1776 I Street, NW l Suite 400 l Washington, DC l 20006-3708 l P: 202.739.8016 l F: 202.533.0130 l spg@nei.org l 

www.nei.org

Susan Perkins-Grew

DIRECTOR

EMERGENCY PREPAREDNESS

NUCLEAR GENERATION DIVISION

July 25, 2011

Mr. Brian J. McDermott

Director for Incident Response

Office of Nuclear Security and Incident Response

Division of Preparedness and Response

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Subject: Transmittal of Revised Hostile Action-Based Exercise Objectives

Project Number: 689

Dear Mr. McDermott:

The Nuclear Energy Institute (NEI)1 and an industry task force have developed and are seeking NRC 

review and endorsement of a standard set of recommended objectives and performance attributes

for use in conducting a Hostile Action-Based (HAB) emergency response exercise. To facilitate your 

review, a copy of this material is attached. This version supersedes a draft previously provided for 

staff review dated April 2010 (ADAMS ML 101180293); we understand and agree that no further 

review work will be performed on this earlier submittal.

The attached revised document incorporates the staff’s comments provided to NEI representatives 

during a public meeting on July 13, 2011.

 1 NEI is the organization responsible for establishing unified nuclear industry policy on matters affecting 

the nuclear energy industry. NEI’s members include all utilities licensed to operate commercial nuclear 

power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel 

fabrication facilities, nuclear material licensees, and other organizations and individuals involved in the 

nuclear energy industry.
Mr. Brian J. McDermott

July 25, 2011

Page 2

NEI and industry members request that the document review schedule developed by the staff target 

an endorsement date of no later than November 1, 2011.

Please contact me at (202) 739-8016; spg@nei.org if you require additional information.

Sincerely, 

Susan Perkins-Grew

Attachment

c: Mr. Joseph D. Anderson, NSIR/DPR/DDEP/OR

Mr. Robert E. Kahler, NSIR/DPR/DDEP/IR

NRC Document Control Desk
ATTACHMENT

1

HAB EXERCISE OBJECTIVES

To meet regulatory requirements and related guidance, a licensee must maintain a 

set of drill and exercise objectives which guides the periodic demonstration of 

response functions described in the site emergency plan. Since an exercise utilizing 

a Hostile Action-Based (HAB) scenario must be conducted during an exercise cycle, 

this set of objectives will need to be expanded to include a subset focused on 

demonstrating those functions uniquely performed in response to a hostile action. 

Appendix A, HAB Drill and Exercise Objectives, presents generic guidance that a 

licensee should use to develop a site-specific set of HAB drill and exercise 

objectives. 

Each objective has an associated listing of Performance Attributes; these attributes 

define successful objective performance and should be used to develop the 

evaluation criteria for each objective. The development of objectives and 

evaluation criteria must be informed by site-specific emergency plan and 

implementing procedure requirements, and the content of existing drill and exercise 

objectives. A licensee is not expected to use the generic objectives verbatim; 

however, the function(s) described by each objective, and the associated 

performance attributes, must be addressed in the objectives and evaluation 

material used by the licensee to conduct an exercise. 

As with any other emergency response exercise, each HAB exercise shall be 

critiqued to identify weaknesses and opportunities for improvement. Identified 

weaknesses shall be entered into the appropriate site corrective action process. 

Licensees should modify their critique processes as necessary to ensure a thorough 

review and evaluation of HAB-related exercise objectives.

Objectives for Offsite Response Organizations (OROs) are developed and evaluated 

in accordance with guidance provided by the Federal Emergency Management 

Agency (FEMA).
2

APPENDIX A - RECOMMENDED DRILL AND EXERCISE OBJECTIVES

Recommended Objective Performance Attributes

1. Demonstrate the ability to implement 

the emergency plan during a hostile 

action-based event.

Timely implementation of:

• emergency classification.

• the formulation of Protective Action 

Recommendations (PARs).

• Offsite Response Organization (ORO) 

notifications.

2. Demonstrate the ability to make initial 

notifications to law enforcement and 

other first-responder agencies during a 

hostile action-based event.

Timely notifications are made to law 

enforcement, fire, medical and other firstresponder agencies as specified by 

appropriate procedures. [Notification 

made to actual or simulated agency 

contact points.]

3. Demonstrate the ability to 

communicate threat-related 

information to the NRC during a hostile 

action-based event.

• Perform accelerated notification to the 

NRC in accordance with appropriate 

procedures. [Notification made to 

actual or simulated NRC for a land or 

waterborne attack scenario.] 

• Perform airborne threat 

communications with the NRC in 

accordance with appropriate 

procedures. [Communications with 

actual or simulated NRC for airborne 

attack scenario.]

4. Demonstrate the ability of on-shift 

Operations and Security personnel to 

coordinate response actions among 

themselves, and with the Incident 

Commander and local law enforcement 

agency (LLEA) personnel.

Discussion, decision-making and 

communication related to:

• threat type, location, progression and 

changes to protective strategies.

• protective measure instructions to onsite personnel [communication may be 

simulated].

• entry, control, coordination and 

deployment of LLEA resources.

• radios or other methods used to 

facilitate communications between 

licensee and law enforcement 

personnel.
ATTACHMENT

3

Recommended Objective Performance Attributes

• understanding plant status and 

damage, personnel casualties and 

response priorities.

5. Demonstrate the ability of on-shift 

Operations and Security personnel to 

coordinate with the Incident 

Commander for deployment of on-site 

and offsite first-responders in a postattack environment.

Discussion, decision-making and 

communication related to:

• deployment of offsite first-responder 

personnel and vehicles to staging areas 

(e.g., fire trucks, ambulances, etc.).

• radios or other methods used to 

facilitate communications between 

licensee and offsite first-responder 

personnel.

• determination of on-site response 

locations and priorities.

• rapid deployment of offsite firstresponder personnel and vehicles to 

on-site response locations while 

maintaining control of site and 

Protected Area access.

• implementation of initial accident 

mitigation actions prior to ERO 

mobilization, including movement of 

on-shift personnel to perform critical 

tasks.

6. Demonstrate the ability to coordinate 

implementation of on-site radiation 

protection measures for offsite firstresponders with the ICP.

Discuss, simulate and/or implement 

radiation protection measures for offsite 

first-responders reporting to the site, as 

appropriate to the scenario (e.g., 

dosimetry, KI, respiratory protection, etc.).

7. Demonstrate the ability of the 

Emergency Response Organization 

(ERO) to support operation of an 

Incident Command Post (ICP).

Discussion, decision-making and 

communication related to:

• support activation of an ICP.

• accessibility by offsite responders.

• dispatch of licensee personnel to the 

ICP to serve as liaisons to ERO 

facilities, and to advise on matters 

related to plant operations, radiation 

protection, and Security.

• availability of site and plant layouts, 

and other aids that the ICP staff might 
4

Recommended Objective Performance Attributes

need to effectively coordinate law 

enforcement, fire and medical 

responses.

• coordination with field responders.

8. Demonstrate the ability to coordinate

mobilization of the Emergency 

Response Organization (ERO) with 

Security and the ICP.

Discussion, decision-making and 

communication related to:

• confirmation that the known threat has 

been neutralized to the extent 

necessary to allow ERO mobilization 

(land or waterborne attack).

• selection of a method(s) to protect 

ERO members during movement and 

provide safe passage (e.g., use 

designated routes, armed escorts, 

vehicles, etc.).

• mobilization instructions provided to 

responders (e.g., routes, escorts and 

exclusion areas; proceed directly to 

facilities; do not detour to inspect 

damage, etc.) .

• allowing ERO members to exit the site 

and proceed to their assigned 

emergency response facilities (e.g., the 

EOF or JIC).

• on-going protection of emergency 

response facilities and staff.

9. Demonstrate the ability of the 

Emergency Response Organization 

(ERO) to coordinate in-plant and onsite response actions with Security and 

the Incident Command Post (ICP).

• Effective interface between the ERO 

emergency director, Security 

supervision and the Incident 

Commander is maintained as 

conditions change.

• Plant status is determined, and 

mitigative actions are planned and 

prioritized.

• Alignment on priorities and assignment 

of resources. 

• Coordination and communications 

supporting timely movement of ERO 

personnel to perform on-site and inplant response actions in a post-attack 

environment (e.g., dispatching an OSC 
ATTACHMENT

5

Recommended Objective Performance Attributes

repair or survey team). 

• ERO personnel adhere to movement 

and other restrictions imposed by 

Security and law enforcement decisionmakers, (e.g., stay clear of perimeter 

zones, definition of free movement 

areas, special identification, two-person 

line-of-sight rule, use of escorts, etc.).

• ERO Liaisons at the ICP are provided 

with information and updates in a 

timely manner.

• As determined by law enforcement 

personnel, coordination and 

communication of actions to preserve a 

crime scene. 

10.Demonstrate the ability of the ERO to 

activate alternative facilities (if required 

by the scenario).

• Determine if activation of alternative 

facilities is necessary based on the 

event conditions, and communicate this 

decision to ERO members.

• Personnel at these locations are able to 

communicate with the Emergency 

Operations Facility, Control Room, and 

Security.

• Personnel at these locations can make 

ORO notifications if required by 

emergency plan implementing 

procedures.

• Personnel at these locations are able to 

perform engineering assessment 

activities, including damage control 

team planning and preparation.

11.As appropriate to the scenario, 

coordinate deployment of fire and 

medical response resources between 

the ICP, on-site ERO facilities, and 

Security.

• Decision-making and coordination 

support timely deployment of 

firefighting and medical responders to 

appropriate site and plant areas.

[Consider limited deployment of actual 

resources to support this 

demonstration.]

12.Demonstrate the ability to account for 

on-site personnel in a post-attack 

environment.

• Discussion of strategies for conducting 

accountability of on-site personnel in a 

post-attack environment, including any
6

Recommended Objective Performance Attributes

associated movement (e.g., assembly 

and release).

• Accountability within ERO facilities, 

including team deployments, is 

maintained consistent with Security 

and law enforcement requirements.

13.Demonstrate the ability to perform an 

assessment of offsite radiological

consequences as appropriate to the 

scenario events.

• Perform offsite dose projections as 

appropriate to the scenario events. 

• Develop dose-based PARs as 

necessary.

• Consider the impact of a release on the 

ICP and first-responder staging areas.

14.Demonstrate the ability of the ERO to 

coordinate the development and 

release of public information in a postattack environment.

• Integrate public information officials 

from participating Federal, State and 

local law enforcement agencies, and 

first-responder agencies, into JIC 

operations. 

• Public information releases are vetted 

for sensitive and safeguards 

information prior to issuance.