HomeMy WebLinkAbout851169.tiff SSINS No. : 6835
UL65-53
C9~!fTY C!P!991cr!PNERS
UNITED STATES 0 C E I V a
NUCLEAR REGULATORY COMMISSION
il
OFFICE OF INSPECTION AND ENFORCEMENT JUC2219�
WASHINGTON, D. C. 20555
July 12, 1985 Gd4EELEL COLA.
IE INFORMATION NOTICE NO. 85-53: PERFORMANCE OF NRC-LICENSED INDIVIDUALS
WHILE ON DUTY
Addressees:
All nuclear power reactor facilities holding an operating license (OL) or a
construction permit (CP) .
Purpose:
In February 1981, the attached IE Circular 81-02 was issued. This Circular,
which was prompted by an NRC inspector's observation of two licensed reactor
operators who appeared to be asleep while on duty in the control room, provided
guidance on conditions and practices which the NRC believes to be necessary
for the maintenance of a professional atmosphere in the control room and through-
out the facility. The purpose of this information notice is to reaffirm the
general principles of control room operations which were provided over four
years ago. While some of the regulatory references cited in the Circular may
have been modified or updated since that time, the basic standards of control
room professionalism remain valid as critical elements for continued safe
reactor operations.
Description of Circumstances:
Continuing observation of control room operation by NRC inspectors indicates
that, in general , the high standards of control room professionalism described
in IE Circular 81-02 are being met at most facilities. Nevertheless, recent
NRC observations at some operating facilities indicate the need for further
management attention to one of the areas described in the Circular:
"Potentially distracting activities in the control room and other
watch stations must be prohibited (for example: radios, TV,
alcohol use or drug abuse, games, horseplay, hobbies, and
reading that is not directly job related)."
In some facility control rooms, NRC inspectors have observed that the playing
of music and operator occupation with reading material that is not job related
continues to be condoned by management. Many utilities have established and
are enforcing a policy which prohibits such activities by on-shift personnel .
Such activities can potentially distract the on-shift personnel from the
performance of their duties and from the monitoring of plant operations and
8507110094 851169
194/RS
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IN 85-53
July 12, 1985
Page 2 of 2
status. It is expected that recipients will review the information in this
notice and the attached Circular for applicability to their facilities and
consider action, if appropriate, to ensure the highest standards of control
room operations.
No specific action or written response is required by this information notice.
If there are any questions regarding this matter, please contact the Regional
Administrator of the appropriate NRC regional office or this office.
es M. Tay , Director
five of In pection and Enforcement
Technical Contact: J. G. Partlow, IE
301-492-4614
Attachments:
1. IE Circular 81-02
2. List of Recently Issued IE Information Notices
Attachment 1
IN 85-53
July 12, 1985 SSINS No. : 6830
Page 1 of 4 Accession No. :
8008220282
IEC 81-02
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
February 9, 1981
IE Circular No. 81-02: PERFORMANCE OF NRC-LICENSED INDIVIDUALS WHILE ON
DUTY
Description of Circumstances:
Recently, an NRC inspector observed two licensed reactor operators who
appeared to be asleep while on duty in the control room. A subsequent NRC
investigation into the matter concluded that the operators were not fully
attentive to their licensed duties of monitoring reactor conditions, which
is a serious matter of safety significance. Furthermore, the investigation
concluded that management controls were inadequate to assure the alertness
of licensed operators while on duty. Enforcement action was taken after
it was determined that attentive operators were not present at the controls
as required by 10 CFR 50. 54(k).
Discussion:
NRC believes that a relationship exists between the professional attitude of
a nuclear plant' s operating and management personnel and the degree to which
the health and safety of the public is protected. NRC believes that
professional attitude is reflected in high standards of performance including
pride in the facility as demonstrated by the nuclear power plant staff.
Factors making up this professional attitude include knowledge of all aspects
of plant status by licensed control room operators, maintaining an orderly and
clean working environment, aggressiveness of the operating staff to prevent
operational problems, and correcting observed deficiencies. NRC believes that
clarification of its position on this subject is necessary because several
recent events involving licensed operators indicate a lack of a professional
attitude at some nuclear power plants.
The following conditions and practices are among those the NRC believes to
be necessary for the maintenance of a professional atmosphere in the
control room and throughout the facility.
1. All on-duty NRC-licensed operators and operating supervisors must be
aware of and responsible for the plant status at all times. This
includes supervisors being responsible for the performance of all
personnel assigned to their shift who could affect plant safety,
regardless of specialty affiliation. Knowledge of the plant' s
status must be assured during shift changes by a formal watch
turnover and relief.
Attachment:
Recently issued IE circulars
r
Attachment 1 IEC 81-02
IN 85-53 February 9, 1981
July 12, 1985 Page 2 of 3
Page 2 of 4
2. All on-duty NRC-licensed operators must be alert, remain within their
immediate areas of responsibility until properly relieved, and be
particularly attentive to the instrumentation and controls located
within these areas at all times.
3. Potentially distracting activities in the control room and other watch
stations must be prohibited (for example: radios, TV, alcohol use or
drug abuse, games, horseplay, hobbies, and reading that is not directly
job related).
4. Control room access must be limited to those persons on official
business only and loitering in this area must be prohibited.
5. All necessary plant-related technical/administrative control room
business must be conducted at a location and in such a manner that
neither licensed control room operator attentiveness nor the professional
atmosphere will be compromised. This includes activities associated with
the use of special eating and training facilities for on-shift personnel .
Additional Information:
NRC inspectors will be particularly mindful of those conditions and practices
described above during future inspections of licensed nuclear facilities.
For more specific information, you are referred to the following NRC documents:
1. 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities ,"
Paragraph 50. 54
2. 10 CFR 55, "Operators' Licenses ," Paragraph 55.31 and 55.40
3. Regulatory Guide 1. 114, "Guidance on Being Operator at the Controls
of a Nuclear Power Plant"
4. IE Information Notice 79-20, Revision 1, "NRC Enforcement Policy -
NRC-Licensed Individuals"
5. Letter from D. G. Eisenhut, NRC, to All Licensees and Applicants,
dated July 31, 1980, Subject: Interim Criteria for Shift Staffing
The following excerpts are taken from some of these documents and are
provided for your information:
1. Only licensed operators are permitted to manipulate the controls
that directly affect the reactivity or power level of a reactor
[10 CFR 50. 54(i)].
2. Licensed operators are required to be present at the controls at all
times during the operation of the facility [10 CFR 50. 54(k)].
3. Operation of mechanisms and apparatus other than controls that may
indirectly affect the power level or reactivity of a reactor shall
only be accomplished with the knowledge and consent of an operator
licensed in accordance with Part 55 [10 CFR 50. 54(j)].
Attachment 1 IEC 81-02
IN 85-53 February 9, 1981
July 12, 1985 Page 3 of 3
Page 3 of 4
4. The NRC-licensed individual shall observe all applicable rules,
regulations and orders of the Commission, whether or not stated
in the license [10 CFR 55.31(d)].
5. The operating test, to the extent applicable to the facility,
requires the applicant to demonstrate an understanding of:
Thg necessity for a careful approach to the responsibility
associated with the safe operation of the facility
[10 CFR 55.23(1)].
6. In order for the operator at the controls of a nuclear power plant
to be able to carry out these and other responsibilities in a timely
fashion, he must give his attention to the condition of the plant
at all times. He must be alert to ensure that the plant is operating
safely and must be capable of taking action to prevent any progress
toward a condition that might be unsafe (Regulatory Guide 1.114.6).
NRC policy regarding responsibility for safe operation of NRC-licensed
facilities as stated in IE Information Notice 79-20, Revision 1, continues
to be as follows:
1. "The facility licensee is responsible for assuring that the facility
is operated safely and within the requirements of the license,
technical specifications, rules, regulations, and Orders of the NRC,
and for the actions of their on-duty employees while on site. "
2. "NRC-licensed individuals are responsible for taking timely and proper
actions that will not create or cause a hazard to ' safe operation of
the facility' (i . e. , actions or activities, including failure to take
action, related to the facility that could have an adverse effect on
the health and safety of the public, plant workers, or the individuals). "
Recommended Action for Licensee' s Consideration:
Each power reactor licensee should review and revise, as necessary, their
administrative controls regarding operator performance to ensure the guidance
contained or referenced herein is incorporated. These administrative controls
should prescribe performance requirements for licensed personnel and specify
types of activities that are prohibited while licensed personnel are on duty.
These administrative controls should be considered for applicability to other
plant personnel whose actions , while on duty, may affect plant safety or the
orderly conduct of facility operation. Licensees should assure dissemination
of these administrative requirements to affected personnel .* It is also
requested that licensees have their licensed personnel review this Circular
and IE Information Notice 79-20, Revision 1, as well as Regulatory Guide 1. 114.
No written response to this Circular is required. If you require additional
information regarding this matter, contact the Director of the appropriate
NRC Regional Office.
*A copy of this Circular was mailed directly to each licensed reactor operator
and senior reactor operator.
Attachment 1 Attachment
IN 85-53 IEC 81-02
July 12, 1935 February 9, 1981
Page 4 of 4
RECENTLY ISSUED
IE CIRCULARS
Circular Date of
No. Subject Issue Issued to
81-01 Design Problems Involving 1/23/81 All power reactor
Indicating Pushbutton facilities with
Switches Manufactured by an OL or CP
Honeywell Incorporated
80-25 Case Histories of 12/5/80 All radiography
Radiography Events licensees
80-24 AECL Teletherapy Unit 12/2/80 All teletherapy
Malfunction licensees
80-23 Potential Defects in Beloit 10/31/80 All power reactor.
Power Systems Emergency facilities with
Generators OL or a CP
80-22 Confirmation of Employee 10/2/80 All holders of a
Qualifications power reactor OL or CP
architect-engineering
companies and nuclear
steam system suppliers
80-21 Regulation of Refueling 9/10/80 All holders of a
Crews power reactor OL or CP
80-20 Changes in Safe-Slab Tank 8/21/80 All Part 50 and Part
Dimensions 70 fuel facility
licensees
80-19 Noncompliance with 8/26/80 All medical licensees
License Requirements for
Medical Licensees
80-18 10 CFR 50. 59 Safety 8/22/80 All power reactor
Evaluations for Changes to facilities with an
Radioactive Waste Treatment OL or CP
Systems
80-17 Fuel Pin Damage Due to Water 7/23/80 All holders of PWR
Jet from Baffle Plate Corner OLs and PWR CPs
OL = Operating Licenses
CP = Construction Permit
Attachment 2
IN 85-53
July 12, 1985
LIST OF RECENTLY ISSUED
IE INFORMATION NOTICES
Information Date of
Notice No. Subject Issue Issued to
85-52 Errors In Dose Assessment 7/10/85 All power reactor
Computer Codes And Reporting facilities holding
Requirements Under 10 CFR an OL or CP
Part 21
85-51 Inadvertent Loss Or Improper 7/10/85 All power reactor
Actuation Of Safety-Related facilities holding
Equipment an OL or CP
85-50 Complete Loss Of Main And 7/8/85 All power reactor
Auxiliary Feedwater At A PWR facilities holding
Designed By Babcock & Wilcox an OL or CP
85-49 Relay Calibration Problem 7/1/85 All power reactor
facilities holding
an OL or CP
85-48 Respirator Users Notice: 6/19/85 All power reactor
Defective Self-Contained facilities holding
Breathing Apparatus Air an OL or CP, research,
Cylinders and test reactor,
fuel cycle and
Priority 1 material
licensees
85-47 Potential Effect Of Line- 6/18/85 All power reactor
Induced Vibration On Certain facilities holding
Target Rock Solenoid-Operated an OL or CP
Valves
85-46 Clarification Of Several 6/10/85 All power reactor
Aspects Of Removable Radio- facilities holding
active Surface Contamination an OL
Limits For Transport Packages
85-45 Potential Seismic Interaction 6/6/85 All power reactor
Involving The Movable In-Core facilities holding
Flux Mapping System Used In an OL or CP
Westinghouse Designed Plants
OL = Operating License
CP = Construction Permit
REG°,n� UNITED STATES
,f; : NUCLEAR REGULATORY COMMISSION
"v. IJ REGION IV
AIL/_
a 611 RYAN PLAZA DRIVE, SUITE 1000
s° ARLINGTON, TEXAS 76011
JUL `l 1385
In Reply Refer To:
Docket: 50-267/85-20
WELD CCUNTY "1 mioNmg11
Public Service Company of Colorado JUL 2 2
ATTN: O. R. Lee, Vice President 19E6
Electric Production
P. 0. Box 840 IGREE.LEY. COLO.
Denver, Colorado 80201
Gentlemen:
This refers to the technical review of the Fort St. Vrain emergency electrical
power system conducted by the Office of Nuclear Reactor Regulation which was
completed on July 5, 1985. The results of this review will be forwarded to
you as a Safety Evaluation in the near future.
During the course of this review, it was discovered that your emergency power
system was in deviation from an FSAR commitment. This deviation is described
in the enclosed Notice of Deviation.
You are requested to respond to the Notice within 30 days by providing a
written statement or explanation which describes the corrective steps taken or
planned, the results achieved and the date when corrective action will be
completed.
The response requested by this letter and the accompanying Notice is not
subject to the clearance procedures of the Office of Management and Budget as
required by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this matter, we will be pleased to
discuss them with you.
Sincerely,
E. H. Johnson, Chief
Reactor Project Branch
Enclosure:
Notice of Deviation
cc w/enclosure: (cont. on next page)
J 1/-71t/oc-
Public Service Company of Colorado -2-
Mr. D. W. Warembourg, Manager
Nuclear Engineering Division
Public Service Company of Colorado
P. 0. Box 840
Denver, Colorado 80201
Mr. David Alberstein, 14/159A
GA Technologies, Inc.
P. 0. Box 85608
San Diego, California 92138
Kelley, Stansfield & O'Donnell
Public Service Company Building
550 15th Street, Room 900
Denver, Colorado 80202
Chairman , Board of County Comm.
of Weld County, Colorado
Greeley, Colorado 80631
Regional Representative
Radiation Programs
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Mr. H. L. Brey, Manager
Nuclear Licensing/Fuels Div.
Public Service Company of Colorado
P. 0. Box 840
Denver, Colorado 80201
J. W. Gahm, Manager, Nuclear
Production Division
Fort St. Vrain Nuclear Station
16805 WCR 19§
Platteville, Colorado 80651
L. Singleton, Manager, Quality
Assurance Division
(same address)
Colorado Radiation Control Program Director
APPENDIX
NOTICE OF DEVIATION
Public Service Company of Colorado Docket: 50-267
Fort St. Vrain Nuclear Generating Station License: DPR-34
During a technical review of the Fort St. Vrain emergency electrical power
system completed on July 5, 1985, a deviation from a commitment was
identified. This deviation involved the failure of the emergency electrical
power supply to conform to the FSAR. In accordance with the "General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (1985) , the deviation is listed below:
A. Section 8.2.5.1 of the Fort St. Vrain Generating Station Final Safety
Analysis Report indicates that the AC and DC power systems are redundant
and independent and meet the single failure criteria.
In deviation from the above, a technical review conducted by the NRC
staff determined that the automatic closure of one emergency diesel
generator breaker is dependent on the operation of components associated
with the other emergency diesel generator.
In accordance with Appendix C to 10 CFR Part 2, Public Service of Colorado is
requested to provide within 30 days a written explanation or statement
describing corrective steps taken (or planned) , the results achieved, and the
date when corrective action will be completed.
Dated at Arlington, Texas,
this 11"4 day of .1a-11/4/ , 1985.
SSINS No. : 6835
IN 85-56
UNITED STATES
NUCLEAR REGULATORY COMMISSIONWEID COUNTY marmots
OFFICE OF INSPECTION AND ENFORC �• �� r1'♦L'1♦ r
WASHINGTON, D. C. 20555 ii I.l L i i1
July 15, 1985 JUC231985
GHcELEY. COLO.
IE INFORMATION NOTICE NO. 85-56: INADEQUATE ENVIRONMENT CONTROL FOR COMPONENTS
AND SYSTEMS IN EXTENDED STORAGE OR LAYUP •
Addressees:
All nuclear power reactor facilities holding an operating license (OL) or a
construction permit (CP).
Purpose:
This information notice is being provided to alert addressees to problems which
can occur if equipment is improperly stored or laid up during construction or
extended plant outages. Addressees also are reminded that programs for proper
storage and preservation of materials and components are required by NRC
regulations (10 CFR 50, Appendix B) , even though not specifically addressed as
license conditions. It is expected that recipients will review the information
for applicability to their facilities and consider actions, if appropriate, to
preclude a similar problem occurring at their facilities. However, suggestions
contained in this information notice do not constitute NRC requirements;
therefore, no specific action or written response is required.
Description of Circumstances:
Licensee event reports , 10 CFR 50. 55(e) reports , and NRC inspection reports
contain many instances where materials and components have been seriously
degraded due to improper storage, protection, or lay up, both at facilities
under construction and facilities with operating licenses. A number of repre-
sentative examples are described in the following paragraphs.
A recent NRC inspection at Nine Mile Point Unit 2 disclosed that the cooling
water heat exchanger for the high pressure core spray diesel generator had
water standing in the tube side of the unit. The heat exchanger had been
delivered to the site and had been"stored in place" in 1977, but was not yet
in service. The source of the water is unknown, but it has been hypothesized
that the heat exchanger had been inadequately drained after a manufacturer' s
hydro-test in 1976. The site construction organization had no program for
inspection or surveillance of equipment in storage. Significant corrosion
damage was observed on the copper alloy tubes and the carbon steel tube sheets
and water boxes.
8507110108
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IN 85-56
July 15, 1985
Page 2 of 3
Corrosion damage similar to that described above was found during an NRC
inspection at Hope Creek. In that instance, the two heat exchangers were
supplied for the engine cooling system for the plant emergency diesel genera-
tors. The heat exchangers had been received onsite sometime before, and stored
in place. They had not yet been placed in service.
In November 1984 the licensee for H. B. Robinson Unit 2 notified the NRC that,
while preparing for restart after a 10 month outage, numerous pinhole leaks had
been detected in the stainless steel service water piping. Further examination
of the piping disclosed other corrosion pits that had not penetrated through
the wall . Temporary repairs were accomplished by the use of about 800 welded
sleeves. The licensee has submitted plans for future complete replacement of
the affected pipe. The corrosion has been attributed to microbiological growth
in the stagnant water that was in the system during the extended outage.
Proper layup of the system could have precluded damage. IE Information Notice
85-30 provides additional information on this phenomenon.
At Palo Verde, the licensee reported in June 1984 that corrosion attack had
been found on internal surfaces of two Unit 2 auxiliary feedwater pumps. The
pumps had not been operated. In December 1984, the licensee reported that the
corrosion had been caused by contaminated water inadvertently left in the pumps
after prestartup flushing of the system.
Discussion:
The cases cited above are a small sample of the wide variety of instances where
improper storage or layup has resulted in significant damage and extended plant
outages. Many of the events are related to balance-of-plant equipment and are
not reportable to the NRC. They do, however, often cause extended outages.
The Robinson service water piping damage extended the plant outage for 4
months, and additional down time will be required in the future to install the
replacement pipe.
At Palo Verde, it required extensive work and 6 months time to finally resolve
that the pumps were still serviceable.
10 CFR 50. 34(a)(7) requires that each applicant for a construction permit shall
provide a description of the quality assurance program to be applied to the
construction of the facility in accordance with the requirements of 10 CFR 50,
Appendix B. 10 CFR 50. 34(b)(6)(ii ) requires a description of how the require-
ments of Appendix B will be satisfied during the operation of each nuclear
power facility. Among the requirements of Appendix B, Criterion XIII addresses
storage, cleaning, and preservation of materials and equipment.
IN 85-56
July 15, 1985
Page 3 of 3
No specific action or written response to this information notice is required.
If you need additional information about this matter, please contact the
Regional Administrator of the appropriate NRC regional office or this office.
-�Edwar L. Ardan, i rec or
Divisign of Emergency Preparedness
and ,E gineering Response
Office of Inspection and Enforcement
Technical Contact: J. B. Henderson, IE
492-9654
Attachment: List of Recently Issued IE Information Notices
Attachment 1
IN 85-56
July 15, 1985
LIST OF RECENTLY ISSUED
IE INFORMATION NOTICES
Information Date of
Notice No. Subject Issue Issued to
85-55 Revised Emergency Exercise 7/15/85 All power reactor
Frequency Rule facilities holding
an OL or CP
85-54 Teletheraphy Unit Malfunction 7/15/85 All NRC licensees
authorized to use
teletheraphy units
85-53 Performance Of NRC-Licensed 7/12/85 All power reactor
Individuals While On Duty facilities holding
an OL or CP
85-52 Errors In Dose Assessment 7/10/85 All power reactor
Computer Codes And Reporting facilities holding
Requirements Under 10 CFR an OL or CP
Part 21
85-51 Inadvertent Loss Or Improper 7/10/85 All power reactor
Actuation Of Safety-Related facilities holding
Equipment an OL or CP
85-50 Complete Loss Of Main And 7/8/85 All power reactor
Auxiliary Feedwater At A PWR facilities holding
Designed By Babcock & Wilcox an OL or CP
85-49 Relay Calibration Problem 7/1/85 All power reactor
facilities holding
an OL or CP
85-48 Respirator Users Notice: 6/19/85 All power reactor
Defective Self-Contained facilities holding
Breathing Apparatus Air an OL or CP, research,
Cylinders and test reactor,
fuel cycle and
Priority 1 material
licensees
85-47 Potential Effect Of Line- 6/18/85 All power reactor
Induced Vibration On Certain facilities holding
Target Rock Solenoid-Operated an OL or CP
Valves
OL = Operating License
CP = Construction Permit
SSINS No. : 6835
IN 85-55
UNITED STATES WillEDMSn011^K
O
NUCLEAR REGULATORY COMMISSION E C E
OFFICE OF INSPECTION AND ENFORCEMENT D .,
WASHINGTON, D.C. 20555
JUL22t�
July 15, 1985
DPIEELCY. COLO.
IE INFORMATION NOTICE NO. 85-55: REVISED EMERGENCY EXERCISE FREQUENCY RULE
Addressees:
All nuclear power reactor facilities holding an operating license (OL) or a
construction permit (CP).
Purpose:
This notice is to alert licensees of revised requirements regarding the frequency
of participation by state and local governments in emergency preparedness
exercises at nuclear power reactor sites. It is expected that addressees will
review the information provided for applicability to their program. Suggestions
contained in this notice do not constitute NRC requirements; therefore, no
specific action or written response is required.
Description of Circumstances:
On July 6, 1984, the Commission published in the Federal Register (49 FR 27733)
(Attachment 1) a revised rule effective August 6, 1984, relating to emergency
preparedness exercises. The revised 10 CFR Part 50, Appendix E, Section IV. F.
relaxes the frequency of participation by state and local governments in emergency
preparedness exercises from annually to biennially. This relaxation applies to
state and local governments that have fully participated (as defined in the
revised rule) in a joint exercise since October 1, 1982. In addition, the new
rule requires (1) each licensee at each site to conduct an exercise of its on-
site plan annually, (2) each licensee to provide an opportunity for state and
local governments to participate annually, (3) each state within the plume
exposure pathway EPZ of a given site to fully participate in an offsite exercise
for that site at least once every 7 years, (4) each state within any ingestion
exposure pathway EPZ to exercise its plans and preparedness related to ingestion
exposure pathway measures every 5 years at some site, and (5) the NRC, in consul-
t tation with FEMA, to determine the need for and extent of state and local
participation in remedial exercises.
This rule change also specifies that a full participation exercise shall be
held within 1 year before operation above 5 percent of rated power and "shall
include participation by each [s]tate and local government within the plume expo-
sure pathway EPZ and each [s]tate within the ingestion exposure pathway EPZ. "
(Note, however, that the United States Court of Appeals for the D. C. Circuit in
UCS v. NRC, 735 F. 2d 1437 vacated the 1982 amendment to the NRC' s regulations
which stated that emergency preparedness exercises were part of the operational
inspection process and not part of any operating license hearing. Therefore, an
8507110068
d mTi 7/241/g15"
IN 85-55
July 15, 1985
Page 2 of 2
applicant should consider scheduling a full participation exercise to permit
litigation of issues concerning the implementation of emergency preparedness as
demonstrated by the exercise. )
To meet the intent of this revised regulation, the NRC staff has determined that
licensees should conduct exercises involving onsite participation at least once
each calendar year (annually) and joint exercises involving the participation of
offsite agencies, which meet the above requirements, at least once every second
calendar year (biennially).
The degree of participation of offsite agencies is specified in the regulation.
The licensees are expected to coordinate the scheduling of the participation of
offsite agencies with the appropriate state and local governments and with the
NRC and FEMA regional offices. For example, a licensee holding a joint exercise
in November of 1985 would meet the biennial requirement by holding another joint
exercise during 1987, and would meet the annual requirement by holding an onsite
exercise during 1986. The conduct of a remedial exercise does not alter annual
and biennial exercise requirements.
Licensees were previously requested by the respective NRC Regional Administrators
to use the milestones established in FEMA Guidance Memorandum #17, "Conducting
Pre-Exercise and Post-Exercise Activities," dated January 8, 1981, in submitting
exercise objectives and scenarios for FEMA and NRC review (Attachment 2).
Licensees should continue to adhere to these milestones for each exercise involving
offsite participation. Guidance concerning the criteria to be used for determining
when remedial exercises will be required is contained in the attached FEMA
Guidance Memorandum EX-1 (Attachment 3).
No specific action or written response is required by this information notice.
If you need additional information regarding this matter, please contact the
Regional Administrator of the appropriate NRC regional office or this office.
�� rd . o an, Director
Divi$ on of Emergency Preparedness
ad Engineering Response
Office of Inspection and Enforcement
Technical Contact: Edward M. Podolak, IE
(301) 492-7290
Attachments:
1. Federal Register Notice 49 FR 27733
2. FEMA Guidance Memorandum #17.
3. FEMA Guidance Memorandum EX-1
4. List of Recently Issued IE Information Notices
•
Federal Register / Vol. 49, No.'131 / Friday. July 8, 1984 / Rules and Regulations 27733'
proviso that if all major elements in the Public Comment
emergency plan are performed in a The NRC proposed rule was published
satisfactory manner during the annual in the Federal Register with a 60-day
exercise.FEMA may recommend and comment period on July 21.1983(48 FR ,
the NRC may find that another exercise 33307).Seventy-one comment letters
with State and local government were received and evaluated by the
participation is not required for up to 2 NRC staff.
years.The proposed rule did not relax in Those commenters(55)favoring
any manner the annual requirement for relaxing the frequency of State and local
onsite exercises that each licensee is governmental participation in
required to conduct which include emergency preparedness exercises were
exercising the control room,technical utilities,consulting firms representing
} support center,and emergency utilities,two State Governors.State and
operation facility functions. local governmental agencies.FENA and
immediately after the Commission private citizens.
approved publication of the proposed Those commenters (14)opposing
rule,the Director of FEMA wrote to NRC relaxing the frequency of State and local
Chairman Palladino,urging the governmental participation in
Commission to"' . . adopt biennial emergency preparedness exercises were
exercise frequency language ' ' in 10 an information service,environmental
CFR Part 50.Appendix E to assure groups,a State Governor.State and
consistency in the regulations. local governmental agencies.EPA and
FEMA's final regulation.44 CFR 350, private citizens.
published in the Federal Register on The comments raised'several
September 28.1983(48 FR 44332). significant issues,to which the
reduced State and local participation in Commission responds as follows:
. emergency preparedness exercises to a Issue No.2
frequency of once every 2 years.The
FEMA final rule is not consistent with Should the Commission adopt a
the position taken by the Commission in biennial exercise frequency for State
_._ ,the NRC proposed rule(an annual and local government participation with
frequency with a specific NRC finding a proviso for remedial exercises for the
NUCLEAR REGULATORY necessary for relaxation).This correction of serious deficiencies rather
difference was a source of some concern than the exercise frequency contained in
COMMISSION • to both agencies and to some of the the proposed rile?
10 CFR Part 50 • commenters on the NRC proposed rule. Discussion:This issue was addressed
The FEMA regulation requires that a by many State and local governmental
Emergency Planning and State within the plume exposure comment letters whose concerns are
Preparedness pathway EPZ fully participate in an generaly characterized by the following
exercise every 2 years with no quote from the FEMA comment letter.
AGENCY:Nuclear Regulatory requirement on the return frequency at a The NRC proposal will be difficult to •
Commission. specific site.Typically,therefore,a State administer.For example,obleenve citeria
Ac' osc Final-rule. - . with two sites might be expected to hilly will need to be developed far use in
participate in an exercise at a specific determining whether State and local -
SUMMARY:The Commission is amending site at least every 4 years,a State with governments have performed in a satisfactory
its regulations to relax the frequency of three sites,every 6 pare;four sites, enough manner to warrant an exemption
participation by State and local every 8 years:five sites,every 10 years. from the succeeding year's exercise.It will be
•
governmental authorities in emergency etc.Whereas,the enclosed NRC rule difficult to apply such d local to the
enta
prepar eeiess exercises at nuclear change stipulates that a State within the satisfaction pf State and tog com lax
power reactor sites.This relaxation P The NRC proposal asl would roue complex
plume exposure pathway EPZ fully situations such as what to do if some
reflects experience gained in observing participate in an exercise every 2 years jurisdictions perform in an unsatisfactory
and evaluating over 150 emergency with a return frequency of at least once manner and the other,in a satisfactory
preparedness exercises since 1980. every 7 years at a specific site.Both manner.Would all jurisdictions have to
EFFECTIVE DATE:Auguste,1984. rules require a multi-site
e,when not
Statt exercise the next year or only the
unsatisfactory ones?If only the
FOR FURTHER INFORMATION CONTACT: fully participating in an exercise at a unsatisfactory ones,an unworkable condition
Michael T.Jamgochian.Accident Source specific site,to partially participate would result wherein-some jurisdictions
Term Program Office,Office of Nuclear every 2 years-at that specific site in would be on annual and other,on biennial
Regulatory Research.U.S.Nuclear - order to support the participation of the frequency.Inequities would result Further. •
Regulatory Commission.Washington. appropriate local governments. the time involved for evalua izg exercise
DC 20555.telephone(301)443-7815. The Commission has selected a return results.including getting commitments from
SUPPLEMENT ARY INFORMATION:On July frequency of 7 years because presently State and local governments to take
corrective actions,has proved time
21.:983,the Commission published in no State has more than 7 operating and/
consuming in die past.If we add time for the
the Federal Register a proposed rule or planned reactors and States with that NRC to make a finding after MIA's
relating to emergency preparedness number of sites or less would not be recommendation,a good portion of a year
exercises (48 FR 33307).The proposed required to exercise in a full could be consumed.This would cause
rule retained the presently required participation mode more often than uncertainty and instability in State and local
annual,full-participation exercise with a about once a year. governments,which should be avoided.
Attachment 1
IN 85-55
July 15, 1986 •
Page 1 of 4
L7n. Fed xelr er /•".4&.'4S:No.:131.:/ Frld r/P21y a..u9ac•/tuldti a«tr•tggi yft ' .•
Commission Reopens=Tiaa -gin government partictpatioa in.thy" : . prepered:levs exercises-TZ•MA has
Commission recognizes the ' licensee's arse)exercise.A State or ' developed and now uses a document: . :•
implemenaatida difficulties wi®.tile , local gorcr-aent may=wider!tat titled"Procedural Policy on-Radiological
pond raC approach.4aarual • response capability to be less than Emergency Preparedness Plan Reviews. •
frequency with a fmdtag to relax).This optimal be cruse of an uaasually large Exercise Observations and Evaluations-
was pointed but by the? Cemergency' personnel Hanover or because there and Interim Findings."These
preparedness regional inspector&t hare been limited responses to real procedures were forwarded to the
majority of the comment letters,the emergencies in the community.The final FEMA regions for tae on August 5.19133.
general thrust in two petitions far • rule requires the licensee to provide for Having considered all corr_merrts
• r ulemaking.'and theACRS. State or local government parti a lion received.experience pined since 1967, •
Issue Na 2 • if they indicate such a desire. . input from emergency preparedness
Issue Na.! regional inspectors,the genera]thrust of
� till less frequent exercises result is . two petitions for rulemaking.and ACRS
making personnel and equipment less Will the deletion of NUREG-0654'as comments, the Commission has
effective or reliable and therefore a footnote adversely affect the intedace concluded that the requirements for
reduce the level of safety? between offsite emergency plans and frequency of participation by State and
Discussion:A few commenters, the licensee's emergency plans? local governmental authorities in
p anly citizens and govetameatal Discussion The proposed rule emergency preparedness exercises
organizations. addressed this issue by included a provision to delete references around nuclear power reactors should
ponitirm out that State and local to NUREC-O654 throughout the be relaxed.The Commission therefore is
emergency response organizations must regulations.NUREC-0654 provides promulgating a final rule which:
frequently respond to various natural specific criteria for the evaluation of the i.Co times to require licensees to
and man-made emesserr,.:es.This standards in¢50.47 and is titled conduct an annual cnsite emergency
continuum of real life emergencies "Criteria for Preparation and Evaluation preparedness exercise,
exercises personnel,equipment, of Radiological Emergency Response 2.Requires that State and local
communication networks and • Plans and Preparedness in Support of. governments participate in emergency
organizational structures on a frequent Nuclear Plants."A few commenters, preparedness exercises every 2 years
basis. primarily a utility and a state with a provision for remedial exercises
The following quote from a comment governmental official,felt that the to assure that deficiencies are corrected
letter sr.-. etes this concern: deletion of the NUREC-0654 footnote In 3.Provides that at least once every 7
While an emergency situation at a nuclear the regulations would preclude its use years,all States within the plume •
power plant may cell for some procedures by reviewers in determining the exposure pathway EPZ-of a given site
that are different from those used under other adequacy of emergency preparedness. must fully participate in an offsite-
emergency situations.many of the response Commission Response:The delegation exercise for that see •
and evec.etkn measures will be similar,if of a reference to NUREG-0654 will not 4.Requires licensees to provide ant-
tot identical.A myriad of major and minor effect eta use as a guidance document for .opportunity for State and local
emergencies demand the maintenance of a emergency planning.In the 1980 government participation in the
force of personnel trained in these rulenra .the Commission included
procedures.By responding to other licensees annual emergency
emergency sioatior such as chemical spills, this reference as a means of formally preparedness exercise,end •
the emergency response personnel will be approving the use of NURZC-0654.See 5-Requires FEMA to determine the
rehearsing many of the procedures they 45 FR 55402.55408(August 19.1960). need for and extent of remedial • ••
would use in the event of an emergency NURI -6654 is endorsed by Regulatory exercises:
' situation at a ritziest power plant Some Guide 1.101,'end will-continue to be The final rule is not totally consistent
examples of these procedures would include used by reviewers in evaluating the with FEMA's final regulation 144 CFR
notification of approaate local authorities, adequacy of emergency preparedness at3. __
esmblis i r co=unicetion links between nuclear power reactor sites. o a This inquenct or lilt the area
local regiorst and state entergea—y respotnc of return izz..lurnry ft=multiple-site
personret rad evacuating or fending abetter Issue No. 4 a• states as previously dismissed.The
for the afeced popular. Do adequate procedures exist for NRC FED` Hon on net=frequency is a
Commission Response EMA Because and F to evaluate whether major sign ficant departure front the 1SRCa
crier at the elementsere performed satisfactorily proposed segulation(48 FR 33307)dated.
emergency response rn
July .r
State and Meal government level during an more study is needed exercise? d ed before n believes
continuously respond to actual Discussion Many commenters, that stf
emergrades,the Ca�ssion does not 'primarily State and local governmental r deletion of the return frequengr
consider that relaxing the frequency of authorities as well as utilities pointed requirement can be Justified
State and local government participation out that there is a need for uniform The Commission is adopting a
biennial exercise frequency,for State
in eme-te my pre
paredness exercises evaluation of exercise performance.
ent
would adversely affect the health and Commission Response:The and local go erre l edia participation with
safety of the public. Con iksion concurs with the a proviso for reined al exercises b
A rovision has been added in the commenters.In order to provide for assure the c s.Thee changesn of serious
final rule to permit State or local uniform evaluation of emergency deficiencies. spa a to the
emergency preparedness regulations are
it)"Marc-r. t. Communion 10 ore received a *Caches of thendocuments are available at the being made because: _
peudon lot rreaaki'a(PAM s'21 from•iaaonai Ccmnis.lon's Public Document Room.1717 i4 a. Experience in observing and
Emergency Itanagmneot Aasocsuou On August as Street NW..Washington.D.C.M 5S.Copier of evaluating over 150 exercises has shown
19C,the C munsuOL tanned a peuuoe for these doa.neau nay be purchased from the that a disproportionate amount of
ratemakin&fruit i-50-G41 from the Adjutant General Government Prntxa Office.tnfv-wauon on emrent
of the State of South Carofma.The general thrust of prices may be obtained by ventmg the U.S.Nadeau
both pennons urged the relaxationof the frequency Regulatory Cornmiss,on.Washington.D.C 22122S. •Guidance for determ.rnng the need for.sad
of e•nr-gamy pre tiredness exerc-nev. Anentlon:Wblr:.at,oru Sales Manager. extent al.remedial exert's..is being developed.
Attachment 1 •
IN 85-55
July 15, 1985
Page 2 of 4
- Federal Register I.'Yo(:49;-No: 131:./ Friddy.'Iulte. 1984•'/ Rules andtitigatiztongi 2T1'..S
Federal State and local government and Finding of No Sirifie•nt Environmental T.Jamgoehiaa.Office of Nuclear -• - •
licensee resources are being expended Impact Regulatory Research.U.S.Nuclear .,
in order to conduct and evaluate annual • The Commission has determined Regulatory Commission,Washington.' • .
ernergency preparedness exercises.As a under the National Environmental Policy DC 20555.Telephone(301)443-7815.
•
result of the substantial expenditure of Act of 1989,as amended.and the Regulatory Flexibility Certification
resources for these exercises,fewer Commission's regulations in Subpart A
resources are available to establish and of 10 CFR Part 51.that this rule is not a In accordance with the Regulatory
maintain the essential day-to-day major Federal action significantly flexibility Act of 1980.5 U.S.C.605(b).
• upgraded state of emergency affecting the quality of the human the Commission hereby certifies that
preparedness. environment and therefore an this final rule will not if promulgated.
have a significant economic impact on a •
b.State and local governments environmental impact statement is not
respond to a variety of actual required.See 10 CFR 51.20(8)(1). substantial number of small entities.The
• emergencies on a continuing basis, thus Moreover.the Commission has final rule clarifies certain elements and
frequently exercising their emergency determined pursuant to 10 CFR 51.32, findings necessary for the issuance of an
d.ess capabilities. that the final rile has no significant operating license for a nuclear power
Pre Pare P environmental impact This plant licensed pursuant to sections 103
c.bTheiennial
flexibility qe provided for in a determination has been made because and 104b of the Atomic Energy Act of
bier t to local will be an incentive the Commission cannot identify any 1954.as amended.42 U.S.C.2133.2134b.
for State and local governments toThe electric utility companies which
impact on the human environment
perform in a satisfactory manner in own and operate nuclear power plants
order to avoid conducting remedial associated with reducing the frequency
of full participation of State and local are dominant is their service areas and
exercises. governments in emergency preparedness do not fall within the definition of a
,a cad lastly,the Commission notes that exercises from annually to biennially. small business found in Section 3 of the
FEMA has had almost 3 years of The alternative app roaches that were Small Business Act.15 U.S.C.632,or
experience with evaluating State and considered in this rulemaking within the Small Business Size
local government radiological proceedings were: Standards set forth in 13 CFR Part 121.
emergency planning and preparedness. 1.To retain the annual full Accordingly,there is no significant
With few exceptions,this experience participation exercise with a provision economic impact on a substantial
has revealed a significant increase in to enable relaxation to every 2 yeah. number of small entities under the
the level of State and local government Z To incorporate by reference into the Regulatory flexibility act of 1980.
radiological preparedness as NBC's regulations,the FcMA list of Subjects In 10 CFR Part s9 .
demonstrated in joint exercises.FEMA . regulations governing the frequency of Antitrust.Classified Information.Fire
has evaluated approximately 150 full participation of State and local
exercises.L only five instances did governments in emergency preparedness prevention.Incorporation by reference.
FE-MA determine that State and local exercises. Intergovernmental relations,Nuclear
governments did not demonstrate 3.To relax the frequency of full power plants and reactors,Penalty,'
adequate preparedness.The participation of State and local Radiation protection.Reactor siting
Commission believes that this enhanced governments in emergency preparedness criteria.Reporting and recordiceeping
level of preparedness should be exercises from annually to biennially. requirements. - -
recog^.ized by allowing State and local There were no environmental impacts Pursuant to the Atomic Ener'Act of
governments to exercise jointly with identified from any of the alternatives 1954.as amended.the Energy
utilities on a binenrial frequency. considered. - Reorganization Act of 1974,as amended
On March 17.1982.the Commission Because FEMA is directly involved in and section 552 and 553 of Title 5 of the
received a petition for rulemaking the evaluation of offsite emergency United States Code,notice is hereby .-
(PRMS6;:3) from National Emergency preparedness exercises and is affected given that the following amendment to
Management Association. On August 30, by the promulgation of these - Title 10.Chapter L Code of Federal
1982 the Cccmissiob received a petition amendments,the hRC consulted Regulations.Part 50 is published as a
for rulemaking(PRM-50-34)from the extensively with FEMA during the document subject to codification.
Adjutant General of the State of South development of this rule.
Carolina.The petition from the National Paperwork Reduction Act Statement PART 50—DOMESTIC LICEPSlNG OF
Emergency Management Association PRODUCTION AND UTILIZATION
The final rule contains no information FACILITIES
requested the NRC to relax the
frequency of full participation by State collection requirements and therefore is
not subject to the requirements of the 1.The authority citation for Part 50
and local governments in emergency Paperwork Reduction Act of 1980(44 continues to read as follows:
• preparedness exercises from annually to U.S.C.3501 et seq.). Authority:Sees.. 1.8.2.183.185.
biennially.The petition from South • 189.88 Stat 936,937.941.9.53.954.955.954 as
Carolina requested that the NRC reduce . . Regulatory Analysis amended.sec.234.83 Stat 1244.as amended
the frequency with which local The Commission has prepared a - (42 US.C.2133.2134.=11.2232.2233.228.
governments must participate in a full regulatory analysis of this regulation. 2239.2282):secs.201.nrt 204 88 Stet 124.
scale emergency preparedness exercise. The analysis examines the costs and 1244.1248.as amended(42 U.S.C.5841.5842
Tne promulgation of this final rule benefits of the rule as considered by the 5846).Sete otherwise noted-
relaxes the frequency of full Commission.A copy of the regulatory Sec.50.7 also issued under Pub.L 95—eo1.).by State and local analysis is available for inspection and sce.10.92 Stat.2951 and U.S.C.also
isSeq.
participation Y P 50.57(d)50.58.SOAI, 50.92 also issued
governments in emergency preparedness copying, for a fee. at the ARC Public under Pub.L 97-415.95 Stat.2071.2073 142
exercises from annually to biennially. Document Room. 1717 H Street NW.. U.S.C.2133.2239).Sec.50.78 also issued
This rile completes ARC action by Washington.DC. Single copies of the under sea 12.88 Stat.939(42 U.S.C.2152).
a anting both petitions for rulemaking. analysis may be obtained from Michael Secs.50.80-50.81 also issued under sec 154.
Attachment 1 -
IN 85-55
. July 15, 1985 .
o _r n
....Q.- Fodeessitagater f WL 48,-No. 23I; P Friday NV 8, 1964"f Kates.-Atfl%ii. edbSl(1 .
68 Stat.954-as aaeaded f420SC 22M).• . emergency plans as te reasonably iehlevabla . conectfout.Any wssSnnaas et leficiazi~
Sea.50.103axz also Waned mean sec.3a4• - without mandatory public participation.flair that m tdestifiedakeli be carreeee• .
68 Stat its.(a U.S.C.22301. - be conducted for each site at which a power
For the purpose:el sec. ,eaStel.958.as reactor Is located for which the fast operating 4.In Appendix E.footnotes 1 and 4
amended(42 U.S.C 227S);-if 50.10(a).(b), license for that site it issued after July 13. are removed:foototes Z and 3 are .
and jc).Scat.56,48..5'1,.at.sad 50.8s(a)an . sea.This exercise shall be conducted within renumbered as footnotes 1 and". and
issued under sec.1eib.88 Stet 948.as 1 yearbefure the issuance a the fast new footnotes 3,4.and 5 are added to
amended(C USC=am ff so.io(b)and operating license for fell power and prior to read as follows:
(c)and 5034 c kneed ands wee I61i.68 operation above 5%d rated power of the fast s Use or r ..;R"simulators or
Stat.943.as amsaded(42 U.S.C 2zr1(i)k and reactor.and shall include participation by p
€€ 50.55(e).5658(b).5070.50.71.51.72.50.73, each State and local government within the computers is acceptable for any exerese. '
and 50.78 are issued under sec-161o.e8 Stat. plume exposure pathway En and each State •"Full participation"when used in
950.as ace"-el d(42 U.S.C.2211(o)). within the ingestion exposits pathway EPZ. conjunction with emergency ptepaea..ness
2.Each licensee at ee=site shall annually exercises for a particular site means
I SCAT (Amended) exercise its emergency plan. appropriate offrite local and State authorities
2. Lit 150.47,Footnote I is removed. 3.Each licensee at each site span exercise and licensee personnel physically and
3. in Appendix E. section IV.F is with offsite authorities such that the State actively take part in testing their integrated
revised to read as follows: and local government emergency pans for capability to adequately access and respond
each operating reactor site are exercised to an accident at a commercial nuclear power
Appendix E--Emergency Planning and biennially.with full or partial participations plant"Full participation"Includes testing the
Preptredxsa Production and by States and local governments.within the major observable portions of the onsite and
Prep red: n for fas plume exposure pathway Eat.State and ofisite emergency plans and rnobn7irntion of
local governments that have fully State:local and licensee pasonnet and other
participated to a Point exercise since October resources in sufficient mumbers to verify the
vv..• • • 1.19EC.an eligible to fully participate in capability to respond to the accident
F. Training. emergency preparedness exercises on a scenario.
for(I)the training biennial frequency.The level of participatiat a"Partial participation when used in - •
The program to provide
of employees and exer f by periodic shall be as follows: connection with emergency preparedness
(a)A State shall at least partially exercises for e particular site ratans
drills.of radiation emergency plaza to ensure
that employees of the licensee are familiar participate in each offsite exercise at each appropriate offsite authorities shall actively
with their specific emergency response _site. take pat in the exercise sufficient to test
duties.and(2)the participation in the (b)A State shall fully peticipete is at lent direction and contol hmcdonc i.e..(a)
one At e exercise every 2 years, merger a action decision making related to
teeing end drills by other persons whoseprotective
(c)At least once every 7 years.all States emergency action \ (b)
assistance may be needed in the event of a within the plume exposure pathway EPZ fora 'g lc pabf and
radiation emergency shall be described.This given site mast fully participate in an offaits State and localon
upabuides among c ea-ad
shall include a description of specialized exercise far that site.This exercise must aLo State and local authorities end the licensee.
initial eneung•and periodic retraining involve full participation by local • • • • •
pron. es to be provided to each of the governments within the plume exposure Dated at Washington.D.C.this 29th day of
foliowin .categories of emergency personnel: pathway Elm ' June 1984-
a.Directors and/or coordinators of the (d)Partial participation by a local
plant eeergccy organizationg For the Nuclear Regulatory Commisaioo.
government acceptable ofisite the
for a
b.Personnel responsible for accident site is acceptable only when local Samuel J.Mak•
assessment including control room shift government is fully participating in a biennial Secretary of theComminioa
personnel: exercise at another site. pre Occ s4-1rn4 rood r_1.x tie a.l -- - ,
c Radiological monitoring teams: (el Each State within any ingestion alWlg ezr lac-st-n 4%'
d.'F ire control teams(fn brigades); exposure pathway EPZ shall exercise its
e.P.epa`and de-.ergs control teams plans and preparedness related to ingestion .
L First aid and resole teams: exposure pathway measures at least once
g.Medical support personnel: every 5 years.
h.Licensee's headquarters support (f)licensees shall enable any State or local --
personnel goverment located within the plume
i.Sectnty personnel. exposure pathway EPZl to participated in
In addition.a reloiogical orientation annual e+censes rah=requested by such
training peg em shall be made available to State or local government •
local servile'persoanek e.g_local emergency 4.Remedial eiencises will be required if
senices/Coil Defense.local law the emergency plan is not satisfactorily -
trSorcear-_t penonneL local news tnerna tested during the biennial exercise.such that
persons. NRC'in consultation with FEMA.cannot find
Toe plan shall describe provisions for the reasonable assurance that adequate
condoct of emergency preparedone exercises protective measures can be taken in the event
are follows:Exercises shell test the sclacitmc7 to a radiological emergency.The extent of
of tiding and content of implementing State and local participation in remedial
procedures and methoµ test emergency exercises must be sufficient to show that -
equipment and com emu nits tions networks, appropriate corrective metiers have been
test the public notification system.and taken regarding the elements of the plan not •
ensure that emergency organization properly tested in the previous exercises.
personnel are familiar with their duties.' 5.An training.including exercises,shall
1.A fu➢participation 4 exercise which provide for formal critiques in order to
tests as murb of the licensee.State and local identify week or deficient areas that need
Attachment 1
I(J-85-55
July 15, 1985.
Page 4 of 4
�r8I .
•
Attachment 2
IN 85-55
.Guidance Memorandum 17 July 15, 1985
1 Radiological Emergency Preparedness Division Page 1 of 3
JOINT EXERCISE PROCEDURES •
In the interest of assuring that the health and safety of the public •
is protected in the event of an accident at a nuclear power plant, it
is necessary for the licensee (applicant) , to conduct an emergency
preparedness exercise jointly with appropriate State and local agencies .
The role of the Federal government at such exercises is to evaluate the
capability of the utility and the State and local governments to protect
the public health and safety in the event of an accident at the facility.
The FEMA official responsible for this activity is the appropriate Regional
Director. •
Over the last few months there have been several joint exercises where FDIA
and NRC have made reviews both orally in an open meeting, and in written
form. We find however, significant variation among regions in the procedures
used for providing the evaluation. The need for a standardized approach
is evident and the following is a guide for both FEMA and NRC personnel
involved in exercise evaluation.
Assignments for offsite observers will be made by the RAC Chairman: Onsite
observers will be assigned locations by the NRC Team Leader. A meeting of
all parties should be conducted prior to the exercise to assure that all
observer locations are staffed by an evaluator, as well as to make whatever
last minute changes are necessary based on field conditions, number of
evaluators available, etc.
The exercise should be followed as soon as possible by a critique . The
critique is a working session for preliminary review of the exercise between
the participants (State and local officials and utility representatives and
the Federal observer teams headed by FE4A and the NRC) . It should be open
to the public and the media . They should, however, attend as observers, and
not participate in the discussions . If local circumstances dictate that a
private session be held with the State authorities, it must be scheduled in
advance and the information provided by the RAC Chairman at the private
meeting" should be repeated in the open session.
-2— Attachment 2 .
IN 85-55
July. 15, 1985
Page 2 of 3
It is desirable to conduct the critique with all the principal parties
present, (e. g. the RAC, the involved State and local authorities, the
licensee and NRC). There may be situations where such a joint critique
is not feasible and separate sessions (one related to licensee participation
and one related to State and local participation) are necessary due to
logistical or funding constraints. These situations are to be cleared in
advance thru the FFMA/NRC Steering Committee. In such cases the RAC 4
Chairman should be available for both critiques.
The joint critique should be chaired by the RAC chairmen and should be
within or near the 10 mile EPZ. As part of the overall format the RAC •
Chairman will discuss observations of the offsite response and the NBC
will discuss observations of the onsite response. The State, local
governments and utility should be present at this meeting to make pre-
sentations. Par the joint critique to be effective, it should take
place within the 24-hour period immediately following the exercise.
'There should also be opportunity for clarification, questions or comments
by licensee, State and local officials.
The RAC Chairman's overview statement should be based on comments from
RAC members and other FFMA observers as well as his own observation. It
should include the strong'points as well as a general statement on the
deficiencies noted. Under no circumstances will the RAC Chairman's
ccmaents indicate that the State or local plan.: passed or failed. Re/she
should indicate that the comments are preliminary to be followed by a
comprehensive evaluation within 14 days. The final FMA findings and
determination, as well as approval of a State and/or local plan, submitted
according to 44 CFR 350 of which the exercise is a part, is reserved to the
Associate Director for Plans and Preparedness in Washington.
The principal milestones for FFMA and NRC exercise observation and critique
are given in Enclosure 1. These milestones are for planning purposes and
actual schedules may need to be different because of local circumstances.
Enclosure No. 1 Attachment 2
IN 85-55
July 15, 1985
•
MILESTONES FOR EXERCISE OBSERVATION AND CRITIQUES Page 3 of 3
- 75 days* State and licensee jointly submit exercise objective to
FESA and NRC Regional Offices.
- 60 days FEMA and NEC Regional Offices discuss and meet with
licensee/State as necessary and prepare response.
- 45 days State and licensee scenario developers submit exercise
scenario to FEMA and NRC Regions for review.
- 35 days FEMA and NRC Regions notify State and licensee of scenario
acceptability.
- 30 days FEMA and NRC Regions develop specific post exercise critique
schedule with the State and advise FEMA and NRC headquarters.
- 15 days The RAC Chairman and NRC team leader will meet to develop
observer action plan (where stationed, how many from each • .
organization, what to look for).
- 1 day Meeting, is the exercise area, 'of all Federal observers both
onsite and offsite to finalize assignments, and give instructions.
E day Exercise
E day FE4A and RAC observers caucus to collate observations. NRC
observers also caucus to collate observations.
E day RAC Chairman and NRC team leader meet, as-soon after their
respective caucuses as practical, to coordinate Federal
participation in critique.
E to + 1 day Joint RAC/NRC critique
General Agenda
A. State, locals and licensee present their views.
B. Critique of offsite actions, by RAC Chairman.
C. Critique of onsite actions, by NRC.
D. Critique of Federal response (if applicable) , by
RAC Chairman.
E. Opportunity for clarification questions or comments by
licensee, State and locals (press and public questions
will not be entertained during the cri+^que).
+ 15 days Written critiques by FE4A Region to State, with copies to FMMA
headquarters and NRC and by NRC Region to license, with copies
to NRC headquarters and FE A.
(Reg' r'anded Susyense Dates)
Attachment 3
IN 85-55
July 15, 1985
; N�
�tct N,� Page 1 of 4
F 'k,;- , 1 Federal Emergency Management Agency
x � Washington, D.C. 20472
rya, t '
_ o
July 1, 1985
GUIDANCE MEMORANDUM EX-1
REMEDIAL EXERCISES
Purpose
This Guidance Memorandum provides criteria and procedures for requiring and
scheduling remedial exercises and other remedial actions to correct deficiencies
identified in exercises to test State and local radiological emergency response
plans. It also provides guidance for determining the extent of participation in
remedial exercises. •
Background
The Federal Emergency Management Agency (FEMA) rule, 44 CFR 350, and the
Nuclear Regulatory Commission (NRC) rule, 10 CFR 50, Appendix E, require
that State and local governments participate in periodic, joint exercises
with utilities. These rules require remedial exercises and other corrective
measures if the results of these exercises do not give reasonable assurance
that adequate protective measures can be taken in the event of a radiological
emergency or the deficiencies identified are significant enough to impact
on the public health and safety. The NRC rule (10 CFR 50, Appendix E,
IV.f.4.) calls for NRC-FEMA consultation in making a determination as to
whether a remedial exercise is needed. The FEMA rule (44 CFR 350.9.c.5)
leaves the determination of the participation required from State and local
governments to the appropriate FEMA Regional Director.
For the purpose of exercise assessment, FEMA uses an evaluation method to apply
the criteria of NUREG-0654/FEMA-REP-1.* FEMA classifies exercise inadequacies
as deficiencies or areas requiring corrective actions. Deficiencies are
demonstrated and observed inadequacies that would cause a finding that offsite
emergency preparedness was not adequate to provide reasonable assurance that
appropriate protective measures can be taken to protect the health and safety
of the public living in the vicinity of a nuclear power facility in the event
of radiological emergency. Because of the potential impact of deficiencies
on emergency preparedness , they are required to be promptly corrected through
appropriate remedial actions including remedial exercises, drills or other
actions . Areas requiring corrective actions are demonstrated and observed
inadequacies of State and local government performance, and although their
correction is required during the next scheduled biennial exercise, they are
not considered , by themselves, to adversely impact public health and safety.
In addition to these inadequacies, FEMA identifies areas recommended for
* The method currently in use is incorporated in the August 5, 1983, memorandum
from the FEI4A Deputy Associate Director of State and Local Programs and
Support to the FEMA Regional Directors, subject: "Procedural Policy on
Radiological Emergency Preparedness, Plan Reviews, Exercise Observations and
Evaluation , and Interim Findings."
Attachment 3
IN 85-55
July 15, 1985
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improvement, which are problem areas observed during an exercise that are
not considered to adversely impact public health and safety. While not
required, correction of these would enhance an organization' s level of
emergency preparedness.
Guidance on Determining the Need for a Remedial Exercise
The following criteria shall be used in determining the need for requiring a
remedial exercise.
1. A deficiency in one or more of the following planning standards of
NIR EG-0654/FEMA-REP-1 will require a remedial exercise. Exceptions
to this requirement may be made when correction of deficiencies can
be demonstrated by other remedial actions.
o Assignment of Responsibility (Organization Control) (A) ;
o Alert and Notification Methods and Procedures (E );
o Emergency Communications (F);
o Public Education and Information (areas related to emergency
public information) (G);
o Accident Assessment ( including field monitoring and radiological
assessment) (I );
o Protective Response (including evacuation and other protection
responses and decisionmaking) (J );
o Radiological Exposure Control (K); and
o Medical and Public Health Support and Services (L) .
2. Remedial exercise action may be required when areas requiring corrective
actions collectively raise doubts as to whether adequate protective
measures can be taken in the event of an emergency.
Procedures for Reporting on the Need for and Scheduling of Remedial Actions
When evaluation of a joint exercise indicates that there is the potential
or need for remedial action, the following procedures will be followed.
1. The FEMA Regional Office will immediately notify FEMA Headquarters, by
telephone, of the nature of exercise inadequacies. FEMA Headquarters
will , in turn, notify and discuss these inadequacies with NRC Headquarters.
2. The FEMA Regional Office will promptly initiate a consultation process
with the members of the Regional Assistance Committee( s) (RAC) , the
State(s) and FEMA Headquarters for these purposes: (a) To classify
all exercise inadequacies, (b) to specify appropriate remedial actions,
including remedial exercises , drills , or other actions, for both
deficiencies and areas requiring corrective actions and (c) to determine
which organizations are to be involved in remedial actions. During
this period, FEMA Headquarters will continue to consult with NRC Headquarters.
Attachment 3
IN 85-55
July 15, 1985
Page 3 of 4
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3. Within 30 days of the exercise, the FEMA Region will transmit a letter
and draft report consisting of, at least, a summary table of the
exercise inadequacies to the State(s) with a copy to FEMA Headquarters
and the RAC(s) . The letter and summary table will confirm the results
of the consultations with the State(s). The State will be asked to
use this letter and summary table of exercise inadequacies as a basis
for working with the FEMA Region in accomplishing the remedial actions.
4. Within 60 days from the exercise, the FEMA Region will prepare and .
transmit copies of the exercise report to the State(s) , RAC(s) and FEMA
Headquarters. If the remedial exercise or other remedial actions
have been taken and evaluated prior to the end of the 60 day period, the
FEMA Region will incorporate its evaluation of these actions within the
exercise report. ( In this case, the report will be completed and forwarded
within 30 days of the remedial exercise or other remedial actions.)
5. FEMA Headquarters will forward a copy of the exercise report to NRC
Headquarters within 10 days of receipt from the FEMA Regional Office.
6. If the remedial exercise or other remedial actions are not conducted
prior to the preparation and forwarding of the exercise report, they
should be completed as soon as possibl.e but not later than 60 days after
the report is forwarded to FEMA Headquarters.
7. If the evaluation of the remedial exercise or other remedial actions
are not incorporated into the exercise report, the FEMA Regional Office
will prepare and forward an evaluation report of these remedial actions
to the State(s) , RAC(s) and FEMA Headquarters within 30 days of the
conduct of their completion.
8. FEMA Headquarters will forward a copy of the remedial action evaluation
report to NRC Headquarters within 10 days of receipt from the FEMA Regional
Office.
Extent of Participation
The extent of State and local government participation in a remedial exercise
shall be determined by the FEMA Regional Director. Some factors to consider in
this determination include:
1. The remedial exercise should address only those activities that are necessary
to demonstrate correction of the identified deficiencies.
2. To the extent possible, the remedial exercise participation should be
limited to organizations having the deficiency(ies).
3. When the corrective action by one organization cannot be demonstrated
without involvement of other organizations, their participation should
be at a level necessary to confirm the corrective action. This includes
participation by utilities which should be arranged through the
appropriate NRC Regional Administrator.
Attachment 3
IN 85-55
_4_ July 15, 1985
Page 4 of 4
Action on Inadequately Performed Remedial Exercises
When evaluation of a renedial exercise indicates that an organization did not
adequately d enonstrate correction of identified deficiencies, one of the
following actions are to be taken.
1. If FEMA has not approved offsite planning and preparedness for the
involved site under 44 CFR 350, FEMA may, in consultation with NRC,
require another renedial exercise and the NRC may consider enforcenent
actions.
2. If FEMA has approved offsite planning and preparedness for the involved
site under 44 CFR 350, FEMA may initiate steps to withdraw the 350
approval or schedule another renedial exercise under the provision of
350.13 and the NRC may consider enforcement actions.
Coordination with NRC
This Guidance Memorandum has been prepared in coordination with the NRC staff.
Attachment 4
IN 85-55
July 15, 1985
LIST OF RECENTLY ISSUED
IE INFORMATION NOTICES
Information Date of
Notice No. Subject Issue Issued to
85-54 Teletheraphy Unit Malfunction 7/15/85 All NRC licensees
authorized to use
teletheraphy units
85-53 Performance Of NRC-Licensed 7/12/85 All power reactor
Individuals While On Duty facilities holding
an OL or CP
85-52 Errors In Dose Assessment 7/10/85 All power reactor
Computer Codes And Reporting facilities holding
Requirements Under 10 CFR an OL or CP
Part 21
85-51 Inadvertent Loss Or Improper 7/10/85 All power reactor
Actuation Of Safety-Related facilities holding
Equipment an OL or CP
85-50 Complete Loss Of Main And 7/8/85 All power reactor
Auxiliary Feedwater At A PWR facilities holding
Designed By Babcock & Wilcox an OL or CP
85-49 Relay Calibration Problem 7/1/85 All power reactor
facilities holding
an OL or CP
85-48 Respirator Users Notice: 6/19/85 All power reactor
Defective Self-Contained facilities holding
Breathing Apparatus Air an OL or CP, research,
Cylinders and test reactor,
fuel cycle and
Priority 1 material
licensees
85-47 Potential Effect Of Line- 6/18/85 All power reactor
Induced Vibration On Certain facilities holding
Target Rock Solenoid-Operated an OL or CP
Valves
OL = Operating License
CP = Construction Permit
Hello