Issue Date: 11/08/11 - 1 - 82002.03

ATTACHMENT 82002.03

REVIEW OF EXERCISE OBJECTIVES AND EXERCISE 

SCENARIO FOR POWER REACTORS

82002.03-01 INSPECTION OBJECTIVE

To verify, during plant construction (and prior to fuel load of the plant), the adequacy of 

the licensee’s Emergency Preparedness (EP) exercise objectives and scenario for 

power reactors; and to ensure the licensee’s ability to transition to monitoring under the 

reactor oversight process.

82002.03-02 INSPECTION REQUIREMENTS

02.01 Evaluate if the licensee provided the Nuclear Regulatory Commission (NRC) 

and the Federal Emergency Management Agency (FEMA) with its proposed exercise 

scenario and objectives, with sufficient time before the exercise, to permit an 

appropriate NRC review. 

02.02 Determine whether the licensee's proposed exercise scenario will enable 

exercise play to address the previously submitted exercise objectives.

02.03 Determine whether the licensee'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, including hostile action scenario 

content.

02.04 Determine whether the licensee's proposed objectives for the exercise meet 

emergency preparedness requirements and provide reasonable acceptance criteria. 

(The requirements may include providing a scenario that drives offsite exercise play for 

evaluation of offsite response organizations, which will be conducted by the Federal 

Emergency Management Agency (FEMA).)

82002.03-03 INSPECTION GUIDANCE

General Guidance

Technical evaluations of the scenario shall be performed by the NRC inspectors. 

However, responsibility for exercise control is to be maintained by the licensee. 

Evaluations conducted in accordance with this procedure are limited to the onsite staff,

activities, records, and facilities of the licensee. Where necessary to verify licensee

performance concerning interactions with organizations and persons involved in offsite 

emergency preparedness, inspection activities are to be limited to reviews of pertinent 

records available through the licensee. If additional information is needed about offsite 

emergency preparedness, it can be obtained from FEMA. 
Issue Date: 11/08/11 - 2 - 82002.03

This attachment should be used in conjunction with the performance of Inspection 

Procedure 82002, “Part 52, Emergency Preparedness Program, Attachment 82002.04, 

“Emergency Preparedness Exercises,” and Inspection Procedure 65001, “Inspections of 

Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Related Work, 

”Attachment 65001.18, “Inspection of Emergency Preparedness ITAAC,” section, 02.14, 

“Exercises and Drills.” 

The scenario is to be evaluated primarily on relative credibility and timing of events. 

The inspector shall 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 the licensee’s controllers. The 

inspector shall utilize insights from accident sequences evaluated as part of the sitespecific probabilistic risk analysis (PRA) to develop a realistic scenario that may include 

likely equipment failures, human errors, recovery actions, and accident sequence 

progression. Scenario-related problems and poorly controlled exercises shall be 

evaluated during the exercise. The NRC inspection of the scenario is to be against the 

requirements of 50.47(b)(14) and Section IV.F. of Appendix E to 10 CFR 50. Results of 

these NRC inspections are to be documented in the inspection reports for those 

inspections completed under Attachment 82002-04, “Emergency Preparedness

Exercises” and Attachment 65001.18, “Inspection of Emergency Preparedness ITAAC,” 

section, 02.14, “Exercises and Drills.” 

Specific Guidance

03.01 Exhibit 1 provides the schedule recommended for the development, submission, 

and review of the licensee exercise scenario. This schedule is in accordance with the 

guidance in Interim Radiological Emergency Preparedness (REP) Program Manual, 

dated August 2002 (see Table 3, “Milestones for REP Exercise Process”). 

03.02 Major onsite elements of licensee exercises are to be included in the objectives. 

These elements normally include aspects of the Emergency Plan to be exercised and 

may include other areas, such as the use of a new set of procedures that licensees wish 

to evaluate for their own information.

a. Elements to be considered in exercises are listed in NUREG-0654, Part II.

b. The inspector is to review the licensee’s Emergency Plan and related 

documentation to confirm adherence with the guidance of NUREG-0654. 

Licensees may be credited for exercising individual elements during any drill or 

exercise. Regulatory Guide 1.101, Revision 4, allows the licensee to develop 

methods and solutions different from those described in NUREG-0654. In the 

event that the licensee has not formally committed to NUREG-0654, they will 

need to show an alternate approach, which will need to be approved by the 

NRC. 

c. The level of specificity of the objectives shall provide measurable and/or 

observable criteria for evaluators. The objectives will 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 qualifying/prior to fuel loading exercise, the NRC team leader will contact 

FEMA to confirm that offsite objectives are consistent with exercise frequency 

requirements, testing communication interfaces between onsite and offsite 

facilities, and testing of the public notification systems.
Issue Date: 11/08/11 - 3 - 82002.03

03.03 Review exercise objectives and scenario. 

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 must be commensurate with the type and scope of exercise 

proposed. Timely NRC/FEMA evaluation of exercise objectives is necessary to 

provide enough time for the licensee to change or revise objectives in advance 

of the exercise, where necessary, without hardship.

b. Exercise Scenario. This scenario should determine whether the licensee’s 

emergency response personnel are familiar with their emergency response 

duties (See 10 CFR 50, Appendix E, Part IV.F.) and to provide for (1) a test of 

the licensee’s integrated capabilities for timely response to a radiological 

accident, (2) a test of the content of selected implementing procedures and 

methods, (3) a test of emergency equipment, and (4) a test of communications 

networks. The objectives and scenario are to provide meaningful training for the 

emergency response organization, including hostile action-based scenario 

content.

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. Consider

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 allowed for the plume to traverse 

the emergency planning zone (EPZ) before the location, centerline, and magnitude are 

determined). 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).

82002.03-04 INSPECTION RESOURCES

The estimated time to complete this inspection procedure is 12 hours. 

82002.03-05 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 4, July 2003.

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).
Issue Date: 11/08/11 - 4 - 82002.03

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 RequirementsRequirements for Emergency Response Capability," January 1983 (Microfiche Address: 

17301/342-363).

Interim Radiological Emergency Preparedness (REP) Program Manual, dated August 

2002 (see Table 3, “Milestones for REP Exercise Process). 

END

Exhibits: 

1. Recommended Schedule for Development, Submission, and Review of Exercise 

Scenario

2. Revision History for IP 82002.03
Issue Date: 11/08/11 E1-1 82002.03

Exhibit 1

Recommended Schedule for Development,

Submission, and Review of Exercise Scenario

Goals 

(number of days

before an exercise) Activities

150 days The NRC regional office informs the licensee of its intent, to 

participate, requests cooperation, and provides agency 

exercise evaluation criteria (objectives) to the licensee. 

90 days The licensee submits exercise evaluation areas (objectives)

to NRC and FEMA.

80 days NRC discusses evaluation of objectives with the licensee 

and negotiates the submittal of revised objectives if major 

revision is required and coordinates with FEMA if offsite 

responses are affected.

75 days Complete NRC and FEMA review of evaluation areas 

(objectives). The NRC regional office transmits a letter of 

confirmation to the licensee documenting the discussion of 

the review of exercise objectives.

60 days The licensee submits the exercise scenario and associated 

materials to the NRC and FEMA for review. Where 

applicable, NRC objectives are to be included.

60 to NRC and FEMA review the scenario for consistency with

45 days objectives, credibility, and sequencing of events.

45 days NRC and FEMA review of exercise scenario completed. The 

NRC regional office informs the licensee of the results of its

scenario review, along with the results of the FEMA scenario 

review if offsite responses are affected.

END
Issue Date: 11/08/11 E2-1 82002.03

Exhibit 2

Revision History for IP 82002.03

Commitment 

Tracking Number

Issue Date Description of 

Change

Training Needed Training 

Completion Date

Comment 

Resolution 

Accession 

Number

N/A 11/08/2011

CN 11-030

ML111040292

Initial issue to 

support 

inspections of 

construction 

programs 

described in IMC 

2504, 

Construction 

Inspection 

Program: 

Inspection of 

Construction and 

Operational 

Programs.

Completed 4 year 

search of historical 

CNs and found no 

commitments 

related to this 

Inspection 

Procedure.

None N/A N/A