ML20247G957
| ML20247G957 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/17/1989 |
| From: | Federal Emergency Management Agency |
| To: | |
| References | |
| OL-I-MAG-092, OL-I-MAG-92, NUDOCS 8905310119 | |
| Download: ML20247G957 (17) | |
Text
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'89 MY 23 P6 :14 FEB g 9Q J M E 8t ANCH Guidance Memorandum EX-3 li.W AING PRE-EXERCISE ACTIVITIES AND POST-EXERCISE MEETINGS P.M. MAR This-Guidance Memorandum (GM) provides guidelines for m e aging pre-exercise activities and post-exercise meetings in support of the Federal Emergency Management Agency's (FEMA) Radiological Emergency Preparedness (REP)
Program 3;:ckaround Under'44 CFR 350, it is_the responsibility of a State and its
.ir. cal governments to conduct joint exercises to test their REP plans as a condition of initial and continued FEMA approval of these plans.
The predecessor GM 17, dated January 8, 1981, provided procedural. guidance intended to improve the conduct of exercises and to establish greater uniformity.among the FEMA Regions in this activity.
While progress has been made, there is-still diversity among g
Regions.
This revision is a further effort at achieving uniformity in preparing for, conducting and assessing exercises.
It supers'edes the January 8,1981, GM 17 and the 35 exercise objectives contained in attachment 2 of the August 5, 1983, memorandum.
Guidelines I.
Pre-erarcise Activity t
Past experience has shown that joint exercises must be planned considerably in advance and each step scheduled.
In order to ensure optimum results, the following milestones should be met, at a minimum, These milestones are predicated on the biennial exercise frequency.
Sirce the milestone time frames have been changed, they shou ld be implemented beginning calendar year 1989.
Until then, the milestone dates in parentheses should be used.
Beginning in 1989, if exercises are conducted more frequently than biennially, the milestone time frames placed in parentheses should be used.
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' MILESTONES EQE EXERCISE-EVALUATION No Later Than Days Prior 12 Exercise Recuired Action 90 days State and licensee jointly develop (75) and submit exercise objectives to FEMA and Nuclear Regulatory Comniitsion- (NRC) Regional Offices.
75 days FEMA and NRC Regional Offices (60) complets reviews of objectives and extent of play after meeting with licensee / State, if necessary.-
60 days State and licensee submit exercise (45)'
scenario to FEMA and NRC Regions for l
review.
45 days FEMA and NRC Regions contact or meet (35).
with State and licensee to-discuss modifications and complete' the scenario.
Agreed upon changes or.
modifications should be documented and distributed.
35 days (optional)
Regional Assistan'ce Committee (RAC)
(30)
Chair calls Controller's meeting to develop coordination of exercise.
30 days FEMA and NRC Regions develop (25) specific post-exercise activity schedule for debriefings and meetings with.the State.
15 days The RAC Chair (and NRC team leader as available) develops evaluator action plan (where stationed, how many from each organization, what to look for).
The product of this will be the exercise evaluator packet which l
includes the specific evaluation i
location assignment.
The packet should provides o
Portions of the plan applicable to their assignment; 2
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o-A' list of all-exercise-evaluators.and their assignments;
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A time-line'of events; o
Scenario. summery;
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Scenario technical-data as-
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, required'for those assigned; j
o LPast exercase findings; q
o Applicable controller-messages; o
Applicable reference materials; o
Logistic information~and o
Log forms for taking notes.
I day.
All-Federal-evaluators, both--onsite.
and offsite, meet in'the exercise area to receive orientation and final instructions.-
Exercise Day (ED)
' Conduct Exercise.
Evaluators-hold Exit Interviews with participants -
(at. assigned locations).
ED+1 Evaluator Debriefing conducted by-RAC Chair.
'ED+1 or 2 NRC holds onsite Exit Meeting.
.EDt Public Meeting'is held by the RAC chairperson and the State (s).
(Qualifying Exercise)
ED+
Participants Meeting is conducted by RAC Chair.
(Continuing Approval-Exercises) l ED+30 Draft FEMA exercise evaluation report sent to State (s).
Whenever an exercise is scheduled, the Region should promptly assure construction of a time line based on the i
above Emilestones and make it available to the State,. RAC w
members, NRC Region, and PEMA Headquarters.
Where a plant
.is located on a Regional boundary, the Region in which the 3
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- p plant 11.s actually located is considered the lead Region for.
. purposes of; scheduling,' coordination and establishing the p
' time line.
Adhering 'to the time line should permit ample time to review'and negotiate any changes to;the exercise
. objectives and the. exercise scenario.-
However, should delays occur which may affect the scheduled exercise date, L
7
- the Regional Director shall so advise the State,.the NRC.
Region,'the RAC members and FEMA Headquarters.- The FEMA Regional Office should make every effort.to rectify slippage
'in:the timetable to avoid < rescheduling the exercise.date.-
The objectives.for the'offsite portion of the exercise should be taken from this document's list of: 36 in Section III,. Exercise Objectives.
'These-exercise objectives functionally restate'the intent of those evaluation criteria in NUREG-0654/ FEMA-REP-1 that can be demonstrated and
' observed in exercises..They are restated in order to
' facilitate.the use of these evaluation criteria for evaluating exercise' performance.. They also constitute the
" major: elements" of offsite emergency planning and preparedness that are to be tested at least once every six
. years as' set forth in NUREG-0654/ FEMA-REP-1 evaluation
. criterion N.1.b. as revised in GMc PR-1 L (page 2).
.Therefore,-
the objectives should be selected in order to. test all major elements at~least once~every six years..Some objectives, because of. their -importance to! adequate emergency response, are to be' included in each biennial exercise for each
- participating organization.
This set of exercise objectives, referred. to as the '" core objectives," are listed in Group A of Section III of this document.
The initial six-year period began on the:date of the first joint exercise after' November 3, 1980, the effective date of.the NRC rule,10 CFR 50 (see GM PR-1).
j 1
The objectives for each exercise shall be reviewed by both
~the FEMA and NRC Regional Offices before specific scenarios are written.
Once reviewed, the State and licensee shall i
develop a scenario for submission which will include, at a l
minimum:
o' The exercise objectives; o
The date(s), time period, place (s), participating organization (s) and extent of State and local government participation (i.e.,
full or partial);
o A time schedule of all key events; o
Identification of simulated events and activities; 4
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o A chronological narrative of exercise events and activities and
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o Appropriate radiological offsite release data with appropriate values for dose calculations, dosimetry,
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field monitoring and meteorological data.
FEMA and NRC Regions will coordinate the review of the j
. scenario.and notify the State and licensee of any
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necessary modification.:t.
If necessary, a meeting to discuss. modifications should be held.
If agreement u
cannot.be reached, FEMA and NRC Headquarters assistance should be sought.
II. Post-exercise Debriefings and Meetinos A.
Three audience groups may be involved in i
post-exercise meetings:
1.
Evaluators, l
l 2.
Exercise Participants and l
3.
Public/ Media.
l
-1 The timing and intent of the' meetings may vary depending upon whether the exercise is conducted in advance of. FEMA 350 approval. (qualifying exercise),
for continued 350 approval or after a remedial exercise.
B.
The following chart illustrates post-exercise meeting requirements for qualifying exercises and exercises for continued FEMA approval.
OffALIFYING EXERCISE CONTINUED APPROVAL EXERCISE
' Evaluator / Participant Evaluator / Participant Exit Interview Exit Interview Evaluator Debriefing Evaluator Debriefing Exercise Participants Exercise Participants Briefing Briefing Public Meeting Meeting to which public and media are invited C.
Guidance on each type of debriefing / meeting follows.
~
1.
Evaluator / Participant M Interview h oualifyino and continued accroval exercises):
Immediately following the conduct of the exercise, 5
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'an-exercise evaluator exit interview with the participants should be held at their assigned locations, lui appropriate, to.briefly-provide a preliminary assessment of the. exercise participants' strengths-and weaknesses.
No attehipt _should be made to categorize exercise performance inadequacies as
" deficiencies" or ' " areas requiring corrective actions" (ARCA).. Also, no indication of a " bottom line" finding on emergency preparedness at these a.
locations should be made.
2.
. Evaluator.Debriefinq:
Soon after the exercise,-the RAC Chair should hold debriefings for all _
- evaluators.- These debriefings'may be conducted by team leaders selected by the RAC Chair.
The purpose of these debriefings is to secure accurate and complete. information from the evaluators per. their assignments to provide the RAC Chair with-the basis-for:eachl finding'as presented during the Exercise Participants' Briefing... During this same. period,
_the NRC team leader; conducts 'a parallel meeting with' the NRC. evaluators.of-onsite performance in the exercise.
If exercise deficiencies are indicated which would trigger. remedial. action, the RAC Chair shall report same to FEMA Headquarters by telephone per GM EX-1.
Following the RAC. Chair's.
telephone contact with PEMA Headquarters, this.
debriefing can serve"as the initial step-in the X
consultation process required in GM EX-1.
3.
Exqrcise Participants Briefino (for cualifying and continued-anoroval exercises) a.
As soon aus.possible af ter. their independent l
interviews, the RAC Chair and the NRC team leader should meet to coordinate and arrange for Federal participation in the joint-Exercise l
Participants' Briefing, b.
Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the completion of an exercise, a briefing involving the exercise
' participants, RAC Chair, NRC representative and other RAC members and Federal evaluators, as appropriate, should be held to discuss the f
preliminary results of the exercise.
This 4
briefing should be held in accordance with 44
)
CFR 350.9(a)(d).
I c.
Recommended agenda to be used is as follows:
i)
Review of onsite actions presented by NRC; 6
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Licensee-presents'their views (clarifying questions _or comments);:
111). Review of.offsite actions by RAC Chair; iv).
State and local. governments present their
- views (clarifying questions or. comments);
v)'
Review of;Federa1' response.(ifLapplicable) by RAC Chair and
.vi)
Opportunity'for clarifying questionsEor comments by licensee, State and local governments.
d; The' presentations should comprise a brief,_
integrated overview covering.the highlights g
of the exercise.
Included in the; presentation should be appropriate commendation (s) for good performance and a
- preliminary assessment of
- the participants
strengths and weaknesses.
At;this1 stage,<no attempt: should be made;to' categorize. exercise performance inadequacies. as'" deficiencies" or
- ARCA's. - 'Also,:no_ indication of a:" bottom.
line" finding should be made as to 'whether State or-local preparedness isJadequate.
e.
As soon.as'possible after this briefing,=the RAC Chair, through.the consultation; process, should provide the State with a tentative identification of the exercise. inadequacies, if any, by classification,
'i.e.,.
" deficiencies" Land ARCA's.
Again, no r
indicationsof'a " bottom line" finding should be made as to whether State or local' preparedness is' adequate.
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- 4. Public Meetina ling analifyina exercinen) a.
A public~ meeting in accordance with 44 CFR 350.10 should be held as soon as possible after the exercise ~in the vicinity of the nuclear power facility.
This meeting shall be noticed in the local media in accordance-with 44 CFR 350.10.
Exercise participants, representatives from the NRC and other appropriate Federal, State and local agencies 1
should attend.
- 4 b.
The meeting should acquaint members of the public with appropriate State and local n
emergency plans and the results of the 7
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>b exercise, including strengths ~and weaknesses-observed.
The meeting should also answer any.
. questions about FEMA's review and evaluation and' receive suggestions.from the public for improvements or changes.
c..
During this'Public Meeting'an assessment of.
the exercise participants' performance should be made.
The timing of the Public. Meeting-with relat~ ion to the post-exercise evaluations pr3cedures will dictate the degree to which-the RAC. Chair can address the exercise participants performance.. When the consultation process has progressed to the point of agreement..onLthe degrees of Inadequacies.in the exercise participants' performance, these inadequacies can be-discussed in their proper categorization, i.e.,'" deficiencies" and ARCA's.
When an
. agreement.on the inadequacies in.the exercise Participants'. performance has not been
' reached, discussions should'be more general, i.e.,. in. terms of strengths and weaknesses.
j d.
For situations in.which a Public Meeting has been held during the 350 app ~roval' process and, thereaf ter, a plan amendment is H
submitted which significantly changes the context or nature of the planning [e.g.,
a change in the emergency planning zone (EPZ) results in the inclusion of additional jurisdictions), the FEMA Regional Director' shall determine whether the amendment
. necessitates holding another Public Meeting.
5.
Meetin9 121 Continued EEE& Aporoval Exercises a.
Following an exercise for continued FEMA approval, a meeting involving exercise participants, representatives from the NRC,-
other appropriate Federal agencies, the public and the media should be held in accordance with 44 CFR 350.9(e) in the L
vicinity of the nuclear power' facility.
This l
meeting shall be noticed in the local newspaper with the largest circulation in the area,f or other media as the Regional Director may select, within five to seven days of the l.
exercise date.
At the discretion of the L -.
Regional Director, this meeting may be combined with the exercise participants briefing.
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b.
The public and media may' attend the meeting.
as observers.
At the discretion of'the i
Regional Director, written questions from the public and media may be submitted at or after the: meeting for. consideration in the exercise
. evaluation.
The Regional Director may further use his/her discretion to solicit and respond to oral questions and' comments during s
1 this meeting.
Under no circumstances should.
it be indicated whether-State or local preparedness is' adequate or inadequate.
. During the meeting, the RAC Chair should.
c.
offer an overview of the exercise and should provide his/her observations.
Comments from the RAC. members and FEMA evaluators may be solicited at the discretion of the RAC Chair.-
6.
"Meetinos" fg exercises conducted during ng approval process:
Requirements'in 44 CFR 350 do not address the conduct of " meetings" for -
exercises, held after the initial. qualifying exercise but before the completion of the 350 approval process.
For such exercises, a meeting as described in 350.9(e), i.e., a meeting, conducted for, continuing FEMA approval exercises, should be held.
FEMA's evaluation of such " interim" exercises is an integral part of FEMA's overall 350 approval process.
- Again, the Regional Director ~may exercise-further discretion by giving the public and the media-an opportunity to orally discuss the performance of the exercise and the preliminary evaluation.
7.
"Meetines" after remedial exercises:
After remedial exercises required under 44 CFR 350.9 (a) (c) (5), it is necessary to hold a debriefing (item II.C.2.. above) and may be necessary to hold a meeting (item. II.C.3. above).
Because remedial actions may vary from remedial exercises involving many organizations to drills including only one or. two organizations, discretion is given to the Regional Director to determine the need to convene a meeting to which the public and media are invited, in accordance with 44 CFR 350.9(e).
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x III. Exercise Obiectives The following, list of.36 exercise objectives is to be incorporated into the designlof REP exercises.
These objectives are correlated to the original 35 exercise objectives-f rom the August 5,1983, memorandum by the numbers. provided in parentheses following the text of each objective.
For all-36 objectives, the need for organizations to demonstrate these capabilities is i
dependent upon their assigned plan responsibilities..
The objectives are presented in three groups.. Group A, numbers 1-15, are " core objectives" that' are to be
. demonstrated in each biennial exercise.
Core objectives
' represent. fundamental emergency' preparedness capabilities needed by all organizations for-effective response to radiological emergencies.
These objectives are scenario
' independent and, therefore, need to be demonstrated'by all organizations in each biennial. exercise.
1 Group B objectives, numbers 16-25, also represent i
fundamental radiological emergency response capabilities and q
should be demonstrated in each biennial exercise.
- However, these objectives are scenariofdependent and may.only impact s;me organizations.
Scenarios should be varied from exercisento exercise to. ensure that these objectives are demonstrated by each appropriate'offsite emergency. response organization at.least once every six years.
Some organizations' may-need to' demonstrate these objectives more frequently because of factors such ass (1) Geographical location and size of jurisdictions,. (2) use of 360 degree evacuation for a significant part or all of the plume Emergency Planning Zone and (3) need to. retest capabilities previously evaluated as areas requiring corrective action.
Group C objectives, numbers 26-36, while not as critical as the more primary and time-sensitive Group A and B objectives, also represent important emergency preparedness capabilities.
For example, the ingestion-related objectives (27-30) Linclude functions that generally would not have to be implemented immediately to protect public health and safety.
Group C objectives need only be demonstrated once every six years.
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Each of the exercise. objectives in Groups B and C should be demonstrated during an exercise within the initial six-year period and then tracked individually to ensure inclusion in exercises within six-vear-intervals. - For example, if the.
. initial six-year period for an offsite response organization began. June 1982 and a - shif t change (objective 34) was demonstrated during the. June 1984 exercise, this objective 1
must be demonstrated again at the latest by.the end of calendar year 1990.
GROUP A - CQEE OBJECTIVES THAT Agg SCENARIO INDEPENDENT NUREG-0654/
OBJECTIVE'i FEMA-REP-1 r
EMERGENCY CLASSIFICATION LEVELS 1.
Demonstrate the-ability to monitor,
- D.3.4.
understand and use' emergency classification levels ' (ECL) through the appropriate implementation.of emergency functions and i
7 activities corresponding to ECL's as required by the' scenario.
The four ECL's are:
Notification of unusual event, alert, site area emergency and general emergency.
MOBILIZATION QE EMERGENCY PERSONNEL a
2.
Demonstrate the' ability to fully alert, E.1.,
mobilize and activate personnel for both E.2.
facility and field-based emergency functions.
(See Objective 34 for 24-hour, continuous staffing function within a six-
. year time frame). (1)
DIRECTION AND CONTROL 3.
Demonstrate the ability to direct, coordinate A.1.d.,
and control emergency activities.
(3)
A.2.a.
COMMUNIC)TIONS 4.
Demonstrate the ability to communicate with F.
a11 ' appropriate locations, organizations (not F.1.f.)
and field personnel.
(5)
FACILITIES EQUIPMENT &MD DISPLAYS 5.
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Demonstrate the adequacy of facilities, G.3.a.,
equipment, displays and other materials to H.2.3.
support er.ergency operations. ~(4) 11
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EMERGENCY WORKER EXPOSURE CONTROL n
6.
Demonstrate.the abil.ity to. continuously K.3.a.b.
monitor and control emergency worker exposure.
(20)
ElILD RADIOLOGICAL MONITORING b
7.
Demonstrate the appropriate-equipment and I.8.,
procedures for determining field radiation
- I.11.
measurements.
(7)-
8.
Demonstrate the appropriate equipment and I.9.
. procedures for the measurement of airbor e radiciodine concentration.s as low as 10 microcurie per cc in the presence of noble
. gases.
(8) 1:
9.
Demonstrate the ability to obtain samples of I.10.
particulate activity in the airborne plume 1
and;promptly, perform laboratory analyses.
(New Objective)~
ELDME DDEE PROJECTION
- 10. Demons ~trat'e the. ability, within the plume I.10.
~
exposure pathway, to project dosage to the public via plume: exposure, based on plant and field data.
(10)
PId7ME PROTECTIVE ACTION DECISIONMAKING
- 11. Demonstrate the' ability to make appropriate J.10. m.
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protective action ~ decisions, based on projected or actual dosage, EPA PAG's, availability of adequate shelter, evacuation time estimates and other relevant factors.
(10) l ALERT. NOTIFICATION M EMERGENCY INFORMATION
- 12. Demonstrate the ability to initially alert the E.6.
public within the 10-mile EPZ and begin dissemination of an instructional message within 15 minutes of a decision by appropriate State and/or local official (s).
(13) m
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X 13.' Demonstrate.the ability to coordinate the E.5.
formulation and dissemination of. accurate' G.4.b.-
information and instructions to the public in a
-timely fashion af ter the initial alert and '
notification:has occurred. (3 4, 25)
- 14. Demonstrate-the ability to brief.the media in G.3.a.,
an accurate, coordinated and. timely: manner.
G.4.a.
24)
(
- 15. Demonstrate the. ability to establish.and G.4.c.
operate-rumor control in a coordinated and timely fashion..
-(26)
GROUP R - SCENARIO-DEPENDENT OBJECTIVES i
- D.EX QE El
'16. Demonstrate the ability ; to make. the' decision J.10. e. f.
to recommend the use of KI to emergency workers and' institutionalized persons,: based.on.
-predetermined criteria, as;well as to distribute.
and administer it once the decision is made, if:
necessitated by radioiodine releases.
(21,22)
- 17. Demonstrate'the ability to makefthe J.10.f.
decision, if the State. plan so specifies, to-recommend the use of KI.for the general public, based on. predetermined criteria, as well as to distribute and administer it once
. the decision is.made,. if necessitated by radioiodine ' releases,(21,22)
IMPLEMENTATION QE PROTECTIVE ACTIONS
- 18. Demonstrate the ability and resources necessary J.9.,
to implement appropriate protective actions J.10. d.g.
for the impacted permanent and transient plume s
L EPE population -(including transit-dependent persons,.special needs. populations, handicapped persons and institutionalized persons).
(15) 19.: Demonstrate the ability and resources J.9.,
necessary to implement appropriate protective J.10.g.
actions for school children within the plume EPZ.
(19) 13
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?P i
sA TRAFFIC;CONTROLL
- 20. Demonstrate the organizational ability and J.10. j. k.
- )
resources necessary to control evacuation traffic flow and to~ control access to.
evacuated and sheltered areas.
(16,17)
RELOCATION CENTERS (REGISTRATION. MONITORING; CONGREGATE j
CARE &HQ_ DECONTAMINATION).
~1
- 21. Demonstrate the adequacy of. procedures, J.12.
f acilities, equipment _ and personnel for the i
registration, radiological monitoring and 1
decontamination of evacuees..(27)
- 22. Demonstrate the adequacy-of facilities, J.10.h..
equipment and. personnel for congregate care of evacuees.
(28)
MEDICAL SERVICES (TRANSPORTATION &HD FACILITIES) l
- 23. Demonstrate the adequacy of. vehicles, L.4.
equipment, procedures and personnel for transporting contaminated, injured or exposed Individuals.
(30)
- 24. Demonstrate the adequacy of medical facilities L.l.
equipment, procedures-and personnel for handling contaminated, injured'or exposed individuals.
(31)
DECONTAMINATION
' 25. Demonstrate the adequacy of facilities, K.5.a.b.
-equipment, supplies, procedures.and personnel for decontamination of emergency workers, equipment and vehicles and for waste disposal.
(29)
GROUP C - QTHER OBJECTIVES:
TQ BE DEMONSTRATED AT LEAST ONCE EEERI SIX-YEARS SUPPLEMENTARY ASSISTANCE (FEDERAL /OTHER)
- 26. Demonstrate -the ability to identify the need c.1.a.b.
for and call upon Federal and other outside support agencies' assistance.
(32)
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,k INGESTION EXPOSURE PATHWAY
- 27. Demonstrate. the appropriate. us.e. of. equipment I.8.,
and procedures for collection and transport J.11.
of: samples of vegetation, food crops, milk, meat, poultry,-water.and. animal feeds (indigenous to the area and stored).
(9)
- 28. Demonstrate the appropriate lab. operations C.3.,
and procedures for measuring and. analyzing J.11..
)
. samples. of vegetation, food crops, milk, meat, poultry, water 'and animal feeds (indigenous to
-the area-and stored).
.(9)
- 29. Demonstrate the ability to project dosage to I.10.,
the public for ingestion pathway exposure and J.9.,
determine appropriate protective measures J.11.
based on field data,'FDA PAG's and other relevant factors.
(11)
- 30. Demonstrate the ability to implement both J.9.,
preventive and emergency protective actions
. J.11.
for. ingestion pathway h,zards. (12)
RECOVERY, REENTRY M RELOCATION
- 31. demonstrate the ability to estimate total M.4.
population ~ exposure.
(34)
- 32. Demonstrate the ability to determine M.l.
appropriate measures for controlled
- reentry and recovery based on estimated total population exposure, available EPA PAG's and other relevant factors.
(35)
- 33. Demonstrate the ability-to implement M.1.
J appropriate measures for controlled reentry and recovery.-
(35)
MOBILIZATION QE EMERGENCY PERSONNEL (24-HODR, CONTINUOUS BASIS)
- 34. Demonstrate the ability to maintain staffing A.1.e.,
on a continuous 24-hour basis by an actual A.4.
shift change.
(2) i EVACUATION QE ONSITE PERSONNEL
- 35. Demonstrate the ability to coordinate the B.6.
evacuation of onsite personnel.
(23)
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UNANNOUNCED &HQ OFF-HOURS
'36.~ Demonstrate the ability to carry 1out emergency N.1.b.
j response functions! (i.e., activato EOC's,.
-mobilize' staff.that report to the EOC's, establish communications linkages and complete
-telephone call down) during an unannounced off-hours drill or exercise.
(New Objective)
IV. CORRELATION R EXERCISE OBJECTIVES NITH LEVELS E EXERCISE
~
As' set. forth in 44 CPR 350.2(j)(k), there are two levels of' participation in exercises, full-and partial participation.
In demonstrating exercise objectives in full participation exercises, the objectives should be fully demonstrated in both facility and. field operations.
In demonstrating exercise objectives in partial participation exercises, the objectives should be~ fully demonstrated in all; facilities while field operations may be simulated.
V.
IMPLEMENTATION The provisions of this'GM should be implemented 120 days from the:date of this memorandum.
There are two exceptions to this implementation time frames. (1) The expanded
' milestone. dates. (e.g.,. from 75 days to 90 days) for the initial milestone and (2) exercise objective 9.
These "should be implemented in all joint exercises to be held beginning in calendar year 1989.
VI. COORDINATION This GM has been coordinated with and concurred in by NRC staff.
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