PROGRAM MANUAL RADIOLOGICAL EMERGENCY PREPAREDNESS OCTOBER 2011 ADMINISTRATOR’S FOREWORD Over the past 31 years, FEMA’s Radiological Emergency Preparedness (REP) Program evolved in size and scope. This program adapted to structural and mission changes by incorporating new missions and organizations, transferring functions as necessary, while still maintaining the public health and safety surrounding a nuclear power plant. Regardless of changes to our mission and structure, the fundamental character, inspiration, and motivation of the REP Program remains the same: The desire to serve our Nation by helping our people and first responders, especially when they are most in need. As we continue to improve FEMA's REP Program, we must view all the work FEMA does in concert with the emergency management community as part of a broad plan for addressing the demands and challenges of a catastrophic disaster. To ensure our efforts become part of an interconnected plan of action, we are focused on our "Whole Community" initiative. This initiative will continue to effectively leverage the capabilities both governmental and non-governmental entities play in preparing for a catastrophic disaster. "Whole Community" uses planning assumptions for catastrophic disasters based on the worst case scenarios. These scenarios challenge preparedness at all levels of government and force innovative non-traditional solutions as part of the response strategy to such events. As the name of the initiative indicates, it is truly the whole community that must be prepared to respond in ways that extend beyond the previous paradigms in which we have traditionally operated.  While preparedness is critical in saving and sustaining lives, the “Whole Community” approach spans not only prevention and protection before a disaster, but also recovery, response operations, and mitigation activities that occur before, during and after a catastrophic event. Our experiences helped us realize and appreciate the important role that state, local and tribal governments play in disaster preparedness, response and recovery. FEMA’s success with the REP Program is heavily dependent upon our ability to communicate, coordinate, and work closely together building on the strengths of local communities and citizens and integrating the public as a critical resource. Each emergency preparedness plan addresses unique considerations that exist in the event of a catastrophic incident at a commercial nuclear power plant. We believe that your radiological emergency response plans are a part of your comprehensive emergency management program. This provides a “Whole Community” approach to strengthen your community’s preparedness against any catastrophic event. Most importantly, we know of the great capacity of individuals to care for their families, friends, neighbors and fellow community members, making our citizens force multipliers rather than liabilities. Together, we make up the “Whole Community”, and we all have an important role to play. We must engage all of our societal capacity, both within and beyond FEMA, to work together as a team. W. Craig Fugate Administrator CONTENTS Part I: Introduction to the Radiological Emergency Preparedness Program Manual A. Purpose B. Scope C. Basis of the REP Program 1. Establishment of the REP Program 2. Programmatic Changes D. Evaluation of Radiological Emergency Preparedness 1. NRC-FEMA Memorandum of Understanding 2. Specific FEMA Review and Approval Procedures 3. Alternative Approaches and Methods 4. Federal Delegation of Tasks 5. Planning and Preparedness Assessment Strategy E. Technical Basis for the REP Program 1. Nature of the Hazard 2. Protective Actions to Reduce Exposure to Radiation 3. Protective Action Guides 4. Emergency Planning Zones 5. Radiological Incident Phases Part II: REP Program Planning Guidance A. Introduction 1. Purpose and Scope 2. Contents and Organization B. Planning Standards C. Planning Guidance 1. Planning Standard A – Assignment of Responsibility (Organization Control) 2. Planning Standard B – On-site Emergency Organization 3. Planning Standard C – Emergency Response Support and Resources 4. Planning Standard D – Emergency Classification System 5. Planning Standard E – Notification Methods and Procedures 6. Planning Standard F – Emergency Communications 7. Planning Standard G – Public Education and Information 8. Planning Standard H – Emergency Facilities and Equipment 9. Planning Standard I – Accident Assessment 10. Planning Standard J – Protective Response 11. Planning Standard K – Radiological Exposure Control 12. Planning Standard L – Medical and Public Health Support 13. Planning Standard M – Recovery and Reentry Planning and Post-Accident Operations 14. Planning Standard N – Exercises and Drills 15. Planning Standard O – Radiological Emergency Response Training 16. Planning Standard P – Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans Part III: REP Program Demonstration Guidance A. Introduction 1. Contents and Organization 2. Background B. REP Exercise Process 1. Scheduling REP Activities 2. Conducting Pre-planning Activities 3. Developing REP Exercise Documents 4. Holding Exercise Planning Meetings 5. Conducting REP Exercises 6. Documenting REP Exercises 7. REP Program Credit for Participation in Actual Incidents C. Exercise Demonstration D. Evaluation of Medical Services Drills Part IV: FEMA REP Program Administration A. Introduction B. Regulatory Summary 1. 44 CFR Part 350 – Review and Approval of State and Local Radiological Emergency Plans and Preparedness 2. 44 CFR Part 351 – Radiological Emergency Planning and Preparedness 3. 44 CFR Part 352 – Commercial NPP: Emergency Preparedness Planning 4. 44 CFR Part 353 – Fee for Services in Support, Review, and Approval of State and Local Government or licensee Radiological Emergency Plans and Preparedness 5. 44 CFR Part 354 – Fee for Services to Support FEMA’s Offsite REP Program C. Non-participating State, Tribal, and Local Governments (NUREG-0654/FEMA-REP-1, Supplement 1 D. Early Site Permit Applications (NUREG-0654/FEMA-REP-1, Supplement 2) E. Protective Action Strategies (NUREG-0654/FEMA-REP-1, Supplement 3) F. Exercise Methodology, More Challenging Drills and Exercises, and Backup Alert and Notification Requirements (NUREG-0654/FEMA-REP-1, Supplement 4) G. Target Capabilities List H. Integration of REP Demonstration Criteria and HSEEP Capabilities 1. Criteria-Capability Crosswalk 2. Exercise Evaluation Guides 3. Customizing EEGs for an Exercise I. Emergency Planning Zone Boundary Changes J. Credentialing Framework K. Use of State, Local, and Tribal Personnel as REP Exercise Evaluators 1. Administrative Process 2. Host Region Responsibilities 3. Evaluator Responsibilities 4. Evaluator Employer Commitment 5. Conditions L. Tribal Policies and Procedures 1. Federally Recognized Tribal Nations and the REP Program 2. Definitions 3. Policy M. Staff Assistance Visits N. Evacuation Time Estimates O. Potassium Iodide for the Public P. Conducting Plan Reviews 1. Radiological Emergency Preparedness Plans/Procedures 2. Division of Functions and Applicability of Criteria 3. Format for Plan Reviews Q. Conducting Scenario Reviews 1. Scenario Review Preparation 2. Radiological Emergency Preparedness Exercise Scenario Review Checklist R. Annual Letter of Certification 1. Guidance 2. Sample Annual Letter of Certification Cover Letter 3. Annual Letter of Certification Review Guide S. Public Information Guide and Process 1. Guidance 2. Review Steps 3. Foreign Language Translation – Legal Requirements and Location of Information T. Disaster Initiated Review U. Decommissioning V. List of Commercial Nuclear Power Plants LIST OF APPENDICES Appendix A: Abbreviations and Acronyms Used in the REP Program Appendix B: Glossary of REP Terms Appendix C: REP Guidance References Appendix D: Historical REP Guidance References LIST OF EXHIBITS Exhibit I-1: Probable Early Effects of Acute Radiation Exhibit I-2: EPZ Characteristics Exhibit II-1: Sample Functional Responsibilities Matrix/Table Exhibit II-2: Design Objectives for Alert and Notification of the Public Exhibit III-1: Milestones for the REP Exercise Process Exhibit III-2: Federal Evaluation Process Matrix Exhibit III-3: Illustration of the Standard Exercise Issue Number Exhibit III-4: Evaluation Standards for Alert and Notification Systems Exhibit IV-1: Plan Review Responsibilities for RAC Agencies Exhibit IV-2: Criteria-Capability Crosswalk Exhibit IV-3: Sample Exercise Evaluation Guide Exhibit IV-4: Plan Review Responsibility Exhibit IV-5: Portion of Sample Plan Review Format for “Franklin County” Exhibit IV-6: Scenario Review Process Exhibit IV-7: Public Information Review Checklist DISCLAIMER This policy represents the Federal Emergency Management Agency (FEMA) Radiological Emergency Preparedness (REP) Program’s interpretations of a statutory or regulatory requirement. The policy itself does not impose legally enforceable rights and obligations, but sets forth a standard operating guideline or agency practice that FEMA employees follow to be consistent, fair, and equitable in the implementation of the Agency’s authorities. FEMA undertook substantial efforts to ensure that this manual incorporated all applicable Radiological Emergency Preparedness Program policy and guidance.1 However, the possibility remains that FEMA overlooked some source(s). For any relevant policy or guidance not incorporated into this manual, the REP Program will regard the subject material, in its current format, as the currently held position on the referenced matter until FEMA can appropriately revise the manual. In addition, FEMA will review changes to other Federal Agency guidance that impacts the REP Program and issue amendments to this manual as warranted. \1\ Exception: The current FEMA-REP series guidance documents are listed in Appendix C and cited in the applicable parts of this manual. The retired guidance documents are listed in Appendix D for historical purposes. Submit comments and changes to the REP Manual to FEMA for consideration. To the greatest extent possible, FEMA will issue all future REP Program guidance as amendments to the applicable parts of this manual. Part I: INTRODUCTION TO THE RADIOLOGICAL EMERGENCY PREPAREDNESS PROGRAM MANUAL I.A. PURPOSE This manual serves as the principal source of policy and guidance for the Federal Emergency Management Agency (FEMA) Radiological Emergency Preparedness (REP) Program. Federal regulations in 44 Code of Federal Regulations (CFR) Part 350 address FEMA’s role in conducting assessments and issuing findings regarding offsite emergency plans/procedures for responding to radiological emergencies at commercial nuclear power plants (NPPs). State, tribal, and local government participation in offsite radiological emergency planning and preparedness is voluntary. However, participation in the REP planning and preparedness process necessitates adherence to the program requirements as set forth in 44 CFR Part 350, the joint Nuclear Regulatory Commission (NRC)/FEMA document NUREG-0654/FEMA-REP-1,\2\ and this REP Program Manual. If state, local, or tribal governments choose not to participate in REP planning, 44 CFR Part 352 outlines the licensee’s obligation to develop offsite plans/procedures to protect the public health and safety. \2\ Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Rev. 1, cited herein as “NUREG-0654/FEMA-REP-1.” The elements of NUREG-0654/FEMA-REP-1 are REP Program requirements for offsite response organizations. In addition to the 16 Planning Standards for radiological emergency preparedness, 44 CFR § 350.5 incorporates by reference NUREG-0654/FEMA-REP-1, which includes associated Evaluation Criteria that further define the Planning Standards. The 16 Planning Standards and associated Evaluation Criteria set the standard that FEMA uses to assess offsite planning and preparedness. NUREG-0654/FEMA-REP-1 Requirement It is FEMA’s position that, unless an alternative approach is proposed and accepted for meeting the intent of the Planning Standards of NUREG-0654/FEMA-REP-1, the associated Evaluation Criteria must be met. Shall and should: Language in the REP Program Manual quoted directly from regulatory material uses both shall and should to denote requirements. The remaining text in the REP Program Manual uses the terms shall, must, and require to denote mandatory items originating in regulatory material including NUREG-0654/FEMA-REP-1 and the CFR. The terms should, suggest and recommend denote guidance outlining a Federally-approved means of meeting the intent of the REP regulations. The term may denotes an option, neither required nor necessarily recommended. Alternative approaches. The Evaluation Criteria listed in NUREG-0654/FEMA-REP-1, as clarified, interpreted, and applied by the NRC, FEMA, and other Federal agencies, represent Federally-approved approaches for meeting the intent of the regulatory requirements. Offsite response organizations (OROs) may propose alternative approaches to meeting those requirements in writing to the appropriate FEMA Regional Office. Part I.D.3 provides a detailed discussion of alternative approaches. Reasonable Assurance. In the communities surrounding commercial nuclear power plants, 44 CFR 3S0.S (b) directs FEMA's REP Program to review state and local radiological emergency plans and preparedness. Approved plans and preparedness "must be determined to adequately protect the public health and safety by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiological emergency." FEMA defines reasonable assurance as a determination that state, local, tribal, and utility offsite plans and preparedness are adequate to protect public health and safety in the emergency planning areas of commercial nuclear power plants. FEMA shall take into consideration plans, procedures, personnel, training, facilities, equipment, drills, and exercises, which in its professional judgment are important to the effective implementation of protective measures offsite in the event or any incident at a commercial nuclear power plant. FEMA shall make its adequacy determination, supported by other Federal agencies, as necessary, by conducting inspections, providing staff assistance visits, organizing, conducting and reviewing training, participating in, observing and evaluating drills and exercises, and by being an engaged partner with Federal, state, local, and tribal government officials and industry stakeholders. In making its reasonable assurance determination, FEMA shall be guided by the standards, criteria, and policy found in applicable laws, regulations, and contemporary emergency preparedness guidance. Where improvements or corrections arc needed, FEMA will work closely with Federal, state, local, and tribal government officials and industry stakeholders to resolve the issue(s). 10 CFR 50 and 10 CFR 52, 44 CFR 350 and 44 CFR 353, NUREG-0654/FEMA-REP- I, Rev. 1 (and Supplements), and the REP Program Manual. Contemporary emergency preparedness guidance includes the National Response Framework (NRF), Community Planning Guidance (CPG) 101, the Target Capabilities List (TCL), the National Incident Management System (NIMS) and Incident Command System (ICS), the Homeland Security Exercise and Evaluation Program (HSEEP) and the Integrated Planning System. Planning and Preparedness Assessment Strategy. The REP Program currently relies on a combination of exercises, SAVs, plan reviews, and an Annual Letter of Certification (ALC) to develop a recommendation of reasonable assurance. Over the course of the last 30 years, the reasonable assurance assessment began to rely on the biennial exercise over the other components. This edition of the REP Program Manual introduces multiple policy changes that allow an ongoing assessment approach through evaluation of a broader range of activities than those previously used. These changes are consistent with national preparedness initiatives and HSEEP, and continue the streamlining of Federal, state, and local efforts and resources and the goal of employing a common assessment strategy. One-stop reference guide. FEMA maintains this document for use by its stakeholders as a desk reference when they need to answer questions or receive clarification on REP planning, exercises, and administrative procedures. This version of the REP Program Manual incorporates previously issued FEMA guidance memoranda, policy memoranda, and some FEMA-REP series documents. This updated manual effectively retires incorporated documents from use as independent resources. Retired guidance documents appear in Appendix D as historical resources. The REP Program Manual retains active guidance documents on specific technical areas such as the FEMA-REP series documents and other REP Program documents too lengthy to incorporate as stand-alone references. Appendix C lists these stand-alone references, and the manual cites them where applicable. To the greatest extent possible, FEMA will issue all future REP Program guidance as amendments to the applicable parts of this manual. I.B. SCOPE This manual provides FEMA guidance that interprets the Planning Standards and Evaluation Criteria in NUREG-0654/FEMA-REP-1 and 44 CFR Part 350. This guidance provides additional detail to OROs on what FEMA expects them to include in their radiological emergency response plans. This manual also provides the Demonstration Criteria that FEMA uses to evaluate the ability of the OROs to implement their radiological emergency response plans. Lastly, this manual provides additional information and guidance to help FEMA staff and OROs perform various REP Program functions (e.g., checklists, templates, references, etc.). Communities potentially affected by a radiological incident at a nearby commercial NPP benefit from essential planning and preparedness activities. . FEMA created the REP Program to address the unique needs of OROs. FEMA reviews and approves ORO planning and preparedness activities before the NRC issues a license to operate an NPP. FEMA also provides ongoing certifications that planning and preparedness efforts remain effective and consistent with relevant regulations. This manual is divided into four main parts and includes additional appendices. Part I introduces the REP Program and provides an overview. It provides the history and establishment of the REP Program, a description of the review process, and the technical basis for the program. This section provides a base knowledge about the REP Program and describes current operations through a synopsis of its evolution. Part II contains the NUREG-0654/FEMA-REP-1 Planning Standards and Evaluation Criteria, along with explanations and guidance on materials to be included in ORO plans/procedures. These explanations are solely guidance and neither exceeds nor replaces any FEMA or NRC regulations. Part III of the REP Program Manual supplements the HSEEP process and provides specific guidance unique to the design, development, conduct, evaluation, and improvement planning associated with REP exercise activities. FEMA created this guidance for REP controllers, evaluators, contractors, and any Federal, state, local, or tribal agencies responsible for planning, preparing, and executing exercises that are used to validate REP Program requirements. This section provides licensee partners with guidelines regarding how the Federal government will coordinate exercise activities in conjunction with the REP Program. Part IV presents supporting reference documentation, where specific information is found in support of the program. It includes information on Potassium Iodide and Disaster Initiated Reviews, scenario reviews, plan reviews, the Annual Letter of Certification (ALC), and other topics. The appendices include acronyms, a glossary, additional REP reference documents (active and retired), plant site identifier numbers and the TCL. The term “ORO” refers to a state, tribal, and/or local government, a licensee emergency response organization (in certain circumstances), and any other supporting organization acting to protect the health and safety of the public offsite (beyond the NPP site boundary). Only the licensee emergency response organization is responsible for activities onsite (within the NPP site boundary). The REP Program Manual uses the term “ORO” or “OROs” instead of specifying state, tribal, and/or local governments, because FEMA acknowledges that local authorities vary from state to state; certain REP activities may be the responsibility of the state in one instance and local jurisdictions in another. The REP Program Manual guidance applies to the entities responsible for the function being discussed. The term “plans/procedures” as used in this manual includes radiological emergency preparedness and response plans, associated implementing procedures such as Standard Operating Guidelines (SOGs), and other supporting and referenced materials. FEMA may review all of these documents to the extent necessary determining whether they meet the intent of the requirements. FEMA uses the generic term “plans/procedures” specifically for flexibility. The ORO may either incorporate procedural detail into its main plans or into separate procedural documents at its discretion. I.C. BASIS OF THE REP PROGRAM This section provides an overview of the legislative mandates and guidance for the REP Program, describes its establishment, and details the impact of post-September 11, 2001 and post-Katrina programmatic changes. I.C.1. ESTABLISHMENT OF THE REP PROGRAM The NRC is responsible for emergency preparedness at the nation’s commercial NPPs. Following the March 1979 Three Mile Island accident, Executive Order 12148 and the Presidential Directive of December 7, 1979 transferred the Federal lead role in offsite emergency planning and preparedness activities from the NRC to FEMA. This assignment aligned with FEMA’s statutory role in promoting, funding, coordinating, and providing technical assistance for disaster preparedness, as defined in Section 201 of the Disaster Relief Act of 1974.\3\ FEMA established the REP Program to manage its responsibility for ORO emergency planning and preparedness in areas around commercial NPPs. The NRC retained responsibility for onsite activities. \3\42 USC 5131, as amended by the Robert T. Stafford Disaster Relief and Emergency Assistance Act, Public Law (Pub.L.)100-707, 102 Stat. 4689 (1988). This Act constitutes the statutory authority for most Federal disaster response activities, especially as they pertain to FEMA and FEMA programs. The NRC Authorization Acts of 1980 (Pub.L. 96-295) and 1982-1983 (Pub.L. 97-415) directed the NRC to establish emergency preparedness as a criterion for licensing commercial NPPs. Specifically, the NRC Authorization Acts prohibit the NRC from issuing an operating license for an NPP unless it finds that “there exists a state, local, or utility\4\ plan which provides reasonable assurance that public health and safety is not endangered by operation of the facility concerned.”\5\ The acts also provide for the NRC to consult FEMA in developing standards for evaluating plans/procedures and in making individual determinations that the plans/procedures provide reasonable assurance for protecting public health and safety.\6\ The NRC revised its regulations in 10 CFR Part 50 to incorporate additional emergency preparedness requirements, including 16 Planning Standards for onsite and offsite emergency response plans/procedures. \4\44 CFR Part 352 allows for the submission of offsite emergency response plans/procedures by a licensee in those instances where OROs, either individually or together, decline or fail to prepare commercial NPP offsite radiological emergency preparedness plans/procedures that are sufficient to satisfy NRC licensing requirements or to participate adequately in preparation, demonstration, testing, exercise, or use of such plans/procedures. \5\ Pub.L. 97415, section 5, 96 Stat. 2067, 2069 (1983). \6\ Pub.L. 96295, section 109(b), 94 Stat. 80, 784 (1980). In 1980, the NRC and FEMA jointly issued NUREG-0654/FEMA-REP-1 to provide onsite and offsite planning guidance to protect public health and safety in the event of an incident at an NPP. This document includes the 16 Planning Standards and associated Evaluation Criteria for assessing whether the licensee and the affected OROs have plans/procedures in place that provide a reasonable assurance that adequate protective measures can and will be taken. FEMA regulations in 44 CFR Part 350 address the review and approval of ORO emergency plans/procedures for responding to radiological emergencies at commercial NPPs. These regulations also include the 16 Planning Standards and incorporate by reference the joint NRC-FEMA guidance document NUREG-0654/FEMA-REP-1. In June 1996, FEMA initiated a Strategic Review of the REP Program in order to improve its efficiency and effectiveness.\7\ FEMA worked with internal and external stakeholders nationwide and published five major recommendations in September 1998.\8\ These recommendations were: 1. Streamline the REP Program; 2. Increase Federal Participation in REP Exercises; 3. Use State, Local, and Tribal Personnel as Exercise Evaluators; 4. Include Native American Tribal Nations in the REP Preparedness Process; and 5. Enhance the REP Training Program. \7\61 FR 35733, Notice of the Federal Emergency Management Agency’s Intent to Conduct a Strategic Review of Its Radiological Emergency Preparedness Activities, July 8, 1996. \8\63 FR 48222, Publication of Radiological Emergency Preparedness (REP) Program Strategic Review Draft Final Recommendations, September 9, 1998. This notice also summarized several short-term improvements implemented at that time. Each recommendation included initiatives for implementation.