Frequently Asked Questions - FEMA REP Program Demonstration Guidance Revised 02/1/2012 NEW 12/2/2011 1) Question: In Exhibit III-2: Federal Evaluation Process Matrix, 1.b.1. is listed as being evaluated once every 8 years. On page III-31, it states it is evaluated once and then only after substantial changes. Which one is correct? Answer: Criteria 1.b.1. will be evaluated once every 8 years. FEMA will correct page III-31 by page change, when possible. 2) Question: Why were there new criteria and revised sections added to the October 2011 RPM version that were not part of the 2009 RPM version? Answer: As previously indicated in the discussion of the public comment adjudication matrices, FEMA accepted, noted, rejected or modified public comments. A review of the Summary of Revisions section contained in the final version of Supplement 4 and compare it with the one contained in the May 2009 draft. Little difference exists between the two documents. The May 2009 version lists a summary of revisions to evaluation criteria A.1.a., C.6., N.1.a., and N.1.b. The only further additions appearing in Supplement 4, i.e., N.1.c. and N.1.d., represent logical outgrowths of adjudicating the public comments. Specifically, N.1.c. applies only to licensees, and N.1.d. simply relocates ingestion scenario language originally appearing in N.1.b. 3) Question: Can FEMA discuss the changes in the Evaluation Areas? (Revised 01/17/2012) 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. 4) Question: Currently, Radiological Monitoring drills are conducted annually, and evaluated every other year. Per criterion N.2.d., the RPM now states that they are conducted annually, with no reference as to how often they are evaluated. Has the frequency of evaluation changed? Answer: No, per the Federal Evaluation Process Matrix, these drills are still evaluated biennially. 5) Question: Plans/procedures need to include the initiating event starting from an ORO versus the standard utility initiation, as may potentially occur during an HAB event. Does this “reverse notification” have to be exercised? Answer: Yes, per Evaluation Criteria sub-element 1.a.1., “Local responders must demonstrate the ability to receive and/or initiate notification to the licensee or other respective emergency management organizations of an incident in a timely manner, when they receive information from the licensee or alternate source.” 6) Question: Criterion 6.b.1 discusses the monitoring of emergency workers and their equipment.  There is no discussion of registration or documentation requirement for the emergency worker.  Shouldn’t a record of monitoring results and decontamination be maintained for the emergency workers?  Answer: Yes, at a minimum, there should be a record for anyone found to be contaminated to include monitoring results before and after decontamination. 7) 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. 8) Question: The new program manual includes a requirement that electronic dosimeters used be tested with hand-held radios or cell phones used by emergency responders to determine whether the dosimeter will be affected by the radio frequency.  What are the testing requirements and how should this be documented?  Is documentation required to FEMA?  Can the manufacturer’s specifications be used to prove that there is no risk of interference from radio or cell signals? A: The testing of electronic dosimeters with the use of hand-held radios is suggested, not required, by the RPM. On Page II-96 it states: “The electronic dosimeters used are tested with any hand-held radios or cellular telephones that may be used by the emergency responders to determine whether the dosimeter will be affected by radio frequency interference.” 9) Question: Is there any guidance for planning for and meeting access and functional needs in general population shelters? To what level will FEMA evaluate the OROs regarding FNSS? Is FNSS required for short term shelters (less than 72 hours)? Answer: As the October 2011 revision of the Radiological Emergency Preparedness (REP) Manual discusses, on page I-8, FEMA developed guidance for shelters to support Federal, state, local, and tribal governments with the integration of children and adults with and without disabilities who have access and functional needs into every aspect of emergency shelter planning and response. This document is titled “Guidance for Planning for Integration of Functional Needs Support Services (FNSS) in General Population Shelters. This guidance is not designed to establish local government as the single shelter operator or establish a new “tier” of sheltering. It is not intended to establish new legal obligations, alter existing obligations, or constitute a legal interpretation of the statutes that are the basis of the guidance materials. The guidance is not meant to duplicate or cover all requirements found in existing or potential shelter plans or Standard Operating Procedures (SOP). This is simply a resource for integrating FNSS into the general shelter planning process and/or existing documents. Listing an agency or organization’s processes/ procedures as an operational tool in this guidance does not constitute a recommendation or endorsement of the resource. In addition, information presented in an operational tool may have been summarized, modified and/or combined with other cited sources. Communities can use this document in conjunction with general population shelter SOP to ensure that all shelter residents benefit equally from programs, services, and activities. This document provides a context for FNSS integration in light of other existing plans and describes a process to use in any planning effort. The scalability of these guidelines enables their application to urban, suburban, and rural localities with multiple or limited resources. The Department of Justice published revised final regulations implementing the Americans with Disabilities Act (ADA) for Title II (State and local government services) and Title III (public accommodations and commercial facilities) on September 15, 2010, in the Federal Register. These requirements, or rules, clarify and refine issues that have arisen over the past 20 years and contain new, and updated requirements, including the 2010 Standards for Accessible Design (2010 Standards). 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 compliance with other regulations or laws promulgated by another Federal Agency or Department. The States are compiling a list of questions for the Department of Justice through the sponsorship of the National Emergency Managers Association that reflect their implementation concerns of the revised ADA laws. Regardless of the length of time a shelter is open, OROs should consider integrating FNSS into the shelter planning process. NEW 12/28/2011 10) 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 should work with the OROs to revise the training. 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 should observe training, seminars and practical demonstrations that are used to assess proficiency. If FEMA attends, it is not to evaluate the training. However, occasionally, it may be appropriate for an ORO to request feedback or assistant/advice on training. FEMA can furnish the appropriate resources and assist with training as requested. 11) Question: With the new planning and response requirements for Hostile Action Based (HAB), will FEMA be evaluating the Federal Response? Answer: FEMA evaluates the Federal Response only when they are responding using OROs procedures. For example, when the United States Coast Guard is used for alerting of waterways, they will be evaluated. The Federal Bureau of Investigation acts outside of the OROs procedures when responding during a Hostile Action scenario, and therefore, will not be evaluated. 12) 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. 13) 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. NEW 01/17/2012 14) Question: Prior to the publication of the October 2011 RPM, Medical Services (MS-1) scenarios were allowed to be played out with an on-site contaminated injured victim per a memo titled “Clarification of Selected Provisions of Guidance Memorandum (GM) MS-1, Medical Services,” dated February 9, 1988.  This memo has been retired (and appears in Appendix D), and the language on page III-63 clearly states that demonstrations should be conducted with a simulated contaminated injured member of the general public.  Given that the clarification memo is now retired and is superseded by the October 2011 program manual, can you please confirm that MS-1 scenarios that use an on-site simulated contaminated injured victim rather than a member of the general public should no longer be acceptable.  Answer: The Guidance Memorandum titled, “Clarification of Selected Provisions of Guidance Memorandum (GM) MS-1, Medical Services,” dated February 9, 1988 has been retired by the October 2011 version of the REP Program Manual. It is up to the Region, utility and ORO involved to determine, in the Extent of Play discussion for the drill, whether the “contaminated, injured individual” will be someone from the onsite organization, a member of the offsite response organization or a member of the general public. 15) 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., 3.a.1., 3.d.1., 2.b.2. and 3.d.2. demonstrated at an ICP.  Additionally, depending on scenario these supplemental criteria, 2.b.2., 2.c.1., and 3.c.1., may need to be demonstrated. 16) Question: Page III-7, Criterion 1.b.1 states, “Responsible OROs must demonstrate, at least once in a baseline evaluation, the availability of fixed facilities that support accomplishment of emergency operations. Baseline evaluations are performed for EOCs and JICs, as well as other fixed facilities such as reception/relocation centers.” Do all facilities get a 1.b.1 evaluation every 8 years, including radio stations, initial warning points, laboratories, hospitals, etc.? Answer: The only facilities that evaluated under 1.b.1 are EOC, JIC, and reception/relocation center. Radio stations, laboratories, initial warning points and hospitals are not evaluated under 1.b.1. NEW 02/01/2012 17) 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.”  18) Question: Will the NRC evaluation of the licensee on off-hours unannounced drills have any impact for the OROs? Should they expect to have NRC evaluators show up at off-site notification points to conduct the evaluation of on-site requirements? (manual reference: Planning Standard N.1.c, Page 11-122) Answer: Planning Standard N.1.c. applies to the licensee only, and therefore will not impact the OROs. 19) Question: Is FEMA going to require that all OROs plan for and demonstrate the capability to make notifications to all other OROs and the licensee, or is it sufficient that the ORO can notify the licensee and allow them to make the notification to the other OROs? (manual reference: E.1, page II-23) Answer: The extent-of-play agreement may drive which notifications need to be demonstrated during an exercise, but OROs need to have the capability to contact other OROs and licensee per E.1 “Initial notification to licensee and the ORO when a notification originates from an entity other than the licensee.” The Explanation below states “Notification protocols: OROs have clear and consistent means for providing emergency notification to all responding organizations.” 20) 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. 21) Question: The Federal Evaluation Process Matrix cross-references evaluation criteria 1.d.1 with planning standards F.1 and F.2, but does not include them under evaluation criteria 1.a.1.  Shouldn’t planning standard F.1 also be cross-referenced under evaluation criteria 1.a.1., as well? Answer: According to the Assessment/Extent of Play below 1.a.1., OROs must demonstrate the ability to contact key personnel in a timely manner.  Therefore, F.1 and F.2 should be cross-referenced and will be added in the updated Manual.  22) 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 agreement.