Memo: April 11, 2013
The Federal Emergency Management Agency’s (FEMA) REP Program issues this memorandum to amend and clarify guidance found in the FEMA REP Program Manual regarding congregate care centers. As you are aware, the Manual is used by stakeholders as a desk reference to answer questions or receive clarification on REP planning, exercises, and administrative procedures. Moreover, Offsite Response Organizations (OROs) are responsible for developing, exercising and maintaining emergency plans and preparedness based on the planning standards and evaluation criteria articulated in NUREG 0654/FEMA-REP-1, Rev.1 as referred to in FEMA regulations at 44 CFR § 350.5.
While OROs have the ability to submit to the FEMA REP Program alternative approaches to this guidance, it has come to the REP Program’s attention that current guidance found in the Manual needs further clarification. In the Explanation section of Criterion J.10.h the current language provides:
OROs also use this 20 percent of the EPZ [emergency planning zone] population as a planning basis for determining the number of congregate care centers needed to accommodate evacuees from the EPZ. While the actual proportion of individuals seeking congregate care could be more or less than 20 percent, it is prudent to incorporate a planning basis that can be modified as the incident warrants.
In the Assessment/Extent of Play section of Sub-element 6.c the current language provides:
For planning purposes, OROs must plan for a sufficient number of congregate care centers in host/support jurisdictions to accommodate a minimum of 20 percent of the EPZ population.
After consultation with stakeholders, including other components within FEMA, the REP Program has determined that suggesting OROs to shelter 20 percent of the EPZ population may be too restrictive. The 2013 REP Program Manual has updated the language:
OROs should plan for a sufficient number of congregate care centers in host/support jurisdictions based on their all-hazard sheltering experience and what is historically relevant for that particular area.
This clarifying language is included in the most recent draft of the 2013 REP Program Manual Update which is currently in the FEMA concurrence process. However, by getting this clarification to you at this time, you will be able to work with OROs to clarify any questions that may arise surrounding this issue. In addition, this information will be posted on the FEMA REP Program website as a “Frequently Asked Question.” This memo will be superseded by the 2013 REP Program Manual Update upon its release.
Current List of Frequently Asked Questions Updated: January 31, 2013
1) Question: How do I receive a copy of the RPM?
Answer: FEMA REPP Website
2) Question: How can I ask a question regarding information in the manual?
Answer: Contact your FEMA Regional Assistance Committee Chairperson. The Chairperson will forward your questions to the RPM Frequently Asked Questions Committee.
3) Question: What is FEMA’s planned process for updating the RPM in the future?
Answer: FEMA’s intent is to review the RPM and update it prior to NREP each year. FEMA plans to issue all future REP Program guidance as page changes to the applicable parts of the RPM.
4) Question: What is the difference between release, publication, effective and implementation dates?
Answer: The release date was when the RPM and Supp. 4 were made publicly available on the internet which was on October 4, 2011. The publication date is when the documents were published in the Federal Register (November 23, 2011). The effective date is when the documents need to be adhered to, which is 30 days after the publication date (December 23, 2011). The implementation date is 30 months after the publication date (June 23, 2014). All sites must complete an HAB Exercise by December 31, 2015. OROs must have their plans completed and submitted to the Regional Office for approval 90 days prior to participating in an HAB Exercise.
5) Question: Will FEMA be conducting a plan review upon implementation of the plan changes due to the new RPM?
Answer: FEMA has determined that these planning and procedural updates must be implemented no later than 30 months from the effective date of the final rule. Each FEMA Regional Office will assist each site’s OROs with technical assistance. FEMA provides services to facilitate offsite radiological emergency planning and preparedness such as: provision of support for the preparation of offsite radiological emergency plans/procedures; FEMA coordination of services from other federal agencies; provision and interpretation of federal guidance; provision of federal and contract personnel to offer advice and recommendations for specific aspects of preparedness such as alert and notification and emergency public information. Following development, all plan changes and updates must be submitted to the FEMA Regional Office for review and approval prior to the 30 month deadline. The plans will be expected to meet the information in each planning standard, including the intent “checkmarks” under each standard.
For OROs that have their HAB exercise prior to the 30 month deadline, the plans needs to be completed and submitted to the Regional Office for approval 90 days prior to the exercise.
PART I: INTRODUCTION
6) Question: On page I-4 of the RPM, “Standard Operating Guidelines” (SOG) was added to the Plans and Procedures definition, with a comment that “FEMA may review all of these documents to the extent necessary.” Does this mean that we will be required to submit all SOGs with our plans for review?
Answer: Yes, SOGs/Standard Operating Procedures (SOPs)/Implementing procedures are reviewed as part of the plan review. A comprehensive review and approval of state and local procedures (SOPs, SOGs, etc.) is both necessary and required. This position is supported not only by the fact that procedures are, by their very nature, part and parcel to overall state and local plans (i.e., they are integrally linked, as a plan without procedures to implement it is of little or no utility) but more importantly, the requirement for such reviews is clearly expressed in applicable regulation.
7) Question: How do the Comprehensive Preparedness Guide (CPG) 101 Version 2.0 dated November 2010 and the Radiological Program relate to each other?
Answer: The Comprehensive Preparedness Guide (CPG) 101 provides guidelines on developing emergency operations plans (EOP). Other regulatory requirements may necessitate the use of additional guides for the development of certain EOP annexes (e.g., the requirements for the Radiological Emergency Preparedness Program). CPG 101 has been designed to complement the use of those guides where required by law or regulation. REPP plans are only reviewed based on NUREG 0654/FEMA REP-1.
8) Question: What provisions must be made for service animals?
Answer: The ADA states that the service animal must be permitted to accompany the individual to all areas of the facility. An individual with a service animal may not be segregated from other customers. The care or supervision of a service animal is solely the responsibility of his or her owner. You are not required to provide care or food or a special location for the animal. Service animals are discussed in the RPM solely for the awareness that a service animal may arrive in a reception center, monitoring/decontamination center, shelter, hospital, etc. FEMA REPP will not be evaluating OROs plans to handle service animals.
9) Question: What does page I-14 mean when it states that controlling surface contamination is a protective action?
Answer: Minimizing/Controlling surface contamination is not a Protective Action Recommendation but it is a protective measure that an ORO may want to consider. EPA-400 1992 discusses controlling surface contamination. Controlling surface contamination at the emergency worker monitoring and decontamination centers would be a protective measure taken. The intent here is to provide examples that may be implemented.
PART II: PLANNING GUIDANCE
10) Question: In Part II of the RPM, what is the intent of the Explanation section under the check marked items related to the sub-element criterion?
Answer: FEMA added an explanation of each Evaluation Criterion based on current guidance. The intent of the explanation is an interpretation of the check marks. OROs will use this guidance or request approval of an alternative approach from their Region’s RAC Chair.
11) Question: Is FEMA going to evaluate mutual aid agreements, Memoranda of Understanding (MOU) or LOAs that Offsite Response Organizations (ORO) have with other governmental and non-governmental organizations? What requires an MOU/LOA – If there is a state-wide MOU, does every single entity need a copy? Agencies that report to the EOC are required by plans, does there have to be an MOU there? With how many resources must the ORO have LOAs? What if they have 10 different providers, do they need LOAs with each one?
Answer: FEMA will not be evaluating MOUs/LOAs between government agencies. FEMA will be evaluating MOU/LOAs that the ORO has with any private organization that is identified in the plan as providing resources. All parties to an MOU or LOA should retain a copy of it.
LOAs are required for primary and backup resources the ORO will utilize in the event of an emergency. OROs can have a separate list of resources to use in the case of extreme emergency when their primary and backup resources are unavailable. For example, in the unlikely circumstance that a laboratory is unavailable to assist and the backup is also not available, the emergency manager could have a list available of all the resources in the area and could prevent a long period of time of elapsing while conducting research. This list is not subject to evaluation, but is a best practice.
12) Question: Sub-element A.2.b. of the NUREG-0654/FEMA REP-1 says that plans/procedures shall include any limitations on the authority of the Letter Of Agreement signatories. Does this mean plans/procedures shall include legal limitations applied by the OROs own policies and laws? Please give an example.
Answer: This means that plans/procedures should include any limitations that are relevant to state, local or tribal statutes and not policy. There may be limits on what can be committed based on the authority of the Emergency Manager (i.e. Public works resources) or the LOA is task specific and anything other than that would need to be approved by a County Commissioner.
13) Question: Throughout the RPM there are references to list of individuals, list of personnel and rosters. Are OROs required to give FEMA names of individuals?
Answer: FEMA reviews titles/positions and does not need personally identifiable information. The ORO may also provide reference to a roster, where required.
14) Question: Is there a 24 hour appropriately trained capability? (A.4)
Answer: Planning Criterion A.4 states that plans/procedures shall include a reference to a roster that identifies at least two shifts of key staff. No person should be on a roster for more than one shift in a row. These personnel should be trained in accordance with Planning Criterion O.1.
15) Question: New Criterion C.6 states, “Each organization shall make provisions to enable onsite response support from OROs in a hostile action-based incident as needed.”
What types of provisions will be expected and how detailed must the plans be?
How will safeguarded plans be reviewed/handled? Will this be evaluated during an exercise?
Will FEMA expect to review safeguarded information/plans?
Should information on site access/evacuation procedures be referenced in public plans?
Answer: The OROs are expected to ensure that provisions are in their emergency plans/procedures that will allow prompt access to the NPP site for in-bound first responders. The OROs will work with the licensee to ensure prompt access as required. Specific safeguarded information does not have to be in the ORO plans/procedures, nor will it be reviewed by FEMA. There must be a statement that an agreement is in place and a reference to MOU/LOAs with the licensee to allow persons to enter the protected area. LOAs that are in the plans/procedures do not need to contain safeguarded information. They may refer to licensee procedures for site access, i.e., “Access to the XXX Site will be controlled in accordance with the XXX Site security procedures”. FEMA will not be evaluating site access during exercise play. FEMA ONLY evaluates the coordination, communication and radiological exposure control; evaluating site access is the NRC’s purview.
16) Question: Referencing page II-30, what is the procedure/process for submitting alternative alert and notification systems for approval?
Answer: The “design report” for an alternative alert and notification system will include a request for approval, a system description and a testing protocol that details the periodic tests of the system. This system will include the proposed capability. Performance may also be based upon the use of the system in concert with existing systems to test the overall totality of the combined systems.This information will be sent from the ORO through the state to the FEMA Region RAC Chair. The RAC Chair will make a recommendation to FEMA REP HQ, who will take into consideration the capability of the particular system and make an approval within 90 business days of receiving the request. All systems will be approved on a case-by-case basis. More information regarding the design report will be found in the FEMA REP-10 Draft that will be released for the first public comment period May 2012. Interim guidance will be released to the regions in April 2012.
17) Question: E.6 – Backup Notification is to be complete with a goal of 45 minutes. How much of the EPZ is expected to be completed in that time frame?
Answer: The affected area should be completed with a goal of 45 minutes.
18) Question: What is the requirement for translating public information materials into non-English languages?
Answer: The RPM, April 2012 version, has been modified to read: At a minimum, EAS messages and special news broadcasts shall be translated into any non-English language spoken by more than 10,000 individuals or more than 5% of the total voting age citizens in a single political subdivision (usually a county, but a township or municipality in some states) within the EPZ.
19) Question: What are the requirements to provide translation of transient public information into additional languages (i.e., large, migrant, non-English speaking populations)?
Answer: There is no requirement to provide translation of transient public information into additional languages. However, it is strongly suggested that if there is a known non-English speaking transient population, that public information be translated.
20) Question: In Criterion F.2, what is meant by mobile medical facilities?
Answer: Typical aid camps, triage stations or other temporary medical care locations.
21) Question: Is the same kind of review process expected for transient population public information? For ingestion public information?
Answer: No, the requirements for transient population and ingestion pathway population public information can be found in Criterion G.1.
22) Question: When does FEMA review Public Information guides?
Answer: New Public Information Brochures/calendars, etc. will be sent to FEMA prior to dissemination for a baseline review and will be submitted annually thereafter with the ALC. All public information must be in a paper format. Websites or other electronic media may supplement the paper version.
23) Question: Social media monitoring is discussed extensively under Criterion G.4.c; however, it is not addressed at all in the evaluation criteria. Will OROs be evaluated on monitoring media outlets?
Answer: Social media is considered part of the general “media”. It is strongly suggested that OROs plan to address social media. Once an ORO has plans to monitor social media, it will be evaluated under 5.b.1.
24) Question: Is there a requirement for each jurisdiction to have an alternate EOC? (H.3)
Answer: No. It is, however, encouraged that facilities within the 10 mile EPZ have an alternate location to use in the event an evacuation is necessary.
25) Question: The RPM now requires that states transport samples to the lab in four hours. Does this mean the sample has to be at the lab within four hours of the time it was collected? In many cases, the state may not be able to accomplish this. What is the basis for this four hour requirement? (manual reference: I.8, page II-63)
Answer: This FAQ has been updated. Upon further review, it has been determined that the requirement to transport a sample to a lab within four hours only applies to samples that are not counted in the field. The manual is being revised as such:
The plans/procedures clearly identify the estimated times required to transport collected air samples to the designated laboratory (ies), perform the required analyses and transmit the results to the appropriate locations (e.g., dose assessment group).
Fixed laboratories or (if available) mobile laboratories can be used in lieu of portable instruments for the FMT to perform an early assessment, provided that: (1) the laboratory is equipped with appropriate counting equipment and (2) the laboratory is able to provide analysis of air samples for airborne radioiodine and particulates in a time comparable to the FMT. If applicable, plans/procedures indicate the placement of mobile laboratories at pre-designated staging areas. In addition, if the plans/procedures state that an additional private laboratory(ies) will be used in support of the state in sample analysis or that the licensee’s laboratory will be used, appropriate LOAs are referenced in the plans/procedures, as described in Criterion A.3 In this case, transportation of plume phase samples to the laboratory or other facility for analysis must be completed within 4 hours.
26) Question: For air samplers, if the air sampler exceeds the flow rate of 10-7 microcuries per cubic centimeter, can it still be used? (I.8)
Answer: 10-7 microcuries/cc is not a flow rate but is the minimal concentration OROs are required to have the capability of detecting and measuring for radioiodine. The flow rate must support the ability to detect and measure a radioiodine concentration of 10-7 micro curries/cc.
Page 11-65 states: the air sampler is capable of providing a sampling flow rate compatible with the type of adsorbent cartridge being used, typically 2 cfm or 5 cfm, depending on adsorbent cartridge geometry. The requirement is to reach the concentration of 10-7 micro curries/cc for radioiodines. If OROs can reach these concentrations taking into consideration the silver zeolite cartridges using different flow rates, that is acceptable.
27) Question: What are the planning, exercise and evaluation requirements for licensed day care providers?
Answer: A state or local Offsite Response Organization (ORO) has the responsibility to properly account and plan for each licensed day care provider in the EPZ. FEMA is aware that there are multiple types of licensed daycare providers and recommends that the ORO plan accordingly for each type. Please reference Planning Criterion J.10.d in the REP Program Manual for the specifics of what is required when planning for licensed daycare providers in the EPZ. FEMA is then responsible for ensuring that each licensed daycare provider or ORO has a plan in place. FEMA will ensure the plan can be adequately executed by requiring a demonstration, interview or a review of the approved plan.
28) Question: Under J.10.j: “Credentialing procedures for ingress/egress and authorizing access to affected areas” is new to the RPM. How detailed do plans need to be and how are plans/procedures going to be evaluated?”
Answer: FEMA reviews Access Control procedures, under 3.d.1. This standard is for any REP response, not just a HAB scenario.
29) Question: Planning guidance now requires that OROs make provisions for the monitoring and decontamination of service animals. What specific provisions are required to be included in the plan? Is simply stating in plans/procedures that service animals will be monitored and decontaminated to the same level as evacuees enough to meet the planning requirement?
Answer: Per the Explanation for J.12 on page II-92, service animals accompanying evacuees with disabilities and access/functional needs are monitored and decontaminated in accordance with the same standards and trigger/action levels for monitoring and decontamination as humans.
30) Question: Does the ORO have to have a list of host hospitals in the plan?
Answer: No. Hospitals have JCAHO requirements for plans to evacuate hospitals and receive transfers as part of their everyday operation. Transportation for these transfers is a function of the hospital system and not the ORO.
31) Question: Medical Service (MS-1) Drills - Are Physician Assistants acceptable substitutes for Physician under the MS-1 requirements?
Answer: Based on state hospital licensing requirements and hospital Standard Operating Guidelines.
32) Questions: Are all ambulance services within the 10mile Emergency Planning Zone required to have Letters of Agreement (LOA) in place for transporting contaminated/injured/exposed individuals? Which ambulance services are required to participate in training and MS-1 drills/other REP exercises?
Answer: LOA’s are necessary because this responsibility is outside normal services provided. This is to ensure that only trained and qualified providers will respond. Only providers listed in the plans are required to participate in MS-1 drills/exercises.
33) Question: Is there a requirement for how exercise scenarios will fit into the cycle?
Answer: Supp 4, page 10, N.1.b. states that “Each scenario variation shall be demonstrated at least once during the 8-year cycle.” Radiological Emergency Preparedness Program Manual (RPM) Part II.C states, “At least one exercise every 8 years must include a post-plume phase ingestion pathway and relocation/reentry/return exercise.” Therefore, there can be no more than 8 years in between the Ingestion Pathway scenarios. Other scenarios can be entered into the exercise cycle at any time.
34) Question: What new locations will be evaluated with an HAB scenario?
Answer: Incident Command Posts (ICP), Staging Areas and Unified Area Commands (UAC) are areas that may be evaluated. ICPs and UACs will be evaluated for coordination and communication and worker safety (if located within the EPZ). Staging Areas will be evaluated for worker safety (dosimetry briefings, etc.)
35) Question: What is considered a communications check versus a drill? Communications drills need to occur with which federal agencies?
Answer: N.2.a requires communication drills to have a content check. The term “content check” means that a message should be read by the initiator and is either repeated back or is otherwise verified as accurately received (i.e. fax, etc).
The only communication drills with federal agencies that needs to be performed is with FEMA. Any issues that OROs are having with federal communication drills should be brought to the attention of the FEMA Regional Administrator.
36) Question: Is it acceptable to provide just-in-time training for mutual aid resources? Is there an instance where just-in-time training would not be acceptable for mutual aid resources?
Answer: Just-in-time training is acceptable training for mutual aid resources, however, training courses should still be offered throughout the year to mutual aid resources as well per Planning Criterion O.1.b.
37) Question: Are there requirements that every ingestion ORO must be offered training on an annual basis and recorded in the Annual Letter of Certification?
Answer: Per Planning Criteria O.1a and O.5 response organizations are provided annual training. Training is recorded in the Annual Letter of Certification.
PART III: DEMONSTRATION GUIDANCE
38) Question: There is a lot of HSEEP type information referred to in RPM. Are OROs and FEMA required to attend training and exercise planning workshops (TEPWs), create controller handbooks, etc.?
Answer: The HSEEP process is in the RPM as a reference. The process of applying HSEEP methodology to REP exercises involves the following steps:
Scheduling REP Activities
Conducting Pre-Planning Activities
Holding Exercise Planning Meetings
Developing REP Exercise Documents
Conducting REP Exercises
REP Exercise Documentation
All REP exercises include an Initial Planning Conference, a post-exercise ORO briefing and an After-Action Report and Improvement Plan. Participation in the TEPW and use of exercise evaluation guides is voluntary; however, FEMA REP staff is encouraged to participate in their Regional TEPWs.
39) Question: Has there been any discussion of extending the exercise timeline to allow for more total exercise time and a reduction of exercise artificialities?
Answer: There is no guidance concerning how long an exercise should or has to last, other than “long enough” to demonstrate all required criteria. Exercise length should be discussed and negotiated during the extent of play meetings and any opportunity to reduce exercise artificiality should be considered when possible and plausible.
40) Question: Can you define a rapidly escalating event?
Answer: By definition, a rapidly-escalating incident is “an incident that develops potential or actual severe core damage within a short time. Such an incident results in an initial declaration of or rapid escalation to a Site Area Emergency or General Emergency.” One scenario variable option is to have an initial classification of or rapid escalation to a Site Area Emergency or General Emergency.
41) Question: Can TTXs be used in place of the typical biennial, full-participation exercise?
Answer: No. Currently, the biennial, full-participation exercise must be conducted as a modified functional exercise.
42) Question: Who keeps track of the various exercise schedules at the various Nuclear Power Plants and local OROs?
Answer: The state, as well as the FEMA Region, will be keeping a record of exercise cycles within the state, to ensure reasonable assurance.
43) Question: Can you provide additional clarification on when the 8 year exercise cycle starts and how that impacts the various OROs and/or States with multiple sites?
Answer: The first hostile action-based (HAB) exercise in which the state fully participates will start the 8 year exercise cycle for the state. The first HAB exercise at a site will start the 8 year exercise cycle for the licensee. The local ORO’s participation in the first HAB exercise will begin their 8 year exercise cycle. Local OROs will participate whenever their site and not necessarily their state holds its HAB exercise. For states with multiple sites, the state is encouraged to rotate their full participation among sites (when not fully participating, the state partially participates to support OROs). This procedure is the same for all scenario options (IPZ, Rapidly Escalating, etc).
All OROs within the 50-mile EPZ, with ingestion pathway responsibilities, should participate in the Ingestion Pathway Exercise. Those OROs that do not fully participate in the exercise shall participate in a tabletop exercise or other ingestion pathway training activity at least once every 8 years. This includes states and county/locals that are affected by a site in another state and/or FEMA Region.
44) Question: Is there are requirement that every ingestion ORO must be offered training on an annual basis and recorded in the Annual Letter of Certification?
Answer: It is FEMA guidance that OROs within the 50-mile EPZ that are not part of the full-participation ingestion exercise with the state participate in an ingestion tabletop exercise or other ingestion pathway training activity at least once during the exercise cycle. OROs report this ingestion pathway training in the ALC. (See page II-125 April 2012) Any FEMA guidance in the manual must be met or an alternative approach must be submitted to the appropriate RAC Chair.
45) Question: For areas where multiple teams/jurisdictions have responsibilities, what are the evaluation requirements?
Answer: All teams must demonstrate at least once every 8 years (Field Monitoring Teams, hospitals, medical transportation providers, monitoring/decontamination teams, traffic access control points, school district); however, criteria that have biennial requirements, must be demonstrated per the REP Program Manual, regardless of the number of teams/jurisdictions in the plan.
46) Question: What are OROs required to demonstrate for a no-release scenario?
Answer: OROs are encouraged to participate in no-release scenario exercises but are not required. Page II-121 of the RPM state “If OROs elect to participate in a joint exercise with no or minimal release, part of the planning for the exercise will include identifying Demonstration Criteria that will not be evaluated during the exercise and determining appropriate alternative demonstration and evaluation venues so that the OROs can meet their biennial evaluation requirements.”
As with any biennial exercise, any criteria that are due to be evaluated, must be evaluated, even with a no-release scenario. The scenario and extent-of-play must be written to assure all necessary criteria are met. The majority of criteria will be met if a scenario reaches a Site Area Emergency Emergency Classification Level (ECL). For the criteria that may not be met through the no-release scenario, inject messages and/or out-of-sequence demonstrations may be used.
47) Question: If an ARC Shelter previously had a baseline evaluation done, does it need to be redone at the start of the first 8 year cycle?
Answer: No. It will be grandfathered in.
48) Question: How does FEMA evaluate the adequacy of training?
Answer: Adequacy of training is determined through evaluation of performance. During an exercise, it may be clear that personnel are unsure or unfamiliar with a procedure, which may result in an ARCA or Deficiency. FEMA may work with the OROs to revise the training, as necessary.
Training may include items such as basic radiation protection, procedures, plan information, such as evacuation routes and notification methods, and basic radiation facts (for just-in-time training for those responders not normally associated with REP incidents). FEMA can observe training, seminars and practical demonstrations used to assess proficiency, wherever possible.
If FEMA attends, it is not to evaluate the training. However, occasionally, it may be appropriate for an ORO to request feedback or assistance/advice on training. FEMA can furnish the appropriate resources and assist with training as requested.
49) Question: Can FEMA discuss the changes in the Evaluation Areas?
Answer: The following lists the changes to the current Evaluation Criteria. The effective dates are listed below:
Effective December 23, 2011 (all future extent-of-plays should follow these criteria):
Criteria 3.a.1. and 3.b.1. are dosimetry and Potassium Iodide (KI) respectively. For ease of evaluation, these criteria have been reconstituted so as 3.a.1. is dosimetry and KI for emergency workers, and 3.b.1. is KI for the public and institutionalized.
Criterion 3.d.2 has been revised such that the impediment must occur during evacuation and on an evacuation route
Similarly, 6.a.1. is Monitoring and Decontamination of Evacuees and Emergency Workers and 6.b.1. is Monitoring and Decontamination of Evacuee and Emergency Worker vehicles and equipment. These criteria have been redone such that 6.a.1. is Monitoring and Decontamination of Evacuees and their vehicles, and 6.b.1. is Monitoring and Decontamination of Emergency Workers, their vehicles and equipment.
Criteria 4.a.1. was removed. The contents of this criterion can be found under 1.e.1.
Because the frequency of these criteria is changing, the following will be effective at the beginning of the first 8-year cycle:
Criteria 1.b.1. will be evaluated once every 8 years. FEMA will correct page III-31 by page change, when possible.
Criteria 5.a.3. was demonstrated “as needed per scenario” and is now listed as once every 8 years. Criteria 5.a.4. was demonstrated “as needed per scenario” and is now listed as biennially.
50) Question: Is there a requirement to evaluate alternate EOCs?
Answer: All alternate EOCs will be evaluated under 1.b.1 once every 8 years. However, they are not required to be exercised, though FEMA highly encourages that alternate EOCs be worked into exercises whenever possible.
51)Question: is it required for an EOC to have a generator?
Answer: No, a generator is not required; however, per Criterion A.1.e, the EOC “shall provide for 24-hour per day operation”. Therefore, it is expected that the EOC will have provisions for continuous operation in the event of a power failure, which may include alternate power sources, alternate locations, the use of a mobile command vehicle, etc. This may already be part of the EOC’s SOGs and can be referred to as needed.
52) Question: For jurisdictions that do not have evacuation routes, do they need to demonstrate 3.d.2 (i.e., the explanation states that the impediment must occur along an evacuation route)?
Answer: Criterion 3.d.2 must be demonstrated by each jurisdiction biennially. In some instances, it may be determined through the extent-of-play that some jurisdictions can accomplish this through interview. For those jurisdictions that do not have a documented evacuation route, impediments should occur on known feeder routes to the evacuation route.
53) Question: Are shelters that are fully run by the American Red Cross (ARC) evaluated in the REP Program and are the counties they are located in considered support counties?
Answer: Per definition, a host/support county is a geographic area that is at least 5 miles and preferably 10 miles, beyond the boundaries of the 10-mile plume Emergency Planning Zone (EPZ) where functions such as congregate care, radiological monitoring, decontamination and registration are conducted. Therefore, any county that has a shelter is considered a support county.
Facilities that are managed by the ARC are evaluated once when designated or when substantial changes occur; all other facilities not managed by the ARC must be evaluated no less than once every eight years.
54) Question: What exercise evaluation criteria will FEMA use to evaluate an Incident Command Post (ICP) during a hostile action-based exercise?
Answer: Through extent-of-play negotiations and based on the consensus of the RAC Chair and OROs, FEMA would likely expect to see exercise evaluation criteria 1.a.1., 1.c.1., 1.d.1., 1.e.1., 2.b.2, 3.a.1 demonstrated at an ICP. Additionally, depending on scenario supplemental criteria, may need to be demonstrated.
55) Question: Must the list of agricultural businesses within the EPZ include farmers markets, farm stands, etc. that may not be licensed? Does the list of agri-businesses include nurseries, etc. that sell garden plants to consumers?
Answer: Lists of agricultural businesses within the Ingestion Pathway Zone will include licensed farmers markets, stands, nurseries, etc. Additionally, public messaging urging those with unlicensed stands, etc, not to sell garden plants should be included in the plans.
56) Question: page II-90: Does this mean that there is a requirement to track products going out of the EPZ? Does this mean that there is a requirement to track products coming into the EPZ? How would this be accounted for within the plans and during demonstration? To what jurisdictional level would these requirements apply?
Answer: Yes, there is a requirement to tract products going out of the EPZ. Products coming into the EPZ should be restricted due to limited access. The tracking of products is done by whichever OROs are designated in the plan. These plans will be discussed during an Ingestion exercise. Actual demonstration of an access control point can be done as agreed upon in the extent-of-play.
57) Question: Demonstration Criterion 3.d.2 - May a hostile action that closes an evacuation route be considered an impediment to evacuation?
Answer: Yes, Criteria 3.d.2 does not mention anything specific in regards to what type of impediment is used. “Criterion 3.d.2: OROs must demonstrate the capability, as required by the scenario, to identify and take appropriate actions concerning impediments to evacuation.”
58) Question: Is purging required for air samples using a silver zeolite cartridge?
Answer: No. Noble gases retained in the cartridge are insignificant, but purging will not negatively affect the count.
Silver zeolite is selective, meaning that it has an affinity for compounds containing iodine, but not for noble gases. If the cartridge has approximately 4 cubic centimeters (cc) of air in it when the pump is turned off and the volume sampled is 20 cubic feet (cf), this is about 7E-6 of the total volume sampled.
Activated charcoal does adsorb noble gases, so purging carbon cartridges was a good practice. Since carbon cartridges are used to simulate silver zeolite, purging is also not required for exercises.
I-133 and I-135 do decay to Xe-133 and Xe-135, respectively. The percent activity concentration of these noble gases will increase between the time the field team takes the sample and the time it counts the cartridge. However, Xe-133 and Xe-135 would not be expected to contribute more than 8 percent of the total activity in the cartridge if field team completes counting less than 4 hours after sampling; an insignificant variation. This activity would only affect dose estimations if the field team or dose assessment scientist back calculates to correct for the decay that occurs between sampling and counting.
59) Question: Assessment Criterion 6.a.1 requires that the reception center facility must have appropriate space, adequate resources and trained personnel to necessary to monitor 20 percent of the population within a 12-hour period. How do service animals affect this criterion? (6.a.1)
Answer: The Assessment/Extent of Play section under Evaluation Criteria 6.a.1 states that OROs conducting this demonstration must have one-third of the resources (e.g., monitoring teams/instrumentation/portal monitors) available at the facility(ies) as necessary to monitor 20% of the population within a 12-hour period. The only demonstration required is that staff, responsible for the radiological monitoring of evacuees, must demonstrate the capability to attain and sustain a monitoring productivity rate per hour needed to monitor the 20% EPZ population planning base within about 12 hours.
60) Question: Can portal monitors be used to monitor vehicles?
Answer: Regardless of manufacturer claims, there are challenges to using portal monitors on vehicles. However, portal monitors may be used on portions of vehicles if the user can demonstrate the sensitivity of the instrument to the standards described in FEMA REP-22. If the 0.0085 μCi/cm2 can be detected on certain portions of the vehicle, a portal monitor may be used in tandem with a hand-held monitor. It is the responsibility of the user to demonstrate the detection sensitivity of the portal monitor in the scanned zone using the planned monitoring technique. Some areas of the vehicle, such as the grill and roof, may still need to be monitored by hand. The interior of a vehicle will still need to be monitored by hand.
61) Question: Should host or receiving hospitals be evaluated for the ability to determine whether patients transferred from an EPZ hospital are contaminated and, if so, if they are able to decontaminate?
Answer: No. The Joint Commission on Accreditation of Healthcare Organizations (JCAHO) requires hospitals to have plans to provide for radioactive isolation and decontamination (EM.02.02.05). Additionally, Occupational Safety Health Act (OSHA) published “Best Practices for Hospital-Based First Receivers of Victims from Mass-Casualty Incidents”, which outlines requirements for monitoring and decontamination for hazards including radioactive contamination. Since these other agencies place requirements on hospitals to prepare for contaminated patients, the REP Program has no need to evaluate these facilities, nor does the ORO have the responsibility to provide training or dosimetry.
62) Question: Per 6.c.1 page III-61, “Individuals arriving at congregate care facilities must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they and their service animals and vehicles, where applicable, have been monitored, cleared and found to have no contamination or contamination below the trigger/action level. However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles monitored and decontaminated (if applicable) and do need confirmation that their vehicle is free from contamination prior to entering the congregate care areas.” Some plans call for impounding contaminated vehicles until the emergency phase is over and they have the resources to decontaminate the vehicle. If a state plans to monitor and decontaminate an evacuee and provide documentation that the individual is free of contamination, why must the evacuee’s vehicle be proven contamination free for the evacuee to enter the congregate care center?
Answer: If the plan/procedures call for impoundment and monitoring and decontamination later, then the OROs should operate according to plan/procedures. Both sentences quoted above from the RPM state if applicable. This applicability allows flexibility based on requirements of the plans/procedures regarding when the decontamination of cars takes place.
63) Question: Do reception centers have to be ADA compliant/accessible? (ADA, pg I-8, 1st paragraph on right) Is the REP Program going to evaluate ADA compliance?
Answer: The REP Program will evaluate centers used for public services during an emergency, congregate care and the services and supplies provided by those centers based on requirements of the sixteen planning standards and the criteria contained in NUREG-0654/FEMA-REP-1 and the October 2011 revision of the REP Program Manual. The REP Program will not evaluate shelters for ADA compliance.
64) Question: What will FEMA evaluate against regarding Potassium Iodide (KI) for the general public? Should states use FDA or EPA guidance? If the NRC is holding the licensee to 25 R for their emergency workers, how can FEMA recommend using guidance that varies so widely?
Answer: FEMA asks that the OROs consider both the FDA and EPA guidance when developing the plans/procedures. FDA breaks down the guidance into multiple age groups. Adults over 40 yrs are recommended to take KI when a Committed Dose Equivalent (CDE) greater than 500 rem is expected. Adults 18 – 40 years are recommended to take KI when a CDE greater than 10 rem is expected. Children/minors are recommended to take KI when a CDE greater than 5 rem is expected. EPA recommends 25 rem CDE. FDA also provides guidance for the dosage. Some OROs prefer to have one number applicable to all workers and the general public and others prefer to split out the recommendations per the recommended age groups.
65) Question: How will FEMA Credit be given for “real world events”? Can credit be given for activities conducted in response to an actual non-REP emergency that is occurring during the time of an exercise, provided an evaluator is present to observe and document the activities?
Answer: It some cases, exercise credit can be awarded for planned events or actual incidents. For an actual event, some criterion may be offered credit based on documentation (mobilization records, etc). If possible, an ORO may call the Regional FEMA Radiological Emergency Preparedness (REP) Branch and ask for a Site Specialist or a REP Program credentialed evaluator, to view response activities. If it is possible for a Site Specialist to be present in the EOC (or at shelter, monitoring/decon, etc), they may be able to provide credit for a range of activities.
Each of these will be considered independently, based on available documentation and incident details. The Regional Assistance Committee (RAC) Chair will make a recommendation for credit to FEMA REP Headquarters, who will then make a determination.
66) Question: Can FEMA do staff assistance visits to an EOC during a disaster response to evaluate criteria, if it is during an exercise year? If so, would this be documented in a separate report or included in the After Action Report?
Answer: Per the RPM page III-25, “Biennial exercise AARs may include the evaluations of drills or out-of-sequence activities (e.g., medical services or reception center drills) conducted within 60 days prior to or 30 days after the exercise date.” The Site Assist Visit during a disaster to evaluate an EOC would be considered an out-of-sequence event. If the SAV occurred beyond this time frame “FEMA issues separate drill AARs for evaluations occurring outside the specified timeframe. The FEMA Regional Administrator (or designee) transmits drill AARs to the NRC Regional Administrator within 45 days of the drill date.”
67) Question: Can partial participation by the state be limited to providing control cell (or simulation cell functions) to ensure adequate demonstration of required criterion by those local jurisdictions that are required to demonstrate once every eight years (so long as they do not exceed the required frequency of demonstration for criteria that apply to the state)?
Answer: Yes, when states partially participate in an exercise, they have the flexibility to support the other OROs via control cell. This should be negotiated with FEMA and licensee and documented in the extent-of-play.
PART IV: PROGRAM ADMINISTRATION
68) Question: What should OROs use when developing Annual Letter of Certification (ALC)?
Answer: On page IV- 49, FEMA has detailed ALC guidance. “The review guide assists state and FEMA Regional personnel with development, submission and review of the ALCs and development of public education and information materials.” FEMA expects the OROs to use this review guide (page IV-51) for organizing the ALC submission.
69) Question: Where can copies of the references listed in Appendix C be found?
Answer: Copies of all references will be found on the FEMA REP Program website, eventually. In the mean time, contact your FEMA Region for copies.
Evaluation Process for No/Minimal Release Scenarios in Biennial Exercises