Frequently Asked Questions – Program Planning Guidance Revised 02/01/2012 NEW 12/2/2011 1) Question: Planning Standard O.1.b. states “Plans identify mutual aid organizations and specify the arrangements for offering training.” What information needs to be provided? Answer: Plans should list training courses offered and identify to which type of agencies this training will be offered. OROs will continue to provide more detailed information in the ALC. 2) Question: On page II-57, what does “radiological equipment stored near the NPP” mean? Answer: Stored near means that the equipment must be accessible within a timely manner and without delay to the response efforts. 3) Question: What is the requirement for translating public information materials into non-English languages? (Revised 01/17/2012) Answer: Refer to page II-45, at a minimum, public information materials shall be translated into any non-English language spoken by more than 10,000 individuals or more than 5% of the county population of voting age (based on current demographic studies). The information referred to on page II-45, G.1 Foreign Language Translation of Public Information Materials applies to persons who have designated that English is NOT their primary language. Pages II-33 and II-41 misquoted this information by leaving out the 10,000 individuals’ requirement. FEMA will revise by page change, when possible. At least every five years, OROs will determine if new translations are necessary. If new documents are necessary, the implementation of such will be complete within one year. 4) Question: Does Page II- 77 J.10.d Section b of the RPM above apply to a licensed in-home daycare? Answer: Yes, any daycare that is licensed, regardless of size or location falls under this planning standard. 5) Question: How does 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. NEW 12/28/2011 6) Question: Is FEMA going to evaluate mutual aid agreements, Memoranda of Understanding (MOU) or Letters of Agreement (LOA) that OROs 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? Answer: FEMA will not be evaluating MOUs/LOAs between government agencies. FEMA will be assessing MOU/LOAs that the Offsite Response Organization (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. 7) 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? Answer: Per NUREG 0654/FEMA REP-1 Supplement 4, “OROs and licensees work together to ensure that emergency plans/procedures are coordinated/communicated and updated as needed to provide prompt access to the NPP site for in-bound first responders.” The process and provisions required may vary from site to site, depending on the agreements reached between the licensee and the OROs. When reviewing plans, FEMA should assure that plans address the ability for OROs to respond on-site. Since this may be safeguarded information, the plans may only refer to an agreement and not have detailed information. 8) Question: Planning Standard J.11 states “Up-to-date lists of the name and location of all facilities which regularly process milk products and other large amounts of food or agricultural products originating in the ingestion pathway Emergency Planning Zone (EPZ), but located elsewhere, shall be maintained.” Can we define Regularly and Large? Where and how will these list be evaluated and maintained? Answer: In the RPM, under Planning Standard J.11, it states that” to meet the intent, plans/procedures shall describe: the location and means of obtaining up-to-date information of the permanent agribusiness facilities within the EPZ.” Therefore, all permanent businesses will be included so regardless of size and regularity. 9) Question: Should the sub-note 93 for 6.a.1. that states “Participation may be rotated among facilities, but each facility must be evaluated no less than once every 8 years.”, also apply to 6.b.1.? Answer: Yes, the sub-note should apply to both. For both 6a1 and 6b1, all OROs with the responsibility of monitoring and decontamination will be evaluated at least once every 8 years. Moving forward – each facility should have an assigned monitoring/decontamination team. This is to ensure that in the event that multiple facilities needed to be stood up, specific teams are familiar with their assigned facilities. For example, Apple Fire Department is responsible for monitoring and decontamination at Red High School. NEW 01/17/2012 10) Question: Criterion D.4 states ORO should have procedures in place that provide for emergency actions to be taken which are consistent with the emergency actions recommended by the licensee. Does this mean that the ORO Protective Action Decision (PAD) must match the Protective Action Recommendation (PAR) that comes from the plant? Answer: No, the PAD does not have to match the licensee PAR. As stated under Criterion 2.b, OROs can base their PADs on plant conditions, licensee PARS, coordination of PADs with other jurisdictions, and other threats/hazards such as weather or hostile actions in accordance with ORO plans/procedures. 11) Question: Criterion I.11 discusses the requirement to take samples from the center line of the plume. If the outer edges of a plume are beyond PAGS, why would a team ignore basic ALARA principles and send someone further in the plume? Answer: FEMA does not require the ORO to obtain the centerline measurements, but the methods or other organizations used to obtain these measurements must be defined in the plan. NEW 02/01/2012 12) 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. 13) 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 LOA signatories. Does this mean plans/procedures shall include legal limitations applied by the OROs own policies and laws? Answer: This means that plans/procedures should include any limitations that are relevant to State, local or tribal statutes and not policy. 14) Question: Per sub-element A.3., if a particular non-governmental organization is a signatory to the plan, must there also be a LOA maintained with that organization for services provided during a response? (manual reference: A.3, page II-10) Answer: All organizations whose response functions are covered by Federal, State, or local laws, regulations or executive orders do not need separate written agreements or Letters of Agreement (LOA), other organizations will require LOAs 15) 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: The most practical option for determining the non-iodine particulate component of the plume is to return the particulate filter to a laboratory for analysis with a Ge(Li) or intrinsic Ge detector. It is important to emphasize the need for a quick turnaround time between field collection and laboratory measurements due to the decay of the particulate sample. For planning purposes, field samples should be transported to a laboratory within approximately four hours of the time of collection. The information obtained from the laboratory measurements of the particulate air filters will be very useful to the decision makers during their process of verifying that the protective action recommendations made during the plume phase were valid, and for providing early information concerning the post plume phase portions of an accident sequence. 16) 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.