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

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/fr%3A98-24153

## Record

- **Collection:** Federal Register
- **Document type:** Notice
- **Published:** September 9, 1998
- **Citation:** 63 FR 48222

## Text

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) [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

[[Page 48226]]

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

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A98-24153. Public record. Not legal advice.