are not communicated through inspection procedures.
2.0 HAB Objectives, first paragraph; Since an exercise utilizing a Hostile Action-Based (HAB) scenario must be conducted at the periodicity required by Federal regulations, this set of objectives should shall include a subset focused on demonstrating those functions uniquely performed in response to a Hostile Action.
Revise this paragraph to include: Specific objectives for exercise demonstration need to be clearly outlined in accordance with ISG.
3.2 Drill Support from Security, third bullet: Devising methods to simulate response actions by, and communications with, security facilities, officers and supervision, should be revised as follows, Devising methods for security facilities, officers, and supervision, to demonstrate appropriate response actions and communications. Where possible, communications from the CAS and Security Shift Supervisor should be in real time and not be simulated via control cell, as suggested in Sections 3.5 and 5.1.
3.3 Incident Command Post: Section is confusing since it infers that no prior pre-planning has taken place. As written, section provides guidance on what constitutes an adequate ICP, rather than aspects associated with the development and conduct of an HAB scenario. NRC-endorsement is not intended to define what constitutes an acceptable ICP facility.
NRC staff would assume that licensee would have coordinated with OROs in pre-designating various locations for ICP based on range of events, using the criteria identified. As such, location used for drill/exercise would be one of the pre-designated ICP locations. In addition, NRC staff would assume that licensees would already have a response procedure developed identifying licensee liaisons, including their responsibilities, procedures for contacting and dispatching, respective interfaces (with ICP and site), and communications methods. As such, guidance should merely recommend that scenario manual contain a description of ICP location, general layout figure, and discussion of expected licensee liaison response and ORO interfaces in relation to respective site procedure.
While guidance states, In order to avoid negative training, the ICP should be established in a location that would be actually used during a real HAB event, and not one selected primarily to facilitate drill performance. The NRCs expectation is that ICP location would be in a pre-designated location established in coordination with OROs, and that use of any other location would be discussed with OROs and FEMA and NRC staff prior to a biennial exercise as part of extent of play determination.
NEI 06-04, Revision 2, Conducting a Hostile Action Based Emergency Response Drill NRC Review Comments 3
3.4 Extent of play discussion under Firefighting and Medical Emergency Response are confusing and can appear to be contradictory. Guidance should simply state, The ability to effectively integrate offsite resources with onsite response is an essential factor in the prompt assessment and mitigation of the consequences of a hostile action directed at the plant site. To achieve this, demonstration of the ability to coordinate initial response actions among the on-shift ERO and Security, local law enforcement, emergency medical, and other first responder agencies is required. In order to avoid negative training, extent-of-play should specify one or more actual vehicle(s) and personnel that will be deployed to specified in-field/on-site scene locations to only the extent needed to sufficiently demonstrate site access, and communication and coordination activities. For firefighting and emergency medical services personnel not actually deployed, communications must be made to and from a control cell. The practice of using a controller to pass messages simulating these communications shall be avoided.
3.4 2nd paragraph reads; The drill extent-of-play must clearly describe the expected simulated and/or actual resources and response actions. If practical, controllers assigned to simulate firefighting and/or emergency medical services personnel should use the same communications equipment employed by actual response personnel. This should be revised to require that the same equipment OROs use is used in drills and exercises to test inter agency communication capabilities.
3.5 First bullet, revise to read as follows; If a communications capability is dependent upon site personnel and offsite responders trading radios with one another, ensure that this action can be performed given the security situation created by the scenario. Scenarios should not be written to allow actions to succeed (e.g. compensating for inadequate procedures), the procedure(s) should be robust enough to cover a variety of situations.
3.5 Additional considerations regarding communications are written as such to infer that the testing and placement/staging of communications equipment is merely a pre-exercise preparation activity rather that integrated into Emergency Plan and/or appropriate response procedure. Specifically, text should be reworded to address:
(1) [1st bullet] If communications capability is dependent upon site personnel and offsite responders trading radios with one another, then this should be a Performance Attribute under the appropriate Objective in Appendix A, rather than as written to ensure scenario will allow action to be performed; (2) [2nd bullet] Placement of replacement batteries and/or chargers to support use of cellular telephones or radios should not be a pre-drill/exercise preparation, but rather identified as a Performance Attribute under appropriate Objective in Appendix A that adequate batteries and/or chargers are in place at appropriate locations; (3) [3rd bullet] To ensure effective communications and interoperability, deployment and use of designated ORO
NEI 06-04, Revision 2, Conducting a Hostile Action Based Emergency Response Drill NRC Review Comments 4
communications vehicles should be considered and discussed as part of extent-of-play determination for a biennial exercise and identified as a Performance Attribute under appropriate Objective in Appendix A.
3.6 Discussion on EP Performance Indicators is generic in nature and has no specific applicability to HAB scenarios. As such, section should be deleted or revised to address HAB-specific EP PI issues.
3.7 Pre-Drill Briefing and Learning Opportunities should be deleted as it does not apply to NRC evaluated exercises.
[1st paragraph] As written, the document is more applicable to what HAB elements should be included in the sites ongoing (annual) training for OROs. Player (Participant) Briefing should be used to review expected extent-of-play and objectives, including performance attributes whose demonstration is driven by scenario.
A Performance Attribute under applicable Objective in Appendix A, applicable to ERO and ORO responders from Incident Command perspective, would be the Prompt initiation of mitigative measures after the simulated active attack has ceased, but before LLEAs have swept the site for safe entry or declared the site secure. This would include the prioritization of repair team dispatch and protection in the aftermath of hostile action through coordination with site security and LLEAs to determine when the site is secure enough to allow limited movement of personnel.
Focus for initial response needs to be on gaining access to areas to critical equipment damaged by hostile access or to establish limited access (pathways) to support the movement of essential personnel.
3.8 Pre-Drill Tabletop, should be deleted as it does not apply to NRC evaluated exercises.
4.1 Scenario Team: Should include statement similar to: Scenario Team may also include regional FBI, U.S. Coast Guard, or other Federal agency involvement based on determined extent-of-play and emergency plan aspects for a particular site.
4.2 Scenario Development and Key Attributes: [3rd paragraph, above bullets] Under An HAB drill scenario must address the following elements, specifically review bulleted items against the guidance in the ISG (Section IV.G) to ensure that all required HAB elements are considered as based on Rule/ISG wording. NEI/industry should consider developing a cross-reference as to where HAB elements of the new Rule/ISG are covered under proposed Revision 2 to NEI 06-04.
Also, Bullets 3 and 4 should be revised to be consistent with wording reflected in ISG (Section IV.G) in regards to immediate actions to be taken to mitigate damage.
4.2
[2nd bullet] The scenario package should contain ancillary attack-related information necessary to support more
NEI 06-04, Revision 2, Conducting a Hostile Action Based Emergency Response Drill NRC Review Comments 5
realistic play. A control cell should be used to realistically simulate communications with the NRC Operations Center and representative of information that would actually be available and in an accurate time frame. The practice of using a controller to pass messages simulating these communications shall be avoided.
In addition, bullet should be expanded to cover ISG wording similar to: scenarios should realistically include collateral damage that may occur (e.g., loss of offsite power and loss of use of certain onsite facilities and areas).
4.2 Under Options for scenario developers may include the following:
[2nd bullet] Delete last sentence: The selected insider should not be from the site Security organization.
Selection of insider organization is a licensee decision; however, NRC will not endorse the exclusion of Security or any other site organization.
Add (to reflect demonstration once over exercise cycle per ISG): Ability to mitigate an accident caused by hostile action may be demonstrated through the simulated use of equipment, procedures, and strategies developed in compliance with 10 CFR 50.54(hh)(2).
4.2 Scenario Development: The HAB scenario should be developed to test the integrated capability and a major portion of the basic elements existing within the emergency preparedness plans and organizations. This should include actual participation (versus simulation) from all OROs which are outlined in the sites Emergency Plan to include real time response and performance of all expected actions. These exercises need to be challenging to reduce anticipatory scenarios which do not fully challenge the participants.
4.3 Scenario Progress: The scenario frameworks illustrated in Figures 4-1 and 4-2 accelerate through the immediate post-attack period to a point where deployment of offsite response assets and mobilization the ERO may be considered. Drill messages, or instructions from a controller, should be used to inform participants of the actions which were completed during this time compressed period (e.g., description of post-attack conditions, establishment of perimeter control and initial sweep of the site, etc.). Any time acceleration during an evaluated exercise should not take away participant opportunities to make EP-related decisions and demonstrate EP capabilities, including the following aspects contained in ISG:
Engineering assessment, repair plan development, and simulated repair of critical equipment damaged by hostile action after the active attack, but before the site is fully secured by LLEAs; and Prioritization of repair team dispatch and protection in the aftermath of hostile action through coordination with site security and LLEAs to determine when the site is secure enough to allow limited movement of personnel.
NEI 06-04, Revision 2, Conducting a Hostile Action Based Emergency Response Drill NRC Review Comments 6
In addition, this section should emphasize that players, specifically through the Incident Command Post, must demonstrate the decision-making that will get the scenario from basically an unsecured site (exact status of adversaries, hazards, etc. unconfirmed) to the point of acceleration - not just through controller injects - and clearly reflect criteria to be meet before acceleration.
4.4 Per ISG, hostile action scenarios should not and need not contain safeguards information, but do not preclude inclusion by licensee if handled in accordance with site procedures and NRC regulations. 1st paragraph should be reworded consistent with ISG to support endorsement, and contain statement (similar to ISG wording) indicating, Nothing in NRC guidance or this document should be construed as allowing the release of safeguards information to unauthorized personnel.
4.5 Mini Scenarios / MSEL Detail
Description:
First paragraph states:
The selected event sequence and times should be credible. This timeline should be treated as 10 CFR 2.390 material and made available only to those controllers needing it to implement the drill.
(Why is this 10 CFR 2.390 material and once the scenario is run how is it controlled?)
5.2 Statement, The licensee should be dispatch liaisons to the ICP, should be expanded upon to ensure deployment ensures that adequate communications methods are provided or staged at ICP to ensure effective and timely communications with Control Room, Security and applicable OROs.
5.2 Incident Command Post Response:
[Last paragraph] Need to clarify whether ORO liaison(s) identified is a licensee representative or a member of an ORO. If licensee liaison, why is it not contained as bullet under paragraph above?
6.2 Operating Experience and Good Practices, section needs to be removed and placed into guidance document.
Rather than inserting lessons-learned in actual document, NEI may consider maintaining lessons-learned on NEI members website as a working document or provide to licensees in a guidance document. This would allow a more effective and timely means to capture and share lessons-learned and to more readily allow for revision and modification of these lessons-learned (based on continued learning through future drills/exercises).
7.1 Operating Experience and Good Practices section needs to be removed and placed into guidance document.
Rather than inserting lessons-learned in actual document, NEI may consider maintaining lessons-learned on NEI
NEI 06-04, Revision 2, Conducting a Hostile Action Based Emergency Response Drill NRC Review Comments 7
members website as a working document or provide to licensees in a guidance document. This would allow a more effective and timely means to capture and share lessons-learned and to more readily allow for revision and modification of these lessons-learned (based on continued learning through future drills/exercises).
Figure 4-1 Framework for a Land-Based or Waterborne Hostile Action-Based (HAB) Drill Under Event Mitigation Phase column, 4th bullet should be revised to indicate, Licensee issues a Protective Action recommendation (PAR) if required based on event classification or site-specific procedures.
Figure 4-1 Framework for a Land-Based or Waterborne Hostile Action-Based (HAB) Drill Need to clarify difference between, and apparent overlap, between Initial Sweep Phase and ERO Mobilization Phase, whose actions are listed in separate columns but appear to be implemented simultaneously based on same 30 to 60 minutes timeframe identified for both. This table is confusing as written.
Figure 4-1 Framework for a Land-Based or Waterborne Hostile Action-Based (HAB) Drill (Event mitigation phase) Offsite authorities develop an appropriate protective action decision in consultation with the ICP. - What if there is no PAR?)
Figure 4-2 Framework for an Airborne Hostile Action-Based (HAB) Drill Under Event Mitigation Phase column, 4th bullet should be revised to indicate, Licensee issues a Protective Action recommendation (PAR) if required based on event classification or site-specific procedures.
Figure 4-2 Framework for an Airborne Hostile Action-Based (HAB) Drill (Threat to impact phase) Emergency classification and implementation of emergency plan; a Protective Action Recommendation (PAR) may be issued.
Statement regarding issuance of a PAR (from an offsite perspective) is confusing and inaccurate, since General Emergency EAL thresholds for classification would not have been met in this phase.
Figure 4-2 Framework for an Airborne Hostile Action-Based (HAB) Drill (Event mitigation phase) Events must drive simulated implementation of strategies to respond to a loss of large areas of the plant due to explosions or fire [per 50.54(hh)(2)].
NEI 06-04, Revision 2, Conducting a Hostile Action Based Emergency Response Drill NRC Review Comments 8
Why is this limited to only an airborne attack, since strategies might be used to mitigate consequences of land-based or waterborne assault based on extent of damage inflicted? ISG does not limit to airborne attack for demonstration over exercise cycle.
Appendix A The recommended objectives should be revised to include at a minimum those listed in NSIR/DPR-ISG-01, examples include;
- The successful simulated repair of simulated damaged equipment to prevent or mitigate core damage, reactor pressure boundary loss, and/or containment loss.
- Demonstration of the ability to mitigate an accident caused by hostile action or other initiators, through the simulated use of equipment, procedures, and strategies developed in compliance with 10 CFR 50.54(hh)(2).
Appendix B Pre-Drill Tabletop Guidelines, this section should be removed from this document and placed into an NEI guidance document or database as it does not apply to NRC Evaluated Exercises.
Figure B-1 Figure is untitled (no header) and is not referenced in Appendix B text regarding use or applicability; and Figure does not illustrate connection between the Control Room and the ICP, which is the most likely scenario during initial response due to the inaccessibility or delay in staffing of other ERFs.