Information Notice No. 89-46: Confidentiality of Exercise Scenarios
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
All holders of licenses for fuel cycle facilities and byproduct material
licensees having an approved emergency response plan.
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.
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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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
Technical Contacts: Edwin D. Flack, NMSS
Douglas M. Collins, Region II
1. List of Recently issued NMSS Information Notices
2. List of All Recently Issued NRC Information Notices
. Attachment 2
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.
89-44 Hydrogen Storage on the 4/27/89 All holders of OLs
Roof of the Control Room or CPs for nuclear
88-82, Torus Shells with Corrosion 5/2/89 All holders of OLs
Supp. 1 and Degraded Coatings in or CPs for BWRs.
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
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.
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.
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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