Issue Date: 06/24/98 - 1 - 82302

NRC INSPECTION MANUAL PEPB

INSPECTION PROCEDURE 82302

REVIEW OF EXERCISE OBJECTIVES AND SCENARIOS FOR POWER REACTORS

PROGRAM APPLICABILITY: 2513, 2515

SALP FUNCTIONAL AREA: PLANT SUPPORT (PLTSUP)

82302-01 INSPECTION OBJECTIVE

To provide guidance for the review of proposed licensee (or

applicant) exercise objectives and scenarios.

82302-02 INSPECTION REQUIREMENTS

02.01 Timeliness of Licensee Submittals. Determine whether the

licensee's (or applicant's) proposed objectives and scenario were

received in sufficient time before the exercise to permit

appropriate NRC review.

02.02 Content of Licensee Exercise Objectives and Scenarios.

Determine whether the licensee's (or applicant's) proposed

objectives for the exercise meet commitments and provide reasonable

acceptance criteria.

02.03 Determine whether the licensee's (or applicant's)

emergency preparedness exercise objectives and scenario provide an

adequate framework for the type and scope of exercise proposed.

Determine whether the scenario is realistic. |

|

02.04 Determine whether the licensee's (or applicant's)

proposed exercise scenario will meet the previously submitted

exercise objectives.

82302-03 INSPECTION GUIDANCE

General Guidance

Evaluations conducted in accordance with this procedure are limited

to the staff, activities, records, and facilities of the licensee

(or applicant.) Where necessary to verify licensee (or applicant)

performance, concerning interactions with organizations and persons

involved in offsite emergency preparedness, inspection activities
82302 - 2 - Issue Date: 06/24/98

are to be limited to reviews of pertinent records available through

the licensee (or applicant). If additional information is needed

about offsite emergency preparedness, it can be obtained from FEMA.

Technical evaluations of the scenario and exercise control are the

responsibility of the licensee (or applicant). The scenario is to

be evaluated primarily on relative credibility and timing of

events. The licensee (or applicant) should review and verify the

technical details including, but not limited to, engineering

operational parameters, engineering logic, source term,

radiological instrumentation data, and units of data provided by

| controllers. The licensee may utilize insights from accident

| sequences evaluated as part of the site-specific probabilistic risk

| analysis (PRA) to develop realistic scenarios which include likely

| equipment failures, human errors, recovery actions, and accident

| sequence progression. Scenario-related problems and poorly

controlled exercises will be evaluated during the exercise. The

in-house inspection of the scenarios is to be against the

requirements of 10 CFR 50.54(t), 50.47(b)(14), and Section IV.F. of

Appendix E to 10 CFR 50. Results of these inspections are to be

documented in the inspection reports for those inspections

completed under Inspection Procedure 82301, "Evaluation of

Exercises for Power Reactors."

Specific Guidance

03.01 Exhibit 1 provides the schedule recommended for the

development, submission, and review of licensee (or applicant)

exercise scenarios. This schedule is in accordance with the

guidance of Table 2, "Milestones for REP Process," in FEMA-REP-14,

"Radiological Emergency Preparedness Exercise Manual," dated

September 1991. 

03.02 Major onsite elements of licensee (or applicant) exercises

are to be included in the objectives. These elements normally

include aspects of the emergency plan to be exercised and may

include areas, such as the use of a new set of procedures, that

licensees (or applicants) wish to evaluate for their own

information. 

a. Major elements that are to be included in all exercises are

listed below along with the specific references in

NUREG-0654, Part II, and Supplement 1 to NUREG-0737.

Elements that are to be Exercised Each YearNUREG-0654

1. Accident detection and assessment I.1, I.2

2. Emergency classification D.1, D.2

3. Notification of onsite and offsite

emergency responders E.1, E.2, E.3,

J.1

4. Communications F.1, F.2, E.2,

E.4, H.6, 8.1

8.2, 8.3, 8.4
1 Items refer to NUREG-0654, Part II, except for element (j) in

which the reference is NUREG-0737, Supplement 1.

2 Item refers to NUREG-0654, Revision 1, Supplement 1.

Issue Date: 06/24/98 - 3 - 82302

5. Radiological exposure control K.1, K.2, K.3,

K.5, K.6, J.3,

J.6

6. Protective action recommendations J.7

7. Staff augmentation A.1, A.3, A.4,

B.7, B.8, B.9

 8. Shift staffing B.1, B.2, B.3;

B.5, Table 2

b. The inspector is to review the emergency plan and related

documentation to determine licensee (or applicant)

commitments. Where the licensee (or applicant) has committed

to the elements of NUREG-0654, the inspector is to take steps

to ensure that those elements of the emergency plan have been

exercised over a period of six years. Licensees may be

credited for exercising elements during any drill or

exercise. A review of licensee critique records can provide

appropriate documentation of elements having been

successfully exercised. Regional personnel may wish to

consider initiating a tracking system for each licensee to

record and monitor when elements are exercised. Regulatory

Guide 1.101, Revision 3, allows the licensee (or applicant)

to develop methods and solutions different from those

described in NUREG-0654. In the event that the licensee (or

applicant) has not formally committed to NUREG-0654,

applicable elements are required to be tested. Applicable

elements as well as the appropriate references are provided

below:

Elements to be Exercised Over

a Period of Six Years NUREG-06541

1. Off-hours staffing (6 p.m. to 4 a.m.).N.1.b2

2. Activation of emergency news center

(Joint Information Center). G.3, G.4

3. Use of fire control teams. N.2.b, 0.4.d

4. Use of first aid and/or rescue teams.K.1, K.2, K.3,

K.4, K.5, L.2,

0.4.f

5. Use of medical support personnel. N.2.c, L.1,

L.4, 0.4.h
82302 - 4 - Issue Date: 06/24/98

6. Use of licensee's headquarters

support personnel. 0.4.i

7. Use of security personnel to provide

prompt access for emergency equipment

and support. 0.4.d

8. Use of backup communications. F.1

9. Rumor control. G.4.c

10. Use of emergency power (where 

a part of plant safety systems, e.g.

Technical Support Center (TSC)). 8.2.1

11. Evacuation of Emergency Response

Facilities (ERFs) and relocation to

backup ERFs, where applicable. J.10.g

12. Ingestion pathway exercise, when J.9, J.11

necessary to support state exercise

requirements.

13. Field monitoring, including soil,

vegetation, and water sampling. I.7, I.8, I.11,

N.2.d

14. Capability for determining

the magnitude and impact of the

particular components of a release. I.3, I.4, I.6,

I.8, I.9, I.10

15. Capability for post-accident coolant

sampling and analysis. I.2

16. Use of potassium iodide. J.6.c

17. Assembly and accountability. J.5

18. Recovery and re-entry. M.1

c. The level of specificity of the objectives should provide

measurable and/or observable criteria for evaluators. The

objectives should also include a description of adequate or

acceptable levels of response.

d. Onsite objectives are to provide for a demonstration of the

correction of previously identified drill or exercise

weaknesses.

e. For the full-participation biennial exercise, the NRC team

leader will contact FEMA to confirm that offsite objectives

are consistent with exercise frequency requirements, testing
Issue Date: 06/24/98 - 5 - 82302

communication interfaces between onsite and offsite

facilities, and testing of the public notification systems.

03.03 Exercise objectives are dependent on the type of exercise

conducted. Descriptions of the types of exercises currently

conducted by licensees and applicants may be found in Inspection

Manual Chapter (IMC) 2500, Appendix I.

a. Exercise Objectives. Attention to details, in the review of

exercise objectives, is required because they provide the

basis for the development of the exercise scenario and

acceptance criteria for exercise evaluation. The licensee's

objectives should be commensurate with the type and scope of

exercise proposed. Information Notice 87-54, "Emergency

Response Exercises," reminds licensees (and applicants) that

off-year exercises are not required to proceed to severe core

damage situations. These exercises can provide an

opportunity for more realistic emergency response training

and evaluation of licensee (or applicant) staff. Timely

evaluation of exercise objectives is essential to provide

enough time for the licensee (or applicant) to change or

revise objectives in advance of the exercise, where

necessary, without hardship.

b. Exercise Scenarios. These scenarios are to provide for (1)

a test of the licensee's (or applicant's) integrated

capabilities for timely response to a radiological accident,

(2) a test of the content of selected implementing procedures

and methods, (3) test emergency equipment, (4) test

communications networks, and to (5) determine whether the

licensee's (or applicant's) emergency response personnel are

familiar with their emergency response duties (See 10 CFR 50,

Appendix E, Part IV.F.). The objectives and scenario are to

provide meaningful training for the emergency response

organization.

03.04 Review the scenario package for familiarization with the

type of accident proposed, an indication of how the objectives will

be met, and the organization and outline of the contents. All

major sections are to be included in the package. Attention is to

be given to the credibility and logical sequencing of events. The

sequence of events must provide sufficient opportunity for player

response activities to satisfy exercise objectives and be

coordinated to a timeline that delineates the continuity of events

in a logical order (e.g., a release not starting before the failure

of related equipment; the point of release being consistent with

anticipated pathways; sufficient time be allowed for the plume to

traverse the emergency planning zone (EPZ) before the location,

centerline, and magnitude are determined; etc.). Insights from the |

site-specific probabilistic risk analysis may be used to assist in |

this determination. Obtain these insights through discussion with |

the regional Senior Reactor Analyst, resident inspector staff, |

licensee PRA group, or by review of PRA documentation (if available |

in usable form). |

82302-04 INSPECTION RESOURCES
82302 - 6 - Issue Date: 06/24/98

The estimated time to complete this inspection procedure is 12

hours. The time expended for this review is to be reported as

direct inspection time.

82302-05 REFERENCES

| Inspection Manual Chapter 2515, Appendix C “Use of Insights Derived

| from Probabilistic Risk Assessment (PRA)”.

|

Regulatory Guide 1.101, "Emergency Planning and Preparedness for

Nuclear Power Reactors," Revision 3, August 1992.

NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and

Evaluation of Radiological Emergency Response Plans and

Preparedness in Support of Nuclear Power Plants," November 1980

(Microfiche Address: 01997/314 - 01998/71). 

Supplement 1 to NUREG-0654, "Criteria for Utility Offsite Planning

and Preparedness - Final Report," September 1988 (Microfiche

Address: 46972/313-348).

Supplement 1 to NUREG-0737, "Clarification of TMI Action Plan

Requirements-Requirements for Emergency Response Capability,"

January 1983 (Microfiche Address: 17301/342-363).

Information Notice 87-54, "Emergency Response Exercises," October

1987 (Microfiche Address: 43156/110-228).

FEMA-REP-14, "Radiological Emergency Preparedness Exercise Manual,"

September 1991. 

FEMA Guidance Memorandum GM-PR-1, "Policy on NUREG-0654/FEMA-REP-1

and 44 CFR 350 Periodic Requirements," October 1985. 

END

Attachments: Exhibit 1
Issue Date: XX/XX/XX E-1 82302, Exhibit 1

Exhibit 1

Recommended Schedule for Development,

Submission, and Review of Exercise Scenarios

Goals Activities

(number of days

before an exercise)

150 days NRC Headquarters and the selected Region exchange

objectives for an exercise in which the NRC Executive and

Site Teams plan to participate. The selected Region

informs the licensee (or applicant) of NRC's intent, to

participate, requests cooperation, and provides combined

agency objectives to the licensee.

90 days The licensee (or applicant) submits exercise objectives

to NRC.

80 days NRC discusses evaluation of objectives with the licensee

(or applicant) and negotiates the submittal of revised

objectives if major revision is required and coordinates

with FEMA if offsite responses are affected.

75 days The Region transmits a letter of confirmation to the

licensee (or applicant) documenting the discussion of the

review of exercise objectives.

60 days The licensee (or applicant) submits the exercise scenario

and associated materials to the NRC for review. Where

applicable, NRC objectives are to be included.

60 to The scenario is reviewed for consistency with

objectives, credibil45 days ity, and sequencing of events.

45 days The Region informs the licensee (or applicant) of its

scenario review and with FEMA should occur if offsite

responses are affected.

END