United States Nuclear Regulatory Commission - Protecting People and the Environment

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 



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.                                                            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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