Publication of Radiological Emergency Preparedness (REP) Program Strategic Review Draft Final Recommendations

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.

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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) [email protected].

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) [email protected].

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

[[Page 48223]]

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:

Reviews and approves State and local government plans for

preparing for and responding to a commercial nuclear power plant

incident.

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.

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.

Conducts training courses pertaining to the evaluation of

State and local government radiological emergency planning and

preparedness.

Reviews and approves State and local government systems

for the alert and notification of the public in the event of a

radiological emergency.

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

[[Page 48224]]

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:

Reviews and approves State and local government plans.

Evaluates State and local biennial exercises of these

plans.

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.

Conducts training courses.

Approves State and local Alert and Notification systems.

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

[[Page 48225]]

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:

1. Emergency operations management. This Evaluation Area contains

elements involved in the overall management of the emergency response

operations to include:

Mobilization of Response Personnel.

Facilities.

Direction and Control.

Communications.

Equipment and Supplies Necessary to Support Operations.

2. 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:

Radiological Exposure Control.

Development of Dose Projections and Protective Action

Recommendations and Decisions, Including Ingestion of Potassium Iodide

(KI).

Consideration for the Protection of Special Populations.

Determination of Traffic and Access Control Points.

Dose Projection and Decisionmaking for the Ingestion

Exposure Pathway.

Decisions Concerning Relocation, Re-entry, and Return.

3. Protective action implementation. This Evaluation Area contains

the implementation of all protective action decisions to include:

Emergency Worker Exposure Control.

Implementation of KI Decision.

Actions to Limit Exposure of Special Populations.

Establishment of Traffic and Access Control.

Implementation of Ingestion Pathway Decisions.

Implementation of Relocation, Re-entry, and Return

Decisions.

4. 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:

Ambient Radiation Monitoring.

Airborne Radioiodine and Particulate Activity Monitoring.

Collection and Analysis of Environmental Samples.

5. 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:

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.

Development of Emergency Instructions.

Provision of Information to the Media.

Establishment of a Public Inquiry System.

6. 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:

Monitoring, Decontamination and Registration of Evacuees

and Emergency. Workers.

Monitoring and Decontamination of Vehicles and Equipment.

Care of Evacuees.

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

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Out-of- sequence of

Evaluation area Consolidate Frequency exercise scenario

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A. Emergency Operations Management... 1, 2, 3, 4, 5, 14, 17,

30

Mobilization of Response Personnel... ........................ Every Exercise......... No.

Facilities........................... ........................ Once if new i.......... No.

Direction and Control................ ........................ Every Exercise......... No.

Communications Equipment............. ........................ Once if new i.......... Yes.

Equipment and Supplies to Support ........................ Every Exercise......... Yes.

Operations.

B. 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.

[[Page 48227]]

Dose Projection and Decision-making ........................ Once in 6 yrs.......... No.

for the Ingestion Exposure

Pathway.ii

Decisions Concerning Relocation, Re- ........................ Once in 6 yrs.......... No.

entry, and Return.ii

C. 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.iii Yes.

Populations.

Establishment of Traffic and Access ........................ 1 per Organization per Yes.

Control.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.

D. 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.

E. Emergency Notification and Public 10, 11, 12, 13

Information.

Activation of the Prompt Alert and ........................ Every exercise......... No.

Notification System.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.

F. Support Operations/Facilities..... 18, 19, 20, 21, 22

Monitoring, Decontamination and ........................ Once in 6 yrs.......... Yes.

Registration of Evacuees and

Emergency Workers.iii

Monitoring and Decontamination of ........................ Once in 6 yrs.......... Yes.

Vehicles and Equipment.iii

Temporary Care of Evacuees vi........ ........................ Once in 6 yrs.......... Yes.

Transportation and Treatment of ........................ Every 2 years.......... Yes.

Contaminated, Injured, and/or

Exposed Individuals.

----------------------------------------------------------------------------------------------------------------

i Will be evaluated if new or changed substantially.

ii The plume phase and the post-plume phase (ingestion, relocation, re-entry and return) can be demonstrated

separately.

iii All facilities must be evaluated once during the six-year exercise cycle.

iv Physical deployment of resources is not necessary.

v This sub-element does not address the ``fast-breaking'' scenario and the 15-minute requirement.

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:

a. 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).

b. Mini-scenarios may be developed to support the increased

participation of local responders.

c. 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.

d. The plume and post-plume phases of the exercise may be separated

by days or months.

e. 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:

Public Education and Information.

Emergency Facilities and Equipment.

Exercises.

Drills.

Radiological Emergency Response Training.

Updates of Plans and Letters of Agreement.

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

[[Page 48228]]

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:

a. 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.

b. 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.

c. Evaluated Post-Plume Only Exercise--This exercise may be

conducted as a tabletop activity.

d. 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.

e. 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:

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

[[Page 48229]]

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.

Attend exercise and drill training activities for informal

comments and suggestions.

Participate in State, tribal, and local emergency

training.

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

[[Page 48230]]

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:

[[Page 48231]]

State, tribal, and local personnel would serve as

evaluators outside their own jurisdictions.

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.

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).

State and tribal governments would maintain a ``Qualified

and Available List'' of evaluators.

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.

[[Page 48232]]

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.

1. 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.

2. 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.

[[Page 48233]]

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.

3. 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

[[Page 48234]]

``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 3/5/98 on

``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 4/2/98 on

``Interim-Use Guidance for Providing Information and Instructions to

the Public for Radiological Emergencies Using the New Emergency

Alert System (EAS).''

4. 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.

5. 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.

6. 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. 98-24153 Filed 9-8-98; 8:45 am]

BILLING CODE 6718-20-P