Updated: May 28, 2014
1 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.
2 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 ninety days prior to participating in an HAB Exercise.
3 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
4 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.
5 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.
PART II: PLANNING GUIDANCE
6 Question: What is involved in the plan approval process for those OROs that have their HAB exercise prior to the 30 month deadline?
Answer: Plans must be submitted to the regional FEMA office for approval 90 days prior to the exercise.
Plan revisions, especially newly written plans, as may be the case with the HAB scenario may take up to a year to complete. It is highly encouraged that OROs work with their FEMA regional office during this time to assure plans are moving in the right direction.
It is also encouraged that drafts of plans be submitted to the FEMA region prior to the 90 day period (it is recommended at 120-180 days) to allow for a cursory review and discussion of content prior to submitting for approval.
A minimum of 90 days prior to the exercise, the plans will be submitted to the FEMA regional office. A determination as to whether the plans are approved will be made by the Regional Assistance Committee Chairperson following the review.
The biennial exercise is based on the approved plans and procedures. It is imperative that the OROs and the FEMA regional office work together in advance to assure the exercise is not delayed because of unapproved plans.
7 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.
8 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.
9 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.
10 Question: Planning Standard E.7 references the American Industrial Hygiene Association “Respiratory Protective Devices Manual of 1963”. Is this still valid?
Answer: The American Industrial Hygiene Association (AIHA) has retired this document. The references to the document have been removed from the RPM; however, the Planning Standard wording will not be changed until NUREG 0654/FEMA REP 1 is updated.
11 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.
12 Question: What is the definition of an “American Red Cross managed” shelter?
Answer: Shelters “managed by the American Red Cross (ARC)” are facilities in which the administrative control position (i.e.: Shelter Manager) is manned by ARC personnel. This usually includes ARC Shelters and ARC/Partner Shelters. These shelters will be evaluated once under 1.b.1 when designated as a shelter or when substantial changes occur. All other shelters must be evaluated no less than once every eight years.
Additionally, it has come to the REP Program’s attention that current guidance found in the Manual needs further clarification. Criterion J.10.h currently states: “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.” And, Sub-element 6.c states: “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.”
13 Question: Are ALL ORO responders to an NPP incident, including tactical responders, considered Emergency Workers and thereby covered under what is expected of Emergency Workers Exposure Control measures?
Answer: Yes. The health and safety of law enforcement /tactical responders like all emergency workers responding must be protected, thereby they are functioning under the same exposure control measures. These measures should be accomplished without impeding or delaying the tactical response.
14 Question: Do ambulance providers who work outside of the EPZ (i.e. responding to a reception center) need to receive dosimetry?
Answer: Yes, ambulance providers should receive dosimetry in cases where these providers are picking up potentially contaminated patients at a reception center, otherwise there is concern that the providers are receiving dose that is not documented. The following wording in the RPM will be added to clarify: “Any responder assigned a mission that could result in exposure to radiation is provided dosimetry and procedures for tracking any exposure received.”
15 Question: Can you address the REP Program Manual guidance concerning the use of a correction factor for converting Direct Reading Dosimeter (DRD) readings to actual dose?
Answer: The REP Program Manual states that “EPA-400-R-92-001 guidance is to apply a factor of 5 to DRD readings to determine the actual dose received during early phase or plume exposures. This citation is erroneous as the EPA Protective Action Guides (PAG) Manual does not suggest a conversion factor of 5 be used.
The REP Program Manual provides three options for managing emergency worker exposure that are considered acceptable in Planning Criterion K.3.a. If a default factor is used, the ORO will be able to explain the basis for the factor’s value along with a statement that upon availability of source term or field team data the value will be recalculated. Other options may be submitted for consideration.
16 Question: Please clarify the training requirements listed in Planning Standard O. Planning Standard O.4 states, “The specialized initial training and periodic retraining programs shall be provided in the following categories…”. Planning Standard O.5 states “Each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities.” This could be contradictory”.
Answer: Training is offered annually. Periodic means that training can occur more often than annual if needed/desired.
PART III: DEMONSTRATION GUIDANCE
17 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.
18 Question: What is the definition of an interview?
Answer: An interview in the REP Program is a question(s) asked by an evaluator during the course of an exercise to obtain information on required elements not demonstrated per the extent-of-play agreement. Evaluators interview participants, as necessary, in order to complete their evaluation. Out-of-sequence events are demonstrations that may include interview questions.
19 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.
20 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 only exception is that for sites licensed under Part 52, the 8 year cycle will start with the initial exercise required by Sec. IV.F.2.a. 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 both exercise types and all scenario options.
All OROs within the 10-mile EPZ must demonstrate ingestion pathway (return, reentry and recovery) responsibilities once every 8 years. OROs between 10- and 50-mile EPZs, with ingestion pathway responsibilities, should also participate in the Ingestion Pathway Exercise. Those OROs (between 10 and 50 miles) that do not fully participate in the exercise should participate in an ingestion pathway tabletop exercise or other ingestion pathway/post plume 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.
21 Question: When does the HAB Cycle start? Can an ORO receive credit for the new cycle with actions leading up to the actual demonstration date?
Answer: Per the NRC Secy 11-053 on page 112: “The first eight-year exercise cycle for a site will begin in the calendar year of the first hostile action exercise.” Any ORO activities that occur during the year that would/could normally be associated with the biennial exercise can be considered part of the new exercise cycle and will not have to be redemonstrated.
22 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.
- 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.
- 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.
23 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.
24 Question: Must the ORO demonstrate the ability to initiate notification of a potential incident at the nuclear plant, as described in 1.a.1, (sometimes referred to as “reverse notification”) biennial?
Answer: While this notification method must be in plans as a capability, it is not a biennial requirement and demonstration of this capability is dependent on the Extent of Play agreement and the scenario, and should be negotiated with the RAC Chair.
25 Question: Will FEMA be inventorying or evaluating the equipment used by mutual aid resources?
Answer: It is suggested that plans address a process of routing incoming responders to a staging area where responders can be trained and provided with the necessary equipment. However, if the incoming resources arrive with their own equipment (monitors and/or dosimetry), they will be evaluated per REPP Standards. FEMA will not inventory equipment that is not part of the REP Program. If an agency has a defined role in the REP plan, they are subject to the planning standards and RPM.
26 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.
27 Question: With a minimal/no release scenario, will an ORO be able to properly demonstrate Criteria 2.b and 3.c?
Answer: Yes these Criteria can be properly demonstrated without a release.
Both Criteria 2.b and 3.c specify “Protective Action Decisions,” not a “Precautionary Action Decisions.” The glossary in the RPM, the definition of a Protective Action Decision is a “measure taken in anticipation of, or in response to, a release of radioactive material to the environment.” By this definition, in a no release scenario, a “Protective Action Decision would never be made,” and therefore would not meet the intent of the criteria as written. However, since the decision making process is the same, whether a Protective or a Precautionary decision is made, 2.b and 3.c can be properly demonstrated during a no release scenario. Changes to the demonstration criteria 2.b and 3.c will state “precautionary/protective” actions in place of the current “protective” actions.
28 Question: What should the KI briefing mention regarding shellfish allergies or pregnant or nursing women?
Answer: The Food and Drug Administration (FDA) is the definitive medical authority in the United States on the use of potassium iodide. The REP Program Manual References these documents which go into detail regarding information needed to present an accurate information briefing:
- Federal Register Volume 66, No. 13, pp. 5427-5440, Consideration of Potassium Iodide in Emergency Plans, Final Rule, Nuclear Regulatory Commission, January 19, 2001.
- Notice from Paul Lohaus (NRC) to All Agreement and Non-agreement States' State Emergency Response Directors dated January 26, 2001 on “Revisions to NRC Regulations on the Use of Potassium Iodide in Emergency Response (STP-01-006).”
- Federal Register, Volume 66, No. 238, pp.64046-64047, Guidance on Use of Potassium Iodide as a Thyroid Blocking Agent in Radiation Emergencies, Food and Drug Administration, December 11, 2001. http://www.fda.gov/Drugs/EmergencyPreparedness/BioterrorismandDrugPreparedness/ucm072265.htm.
29 Question: During a rapidly escalating event, is an ORO required to provide specific evacuation route instructions to the public (e.g., take Highway 1 to Highway 2) or can the ORO provide basic instructions (without the specific route to get there)?
Answer: Instructions to the public must me provided whether it is a rapidly escalating event or not. The requirement to provide the public with safe evacuation routes is the same. Even without time to do an independent assessment, the ORO knows the wind direction and would traditionally steer the public away from that area. At a minimum, the instructions must include the direction to travel and areas to avoid.
30 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.”
PART IV: PROGRAM ADMINISTRATION
31 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 meantime, contact your FEMA Region for copies.