Frequently Asked Questions - Challenging Drills and Exercises Revised 02/01/2012 NEW 12/9/2011 1) Question: What are OROs required to demonstrate for a no-release scenario? (Revised 1/17/2012) 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 (dose assessment, field monitoring, and monitoring/decontamination), inject messages and/or out-of-sequence demonstrations may be used. 2) Question: Planning Standard N.1.b. now states that one “full-scale exercise” needs to be completed once every 8 years. Does this mean that every school, reception center, etc. must play that year and that there can be no out-of-sequence associated with this full-scale exercise? Can FEMA explain more clearly the definition of “full-scale”? Answer: The requirement that a full-scale exercise needs to be completed once every 8 years is a misprint. Only the “qualifying” exercise necessary to obtain the initial operating license constitutes a “full-scale” exercise. FEMA considers all subsequent biennial exercises “functional” and, per 44 CFR Part 350, may be “full participation” or “partial participation”; both allow for some “out-of-sequence” demonstrations. Moreover, State, tribal, and local OROs must conduct joint full participation exercises with the licensee biennially (i.e., every two years) in order to comply with the regulations in 44 CFR § 350.9(c). This applies to OROs that have an NPP within their boundaries or that lie wholly or partially within the 10-mile plume exposure Emergency Planning Zone (EPZ) of such a site. The current exercise cycle is 8 years and spans 4 biennial exercises. The first qualifying exercise should be a full-scale exercise that tests real-time response with all ORO entities participating and includes the integrated demonstration of all activities that would occur if the exercise scenario were to occur in real life. In the event of a new reactor at an existing site, as long as the EPZ has not changed, the biennial full participation exercise maybe utilized in lieu of a full-scale exercise. Full participation is a REP-specific term found in 44 CFR § 350.2(j) that refers to an exercise that tests: (1) engagement of State, tribal, and local government emergency personnel in sufficient numbers to verify the capability to respond to the actions required by the accident scenario; (2) the integrated capability to adequately assess and respond to an accident at an NPP; and (3) the implementation of the observable portions of State, tribal, and/or local plans. The regulatory provisions give OROs with responsibilities to multiple NPPs flexibility to partially participate in some biennial exercises. States with multiple sites may rotate their full participation among the sites (i.e., when not fully participating at a site, the state partially participates to support OROs). If a local ORO lies within the EPZ of more than one NPP and full participation poses an undue hardship, it may request permission to partially participate. OROs submit requests for exemption from full participation to the FEMA Regional Office, which will forward the request to FEMA Headquarters. 3) Question: When does the 8-year exercise cycle begin and will OROs have to complete 6-year cycle requirements in the new cycle? A: The 8-year exercise cycle will begin on the date of the first hostile action-based exercise held after the RPM implementation. This should occur by December 31, 2015. FEMA highly encourages OROs that will be in the middle of their 6-year cycle when the 8-year cycle begins to accomplish outstanding requirements through negotiations with the RAC Chairperson. 4) Question: How can FEMA implement HSEEP, when 44 CFR Part 350 was not revised? Answer: During the comment period, commenters voiced concerns about OROs that did not adopt HSEEP because they do not receive Federal preparedness grant funds, as well as about the tension between HSEEP’s no-fault methodology and the statutorily-based performance/outcome-based REP exercise requirements. Given that all FEMA Regions already completed HSEEP/REP integration exercises in 2010, FEMA does not see the need to amend 44 CFR Part 350. The final RPM and Supplement 4 sought to align with and integrate national preparedness initiatives such as HSEEP, NIMS, and ICS. These initiatives seek to streamline Federal, State, tribal, and local government efforts, employ a common assessment strategy, use standard terminology, and provide a set of standardized organization structures. FEMA Directive 123-15 empowered FEMA Regional REP Program offices to integrate HSEEP methodology and doctrine into their exercises. REP Program exercises will use the HSEEP methodology and guidance for exercise program management, design, development, conduct, evaluation, and improvement planning. Utilizing the HSEEP methodology will not alter requirements for the REP Program under NUREG-0654, establish any additional exercise evaluation requirements for the REP Program, or replace existing REP Program Demonstration Criteria with new capabilities. FEMA will continue to issue Areas Requiring Corrective Action (ARCAs) and Deficiencies during REP exercises when appropriate. In order to facilitate the REP Program/HSEEP transition process, FEMA developed two tools as part of the RPM release: the criterion-capability crosswalk and REP Program-specific exercise evaluation guides. The evaluation guides include Target Capability sets identified by FEMA that correlate to the REP Program Demonstration Criteria to permit the evaluation of REP Program exercises using HSEEP exercise documents. Compliance with this new methodology will create more consistently formatted After-Action Report/Improvement Plans (AAR/IP) across Federal, State, tribal, and local jurisdictions, as well as include enhanced tracking and implementation of corrective actions identified in the AAR/IP. The benefits of following these methodologies and “speaking the same language” include: OROs who already adopted the HSEEP methodology will not need to employ differing processes and report formats for their REP Program and non-REP Program exercise activities; OROs can use REP Program exercise AARs to document progress toward their overall preparedness and Target Capability goals; and OROs required to utilize the HSEEP methodology as a condition of receiving Federal preparedness grant funds can use REP Program exercise AARs to satisfy grant spending documentation requirements. In anticipation of the final RPM, most FEMA Regional offices began implementing HSEEP methodology. All Regions completed an HSEEP integration exercise in 2010. 5) 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. 6) Question: I have heard that FEMA changed some HSEEP terminology. How does that affect REP and will changes be made in the RPM? A: As stated in the Department of Homeland Security, September 2011, National Preparedness Goal document, Target Capability Lists (TCLs) have been renamed “Core Capabilities”, and some of the capabilities have been combined and/or renamed. “These core capabilities represent an evolution from the Target Capabilities List. The transition to core capabilities expands the focus to include Mitigation ….Core capabilities and targets, like the risks we face, are not static. They will be vetted and refined, taking into consideration the risk and resource requirements, during the planning process established through PPD-8.” This information will be changed in the RPM via a page change. NEW 12/28/2011 7) Question: Does Ingestion Pathway Exercise need to be done per licensee or per state? Answer: For States with multiple sites, the State may rotate their full participation among sites (when not fully participating, the State partially participates to support OROs), although it is suggested that full participation in an ingestion for the State not exceed an eight year period. 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 during the exercise cycle. 8) 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. NEW 02/01/2012 9) Question: What additional Federal agencies does FEMA expect the states to include in their plans for HAB planning? (manual reference: C.6, page II-19) Answer: NUREG Criterion A.3 states, “Each plan shall include written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role within the Emergency Planning Zones.” To meet the intent of this criterion, all ORO Plans and Procedures including HAB shall: * Identify assisting organizations and the type of assistance (capabilities and resources) they will provide. * Specify for each organization identified whether the aid is covered under an inter-governmental mutual assistance compact or whether a Letter of Agreement (LOA) is needed. * Include LOAs by reference or in a suitable appendix. * Include or reference applicable LOAs between the licensee and ORO including arrangements for access to the NPP site, if appropriate. * State that the LOAs include details on what services will be provided and how the agreements will be activated. * State that LOAs are reviewed annually to verify their validity. The Explanation section of this criterion states that, “Supporting an emergency response involves a variety of capabilities. Licensees and OROs may establish agreements with government or private-sector providers to delineate the type of support and assistance they can provide. Intergovernmental support is increasingly being secured through mutual assistance compacts supported by legislation. However, for those support arrangements between jurisdictions that are not covered by mutual assistance compacts, and for support arrangements with private-sector entities, LOAs are needed.” 10) 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.