Issue Date: 07/21/16 1 71114.08

NRC INSPECTION MANUAL NSIR/DPR

INSPECTION PROCEDURE 71114 ATTACHMENT 08

EXERCISE EVALUATION – SCENARIO REVIEW

Effective Date: 10/01/2016

PROGRAM APPLICABILITY: 2515 A

71114.08-01 INSPECTION OBJECTIVE

Review licensee submitted biennial exercise scenarios to ensure the exercise demonstration 

provides opportunities to demonstrate the licensee’s capability to adequately perform key skills 

in principal functional areas to protect public health and safety in the unlikely event of a 

radiological emergency.

71114.08-02 INSPECTION REQUIREMENTS

Note: Licensees may structure exercise scenario packages differently and this should be 

found acceptable, provided that the exercise, as conducted, will meet requirements of 10 CFR 

Part 50, Appendix E, § IV.F.2, and the facility emergency plan. 

02.01 Verify the submitted scenario package includes: exercise objectives that support 

demonstration of key skills in principle functional areas, a timeline of exercise events, a 

description of imbedded drills, a description of key injects and messages, the expected 

emergency response organization (ERO) and offsite response organization (ORO) participation,

and plant and player safety considerations.

02.02 Verify the scenario has required minimum exercise elements and identification of 

performance opportunities.

02.03 Evaluate the ability of the scenario to provide opportunities for the ERO to demonstrate 

proficiency in key skills necessary to implement the principle functional areas of emergency 

response, including those skills specific to emergency response duties in the control room, 

technical support center (TSC), operational support center (OSC), emergency operations facility

(EOF), and joint information center (JIC)/joint information system (JIS).

02.04 Submit and review scenario comments with Federal Emergency Management Agency 

(FEMA) representative to ensure that scenario comments are consistent. Provide any exercise 

comments, questions or concerns to the licensee no later than 30 days prior to the scheduled 

exercise date.
Issue Date: 07/21/16 2 71114.08

71114.08-03 INSPECTION GUIDANCE

Note: The following items are coordinated with Exhibit 1 as a tool for the inspector to perform 

their review.

03.01 Verify scenario submittal is complete.

a. Completeness may be indicated by including exercise objectives that support 

demonstration of key skills in principle functional areas, a timeline of exercise events, a 

description of imbedded drills, a description of key injects and messages, the expected 

ERO and ORO participation, and plant and player safety considerations.

Note: Scenarios are submitted per 10 CFR § 50.4. The document is entered into the 

Agencywide Documents Access and Management System (ADAMS) by the Document Control 

Desk as not publicly available. Confidentiality of the scenario shall be maintained and a 

Sensitive Unclassified Non-Safeguards Information (SUNSI) review (for purposes of making the 

document public) shall not be performed until after completion of the exercise. The SUNSI 

review is performed by a Subject Matter Expert (e.g., a member of the U.S. Nuclear Regulatory 

Commission (NRC) Emergency Preparedness (EP) staff or the Project Manager for the specific 

site). Licensees may include a cover page with wording similar to the following: “This 

document’s availability should be controlled as non-public to ensure confidentiality from exercise 

responders until the conduct of the exercise is concluded.” After completion of the exercise and 

following a SUNSI review, the cover page may be removed or redacted, the file version updated 

in ADAMS and the document may be made publicly available, as determined by the SUNSI 

review. If a Freedom of Information Act request is submitted prior to the exercise date, notify 

NRC HQ and refer to ML12158A329 for disposition of the public release of the scenario.

03.02 Review the scenario submittal for the following:

a. The minimum expected exercise elements are included in the scenario. 

Element Description Reference in guidance documents 

1 Accident detection and assessment NUREG-0654: I.1, I.2 

2 Emergency classification NUREG-0654: D.1, D.2 

3

Notification of onsite and offsite 

emergency responders NUREG-0654: E.1, E.2, E.3, J.1 

4 Communications NUREG-0654: F.1, F.2, E.2, E.4, H.6

NUREG-0737, Supp 1: 8.1, 8.2, 8.3, 8.4 

5 Radiological exposure control NUREG-0654: K.1, K.2, K.3, K.5, K.6, J.3, 

J.6 

6 Protective action recommendations NUREG-0654: J.7 

7 Staff augmentation NUREG-0654: A.1, A.3, A.4, B.7, B.8, B.9 

8 Shift staffing NUREG-0654: B.1, B.2, B.3, B.5, Table 2 

b. The scenario is sufficiently varied from those used in the last two years of biennial 

exercises, off-year exercise(s), integrated response facility drills etc. 

c. ERO pre-conditioning is avoided to minimize anticipatory responses.
Issue Date: 07/21/16 3 71114.08

d. To the extent possible, scenario and exercise play requires the ERO “earn” event 

information.

e. Clearly identified Drill/Exercise Performance Indicator (DEP PI) opportunities.

Note: Technical evaluations of the scenario data and exercise control are the responsibility of 

the licensee. Review and verification of technical details such as, engineering operational 

parameters, engineering logic, source term, radiological instrumentation data, plant parameter 

units and data/injects provided by controllers is the responsibility of the licensee. Problems with 

the licensee’s review and verification may be revealed during the exercise or its critique and will 

be handled by IP71114.01 or IP71114.07, respectively. The inspector should only evaluate the 

scenario for its relative credibility and timing of events. 

03.03 Evaluate scenario opportunities for the ERO to demonstrate key skills by ensuring:

a. Opportunities for the ERO to perform their key skills as applicable to their emergency 

response duties in the TSC, OSC, EOF, and JIC/JIS are provided. 

b. Scenario data and progression of events are credible, logical, and challenging. The 

demands of the onsite and offsite exercise objectives will likely preclude complete 

fidelity between the scenario and the actual ERO response. The inspector will need to 

use judgment, based on experience, in performing this review. Examples of items to 

consider include: 

1. Exercise play should be consistent with all simulated events or conditions.

2. If the core is simulated as being melted, the corresponding in-plant radiation 

levels should increase comparably. 

3. If a loss of AC power source is simulated, equipment and instrumentation that 

relies on that source should not be considered operable.

4. A release should not be simulated as being stopped until the cause of the 

release has been corrected or mitigated.

5. Simulated releases should not begin before the failures that cause the release to 

occur.

6. Simulated field monitoring data should be consistent with simulated wind 

directions and plume transit times (e.g., the dose rate increases after the plume 

reaches that point).

7. The timing of scenario events should be comparable with the time it would take 

the ERO to perform particular tasks under actual emergency conditions (e.g., 

time spent obtaining a radiation work permit, getting a work briefing, donning 

personal protective equipment, obtaining tools and parts, etc.).

c. In addition to the above, hostile action based (HAB) scenarios should be reviewed for 

the following considerations:
Issue Date: 07/21/16 4 71114.08

Note: 10 CFR Part 50 does not specify a frequency for the conduct of the hostile action 

exercise during the eight year exercise cycle. It is the expectation of the NRC that licensees not 

plan a hostile action exercise at the beginning of an exercise cycle and wait to the end of the 

next exercise cycle to conduct their next hostile action exercise.

1. Two consecutive HAB exercises should not be “no or minimal radiological 

release” scenarios. 

2. Mitigative measures should commence after the simulated active attack has 

ceased but before local law enforcement agencies (LLEA) have swept the site for 

safe entry or declared the site secure. Securing the site may take days, and it is 

important that licensees train personnel to respond in the aftermath of hostile 

action events. Licensees shall demonstrate planning for and prioritization of 

mitigative action teams and protection of team personnel in efforts to prevent or 

ameliorate core damage or containment failure. 

3. The planning necessary to conduct a HAB exercise will challenge expectations 

for scenario confidentiality. For example, a drill or practice exercise involving a 

hostile action scenario may be conducted prior to the biennial exercise. In 

addition, prior reviews and approvals by various site personnel and OROs may 

be needed to involve offsite responders and other resources normally associated 

with hostile action response. Although some ERO members may infer that a 

hostile action scenario will be used in the biennial exercise, participants should 

not have knowledge of scenario details (e.g., specific events, timelines, or related 

information). Scenarios used for hostile action exercises must be sufficiently 

different from those used in drills/exercises during the previous 2 years. 

Specifically, the elements and consequences of the hostile action must be varied 

(e.g., attack type or direction, number of attackers, attack timeline, damage, 

casualties and offsite consequences). Provided that the above requirements are 

met, it is acceptable for the same ERO members to participate in hostile action 

drills or practice exercises and the subsequent biennial exercise.

4. Verify scenario exercise objectives include HAB elements. Refer to NEI 06-04, 

“Conducting a Hostile Action-based Emergency Response Drill” Rev. 2, 

Appendix A, “Drill and Exercise Objectives” for acceptable exercise objectives.

d. Review the scenario against the licensee’s records/schedule for scenario elements 

performed and required to be demonstrated during the exercise cycle.

Element Description Reference in guidance documents 

1 Hostile Action Based ISG: N.1.b.i.

2 An initial classification of, or rapid 

escalation to, a Site Area Emergency or 

General Emergency

ISG: N.1.b.ii

3 No radiological release or an unplanned 

minimal radiological release that requires 

the site to declare a Site Area 

Emergency, but does not require 

declaration of a General Emergency

ISG: N.1.b.iii
Issue Date: 07/21/16 5 71114.08

4 Off-hours staffing (6 p.m. to 4 a.m.) ISG: N.1.c

5 Activation of emergency news center 

(Joint Information Center)

NUREG-0654: G.3, G.4

6 Use of fire control teams NUREG-0654: N.2.b, 0.4.d

7 Use of first aid and/or rescue teams NUREG-0654: K.1, K.2, K.3, K.4, K.5, 

L.2, O.4.f

8 Use of medical support personnel NUREG-0654: N.2.c, L.1, L.4, O.4.h

9 Use of licensee's headquarters support 

personnel

NUREG-0654: O.4.i

10 Use of security personnel to provide 

prompt access for emergency equipment 

and support

NUREG-0654: O.4.d

11 Use of backup communications NUREG-0654: F.1

12 Rumor control NUREG-0654: G.4.c

13 Use of emergency power (where a part of 

plant safety systems, e.g. TSC) 

NUREG-0737, Supp. 1: 8.2.1

14 Evacuation of Emergency Response 

Facilities (ERFs) and relocation to backup 

ERFs, where applicable

NUREG-0654: J.10.g

15 Ingestion pathway exercise, when 

necessary to support state exercise 

requirements

NUREG-0654: J.9, J.11 

16 Field monitoring, including soil, 

vegetation, and water sampling

NUREG-0654: I.7, I.8, I.11, N.2.d

17 Capability for determining the magnitude 

and impact of the particular components 

of a release

NUREG-0654: I.3, I.4, I.6, I.8, I.9, I.10

18 Capability for post-accident coolant 

sampling and analysis. 

NUREG-0654: I.2

03.04 Submit scenario comments.

a. Comments about the scenario should have a regulatory basis. Comments, questions, or 

concerns should be provided to the licensee no later than 30 days prior to the scheduled 

exercise date.

b. Schedule a call at least 30 days prior to the exercise with licensee EP Supervision and 

any other licensee participants (licensee discretion).

c. Notify the licensee of the completion of the scenario review and identify any issues or 

concerns.

d. If there is any disagreement, that cannot be settled, from the licensee on issues 

identified that would impact the ability to successfully meet the performance objectives, 

engage regional management and recommend the issues noted from the scenario 

review be provided to the licensee in a letter from the Region.
Issue Date: 07/21/16 6 71114.08

e. Contact the Regional State Liaison Officer to submit and review any scenario comments 

to the Regional Assistance Committee Chair.

71114.08-04 RESOURCE ESTIMATE

The estimated time to complete this inspection procedure is 12-16 hours. The time expended for 

this review is to be reported as direct inspection time.

71114.08-05 PROCEDURE COMPLETION

This procedure is considered complete when all the inspection requirements listed in the 

procedure have been satisfied. Routine reviews of problem identification and resolution 

activities performed in this attachment should equate to approximately 10 to 15 percent of the 

resource estimate range described above. For the purpose of reporting completion in the 

Reactor Program System (RPS), the sample size is defined as one (1). The inspector shall 

ensure that a sample size of one (1) is reported in the RPS, Item Reporting, and completion 

noted in the RPS, Inspection Planning, when the procedure is completed in its entirety. 

However, reporting of sample sizes and inspection completion status shall reflect the same level 

of sensitivity (i.e., “Official Use Only - Security- Related Information”) as inspection planning and 

documentation issues and shall not appear in any publicly available document.

71114.08-06 REFERENCES 

NSIR-DPR-ISG-01, “Emergency Planning For Nuclear Power Plants” 

Order EA-02-026, “Order for Interim Safeguards and Security Compensatory Measures,” 

February 25, 2002 

SECY-03-0165, “Evaluation of Nuclear Power Reactor Emergency Preparedness Planning 

Basis Adequacy in the Post-9/11 Threat Environment,” September 22, 2003 

RG 1.214, “Response Strategies for Potential Aircraft Threats,” September 2009 

NEI 06-04, “Conducting a Hostile Action-based Emergency Response Drill” Rev. 2, Appendix A, 

“Drill and Exercise Objectives” (ML112091915)

END

Exhibit:

Scenario Review Checklist

Attachment:

Revision History for IP 71114.08
Issue Date: 07/21/16 E1-1 71114.08

Exhibit 1 – Scenario Review Checklist 

Exercise Location:

Planned Exercise Date: 30 days before: 60 days before:

Scenario Submittal Checklist Action Notes

03.01 Verify the scenario submittal is complete by including:

a. Exercise objectives that support demonstration of key skills in principle functional 

areas

b. A timeline of exercise events

c. A description of any imbedded drills

d. A description of key injects and messages 

e. The expected ERO and ORO participation

f. Plant and player safety considerations

03.02 Review the scenario for the following:

a. Verify scenario contains minimum expected elements:

1. Event classification. 

2. Timely notification of offsite authorities.

3. PAR development (development of PARs involving public evacuation or 

sheltering is required only in exercises that include a General Emergency).

4. Radiological assessment.

5. Shift staff response to accident transients or other events that meet EAL 

criteria while implementing the emergency plan.

6. ERO response and ERF activation following declared emergencies

7. Integration of licensee response with OROs to include briefings, 

coordination of worker protection, and, as appropriate to the scenario, 

coordination of public protective actions radiological release monitoring, 

and offsite response to the site.

8. Communications between onsite and offsite ERFs

9. Dissemination of information to the public via media channels and press 

briefings.
Issue Date: 07/21/16 E1-2 71114.08

10. Development and implementation of radiological or physical protection 

(i.e., in response to HAB) protective actions for onsite workers as 

appropriate to the scenario.

11. Operational and engineering assessment of accident sequences.

12. Accident mitigation by simulated equipment repair. This must include 

mechanical, electrical, and/or instrumentation and control activities. The 

scenario should allow some repairs to be successful, but must provide the 

opportunities to demonstrate mitigation planning, repair execution and 

radiological control support of repair teams.

b. The scenario is sufficiently varied from the last biennial exercise, and any offyear exercise(s), integrated response facility drill, etc. used in the last 2 years by 

ensuring that:

1. No more than one EAL is common to the previous exercise or any practice 

drills/exercises conducted in preparation for this exercise.

2. Failure mechanisms used for reaching initiating conditions and the failed 

equipment is varied to the extent practical. 

3. The exercise scenario has not been used as a drill within the last 2 years, 

or used for a practice drill for the present biennial exercise.

c. That ERO pre-conditioning is avoided by ensuring scenario timeline and or initial 

conditions do not provide obvious clues of impending equipment or system 

failures.

d. To the extent possible, scenario and exercise play requires the ERO “earn” event

information.

e. DEP PI opportunities are clearly identified.
Issue Date: 

07/21/16 E1-3 71114.08

03.03 Evaluate the ability of the scenario to provide opportunities for the ERO to 

demonstrate proficiency in key skills by ensuring:

a. Opportunities provided during drill and or exercise to develop and maintain key 

emergency response skills as follows:

1. Demonstration of all functions in each ERF (e.g., all ERFs that are 

responsible for dose assessment perform those duties in response to a 

radiological release).

2. The use of alternative facilities to stage the ERO for rapid activation during 

a hostile action.

3. Real-time staffing of facilities during off-hours (i.e., 6:00 p.m. to 4:00 a.m.).

4. Provide medical care for injured, contaminated personnel (every two 

years).

5. Response to essentially 100% of EAL initiating conditions.

6. Response to actual industry event sequences appropriate for the nuclear 

plant technology (e.g., BWR or PWR).

7. All licensee ERO teams must be provided the opportunity to demonstrate 

key skills within the scope of their duties.

8. Use of procedures developed in response to an aircraft threat and in 

compliance with 10 CFR 50.54(hh)(1).

9. Use of the strategies associated with 10 CFR 50.54(hh)(2) to mitigate 

spent fuel pool damage scenarios (all strategies, such as makeup, spray, 

and leakage control, but not every variation of a given strategy).

10. Use of the strategies associated with 10 CFR 50.54(hh)(2) to mitigate 

reactor accidents and maintain containment (10 strategies for boiling water 

reactors and 7 strategies for pressurized water reactors, but not every 

variation of a given strategy).

b. Scenario data and progression of events are credible, logical and challenges the 

ERO to demonstrate their proficiency, particularly in accident assessment. 

c. In addition to the above, hostile action based (HAB) scenarios should be 

reviewed for the following considerations:

1. HAB scenarios should vary the radiological release from exercise to 

exercise. 
Issue Date: 

07/21/16 E1-4 71114.08

2. Mitigative measures should commence after the simulated active attack 

has ceased but before Local Law Enforcement Agencies (LLEA) have 

swept the site for safe entry or declared the site secure.

3. The planning necessary to conduct a HAB exercise will challenge 

expectations for scenario confidentiality. Scenarios used for hostile action 

biennial exercises must be sufficiently different from those used in 

drills/exercises during the previous 2 years. Specifically, the elements and 

consequences of the hostile action must be varied (e.g., attack type or 

direction, number of attackers, attack timeline, damage, casualties, offsite 

consequences, etc.). Provided that the above requirements are met, it is 

acceptable for the same ERO members to participate in hostile action 

drills or practice exercises and the subsequent biennial exercise.

4. Review HAB Scenario objectives for completeness. Refer to NEI 06-04, 

“Conducting a Hostile Action-based Emergency Response Drill” Rev. 2, 

Appendix A, “Drill and Exercise Objectives”

d. Review records/schedule required for the eight year exercise scenario cycle to 

include: 

1. Response to hostile action, including interface with LLEAs. 

2. Engineering assessment, repair plan development, and physical repair of 

critical equipment damaged by hostile action after the active attack, but 

before the site is secured by LLEAs. 

3. Response to one scenario with no radiological release or an unplanned 

minimal radiological release that does not require evacuation or sheltering 

of the public.

4. Response to a scenario with radiological releases that require evacuation 

and/or sheltering of the public.

5. Response to a scenario that begins with a Site Area Emergency or 

General Emergency, or escalates rapidly (within 30 minutes) to an SAE or 

GE.

6. Successful simulated repair of simulated damaged equipment to prevent 

or mitigate core damage, reactor vessel loss, and/or containment loss. 
Issue Date: 07/21/16 E1-5 71114.08

7. Demonstration of the ability to mitigate an accident through the simulated 

use of equipment, procedures, and strategies developed in compliance 

with 10 CFR 50.54(hh)(2).

8. Demonstration of each of the licensee’s site specific reactor technology or 

vintage at least once during the exercise cycle.

03.04 Submit and review exercise scenario comments with FEMA. Provide any 

exercise comments, questions or concerns to the licensee no later than 30 days prior to 

the scheduled exercise date.
Issue Date: 07/21/16 Att1-1 71114.08

Attachment 1 - Revision History for - IP 71114.08

Commitment 

Tracking 

Number

Accession 

Number

Issue Date 

Change Notice

Description of Change

Description of 

Training Required 

and Completion Date

Comment and 

Feedback Resolution 

Accession Number 

(Pre-Decisional, NonPublic Information)

N/A ML12191A249

09/19/12

CN 12-021

Initial Issuance. Yes - Provided at EP 

Face to Face 

counter-part meeting 

09/09/2011 & 

05/31/2012

ML12191A255

ML15237A301

07/21/16

CN 16-017

Removed “to the RAC Chair” from the title of 

step 03.04 to “Submit scenario comments to 

the RAC Chair” and added detail describing 

scenario comment documentation 

expectations.

Feedback Form 71114-1925 – Align 

procedure with standard section numbering 

format of completion section under 

71114.08-05 and the references under 

71114.08-06 

Added to section 71114.08-05 “Procedure 

Completion” the IP 71152 “Problem 

Identification and Resolution” expectation for 

routine PI&R activity reviews to be 

approximately 10 to 15 percent of the 

baseline cornerstone inspection procedure 

resources estimates. The 10 to 15 percent 

approximation is based on the overall 

expected inspection effort and is a general 

estimate only. 

None required Comment Resolution –

ML15237A344

Feedback Form –

71114.08-1925 

(ML15237A307)