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
Revision:	0
From:	Cunningham R E NRC/NMSS/IMNS
To:
References
IN-89-046, NUDOCS 8905080009
Download: ML031190361 (10)

UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDSWASHINGTON, D.C. 20555May 11, 1989NRC INFORMATION NOTICE NO. 89-46: CONFIDENTIALITY OF EXERCISE SCENARIOS

Addressees

All holders of licenses for fuel cycle facilities and byproduct materiallicensees having an approved emergency response plan.

Purpose

This information notice is being provided to alert fuel facility and certainbyproduct material licensees of the unacceptable practice of conducting therequired annual radiological emergency response exercises using 'players whoare familiar with the details of the exercise scenarios. It is expected thatrecipients will review the information for applicability to their programs,distribute the notice to responsible radiation protection and emergency responsestaff, and consider actions, if appropriate, to ensure that emergency responseexercises fulfill their intended purpose. However, suggestions contained inthis 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 emergencyexercise at a fuel facility in NRC Region II, the inspectors learned thatthe licensee was planning to use a scenario that was familiar to the exerciseplayers. The inspectors also learned that a training handout was provided tomembers of the emergency organization which intentionally included the actualscenario to be used for the exercise. The scenario and the various players'anticipated roles were apparently discussed and "rehearsed." The handoutalso offered applicable emergency procedures (or portions thereof) for useby players during the exercise. Subsequent inspections at other fuel cyclefacilities have revealed that this situation is not unique. Failure toconduct a radiological emergency exercise in a manner that adequately testsa licensee's ability to implement the Radiological Contingency Plan couldresult in an NRC request to conduct a remedial exercise, as occurred in thecase discussed above.Discussion:Fuel facility and major byproduct materials licensees were ordered under aGeneric Order published in the Federal Register (Vol. 46, No. 31, February 17,1981) to submit radiological contingencyplans to the NRC licensing staff forincorporation into their licenses. The emergency response plans submitted in508000 Z I"191 IN 89-46May 11, 1989 response to this order have been incorporated as license conditions for anumber of years. These plans include requirements for periodic training,drills, and exercises. The purpose of training and drills is to familiarizeparticipants with the contents of the contingency plan, procedures, and thetypes of events that would take place in the facility.However, for exercises, it was the NRC's intention that participants not haveprior knowledge of the specific exercise scenario. Exercises are conductedto test response capabilities and ensure that radiological emergency personnelare familiar with their duties. Observers of exercises cannot evaluate theeffectiveness of personnel actions if the personnel have been briefed on thescenarios 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 beknown to most exercise participants. The licensee shall critique each exer-cise using individuals not having direct implementation responsibility forthe plan. Critiques of exercises must evaluate the appropriateness of theplan, emergency procedures, facilities, equipment, training of personnel, andoverall effectiveness of the response. Deficiencies found by the critiquesmust be corrected."No specific action or written response is required by this information notice.If y-o-u -ave any questions -aboudtthis Matte, pea~se direct them to the technicalcontact listed below, or to the Regional Administrator of the appropriate NRCRegional Office.Richard E. Cunningham, DirectorDivision of Industrial andMedical Nuclear SafetyOffice of Nuclear Material Safetyand SafeguardsTechnical Contacts: Edwin D. Flack, NMSS(301) 492-0405Douglas M. Collins, Region II(404) 242-5586

Attachments:

1. List of Recently issued NMSS Information Notices2. List of All Recently Issued NRC Information Notices Attachment 1IN 89-46May 11, 1989 LIST OF RECENTLY ISSUEDNMSS INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to89-3789-3589-34.89-25Proposed Amendments to 40CFR Part 61, Air EmissionStandards for RadionuclidesLoss and Theft of UnsecuredLicensed MaterialDisposal of AmericiumWell-Logging SourcesUnauthorized Transfer ofOwnership or Control ofLicensed ActivitiesNuclear Criticality SafetyAlternative Waste ManagementProcedures in Case of Denialof Access to Low-Level WasteDisposal SitesDose Calibrator QualityControlPotential ElectricalEquipment Problems04/04/8903/30/8903/30/8903/07/8903/06/8902/08/8902/09/8901/11/8989-2489-13All U.S. NRClicenseesAll U.S. NRC byproduct,source and specialnuclear material licenseesAll holders of U.S.NRC specific licensesauthorizing well-loggingactivities.All NRC source,byproduct, and specialnuclear materiallicensees.All fuel cyclelicensees and otherlicensees possessingmore than critical massquantities of specialnuclear material.All holders of NRCspecific licenses.All NRC medicallicensees.All fuel cycle andmajor nuclear materialslicensees.89-1289-03 Attachment 21. 81-48May 11, 1989Pag 1 of 1LIST OF RECEIITY ISSUEDNRC INFORRATIUON NOTICESLftcrrition ,ace orNotice No. Suebect Issuance89.45 Metalclad. Low-Voltage 5/8/89Power Circuit 3reakorsRefurbisheo with Sub-stanoard Parts89-44 Hydrogen Storage an tne 4/27/89Roof of the Control Room28-82. Torus Stells with Corrosion Si2/89Supp. I ane Cegraded Coatings inIld Containments89-43 Permanent Deformation of 5/1/89Torque Switch HelficalSprings in LizitorqueSA-Type Motor Operators88-97. Potentially Substandard 4/28/89Supp. I Valve Replacerent Parts89-42 Failure of Rosemount 4/21/89Focels 1153 ano 1:54Transi tters89-41 Operator hesponse to 4/2,089Pressurization of Low-Pressure InterfacingSystemsa8-75, Disabling of 01esel 4/1689Supplement I Generator Cut;ut CircuitSreakers by Anti-;PwmCfrcuitry-- -------8t.4C: -ffsattsfc:ory1:orar rettT/I4/1s~9Results ano Their Etfdct onthe Requalificat1on Program89-i9 Cist of Pertles Excluoed 4/5/89from Federal Procurementor Rlon-Procurement ProgramsCL

• Coerating LicenicC?

• Construction PermitUNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D.C. 20555OFFICIAL BUSINESSPENALTY FOR PRIVATE USE, $300Issued toAll holders of OLsor CPs for nuclearpower reactors.All rolders of OLsor CPs for ruclearpower reactors.All holders of OLsor CPs for 864s.All holders of OLsor CPs for nuclearpower reactors.All holders of OLSor CPs for nuclearpower reactors.All holders of OL5or CPs for nuclearpower reactors.All holvers of OLsor CPS for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All hoieers ofCLs~or CPS for nuclearpower reactors.All holders of CLsor CPs for nuclear;ower reattors.FIRST CLASS MAILPOSTAGE 1 FEES PAIDUSNARCPERMIT No. 0.67 IN 89-46May 11, 1989 response to this order have been incorporated as license conditions for anumber of years. These plans include requirements for periodic training,drills, and exercises. The purpose of training and drills is to familiarizeparticipants with the contents of the contingency plan, procedures, and thetypes of events that would take place in the facility.However, for exercises, it was the NRC's intention that participants not haveprior knowledge of the specific exercise scenario. Exercises are conductedto test response capabilities and ensure that radiological emergency personnelare familiar with their duties. Observers of exercises cannot evaluate theeffectiveness of personnel actions if the personnel have been briefed on thescenarios 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 beknown to most exercise participants. The licensee shall critique each exer-cise using individuals not having direct implementation responsibility forthe plan. Critiques of exercises must evaluate the appropriateness of theplan, emergency procedures, facilities, equipment, training of personnel, andoverall effectiveness of the response. Deficiencies found by the critiquesmust 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 technicalcontact listed below, or to the Regional Administrator of the appropriate NRCRegional Office.PriinaI Signed byRichard E. Cunningham, DirectorDivision of Industrial andMedical Nuclear SafetyOffice of Nuclear Material Safetyand SafeguardsTechnical Contacts: Edwin D. Flack, NMSS(301) 492-0405Douglas M. Collins, Region II(404) 242-5586

Attachments:

1. List of Recently issued NMSS Information Notices2. List of All Recently Issued NRC Information NoticesEditor *IMNSEKraus RECunningham4/6 /89 5/7/89*See previous concurrenceOFC: IMOB* :IMSB* :IMOB* :OGC* :RII* :IMOB* :IMSB* : IMNS*---------------------------------------------for tel.-------------------------NAME:JMetzger/ll:GBidinger:JLyash :RFonner :DCollins :DCool :LRouse :GSjoblomDATE:4/20 /89 :4/26/89 :4/g§sLi j046S82n:5cQZ/89 :5/4/89: 4/27/89: 5/5/89 IN 89-May , 1989Page 2 ofHowever, for exercises, it was the NRC's intention that participants not haveprior knowledge of the specific exercise scenario. Exercises are conducted totest response capabilities and ensure that radiological emergency personnelare familiar with their duties. Observers of exercises cannot evaluate theeffectiveness of personnel actions if the personnel have been briefed on thescenarios 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 scenariospostulated as most probable for the specific site and the scenarios shall notbe known to most exercise participants. The licensee shall critique eachexercise using individuals not having direct implementation responsibility forthe plan. Critiques of exercises must evaluate the appropriateness of theplan, emergency procedures, facilities, equipment, training of personnel, andoverall effectiveness of the response. Deficiencies found by the critiquesmust be corrected."No specific action or written response is required by this InformationNotice. If you have any questions about this matter, please direct them tothe technical contact listed below, or to the Regional Administrator of theappropriate NRC Regional Office.Richard E. Cunningham, DirectorDivision of Industrial andMedical Nuclear Safety, NMSSTechnical Contacts: Edwin D. Flack, NMSS(301) 492-0405Douglas M. Collins, Region II(404) 242-5586

Attachments:

1. List of recently issued NMSS Information Notices2. List of all recently issued NRC Information NoticesEditorEKrausiha4/6 /89 5/9F/89*See previous concurrenceOFC: IMOB* :IMSB* :IMOB* :OGC* :RII* :IMOSB ;.MSB* : Imqh---------------------------------------------for tel.--- ---------NAME:JMetzger/ll:GBidinger:JLyash :RFonner :DCollins " :LRouse :GwMb mDATE:4/20 /89 :4/26/89 -4/2618 404 29:51089- :5/q /89:5/27/89:5/\ /89OFFI LPLL RECORDU CUY I IN 89-Vw Apri4- , 1989Page 2 ofHowever, for exercises, it was the NRC's intention that participants not haveprior knowledge of the specific exercise scenario. Exercises are conducted totest response capabilities and ensure that radiological emergency personnelare'familiar with their duties. Observers of exercises cannot evaluate theeffectiveness of personnel actions if the personnel have been briefed on thescenarios 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 scenariospostulated as most probable for the specific site and the scenarios shall notbe known to most exercise participants. The licensee shall critique eachexercise using individuals not having direct implementation responsibility forthe plan. Critiques of exercises must evaluate the appropriateness of theplan, emergency procedures, facilities, equipment, training of personnel, andoverall effectiveness of the response. Deficiencies found by the critiquesmust be corrected." XNo specific action or written response is required by this InformationNotice. If you have any 4uestions about this matter, please direct them tothe technical contact listed below, or to the Regional Administrator of theappropriate NRC Regional Office.Richard E. Cunningham, DirectorDivision of Industrial andMedical Nuclear Safety, NMSS

Technical Contact:

Douglas M. Collins, Region II(404) 242-5586

Attachments:

1. List of recently issued NMSS Information Notices2. List of all recently issued NRC Information NoticesEditor IMNSEKraus RECunningham4/6 /89 4/ /89*See previous concurrenceOFC: IMOB* :IMSB* :IMOB* :OGC* :RIIJfl : IMOB : IM5B* : IMNS_________---------------------- -------------------------NAME:JMetzger/ll:GBidinger:JLyash :RFonner: D-flinw DCool: LRouse: GSjoblonDATE:4/20 /89 :4/26/89 4 /89:4?27/89:A/ /89 IN 89-April 1989Page 2 ofHowever, for exercises, it was the NRC's intention that participants not haveprior, knowledge of the specific exercise scenario. Exercises are conducted totest response capabilities and ensure that radiological emergency personnelare famIliar with their duties. Observers of exercises cannot evaluate theeffectiveness of personnel actions if the personnel have been briefed on thescenarios 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 scenariospostulated as most probable for the specific site and the scenarios shall notbe known to most exercise participants. The licensee shall critique eachexercise using individuals not having direct implementation responsibility forthe plan. Critiques of exercises must evaluate the appropriateness of theplan, emergency procedures, facilities, equipment, training of personnel, andoverall effectiveness of the response. Deficiencies found by the critiquesmust be corrected."No specific action or written response is required by this InformationNotice. If you have any questions about this matter, please direct them tothe technical contact listed below, or to the Regional Administrator of theappropriate NRC Regional Office.Richard E. Cunningham, DirectorDivision of Industrial andMedical Nuclear Safety, NMSS

Technical Contact:

Douglas M. Collins, Region II(404) 242-5586

Attachments:

1. List of recently issued NMSS Information Notices2. List of all recently issued NRC Information NoticesEditor IMNSEKraus RECunningham4/6 /89 4/ /89*See previous concurrenceoFC: IMOB* :IMSB* :,M OGC* l IMOB :IM, :IMNSNAME:JMetzger/ll:GBidingertyash :RFonner :DCool :GSjoblomDATE:4/20 /89 :4/26/89 :4l66l2 4Q42j 690j /89 :4Z/,89 :4/ /89 IN 89-April , 1989Page 2 ofConduct of drills and exercises are to ensure that radiological emergencypersonnel are familiar with their duties. Observers of drills and exercisescan t evaluate the effectiveness of personnel actions if the personnel havebeen 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 scenariospostulated as most probable for the specific site and the scenarios shall notbe known to most exercise participants. The licensee shall critique eachexercise using individuals not having direct implementation responsibility forthe plan. Critiques of exercises must evaluate the appropriateness of theplan, emergency procedures, facilities, equipment, training of personnel, andoverall effectiveness of the response. Deficiencies found by the critiquesmust be corrected."No specific action or written response is required by this InformationNotice. If you have any questions about this matter, please direct them tothe technical contact listed below, or to the Regional Administrator of theappropriate NRC Regional Office.Richard E. Cunningham, DirectorDivision of Industrial andMedical Nuclear Safety, NMSS

Technical Contact:

Douglas M. Collins, Region II(404) 242-5586

Attachments:

1. List of recently issued NMSS Information Notices2. List of all recently issued NRC Information NoticesEditor ,EjIK INNSEKraus RECunningham4/6 /89 4/ /89OFC: IOA :MISBW J9 IM i / :0GC,4 :IMOB :MISB :IMNS-------- ---- ----f/'---- g- -----------------NAME 1Ietzger/ll:GBidinger: gash :RFo9r :DCool :LRouse :GSjoblomDATE:4/20 /89 :4/<P/89 :4/6&/89 :4/04 /89 :4/ /89 :4/ /89 :4/ /89OFFICIAL RECORD COPY IN 89-April , 1989Page 2 of7Conduct of drills and exercises are to ensure that radiologi emergencypersonnel are familiar with their duties. observerse of d us and exercisescannot evaluate the effectiveness of personnel actions i the personnel havebeen 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 scenariospostulated as uost probable for the specific si and the scenarios shall notbe known to most exercise participants. The censee shall critique eachexercise using individuals not having direct mplementation responsibility forthe plan. Critiques of exercises must eva ate the appropriateness of theplan, emergency procedures, facilities, uipment, training of personnel, andoverall effectiveness of the response. eficiencies found by the critiquesmust be corrected."No specific action or written resp se is required by this InformationNotice. If you have any question about this matter, please direct them tothe technical contact listed be w, or to the Regional Administrator of theappropriate NRC Regional OfficRichard E. Cunningham, DirectorDivision of Industrial andMedical Nuclear Safety, NMSSTechnical Cont t: Douglas M. Collins, Region II(404) 242-5586

Attachment:

1. List f recently issued NMSS Information Notices2. List of all recently issued NRC Information NoticesEditor IMNSEKraus RECunningham4/G /89 4/ /89UF1: :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/ /89OFFICIAL RECORD CUPY