Disaster and emergency areas: Radiological emergency preparedness program; strategic review; recommendations,
[Federal Register: September 9, 1998 (Volume 63, Number 174)]
[Notices]
[Page 48222-48234]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr09se98-74]
FEDERAL EMERGENCY MANAGEMENT AGENCY
Publication of Radiological Emergency Preparedness (REP) Program Strategic Review Draft Final Recommendations
AGENCY: Federal Emergency Management Agency (FEMA).
ACTION: Notice with request for comments.
SUMMARY: In June 1996, FEMA initiated a Strategic Review of the REP Program in order to improve, streamline, and enhance the efficiency and effectiveness of the Program. A Strategic Review Steering Committee (SRSC) guided the Review, developed four concept papers based on stakeholder suggestions, and held a series of stakeholder meetings across the country. The SRSC submitted one concept paper to the FEMA and NRC Offices of General Counsel for further review and consolidated the remaining three concept papers into this document.
DATES: We invite your comments on these proposed recommendations. Please submit any comments on or before October 26, 1998.
ADDRESSES: Please address your comments to the Rules Docket Clerk, Office of the General Counsel, Federal Emergency Management Agency, room 840, 500 C Street SW., Washington, DC 20472; (telefax) (202) 646- 4536, or (email) rules@fema.gov.
FOR FURTHER INFORMATION CONTACT: Vanessa E. Quinn, Acting Chief, State and Local Regulatory Evaluation and Assessment Branch, Exercises Division, Preparedness, Training, and Exercises Directorate, Federal Emergency Management Agency, 500 C Street SW., Washington, DC 20472, (202) 646-3664, or (email) vanessa.quinn@fema.gov.
SUPPLEMENTARY INFORMATION:
Radiological Emergency Preparedness Program Strategic Review Steering Committee Draft Final Recommendations
The Director of the Federal Emergency Management Agency (FEMA) established the independent Strategic Review Steering Committee (SRSC) in June 1996. Steering
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Committee members were drawn from both FEMA and the Nuclear Regulatory Commission (NRC). The purpose of the SRSC was to solicit comments from stakeholders of the Radiological Emergency Preparedness (REP) Program, to consider ways to streamline the program, and to develop recommendations.
The SRSC has developed the following preliminary recommendations and will continue to refine them in light of additional comments. In making the SRSC draft recommendations public, FEMA invites further comment. It should be noted that neither FEMA nor the NRC has formally reviewed, endorsed, or adopted any of the recommendations in their present form. The final recommendations will undergo the appropriate FEMA and NRC review processes. The draft final recommendations follow.
Executive Summary
REP Program: Establishment and Activities
The REP Program was established as a consequence of the March 1979 accident at the Three Mile Island nuclear power plant. In December 1979, the lead Federal role for offsite radiological emergency activities pertaining to U.S. commercial nuclear power plants was transferred from the NRC to FEMA. Subsequent actions initiated by Congress, the NRC, and FEMA established the legal and regulatory foundation for a joint NRC/FEMA REP Program.
Under its REP Program, FEMA:
‹bullet› Reviews and approves State and local government plans for preparing for and responding to a commercial nuclear power plant incident.
‹bullet› Evaluates State and local biennial exercises of these plans. A joint NRC/FEMA document, NUREG-0654/FEMA-REP-1, Revision 1, contains the 16 Planning Standards used by FEMA in reviewing plans and evaluating exercises.
‹bullet› Provides findings to the NRC with respect to the adequacy of State and local plans, as measured against the 16 Planning Standards, that there is ``reasonable assurance'' that these plans can be implemented. Reasonable assurance is defined as assurance that the health and safety of the public living in the vicinity of a commercial nuclear power plant can be protected in the event of an incident at the nuclear power plant. Currently, FEMA's confirmation of the adequacy of emergency preparedness at each site is primarily based on the results of the evaluated biennial exercises.
‹bullet› Conducts training courses pertaining to the evaluation of State and local government radiological emergency planning and preparedness.
‹bullet› Reviews and approves State and local government systems for the alert and notification of the public in the event of a radiological emergency.
‹bullet› Coordinates Federal agency assistance to State and local governments in planning and preparing for a radiological emergency; chairs a Federal interagency committee, the Federal Radiological Preparedness Coordinating Committee (FRPCC).
Background of the REP Program Strategic Review
In June 1996, considering the 17-year maturity of the REP Program and Stakeholder requests for a reconsideration of Program requirements and implementation, FEMA initiated a Strategic Review. The SRSC, with membership from FEMA Headquarters and Regions and the NRC, was chartered to undertake a formal review of REP activities. While undertaking this effort to improve, streamline, and enhance the efficiency and effectiveness of the REP Program, the SRSC was mindful of the provisions of the Government Performance and Results Act and the National Performance Review.
This Review was announced in the Federal Register on July 8, 1996, and suggestions for improvement were solicited from the REP community. On the basis of comments from Stakeholders, four draft concept papers were developed and presented to the REP community through a series of meetings held in various parts of the U.S. The concept papers addressed the following subjects: Exercise Streamlining, Partnership, Radiological Focus, and Delegated States. After considering comments received on the concept papers, one of the papers, Delegated States, was forwarded to FEMA and the NRC's Office of General Counsel for further review; the other three were consolidated into the subject document. Five major recommendations were made.
In addition to the major recommendations, which are summarized below, several potential short-term improvements to the REP Program were identified during the review process and implemented by FEMA. Specifically, FEMA has (1) established a Regional Assistance Committee (RAC) Chairpersons Advisory Council (RAC AC) that reports to the FRPCC; this Advisory Committee has already improved coordination, communication, and consistency among FEMA's Regions; (2) proposed legislation establishing a REP Program Fund, which will ensure continuity, the availability of funds until expended, and a measure of flexibility that will support the REP Program significantly better than the current budget system; (3) reorganized the REP Program, uniting FEMA Headquarters' REP Program functions in one location; and (4) established a REP Home Page.
Summary of Major Recommendations
Recommendation 1--Streamline the REP Program. The SRSC recommends that: the exercise evaluation process be streamlined by consolidating, combining, and/or eliminating objectives and evaluation criteria; flexibility in exercise scenarios be increased; the increased importance of the Annual Letter of Certification (ALC) be emphasized and ALC requirements be consistent among the FEMA Regions; additional approaches be provided, for use in conjunction with a streamlined program, to demonstrate and confirm reasonable assurance; and REP policy and guidance be revised to support a streamlined program.
Recommendation 2--Increase Federal Participation in REP Exercises. The SRSC recommends that: FEMA take a lead role in planning and coordinating federal participation in emergency preparedness exercises; FEMA complete the development and incorporation of the Radiological Incident Annex to the Federal Response Plan; an interagency task group be established to review the charters of the various response committees to determine if the committees' responsibilities can be streamlined to be more efficient; FRPCC agencies identify additional resources to enable them to participate in radiological preparedness and response activities; the role of the FRPCC in developing REP policy be reinforced; agencies' radiological preparedness and response training courses be reviewed and revised, as necessary, to reflect current concepts and experience; and a REP-funded position be established in FEMA's Response and Recovery Directorate.
Recommendation 3--Use State, Local, and Tribal Personnel as Federal Evaluators. The SRSC recommends that FEMA use State, local, and tribal personnel as Federal evaluators in the exercise process under certain conditions; FEMA develop a Memorandum of Understanding (MOU) that addresses the relationship between FEMA and the non-Federal evaluator; and the RAC AC develop qualification standards that will be applied to all evaluators, who would be subject to
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performance reviews after the evaluation process has been completed.
Recommendation 4--Include Native American Tribal Nations in the REP Preparedness Process. The SRSC recommends that FEMA's American Indian and Alaska Native Policy be reviewed to identify areas for Federal and tribal REP relationships; all Federally recognized tribes within the emergency planning zones (EPZ) be identified and current relationships be determined; FEMA coordinate with other Federal agencies to identify current policies and practices; and FEMA work with tribal representatives and other Federal agencies to develop an approach to increase tribal involvement in REP activities.
Recommendation 5--Enhance the REP Training Program. The SRSC recommends that: FEMA establish qualification standards for REP exercise evaluators and establish an enhanced training curriculum for REP evaluators; opportunities for FEMA REP staff to teach evaluator training be increased; current radiological courses be revised as required by the outcomes of the REP review and REP training course development, revision, and delivery be included in the REP budget; and a REP Program Administration Course be developed for all REP staff.
Announcement of SRSC Results
An Emergency Education Network (EENET) broadcast was held on July 30, 1998, where SRSC members presented proposed recommendations and answered questions. In addition, the proposed recommendations were posted on FEMA's REP Home Page and will be shared at meetings and conferences during the next few months.
Implementation Strategy
The SRSC anticipates formally conveying the final recommendations to the FEMA Headquarters REP Program Office in, approximately, October. Having completed its chartered mission, the SRSC will then be dissolved. Headquarters, the RAC Chairs for the nine FEMA Regions that have REP Programs, and REP Program staff will then work with the REP community to implement the changes.
Considerations and Results
While conducting its Review and formulating recommendations, the SRSC established as a goal the improvement of relations with REP Stakeholders. The Committee feels that Federal, State, tribal, and local relationships have been strengthened as a result of the Review, and that these partners will continue to be actively involved in the implementation phase. FEMA plans to conduct REP Partnership Workshops with participation from the REP community. A Workshop for the FEMA REP staff is being planned for December of this year, in preparation for FEMA's Stakeholder Partnership Workshops.
Paramount in the Committee's deliberations was the requirement to preserve the REP Program's mission of providing reasonable assurance that the health and safety of the public living in the vicinity of commercial nuclear power plants can be protected. As a result of the Review, the amount of pertinent information available to FEMA's Regional Directors when considering a reasonable assurance finding has been expanded. The SRSC believes that implementation of its recommendations will maintain the well-regarded discipline of the REP Program of the past, while increasing the flexibility and efficiency of the REP Program of the future.
Introduction
In December 1979, President Carter assigned the lead Federal role for offsite radiological emergency activities pertaining to U.S. commercial nuclear power plants to FEMA as a result of the March 1979 accident at the Three Mile Island nuclear power plant. Subsequent actions initiated by Congress, the NRC, and FEMA established the legal and regulatory foundation for a joint NRC/FEMA REP Program.
Within the framework of its REP Program, FEMA:
‹bullet› Reviews and approves State and local government plans.
‹bullet› Evaluates State and local biennial exercises of these plans.
‹bullet› Provides findings to the NRC with respect to the adequacy of State and local plan and makes a determination of reasonable assurance that public health and safety can be protected.
‹bullet› Conducts training courses.
‹bullet› Approves State and local Alert and Notification systems.
‹bullet› Coordinates Federal agency assistance to State and local governments in planning and preparing for a radiological emergency.
Over its 19-year history, REP Program communities have developed some of the best-prepared emergency managers in the nation. REP Program stakeholders felt that this capability had not been recognized in the current implementation of the REP Program and its rules and regulations.
In response to comments received recommending program changes, FEMA decided to undertake a Strategic Review of the REP Program. FEMA announced the Strategic Review in the Federal Register in July 1996, and solicited suggestions for improvement of the REP Program from the REP community. In November 1996, FEMA formed the Strategic Review Steering Committee (SRSC). Original members were (1) representatives of FEMA and NRC Headquarters organizations; (2) the Preparedness, Training and Exercise Division Directors from FEMA Regions 1, 4, and 10; and (3) the RAC Chairs from FEMA Regions 3, 5, 6 and 7. The SRSC met for the first time in January 1997 to review all of the comments received from the REP community. On the basis of the Stakeholder comments, the SRSC developed four draft concept papers--''Partnership in the REP Program,'' ``Exercise Streamlining,'' ``Focus on Radiological Aspects of REP vis-a-vis All-Hazard Aspects of REP,'' and ``Delegated State''-- and presented them to the REP community through a series of Stakeholder meetings held in the Fall of 1997.
After considering comments received on the concept papers, the ``Delegated State'' concept paper was forwarded to FEMA and the NRC's Office of General Counsel for further review. The remaining three papers were consolidated into five major recommendations addressing: REP Program streamlining; the use of State, tribal, and local government personnel as evaluators; Federal participation in REP exercises; the role of Native American tribal nations in REP preparedness; and REP training. These recommendations are discussed in detail in this report.
Recommendation 1: Streamline the REP Program
Issue
Most of the comments indicated that the Stakeholders are dissatisfied with the exercise evaluation process, the existing guidance, and the use of only the biennial exercise results to confirm reasonable assurance. Respondents also indicated that the FEMA Regions are not implementing the program in a uniform and consistent manner.
Background
The regulatory basis for REP is found in FEMA regulations (44 CFR Parts 350, 351, and 352), NRC regulations (10 CFR 50.33, 50.47, 50.54, and Appendix E to 10 CFR Part 50), and in the NRC/FEMA MOU. FEMA is responsible for assessing the adequacy of offsite emergency preparedness and provides its findings and determinations to the NRC. If FEMA and NRC staffs determine that the state of emergency preparedness does not
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provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency (the ``reasonable assurance'' finding), the NRC will take appropriate enforcement action. The MOU indicates that FEMA's findings on preparedness are based on an assessment that: (1) Offsite plans are adequate as measured against the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1 and (2) there is reasonable assurance that plans can be implemented as demonstrated in exercises. Currently, FEMA's confirmation of the adequacy of emergency preparedness at each site is based primarily on an evaluation of the biennial full- participation exercise.
Introduction to Actions A-E
The SRSC, in its review of program implementation and guidance, has identified the need for changes to the REP Program in the following areas: a streamlined exercise evaluation process, revision of policy and guidance, increased flexibility in scenario development, a more flexible process to confirm reasonable assurance, and enhanced use of the Annual Letter of Certification (ALC). Combinations of these approaches will be used to confirm that reasonable assurance is maintained. These approaches are addressed in more detail in Actions A through E of this report.
Action A. Streamline the Exercise Evaluation Process by Consolidating, Combining and/or Eliminating Objectives and Evaluation Criteria
Introduction to Recommendation 1.1
Exercises are currently evaluated in an ``objective based'' format. FEMA-REP-14 and -15 identify 33 exercise objectives and include a sizeable number of Points of Review (POR) that must be satisfactorily demonstrated to successfully meet the requirements of each objective. This system is very structured and leaves little latitude for satisfying the objective by alternate means. Stakeholders have identified the obvious similarities between objectives. Experience in exercise evaluations indicates that several objectives can easily be combined, and others deleted, without weakening the evaluation process.
Comments have also been received from Stakeholders suggesting that the REP exercise program be streamlined to concentrate more on specific radiological aspects of REP and less on the ``all-hazards'' response. An exercise that only involves radiological activities is difficult to conduct when the ``glue'' for demonstrating an integrated response to a simulated emergency lies in the non-radiological functions. However, as proposed in other sections of this paper, some of the all-hazards Evaluation Areas could receive credit from other exercises, from response to real events, and through Staff Assistance Visits. This will provide flexibility to response organizations because those all-hazards valuation Areas granted credit may not be evaluated during exercises. Recommendation 1.1: Establish Evaluation Areas for Consolidation of Objectives into Sub-elements
The SRSC recommends the consolidation of current objectives into the six Evaluation Areas identified below. These Evaluation Areas would be established to support a ``results-oriented'' evaluation process. Results-oriented exercise evaluation allows FEMA to focus on the outcome of actions taken by players in the implementation of their plans and procedures. This approach will give the exercise players more latitude to reach the desired results. Evaluators will then concentrate on the results of an exercise activity, not on the steps taken to arrive at a result.
Within each Evaluation Area, objectives would be combined and duplicative PORs would be eliminated. In addition, we recommend deleting Objectives 23, 31, 32, and 33.
The six Evaluation Areas and sub-elements are as follows:
-
Emergency operations management. This Evaluation Area contains elements involved in the overall management of the emergency response operations to include:
‹bullet› Mobilization of Response Personnel.
‹bullet› Facilities.
‹bullet› Direction and Control.
‹bullet› Communications.
‹bullet› Equipment and Supplies Necessary to Support Operations.
-
Protective action decisionmaking. This Evaluation Area contains all aspects of the decisionmaking process to protect the health and safety of the public and emergency workers within the affected area to include:
‹bullet› Radiological Exposure Control.
‹bullet› Development of Dose Projections and Protective Action Recommendations and Decisions, Including Ingestion of Potassium Iodide (KI).
‹bullet› Consideration for the Protection of Special Populations.
‹bullet› Determination of Traffic and Access Control Points.
‹bullet› Dose Projection and Decisionmaking for the Ingestion Exposure Pathway.
‹bullet› Decisions Concerning Relocation, Re-entry, and Return.
-
Protective action implementation. This Evaluation Area contains the implementation of all protective action decisions to include:
‹bullet› Emergency Worker Exposure Control.
‹bullet› Implementation of KI Decision.
‹bullet› Actions to Limit Exposure of Special Populations.
‹bullet› Establishment of Traffic and Access Control.
‹bullet› Implementation of Ingestion Pathway Decisions.
‹bullet› Implementation of Relocation, Re-entry, and Return Decisions.
-
Field measurement and analysis. This Evaluation Area addresses the verification of predictive models used in accident assessment and the identification of contaminated areas to include:
‹bullet› Ambient Radiation Monitoring.
‹bullet› Airborne Radioiodine and Particulate Activity Monitoring.
‹bullet› Collection and Analysis of Environmental Samples.
-
Emergency notification and public information. This Evaluation Area addresses the timely notification and dissemination of emergency instructions to the affected population and the provision of emergency information to the media to include:
‹bullet› Activation of the Prompt Alert and Notification System.
Note: Current Objective 10, ``Alert and Notification,'' as it applies to the 15-minute criterion would be demonstrated as a separate and distinct drill conducted once every six years. The drill would be a ``no notice'' drill, would simulate a fast-breaking scenario, and would be initiated by a FEMA controller. Failure to correctly demonstrate this event would result in a Deficiency.
‹bullet› Development of Emergency Instructions.
‹bullet› Provision of Information to the Media.
‹bullet› Establishment of a Public Inquiry System.
-
Support operations/facilities. This Evaluation Area addresses the support operations and facilities necessary to provide the reception, care and treatment, if needed, of individuals from the affected areas to include:
‹bullet› Monitoring, Decontamination and Registration of Evacuees and Emergency. Workers.
‹bullet› Monitoring and Decontamination of Vehicles and Equipment.
‹bullet› Care of Evacuees.
‹bullet› Transportation and Treatment of Contaminated, Injured and/ or Exposed Individuals
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Introduction to Recommendation 1.2
Several comments were received regarding the frequency of Medical Services drills (Objectives 20 and 21). As a result of demonstrated capability, hospital accreditation standards, and the establishment of universal health precautions, there is justification for evaluating Medical Services drills less frequently than once a year. Stakeholders also expressed a desire for more frequent demonstration of post-plume phase objectives (Objectives 23-29). Since post-plume phase objectives represent a significant portion of long-term recovery efforts and interaction with the Federal response, it seems advisable to increase their demonstration to something more frequent than every six years. Currently the requirement calls for evaluating the post-plume phase objectives at least once every six years; State, tribal, and local government officials may demonstrate these functions more often if they choose. Recommendation 1.2: Reduce Frequency of Demonstration
The SRSC recommends that the frequency of Medical Services drills be reduced to once every two years. The SRSC recommends that post-plume phase activities be evaluated at least once in the six-year cycle. If more frequent demonstration of post-plume phase activities is desired, States may negotiate the evaluation of this activity as part of their six-year agreement (See Action D). FEMA will evaluate all other Evaluation Areas at least once per six-year exercise cycle at those organizations with responsibility as determined by the organization's plans and procedures. Each State, tribal, and/or local entity with multiple sites within its boundaries shall be evaluated at one site on a rotational basis according to the frequency indicated in Table 1. When not fully participating in an exercise at a site, the responsible organizations shall partially participate in exercises to support the full participation of appropriate governments. Table 1 indicates the recommended frequency for evaluation. Introduction to Recommendations 1.3, 1.4, and 1.5
Stakeholders indicated a desire for more flexibility for out-of- sequence demonstrations and the opportunity for direct feedback to exercise participants. They also sought the opportunity to correct issues during the demonstration for a more positive learning experience for participants. It is possible to perform numerous exercise evaluations out of sequence from the biennial exercises. Out-of- sequence demonstrations may be scheduled during the non-exercise year, at other times during the exercise year, and/or on another day during the exercise week. Recommendation 1.3: Negotiate Use of Out-of-Sequence Demonstrations
The SRSC recommends that FEMA and State, tribal, and local governments negotiate the use of out-of-sequence demonstrations of Evaluation Areas (within the specified evaluation frequency) as specified in Table 1. Recommendation 1.4: Give Direct Feedback
The SRSC recommends that Federal evaluators give direct feedback to exercise participants immediately following the exercise. These out- briefings should not attempt to detail the seriousness of any inadequacies observed, but should allow the evaluators to give positive feedback and to make general recommendations for improvement. Recommendation 1.5: Correct Issues Immediately
The SRSC recommends that immediate correction of issues identified be allowed during out-of-sequence activities, since most, if not all, would be conducted as drills or tabletop activities. For example, if inappropriate monitoring techniques were demonstrated, a State, tribal, or local trainer, in conjunction with the evaluator, could provide instruction on proper monitoring and then allow for immediate re- demonstration. The issue would be documented, if appropriate, as an Area Requiring Corrective Action (ARCA), with a statement documenting the completion of the corrective action. However, attempting immediate correction during an integrated exercise is not recommended as it may be disruptive and may possibly affect other Evaluation Areas. Introduction to Recommendation 1.6
At the present time, FEMA-REP-14 and -15 indicate that demonstration of objectives 32 and 33, unannounced and off-hours exercises and drills, may be satisfied by a response to an actual emergency. Stakeholders requested that the granting of credit for other exercise objectives be considered. Recommendation 1.6: Expand the Use of Credit
The SRSC recommends that FEMA Regional Directors be delegated the authority to approve the expanded use of credit for those Evaluation Area sub-elements identified in Table 1. Stakeholders will develop specific criteria for the approval of credit for actual events and/or other exercises during the implementation phase. Staff Assistance Visits may also be used to prepare documentation for granting of exercise credit by the Regional Director, as specified in Table 1.
Table 1.--Federal Evaluation Process Matrix
Out-of- sequence of Evaluation area
Consolidate
Frequency
exercise scenario
-
Emergency Operations Management... 1, 2, 3, 4, 5, 14, 17,
30
Mobilization of Response Personnel... ........................ Every Exercise......... No.
Facilities........................... ........................ Once if new ‹SUP›i.......... No.
Direction and Control................ ........................ Every Exercise......... No.
Communications Equipment............. ........................ Once if new ‹SUP›i.......... Yes.
Equipment and Supplies to Support ........................ Every Exercise......... Yes.
Operations.
-
Protective Action Decision Making. 5, 7, 9, 14, 15, 16, 17,
26, 28
Radiological Exposure Control........ ........................ Every Exercise......... Yes.
Development of Dose Projections and ........................ Every Exercise......... No.
Protective Action Recommendations
and Decisions.
Consideration for the Protection of ........................ Every Exercise......... No.
Special Populations.
Determination of Traffic and Access ........................ Every Exercise......... No.
Control.
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Dose Projection and Decision-making ........‹SUP›................ Once in 6 yrs.......... No.
for the Ingestion Exposure
Pathway.‹SUP›ii
Decisions Concerning Relocation, Re- ..................‹SUP›...... Once in 6 yrs.......... No.
entry, and Return.‹SUP›ii
-
Protective Action Implementation.. 5, 14, 15, 16, 17, 27,
29
Emergency Worker Exposure Control.... ........................ Every Exercise......... Yes.
Implementation of KI Decision........ ........................ Once in 6 yrs.......... Yes.
Actions to Limit Exposure of Special ........................ Once in 6 yrs.‹SUP›iii
Yes.
Populations.
Establishment of Traffic and Access ........‹SUP›................ 1 per Organization per Yes.
Control.‹SUP›iv
exercise.
Implementation of Ingestion Pathway ........................ Once in 6 yrs.......... No.
Decisions.
Implementation of Relocation, Re- ........................ Once in 6 yrs.......... No.
entry, and Return decisions.
-
Field Measurement and Analysis.... 6, 8, 24, 25
Ambient Radiation Monitoring......... ........................ Every Full
Yes.
Participation Exercise.
Airborne Radioiodine and Particulate ........................ Every Full
Yes.
Activity Monitoring.
Participation.
Collection and Analysis of
........................ Once in 6 yrs.......... Yes.
Environmental Samples.
-
Emergency Notification and Public 10, 11, 12, 13
Information.
Activation of the Prompt Alert and ....................‹SUP›.... Every exercise......... No.
Notification System.‹SUP›v
Activation of the Prompt Alert and 10...................... Separate Drill once in No.
Notification System (Fast Breaking).
6 yrs.
Development of Emergency Instructions ........................ Every exercise......... No.
Provision of information to the media ........................ Every exercise......... No.
Establishment of a Public Inquiry ........................ Every exercise......... No.
System.
-
Support Operations/Facilities..... 18, 19, 20, 21, 22
Monitoring, Decontamination and
..................‹SUP›...... Once in 6 yrs.......... Yes.
Registration of Evacuees and
Emergency Workers.‹SUP›iii
Monitoring and Decontamination of .......................‹SUP›. Once in 6 yrs.......... Yes.
Vehicles and Equipment.‹SUP›iii
Temporary Care of Evacuees ‹SUP›vi........ ........................ Once in 6 yrs.......... Yes.
Transportation and Treatment of
........................ Every 2 years.......... Yes.
Contaminated, Injured, and/or
Exposed Individuals.
‹SUP›i Will be evaluated if new or changed substantially.
‹SUP›ii The plume phase and the post-plume phase (ingestion, relocation, re-entry and return) can be demonstrated
separately.
‹SUP›iii All facilities must be evaluated once during the six-year exercise cycle.
‹SUP›iv Physical deployment of resources is not necessary.
‹SUP›v This sub-element does not address the ``fast-breaking'' scenario and the 15-minute requirement.
‹SUP›vi Facilities managed by the American Red Cross will be evaluated once when designated or when substantial changes occur, all other facilities must be evaluated once in the six-xercise cycle.
Action B. Increase Flexibility in Exercise Scenarios
Introduction to Recommendation 1.7
Stakeholders expressed concern that exercise scenarios were not realistic and did not offer sufficient flexibility for making the exercise a useful training activity. Currently, the scenario for a simulated nuclear power plant accident is developed jointly by the State and the licensee and is submitted to the Regional offices of NRC and FEMA for review. The FEMA RAC Chairperson reviews the scenario to confirm that the source term and scenario events are adequate to drive the agreed-upon exercise objectives. Recommendation 1.7: Implement New Options
The SRSC recommends that the following options be implemented in the development of exercise scenarios:
-
States may demonstrate their post-plume phase capabilities more frequently than once every six years. Demonstration criteria for this option would be developed during negotiations for the ``Six-Year Agreement'' (see Action D).
-
Mini-scenarios may be developed to support the increased participation of local responders.
-
Exercises may begin at any of the four emergency classification levels (ECL) and/or an ECL may be skipped to reflect a fast-breaking event.
-
The plume and post-plume phases of the exercise may be separated by days or months.
-
State, tribal, and local governments may provide a ``Trusted Agent'' to enhance development of the scenario and extent-of-play. A Trusted Agent is a staff member involved in exercise planning but not a member of the response team.
Action C. Annual Letter of Certification
Introduction to Recommendations 1.8, 1.9, and 1.10
The Annual Letter of Certification (ALC), submitted by the governor or the governor's designee, is a tool for State, tribal, and local governments to document periodic requirements that are used to confirm reasonable assurance. Currently, regional offices are not requiring the submittal of consistent information across the country. On the basis of guidance contained in Guidance Memorandum PR-1, the following documentation is requested:
‹bullet› Public Education and Information.
‹bullet› Emergency Facilities and Equipment.
‹bullet› Exercises.
‹bullet› Drills.
‹bullet› Radiological Emergency Response Training.
‹bullet› Updates of Plans and Letters of Agreement.
‹bullet› Alert and Notification.
Under the SRSC's recommendations, the ALC would become a critical component of a three-part comprehensive assessment process to confirm reasonable assurance. The ALC, in combination with the results of Federally evaluated exercises and Staff
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Assistance Visits, would be the basis for the reasonable assurance finding. Documentation would be submitted with the ALC or provided for review during a regularly scheduled Staff Assistance Visit. Recommendation 1.8: Revise ALC-related Regulations
The SRSC recommends that the importance of the ALC be emphasized by addressing it in a revision to the regulations. Recommendation 1.9: Revise ALC Submittal Requirements
The SRSC recommends the revision of ALC submittal requirements to support program changes. These requirements would be used for the review and approval of the ALC and would be consistently administered by all Regions. Recommendation 1.10: Verify ALC Documentation
The SRSC recommends that ALC documentation on file be verified during Staff Assistance Visits.
Action D. Provide Additional Approaches That Can Be Used in Conjunction With a Streamlined Program To Demonstrate and Confirm Reasonable Assurance
Introduction to Recommendation 1.11
Stakeholders requested a flexible approach for determining reasonable assurance. Stakeholders perceive that FEMA's confirmation of reasonable assurance is currently based primarily on the biennial exercise evaluation. The SRSC proposes that FEMA revise the process by which the adequacy of offsite emergency preparedness is demonstrated and confirmed. FEMA would continue to provide reasonable assurance to the NRC on a biennial basis. The finding of reasonable assurance would be a three-part comprehensive assessment process consisting of the ALC in combination with the results of federally evaluated exercises and Staff Assistance Visits. The documentation submitted in the ALC may be verified during regularly scheduled site visits.
FEMA's process for review and approval of State, tribal, and local emergency plans and preparedness at commercial nuclear power plants should also be improved. FEMA regulation 44 CFR Part 350 establishes policy and procedures to be utilized in the review, evaluation, and approval of State, tribal, and local governments' emergency plans and procedures. Currently, those sites that do not have a formal ``350'' approval, have been granted interim approval. The formal 350 approval process should be accelerated on the basis of demonstrated capability by State, tribal, and local organizations. A formal 350 approval will be required to take full advantage of the recommended program enhancements. Those sites without a formal 350 approval will be required to participate in an exercise biennially.
Full implementation of this recommendation will require a change to both NRC and FEMA regulations. The regulations currently require that an exercise of the offsite plans at each site be conducted biennially. Recommendation 1.11 (the six-year cycle) gives a State the option of foregoing the third biennial exercise; therefore, a rule change will be needed to accomplish the recommendation. Recommendation 1.11: Negotiate Six-Year Agreements
The SRSC recommends that FEMA negotiate with affected State, tribal, and local governments a six-year agreement for each site. These six-year agreements would identify all items to be completed by State, tribal, and local governments for the biennial confirmation of reasonable assurance. Agreements would be reviewed annually to reflect necessary changes. Successful completion of agreed-upon activities would result in the recommendation of a positive reasonable assurance finding. The FEMA Regional Director would issue the finding to the NRC Regional Administrator.
Government entities with formal 350 approval may choose to conduct and participate in an exercise three times during the six-year cycle or to participate in an exercise twice and, in lieu of a third exercise, negotiate the following alternatives with FEMA during development of the proposed six-year agreement:
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Evaluated Integrated Radiological Focus Drills--Included are dose assessment, radiological field monitoring, evacuee and emergency worker monitoring and decontamination, radiological exposure control, and radiological laboratories.
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Evaluated Drills--Involved are a combination of some of the Evaluation Areas of the offsite emergency response capabilities. The Evaluation Areas of emergency response include activities such as Emergency Operations Management, Protective Action Decision-making, Protective Action Implementation, Field Measurement and Analysis, Emergency Notification and Public Information, and Support Operations/ Facilities. Not all offsite facilities would need to participate in these drills. State, tribal, and local responders would have the opportunity to consider emergency response strategies, to provide supervised instruction, and to focus on training objectives.
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Evaluated Post-Plume Only Exercise--This exercise may be conducted as a tabletop activity.
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State Assessment--This option would be permitted for those jurisdictions below the State level. State personnel would not evaluate response organizations for which they have direct program responsibility. Areas for which State Assessment may be performed are schools, congregate care, special populations, training, and non- radiological drills. Results of all State Assessments would be documented in the ALC and would be available during Staff Assistance Visits.
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FEMA Verification and Program Reviews--This may be done through Staff Assistance Visits.
Post-plume phase response must be evaluated once within the six- year exercise cycle. Each government entity with multiple sites within its boundaries will rotate its full-participation exercises to ensure that all sites fully participate over a given period (the length of this period will depend on the number of sites in the government entity). When not fully participating in an exercise at a site, the government entity shall partially participate in exercises to support the full participation of appropriate local governments.
During the option year, governments will demonstrate correction of previously identified ARCAs in scheduled drills or through separate Staff Assistance Visits. Recommendation 1.12: Conduct Staff Assistance Visits
The SRSC recommends that FEMA REP personnel conduct Staff Assistance Visits to:
‹bullet› Review documentation of activities to verify capabilities for those exercise Evaluation Areas that can be determined by site visits as negotiated. This will include facility and equipment inspections. For example, several of the objectives require verification that appropriate equipment is available for emergency workers. The use of Potassium Iodide (Objective 14) requires the evaluator to confirm that sufficient doses exist to be given to all emergency workers and institutionalized individuals. In addition, monitoring equipment and dosimetry operation/maintenance verification is required on a regular basis (Objectives 5, 14, 16, 17, 18, 22, 24, and 25). Specific areas in
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which site visits would apply are contained in Table 1.
Assist responders with the development and submission of applications for credit for response to emergencies and participation in non-REP exercises. All applications would be submitted to the FEMA Regional Director for approval.
‹bullet› Attend exercise and drill training activities for informal comments and suggestions.
‹bullet› Participate in State, tribal, and local emergency training.
‹bullet› Review information and other documentation to verify ALC submissions.
Action E. Revise REP Policy and Guidance To Support a Streamlined Program
Introduction to Recommendations 1.13, 1.14, 1.15, and 1.16
Many commenters noted the need to update FEMA REP policy and guidance to include numerous changes that have occurred since the documents were published and to resolve inconsistencies with other guidance. Some commenters saw a need to revise guidance to recognize the evolution of emergency management since program inception.
Some examples of changes that are required are an update to reflect the Emergency Alert System (EAS) and the use of ``Special News Broadcasts'' and an update to ensure consistency with the current EPA- 400 ``Manual of Protective Action Guides.''
The SRSC has compiled a list of existing FEMA policy and guidance in Appendix 1. Recommendation 1.13: Develop a REP Program Handbook
The SRSC recommends that regulations, policy, and guidance governing administration of the REP Program be reviewed and that current operative guidance be identified. This operative guidance would be reviewed, revised, and updated. The revised material would form the basis for the development of a REP Program Handbook. Related technical manuals would be catalogued and referenced appropriately. Recommendation 1.14: Revise NUREG-0654/FEMA-REP-1
The SRSC recommends that NUREG-0654/FEMA-REP-1, Rev.1, be revised to reflect current technical standards and practices in emergency management. The FEMA/NRC MOU would also be updated appropriately to reflect changes. Recommendation 1.15: Review Guidance Annually
The SRSC recommends that FEMA Headquarters, in conjunction with the RAC AC and other Stakeholders, review all REP Program guidance, at least annually, and incorporate appropriate changes. Program guidance will no longer be issued through memoranda, but as changes to the REP Program Handbook. Recommendation 1.16: Post Guidance on the REP Home Page
The SRSC recommends that all REP Program guidance be posted on the REP Home Page.
Recommendation 2: Increase Federal Participation in REP Exercises
Issue
Stakeholders have consistently recognized the significant role of the Federal Government in preparing for and responding to radiological emergencies and the importance of Federal participation to assure that all partners receive the needed experience of operating as a team. Comments submitted during the Strategic Review process indicated a concern that, because of a lack of resources or due to other priorities, Federal representatives are not adequately fulfilling their radiological emergency preparedness responsibilities.
Background
The existing infrastructure for emergency response to a nuclear power plant accident has matured since the inception of the REP Program. The regulations and guidance assured that a coordinated response capability evolved between the nuclear power plant operator and the State and local organizations. The emergency response capability of the Federal government developed separately. This is satisfactory for the early hours of an emergency response since State, tribal, and local governments serve in a first responder role without assistance from the Federal government. It is expected that Federal assistance would arrive later, when the State, tribal, and local organizations would be strained and additional resources needed. Because the level of sophistication for post-plume phase response has developed at a slower rate (since post-plume phase exercises are required less frequently--every six years), the need for a coordinated response with the Federal government was not recognized in the first years of the program. After the experience of three or four post-plume phase exercises, the States have realized there is a missing partner in many of these exercises--the Federal Government. The Federal response will significantly change and enhance the response of the State, tribal, local, and operator participants. The post-plume phase exercises that are now being conducted without Federal participation are creating an inaccurate understanding of the later phases of an emergency. Occasionally, States have requested Federal participation in exercises and the Federal agencies have accommodated some of these requests.
Introduction to Recommendations 2.1, 2.2, 2.3, 2.4, 2.5, 2.6, and 2.7
To fully carry out their radiological responsibilities, Federal representatives need to be involved in both preparedness and response functions. In addition to evaluating exercises, they should be reviewing plans, conducting training, and developing and participating in various exercises. To do this more effectively, there should be a Federal entity that plays a stronger role in guaranteeing that Federal agencies fulfill their radiological responsibilities.
One of the problems identified was the confusion about the various response plans involved. The Federal Radiological Emergency Response Plan (FRERP) was drafted at the direction of Congress after the Three Mile Island accident and was finalized in 1985. In 1992, FEMA revised its emergency response policy and issued the Federal Response Plan (FRP) as an ``all hazards'' plan. With the publication of the new plan came questions regarding which plan FEMA intended to use to respond to radiological emergencies. FEMA indicated that the FRP was its standard method of response and FEMA committed to prepare an annex to the FRP that would explain how the two plans would be used simultaneously. A revision to the FRERP was published in 1996 that mentioned the relationship when both plans were being used at the same time, but the details were again left to be outlined in an annex to the FRP. To date, this annex has not been developed.
One of the reasons given by Federal agencies for not performing all of their radiological functions is the competing demands placed on them due to their membership in other Federal response committees. On the national level the primary groups are the National Response Team, the Catastrophic Disaster Response Group, the Emergency Support Function Leaders Group, and the FRPCC. On the Regional level the primary groups are the Regional Assistance Committees, the Regional Interagency Steering
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Committees, and the Regional Response Teams. The resource commitment for some Federal agencies could be even greater for agencies that have fewer than 10 Federal Regions or for those without a regional structure.
Comments reflected frustration, the lack of responsiveness to specific requests, and the insufficient technical capability within FEMA. Stakeholders felt that this resulted in an overreliance on contractor support to develop guidance. Some of this guidance appeared to be arbitrary and inconsistently applied in the FEMA Regions. The 15 member agencies of the FRPCC have sufficient capability to address technical issues in the REP Program. FEMA can take advantage of that capability and depend on the support of the FRPCC for response to technical requests.
The biggest obstacle to increased Federal participation, including RAC support, is insufficient resources. The appropriate management level of each affected agency (FEMA, Department of Energy, NRC, Environmental Protection Agency, U.S. Department of Agriculture, Department of Health and Human Services, Department of the Interior, Department of Transportation, Department of Defense, etc.) must agree to make this a priority and must ensure that internal procedures are developed to support increased participation. To create a true partnership, Federal agencies should regularly participate in post plume phase exercises to develop an integrated response.
Recommendation 2.1: Have FEMA Take the Lead Role
The SRSC recommends that FEMA take the lead role in planning and coordinating Federal agency participation in federally evaluated post- plume phase exercises. FEMA should meet with State, tribal, and local governments to identify those opportunities in which substantial Federal involvement is requested. FEMA should share this information with the other Federal agencies and help facilitate their involvement.
Furthermore, FEMA should coordinate the development of a comprehensive exercise schedule for full participation of Federal resources.
Recommendation 2.2: Complete the Radiological Incident Annex
The SRSC recommends that FEMA complete the development and incorporation of the Radiological Incident Annex to the FRP, to be followed by training or briefing of the Federal agencies in Headquarters and the Regions.
Recommendation 2.3: Establish an Interagency Taskforce
The SRSC recommends that an interagency task force be established to review the charters of the various response committees to determine if they can be streamlined or combined for efficiency and effectiveness in accordance with the National Performance Review. This may enable agencies to participate more extensively in Federal response planning and preparedness activities. This could also eliminate duplicate projects being conducted by separate planning groups and would enhance the understanding of other response plans among Federal responders.
Recommendation 2.4: Identify Additional Resources
The SRSC recommends that the FRPCC agencies identify additional resources to participate in a comprehensive exercise process and provide the resources necessary to coordinate and implement Federal participation in radiological preparedness and response activities.
Recommendation 2.5: Reinforce the FRPCC's Role
The SRSC recommends the reinforcement of the FRPCC's role in developing REP policy. A protocol, developed by FEMA, to refer technical questions to the FRPCC and its Subcommittees for resolution would serve as the vehicle for policy coordination. Issues emerging from exercise evaluations and plan reviews would be included in the protocol hierarchy.
Recommendation 2.6: Revise Training Courses
The SRSC recommends the conduct of a review and revision of the training courses sponsored by the FRPCC agencies for radiological preparedness and response. The level of experience in the States; new concepts in radiological response; and the response partnership of the facility, State, tribal, local, and Federal organizations, must be reflected in revised course material.
Recommendation 2.7: Facilitate Communications
The SRSC recommends that a REP-funded position be established in FEMA's Response and Recovery Directorate in order to facilitate communications between REP preparedness and response entities and to coordinate Federal response play in REP exercises.
Recommendation 3: Use State, Tribal, and Local Personnel as Federal Evaluators
Issue
Stakeholders indicated a desire to use State, tribal, and local personnel to augment FEMA's REP exercise evaluation teams. They felt that these employees would provide an experienced cadre that would result in an improved evaluation process and a reduction in exercise costs.
Background
At least five years ago, the National Emergency Management Association (NEMA) discussed the use of State personnel to augment FEMA's REP exercise evaluation teams. A Focus Group explored this issue again during the Kansas City Stakeholders Meeting in September 1997. Most of the basic concepts were introduced by the State participants who attended.
The first legal opinion on the subject was offered in a July 26, 1993, memorandum, which stated that FEMA lacked the authority to accept the gift of services and cover the expenses of State personnel as evaluators. On the basis of Stafford Act Amendments, a second legal opinion, which allowed the limited use of and compensation for State evaluators, was offered on April 29, 1996.
Based on a preliminary review of the concept, FEMA's Office of General Counsel (OGC) saw no substantial legal problems with the use of State, tribal, and local personnel as evaluators. Further legal precedent is also found in both the Chemical Stockpile Emergency Preparedness Program (CSEPP) and the Urban Search and Rescue (USAR) Program.
Introduction to Recommendations 3.1, 3.2, and 3.3
The use of State, tribal, and local personnel as FEMA evaluators could result in an overall cost benefit to the program. Such use would also improve partnership between FEMA and the State, tribal, and local governments. The non-Federal evaluator receives a different perspective on how another jurisdiction in a similar situation operates and a better understanding of the evaluation process.
Recommendation 3.1: Establish Conditions
The SRSC recommends that FEMA adopt the use of State, tribal, and local government personnel as evaluators under the following conditions:
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‹bullet› State, tribal, and local personnel would serve as evaluators outside their own jurisdictions.
‹bullet› FEMA is responsible for managing the evaluation team and paying invitational travel expenses. FEMA would make a written request for evaluators. FEMA's commitment would include all pre-determined transportation costs (air, private vehicle, rental car, parking, airport shuttle, etc.) and per diem expenses as stated in the individual invitational travel letter issued for each specific assignment.
‹bullet› The State, tribal, and local governments agree to maintain the costs of the employee's compensation package to include liability coverage (paid staff only, i.e., no volunteers).
‹bullet› State and tribal governments would maintain a ``Qualified and Available List'' of evaluators.
‹bullet› FEMA Regions would budget for expenses involved in use of State, tribal, and local evaluators. FEMA Headquarters would approve and transfer these funds.
Recommendation 3.2: Develop an MOU
The SRSC recommends that an MOU be developed between FEMA and the State, tribal, and local governments that addresses the relationship between FEMA and non-Federal evaluators.
Recommendation 3.3: Develop Qualification Standards
The SRSC recommends that the RAC AC develop non-Federal evaluator Qualification Standards. Evaluators would be subject to performance reviews after completing each exercise.
Recommendation 4: Include Native American Tribal Nations in the REP Preparedness Process
Issue
Stakeholders expressed concern that Native American tribal nations were not appropriately recognized as separate and sovereign entities within the REP Program.
Background
On April 29, 1994, President Clinton issued a memorandum to the heads of executive departments outlining the principles that executive departments and agencies, including every component bureau and office, were to follow in their interactions with Native American tribal governments. The President pointed out that ``The United States Government has a unique legal relationship with Native American tribal governments as set forth in the Constitution of the United States, treaties, statutes, and court decisions. As executive departments and agencies undertake activities affecting Native American tribal rights or trust resources, such activities must be implemented in a knowledgeable, sensitive manner respectful of tribal sovereignty.''
Introduction to Recommendations 4.1, 4.2, 4.3, and 4.4
On June 24, 1997, FEMA Director Witt presented the draft Agency policy on American Indian and Alaska Natives to tribal leaders on the Standing Rock Sioux Reservation. Following that historic meeting, letters were sent to leaders of all Federally recognized tribes, State governors, State emergency management directors, and national constituency and official organizations requesting their review and comments on the draft policy. On November 17, 1997, FEMA published the policy in the Federal Register for public comment. On February 17, 1998, FEMA published another Federal Register notice extending the comment period until March 15, 1998. Subsequently, an announcement of the Agency's consultation sessions on the draft policy was published in the Federal Register on March 6, 1998. Six officially announced sessions and three additional forums were organized by the Regional offices to consult with and gather input on the policy from more than 100 tribal leaders and representatives.
Recommendation 4.1: Identify Areas for REP Relationship
The SRSC recommends the conduct of a review of the FEMA American Indian and Alaska Native Policy to identify areas for Federal and tribal REP relationships in the REP Program.
Recommendation 4.2: Identify tribes in the EPZs
The SRSC recommends that RAC Chairpersons, in coordination with the regional tribal liaison, identify all Federally recognized tribes in the 10-and 50-mile EPZs of all nuclear power plant sites and determine how EPZ States and counties currently relate with the tribes.
Recommendation 4.3: Identify Current Policies and Practices
The SRSC recommends that FEMA coordinate with other Federal agencies, including the NRC and DOI, to identify current policies and practices in government-to-government relations.
Recommendation 4.4: Increase Tribal Involvement
The SRSC recommends that for those Regions with tribes in their EPZs, RAC Chairpersons and representatives from the NRC and the tribal governments develop an approach to increase tribal involvement in the REP Program.
Recommendation 5: Enhance the REP Training Program
Issue
Stakeholders recommended that an evaluator certification program be developed. The program was to have a very structured, formalized approach for the identification and recruitment of qualified evaluators.
Background
Current evaluator selection depends largely upon individual evaluator qualifications and on completion of the Emergency Management Institute (EMI) REP Exercise Evaluation course. Evaluators must be FEMA employees, FEMA Regional American Red Cross representatives, FEMA REP contractors, or employees of RAC departments or agencies. The Regions usually assign evaluators with existing qualifications in mind. The EMI REP Exercise Evaluation Course is the only formal training required for REP exercise evaluators.
Until 1998, instructional staff comprised the EMI course manager and two contract instructors. In 1998, EMI eliminated one contract instructor in favor of using two regional REP staff. The EMI implemented this change in order to have the students taught by FEMA staff involved in the program on a daily basis, to provide a growth opportunity to qualified regional REP staff, and to decrease costs.
The course is currently taught at EMI twice every fiscal year. The number of students in a class is limited to 36. Twenty-five slots are reserved for Federal evaluators in every class; the remainder of the class comprises State, local, or utility representatives. In the last two years no class has been completely filled. Enrollment has declined over the past several years because of market saturation; the course was conducted in the Regions and offsite a total of 12 times between 1992 and 1994. In addition, there is less job turnover.
FEMA staff and contractors represent the bulk of the audience in the REP Exercise Evaluation Course. The RAC agencies are less well represented. The National Emergency Training Center (NETC) Admissions Office maintains a database of participants who successfully complete the course.
Informally, some Regions require new evaluators to attend an exercise as observers or to work with another more experienced evaluator for one or two exercises.
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Introduction to Objectives 5.1, 5.2, 5.3, and 5.4
The current 4.5-day EMI course covers the role of the evaluator and all 33 exercise objectives with several related activities. Course material is based on FEMA-REP-14 and -15.
The following statement by EMI summarizes the current course:
A central theme of the course is to evaluate performance based on the relevant plan and procedures. All deviations are to be documented and reported to the team leader for disposition. The evaluator is the eyes and ears of FEMA and should not ignore what might, at first glance, appear to be unimportant events. Evaluators should not interfere with participants, but may be required to ask questions at appropriate (slow) times of the exercise. There should be no prompting or leading by evaluators. Course participants are cautioned to be courteous, tactful, and polite during the course of the evaluation. Furthermore, they are instructed not to characterize issues at any particular level.
A video-based tabletop exercise is used in which the participants evaluate one or two objectives. The completed checklists and narrative summaries are examined with each student, and the instructors make suggestions for improvement. This activity takes 1.5 days to complete.
A refresher training or advanced training course is not available. It is generally assumed that ongoing experience evaluating exercises will keep the skills fresh and that the regional REP staff will apprise the evaluators of changes in the process. Other REP training includes the REP Planning Course and the two Accident Assessment Courses. Radiological training courses are also available from other Federal agencies and private sources.
A common training program for all REP evaluators can help ensure consistent application of program guidance and policy. The REP Program Office and Regions should consider developing a REP Program Administration course for all FEMA REP staff. This course would give an overview of the revised REP Program, discuss use of job aids/procedures for granting exercise credit, negotiating extent of play agreements, ALC review, and other aspects of the post-Strategic Review REP Program. The SRSC believes this would help ensure program consistency and provide a formal training setting, which has advantages over on-the-job training.
Recommendation 5.1: Establish Qualification Standards
The SRSC recommends that qualification standards be established for REP exercise evaluators, in conjunction with the standards outlined in Recommendation 3.3. Before establishing such standards, the required knowledge, skills, and abilities should be identified and an enhanced training curriculum for REP staff and evaluators should be developed. However, the establishment of a formal certification program for Federal evaluators is not recommended.
Recommendation 5.2: Increase Training Opportunities
The SRSC recommends that opportunities for FEMA REP staff to teach evaluator training be increased.
Recommendation 5.3: Revise Radiological Courses
The SRSC recommends that current radiological courses be revised as required by the outcomes of the REP Strategic Review, and that REP training course development, revision, and delivery be included in the REP budget.
Recommendation 5.4: Develop an Administration Course
The SRSC recommends the development of a REP Program Administration Course for all FEMA REP staff.
Appendix 1--Existing Federal Emergency Management Agency Radiological Emergency Preparedness (REP) Policy and Guidance
Some of the material in the documents cited is out of date. Where possible, this has been noted.
There also may be some redundancy in this list. One particular document may provide more detail than another, and, thus, is listed.
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FEMA-REP-Series Documents
``Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,'' U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, NUREG-0654/FEMA-REP-1, Rev. 1, Washington D.C., November 1980.
``Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants--Criteria for Utility Offsite Planning and Preparedness, Final Report,'' U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, NUREG-0654/FEMA-REP-1, Rev. 1, Supp. 1, Washington D.C., September 1988.
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Criteria for Emergency Planning in an Early Site Permit Application,'' Draft Report for Comment, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, NUREG-0654/FEMA-REP-1, Rev. 1, Supp. 2, Washington D.C., April 1996.
``Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants--Criteria for Protective Action Recommendations for Severe Accidents,'' Draft Report for Interim Use and Comment, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, NUREG-0654/FEMA-REP-1, Rev. 1, Supp. 3, Washington D.C., July 1996.
``Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1--Airborne Release,'' FEMA-REP-2, Rev. 2, June 1990.
``Guidance for Developing State, Tribal, and Local Radiological Emergency Response Planning and Preparedness for Transportation Accidents,'' FEMA-REP-5, Rev. 1, June 1992.
``Exercise Evaluation and Simulation Facility Evacuation Events Models: Part 1--PREDYN Users Guide,'' FEMA-REP-6, April 1984.
``Exercise Evaluation and Simulation Facility Evacuation Events Model: Part II--Users Manual,'' FEMA-REP-7, April 1984.
``Application of the I-DYNEV System (To Compute Estimates of Evacuation Travel Time at Nuclear Power Stations),'' FEMA-REP-8, December 1984.
``Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants,'' FEMA-REP-10, November 1985.
``Guidance on Offsite Emergency Radiation Measurement Systems, Phase 2--The Milk Pathway,'' FEMA-REP-12, September 1987.
``Guidance on Offsite Emergency Radiation Measurement Systems, Phase 3--Water and Non-Dairy Food Pathway,'' FEMA-REP-13, May 1990.
``Radiological Emergency Preparedness Exercise Manual,'' FEMA- REP-14, September 1991.
``Radiological Emergency Preparedness Exercise Evaluation Methodology,'' FEMA-REP-15, September 1991.
``Emergency Response Resources Guide for Nuclear Power Plant Emergencies,'' NUREG-1442/FEMA-REP-17, Rev.1, July 1992.
``Statements of Consideration for FEMA-REP-14 and FEMA-REP-15,'' FEMA-REP-18, January 1992.
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Guidance Memoranda
GM IT-1. ``A Guide to Documents Related to the REP Program,'' October 1, 1985.
GM 4. ``Radio Transmission Frequencies and Coverage,'' April 1, 1980.
GM 5. ``Agreements Among Governmental Agencies and Private Parties,'' Rev. 1, October 19, 1983.
GM 8. ``Regional Advisory Committee Coordination with Utilities,'' Rev. 1, October 19, 1983.
GM 16. ``Standard Regional Reviewing and Reporting Procedures for State and Local Radiological Emergency Response Plans,'' August 7, 1980.
GM 20. ``Foreign Language Translation of Public Education Brochures and Safety Messages,'' Joint FEMA/NRC Issuance, October 19, 1983.
GM 21. ``Acceptance Criteria for Evacuation Plans,'' February 27, 1984.
GM 22. ``Recordkeeping Requirements for Public Meetings,'' October 19, 1983.
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GM 24. ``Radiological Emergency Preparedness for Handicapped Persons,'' April 5, 1984.
GM PI-1. ``FEMA Action to Pilot Test Guidance on Public Information Materials and Provide Technical Assistance On Its Use,'' October 2, 1985.
GM FR-1. ``Federal Response Center,'' December 3, 1985.
GM AN-1. ``FEMA Action to Qualify Alert and Notification Systems Against NUREG-0654/FEMA-REP-1 and FEMA-REP-10,'' April 21, 1987.
GM EV-2. ``Protective Actions for School Children,'' November 13, 1986. Note: Guidance in FEMA-REP-14 superseded pages 6-13 concerning the following: (1) Clarification of guidance related to the demonstration of protective action capabilities for schools in exercises, and (2) modifications to the set of questions as reflected in the Points of Review and Demonstration Criteria in Objective 16 of FEMA-REP-15.
GM IN-1. ``The Ingestion Exposure Pathway,'' February 26, 1988. Note: Guidance in FEMA-REP-14 and FEMA-REP-15 superseded pages 12- 17.
GM PR-1. ``Policy on NUREG-0654/FEMA-REP-1 and 44 CFR Periodic Requirements,'' October 1, 1985. Note: Guidance in FEMA-REP-14 superseded two parts of the guidance contained in GM PR-1. These two changes were: (1) The provision set forth on page 3 (section 3) for partial participation in ingestion exercises for States with multiple sites located within their borders has been terminated. Per guidance provided in the Manual, such States would only need to partially participate in ingestion exercises when full participation exercises are conducted in bordering States, and (2) During the year in which the full-participation exercise is held at one of the sites, the responsible State and local governments should review their plans and procedures for the other sites within the State to verify their accuracy and completeness. This review should validate the identification of farms, food processors and distributors. This review and any resultant revisions should be made and reported in the Annual Letter of Certification, as described in GM PR-1, as part of their annual review and plan update.
GM MS-1. ``Medical Services,'' November 13, 1986. Note: Guidance contained in Sections D.20 and D.21 of the Manual superseded GM MS-1 with respect to the following: (1) Minimum staffing for medical facilities, (2) deferral of radiological monitoring by transportation providers to medical facility staff, and (3) the role of licensee personnel in supporting State and local government medical services functions.
GM RG-2. ``Guidance for FEMA Regional Implementation of the FEMA Rule,'' 44 CFR Part 352, February 8, 1993.
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Additional Memoranda of Importance
Memorandum from Richard Krimm to Frank Finch dated 5/17/85, on ``Congregate Care Facilities.''
Memorandum from Richard Krimm to NTH Division Chiefs, FEMA Regional Offices dated 12/24/85, on ``Guidance on NUREG-0654/FEMA- REP-1 Evaluation Criterion J.12.''
Memorandum from Richard Krimm to Frank Begley dated 2/2/87 on ``24-hour Staffing Capability.''
Memorandum from Richard Krimm to Frank Begley dated 9/23/87 on ``Alternate Emergency Operations Center (EOC).''
Memorandum from Richard Krimm to Frank Begley dated 12/9/87, on ``Quad Cities Emergency Planning Zone (EPZ) Boundary Determination (split jurisdiction).''
Memorandum from Richard Krimm to Frank Begley dated 1/5/88, on ``Radiological Monitoring.''
Memorandum from Richard Krimm to NTH Division Chiefs dated 2/9/ 88, on ``Clarification of Selected Provisions of Guidance Memorandum (GM) MS-1, Medical Services.''
Memorandum from Richard Krimm to Frank Begley dated 2/26/88 on ``Annual Letter of Certification.''
Memorandum from Grant Peterson to Regional Directors dated 3/7/ 88, on ``Guidelines for Regions to Use In Implementing NUREG-0654/ FEMA-REP-1, Rev. 1, Supplement 1, With Qualifying Exercises.''
Memorandum from Richard Krimm to Frank Begley dated 5/25/88 on ``Relocation Centers.''
Memorandum from Richard Krimm to Frank Begley dated 9/19/88, on ``Medical Services and Radiological Monitoring Guidance.''
Memorandum from Craig Wingo to William Fucik dated 9/20/88 on ``FEMA Policy Concerning Receiving Schools Around the Perry Island NPS.''
Memorandum from Richard Krimm to Frank Begley dated 9/22/88 on ``Interpretation of 'Shall' and 'Should' as Used in NUREG-0654/FEMA- REP-1 and Off-Hours Unannounced Drills/Exercises.''
Memorandum from Richard Krimm to Glenn Woodard dated 9/30/88 on ``Clarification of Annual Medical Emergency Drill Provisions for States with Separate Sets of Primary and Backup Medical Facilities.''
Memorandum from Richard Krimm to Frank Begley dated 12/7/88, on ``Landmark Descriptions.''
Memorandum from Grant Peterson to Paul Giordano dated 12/7/89, on ``Guidance on Ingestion Pathway Exercises.''
Memorandum from Grant Peterson to Regional Directors dated 1/12/ 90 on ``Distribution and Use of the Generic Ingestion Pathway Brochure, entitled ``Radiological Emergency Information.''
Memorandum from Frank Begley to Kenneth V. Miller (Missouri Department of Health) dated 3/23/90 on ``Exercise Demonstration of Two Radiological Monitoring Field Teams.''
Memorandum from Dennis Kwiatkowski to William Tidball dated 11/ 2/90 on ``Request from the State of New York for Waiver of Self- Reading Dosimetry Requirements for Emergency Workers.''
Memorandum from Dennis Kwiatkowski to Stephen Harrell dated 1/ 16/92, on ``Response to Request From Region VII for Resolution of Radiological Emergency Preparedness (REP) Program Issues, including Radiological Monitoring for 20 percent of the population; Ingestion Pathway Exercises; Dosimetry and Protective Clothing; Medical Care of Nursing Home and Medically Dependent Hospital Evacuees; Portal Monitors.''
Memorandum from Dennis Kwiatkowski to Walter Pierson dated 3/26/ 92 on ``Response to Region III's Request for Guidance on Ingestion Pathway Exercise Demonstration.''
Memorandum from Dennis Kwiatkowski to Walter Pierson dated 5/15/ 92, on ``Objective 13: Alert, Notification, and Emergency Information--Public Instructions.''
Memorandum from Dennis Kwiatkowski to Robert Adamcik dated 1/13/ 93, on ``Pennsylvania Emergency Management Agency Request for Clarification of FEMA-REP-14 Dosimetry Requirements Under Objective 5, Emergency Worker Exposure Control.''
Memorandum from Craig Wingo to Stephen Harrell dated 3/5/93, on ``Response to Policy Clarification on Radiological Emergency Planning for Day Care Centers.''
Memorandum from H. Joseph Flynn, (FEMA) Associate General Counsel for Program Law, to Richard W. Krimm, dated 4/30/93, on ``Legal Opinion on Letters of Agreement.''
Memorandum from Margaret Lawless to RAC Chairs dated 6/25/93 on ``Guidance on Planning Requirements Whenever Changes are Made to Existing 10-Mile EPZs.'' (contains memorandum from Craig Wingo to Stephen Harrell dated 6/24/93 on ``Request for Guidance on Areas Beyond the 10 mile EPZ Ring.'')
Memorandum from Richard Krimm to Regional Directors dated 9/14/ 93 on ``Technical Review of REP Exercise Scenarios.''
Memorandum from Richard Krimm to Regional Directors dated 10/13/ 93 on ``Adequate Demonstration of Objective 16 at Radiological Emergency Preparedness Exercises.''
Memorandum from Delbert Kohl to Charles Biggs dated 3/28/94 on ``Clarification of Communication Equipment Needed by Field Monitoring Teams for Radiological Emergency Preparedness.''
Memorandum from Joe Flynn to Dennis Kwiatkowski dated 4/6/94 on ``Impact of OSHA's HAZMAT Standard on REP Program.''
Memorandum from Delbert Kohl to Stuart Rifkind dated 5/27/94 on ``Ingestion Planning--Indiana.''
Memorandum from Dennis Kwiatkowski to Regional Directors, Regions I-X, dated 7/25/94, on ``Environmental Protection Agency's (EPA) Manual of Protective Action Guides (PAGs) and Protective Actions for Nuclear Incidents (EPA 400-R-92-001).''
Memorandum from Robert Fletcher to Stuart Rifkind dated 11/9/94 on ``Clarification on Alert and Notification System--the Order of Sirens and EBS Messages.''
Memorandum from Robert Fletcher to Rita Calvan dated 12/12/94 on ``FEMA Review and Approval Process for the Susquehanna Steam Electric Station Offsite Radiological Emergency Plans and Preparedness.''
Memorandum from Dennis Kwiatkowski to Robert Adamcik dated 12/ 13/94 on
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``Pennsylvania Emergency Management Agency Request for Exemption from REP-14 and REP-15 EBS Provisions.''
Memorandum from Robert Fletcher to Charles Biggs dated 2/23/95 on ``Request for Exemption on Back-up Medical Facilities.''
Memorandum from Robert Fletcher to Charles Biggs dated 3/9/95 on ``EPA Manual of Protective Action Guides and Retrospective Determinations of Total Dose.''
Memorandum from Bill Wark to Larry Bailey dated 6/6/95 on ``Evaluation of Activities at Designated Radio/Television Stations That Broadcast Emergency Messages.''
Memorandum from William Wark to Joseph Dominguez, dated 2/21/96, on ``Annual Distribution of Emergency Information to the Public.''
Memorandum from William Wark to Joseph Dominguez, dated 4/12/96, on ``Precautionary Evacuation for the Emergency Planning Zone (EPZ) of the Diablo Canyon Site.''
Memorandum from Vern Wingert to Larry Robertson dated 8/21/96 on ``Dosimeter Guidance for Emergency Workers.''
Memorandum from Kay Goss to Regional Directors dated 12/23/96 on ``Forwarding of Draft Agency Guidance to Clarify REP Policy on Use of Dosimeters by Bus Drivers.''
Memorandum from Kay Goss to Regional Directors dated 1/10/97 on ``Purpose of Memo and Draft Guidance on the Use of Dosimetry by Bus Drivers.''
Letter from Woodie Curtis to Paul Schmidt (Wisconsin Department of Health and Social Services) dated 3/7/97 on ``Several Technical Issues.''
Memorandum from Ihor Husar to Eric Jenkins dated 3/5/98on ``Review and Determination on the Nebraska Emergency Management Agency's Petition to Delete Nemaha County Hospital From the Nebraska Radiological Emergency Response Plans (Cooper Nuclear Station).''
Memorandum from Kay Goss to Regional Directors, dated 4/2/98on ``Interim-Use Guidance for Providing Information and Instructions to the Public for Radiological Emergencies Using the New Emergency Alert System (EAS).''
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FEMA Policy Statements
``Policy Statement on Respiratory Protection,'' Federal Emergency Management Agency, November 22, 1985.
``Policy Statement on the Use of NUREG-0654/FEMA-RP-1 and Guidance Memoranda,'' Federal Emergency Management Agency, September 21, 1988.
``Policy Statement on Disposal of Waste Water and Contaminated Products from Decontamination Activities,'' Federal Emergency Management Agency, January 1989.
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Other Basic and Pertinent Guidance
``Potassium Iodide as a Thyroid-Blocking Agent in a Radiation Emergency: Final Recommendations on Use,'' Food and Drug Administration, U.S. Department of Health and Human Services, 47 FR 28,158, June 29, 1982.
``Accidental Radioactive Contamination of Human Food and Animal Feeds: Recommendations for State and Local Agencies,'' Food and Drug Administration, U.S. Department of Health and Human Services, 47 FR 47,073, October 22, 1982.
Note: Revised FDA Protective Action Guides are due to be published in late May 1998.
``Federal Policy on Distribution of Potassium Iodide Around Nuclear Power Sites for Use as a Thyroidal Blocking Agent,'' Federal Emergency Management Agency, 50 FR 30,258, July 24, 1985.
``Mass Care--Preparedness and Operations, Disaster Services Regulations and Procedures,'' ARC 3031, American Red Cross (ARC), Washington, DC, April 1987.
``Federal Response Plan (FRP),'' Federal Emergency Management Agency, FEMA 229, April 1992.
``Manual of Protective Action Guides and Protective Actions for Nuclear Incidents,'' U.S. Environmental Protection Agency (EPA), EPA 400-R-02-001, May 1992.
``Emergency Planning and Preparedness for Nuclear Power Reactors,'' NRC Regulatory Guide 1.101 Rev.3, August 1992.
``Memorandum of Understanding between Federal Emergency Management Agency and Nuclear Regulatory Commission,'' 58 FR 47,996, Sept. 14, 1993.
Note: This MOU, which was entered into June 17, 1993, supersedes all previous FEMA/NRC MOU's.
``Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response,'' Federal Emergency Management Agency, March 1995.
``Federal Radiological Emergency Response Plan (FRERP),'' Federal Emergency Management Agency, May 1, 1996.
``Respiratory Protection,'' Occupational Safety and Health Administration, 29 CFR 1910.134.
``Respiratory Protection--A Manual and Guideline,'' 2nd edition, Publication #63PC91, American Industrial Hygiene Association (AIHA), Fairfax, VA.
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Background Material
``Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants,'' NUREG-0396, EPA 520/1-78-016, Nuclear Regulatory Commission and Environment Protection Agency, December 1978.
``Background for Protective Action Recommendations: Accidental Radioactive Contamination of Food and Animal Feeds,'' Food and Drug Administration, U.S. Department of Health and Human Services, August 1982. DHHS Publication FDA 82-8196.
``Personal Dosimetry Performance Criteria for Testing,'' American National Standards Institute, Standard N13.11-1983. ``Criteria for Protective Action Recommendations for General Emergencies,'' NRC Information Notice 83-28, May 1983.
``Preparedness and Response in Radiation Accidents,'' Food and Drug Administration, U.S. Department of Health and Human Services, August 1983. DHHS Publication FDA 83-82111.
Memorandum from Richard Krimm to Glenn Woodard dated 4/22/86 on ``Clarification of the 15-Minute Design Objective for Alert and Notification Systems.''
``Evacuation: An Assessment of Planning and Research,'' RR-9, Federal Emergency Management Agency, November 1987.
``Management of Persons Accidentally Contaminated with Radionuclides,'' National Council of Radiation Protection, Report No. 65, 1979.
``Check List for Review and Evaluation of Emergency Public Information Brochures for Ingestion Pathway Measures,'' Federal Emergency Management Agency, July 1990 (contains cover memorandum from Grant Peterson to Regional Directors dated 6/12/90).
``Response Technical Manual (RTM-91),'' NUREG/BR-0150, Vol. 1, Rev. 1, U.S. Nuclear Regulatory Commission, April 1991.
``State of the Art in Evacuation Time Studies for Nuclear Power Plants,'' NUREG/CR4831, NNL-776, March 1992.
``Resources Available for Nuclear Power Plant Emergencies Under the Price-Anderson Act and Robert T. Stafford Disaster Relief and Emergency Assistance Act,'' NUREG-1457, July 1992.
``Repair and Maintenance Manuals for Radiological Instruments,'' CPG 4-1, Vols. 1-10, Federal Emergency Management Agency, July 20, 1992.
``American National Standard for Respiratory Protection,'' ANSI 288.2-1992, American National Standards Institute, NY, NY.
``RG REP 05, Rev. 1, REP Evacuation Time Study Review Guide (Checklist),'' Federal Emergency Management Agency, April 1993.
``Emergency Alert System,'' CPG 1-40, Federal Emergency Management Agency, June 1996.
``Emergency Alert System: A Program Guide for State and Local Governments,'' CPG 1-41, Federal Emergency Management Agency, June 1996. Memorandum from Kay Goss to All Regional Directors dated 11/ 25/96 on ``Disposition of FEMA-Owned Radioactive Sources in the States.''
``RG REP 02, Rev. 8, REP Annual Letter of Certification Review Guide (Checklist),'' Federal Emergency Management Agency, October 1997. Memorandum from Kay Goss to All Regional Directors dated 6/23/ 97 on ``Monitoring of Radiation Exposure by States.''
Dated: August 31, 1998. Kay C. Goss, Associate Director for Preparedness, Training, and Exercises.
[FR Doc. 98-24153Filed9-8-98; 8:45 am]
BILLING CODE 6718-20-P
