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Information Notice No. 89-46: Confidentiality of Exercise Scenarios
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON, D.C. 20555 May 11, 1989 Information Notice No. 89-46: CONFIDENTIALITY OF EXERCISE SCENARIOS Addressees: All holders of licenses for fuel cycle facilities and byproduct material licensees having an approved emergency response plan. Purpose: This information notice is being provided to alert fuel facility and certain byproduct material licensees of the unacceptable practice of conducting the required annual radiological emergency response exercises using "players" who are familiar with the details of the exercise scenarios. It is expected that recipients will review the information for applicability to their programs, distribute the notice to responsible radiation protection and emergency response staff, and consider actions, if appropriate, to ensure that emergency response exercises fulfill their intended purpose. However, suggestions contained in this 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 emergency exercise at a fuel facility in NRC Region II, the inspectors learned that the licensee was planning to use a scenario that was familiar to the exercise players. The inspectors also learned that a training handout was provided to members of the emergency organization which intentionally included the actual scenario to be used for the exercise. The scenario and the various players' anticipated roles were apparently discussed and "rehearsed." The handout also offered applicable emergency procedures (or portions thereof) for use by players during the exercise. Subsequent inspections at other fuel cycle facilities have revealed that this situation is not unique. Failure to conduct a radiological emergency exercise in a manner that adequately tests a licensee's ability to implement the Radiological Contingency Plan could result in an NRC request to conduct a remedial exercise, as occurred in the case discussed above. Discussion: Fuel facility and major byproduct materials licensees were ordered under a Generic Order published in the Federal Register (Vol. 46, No. 31, February 17, 1981) to submit radiological contingency plans to the NRC licensing staff for incorporation into their licenses. The emergency response plans submitted in 8905080009 . IN 89-46 May 11, 1989 Page 2 of 2 response to this order have been incorporated as license conditions for a number of years. These plans include requirements for periodic training, drills, and exercises. The purpose of training and drills is to familiarize participants with the contents of the contingency plan, procedures, and the types of events that would take place in the facility. However, for exercises, it was the NRC's intention that participants not have prior knowledge of the specific exercise scenario. Exercises are conducted to test response capabilities and ensure that radiological emergency personnel are familiar with their duties. Observers of exercises cannot evaluate the effectiveness of personnel actions if the personnel have been briefed on the scenarios 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 be known to most exercise participants. The licensee shall critique each exer- cise using individuals not having direct implementation responsibility for the plan. Critiques of exercises must evaluate the appropriateness of the plan, emergency procedures, facilities, equipment, training of personnel, and overall effectiveness of the response. Deficiencies found by the critiques must 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 technical contact listed below, or to the Regional Administrator of the appropriate NRC Regional Office. Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Technical Contacts: Edwin D. Flack, NMSS (301) 492-0405 Douglas M. Collins, Region II (404) 242-5586 Attachments: 1. List of Recently issued NMSS Information Notices 2. List of All Recently Issued NRC Information Notices . Attachment 2 IN 89-46 May 11, 1989 Page 1 of 1 LIST OF RECENTLY ISSUED NRC INFORMATION NOTICES _____________________________________________________________________________ Information Date of Notice No._____Subject_______________________Issuance_______Issued to________ 89-45 Metalclad, Low-Voltage 5/8/89 All holders of OLs Power Circuit Breakers or CPs for nuclear Refurbished with Sub- power reactors. standard Parts 89-44 Hydrogen Storage on the 4/27/89 All holders of OLs Roof of the Control Room or CPs for nuclear power reactors. 88-82, Torus Shells with Corrosion 5/2/89 All holders of OLs Supp. 1 and Degraded Coatings in or CPs for BWRs. BWR Containments 89-43 Permanent Deformation of 5/1/89 All holders of OLs Torque Switch Helical or CPs for nuclear Springs in Limitorque power reactors. SMA-Type Motor Operators 88-97, Potentially Substandard 4/28/89 All holders of OLs Supp. 1 Valve Replacement Parts or CPs for nuclear power reactors. 89-42 Failure of Rosemount 4/21/89 All holders of OLs Models 1153 and 1154 or CPs for nuclear Transmitters power reactors. 89-41 Operator Response to 4/20/89 All holders of OLs Pressurization of Low- or CPs for nuclear Pressure Interfacing power reactors. Systems 88-75, Disabling of Diesel 4/17/89 All holders of OLs Supplement 1 Generator Output Circuit or CPs for nuclear Breakers by Anti-Pump power reactors. Circuitry 89-40 Unsatisfactory Operator Test 4/14/89 All holders of OLs Results and Their Effect on or CPs for nuclear the Requalification Program power reactors. 89-39 List of Parties Excluded 4/5/89 All holders of OLs from Federal Procurement or CPs for nuclear or Non-Procurement Programs power reactors. _____________________________________________________________________________ OL = Operating License CP = Construction Permit ..
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