ML080850968
| ML080850968 | |
| Person / Time | |
|---|---|
| Issue date: | 03/20/2008 |
| From: | Schrader D, Zimmerman R Office of Nuclear Security and Incident Response, Federal Emergency Management Agency |
| To: | Fertel M Nuclear Energy Institute |
| Anderson Joseph , NSIR/DPR 415--4114 | |
| References | |
| Download: ML080850968 (15) | |
Text
March 20, 2008 Marvin S. Fertel Senior Vice President and Chief Nuclear Officer Nuclear Energy institute 1776 I Street, NW -- Suite 400 Washington, DC 20006-3708
SUBJECT:
INTENT TO ENGAGE STAKEHOLDERS ON DRAFT PRELIMINARY CHANGES TO RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE GUIDANCE
Dear Mr. Fertel:
Over the past year, the Federal Emergency Management Agency (FEMA), in coordination with the Nuclear Regulatory Commission (NRC), has developed draft preliminary changes to existing guidance for the development of radiological emergency preparedness (REP) exercise scenarios and evaluation of demonstration criteria. The intent of these draft preliminary changes is to help avoid the preconditioning of exercise participants, while addressing challenges to existing REP programs posed by the post-September 11, 2001 threat environment.
A summary of draft preliminary changes to FEMAs REP Program Manual is enclosed, which addresses key enhancement areas (i.e., non-sequential escalation in event classification, varying radiological release conditions, spectrum of scenarios). This summary is not intended to be all inclusive, but rather of sufficient detail to support the initial engagement of State and local stakeholders, the commercial nuclear power industry, and non-governmental organizations to aid in informing the final development of revisions and/or supplements to applicable NRC and FEMA regulations and guidance, including, but not limited to, the joint FEMA/NRC Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in support of Nuclear Power Plants (NUREG-0654/FEMA-REP-1, Rev.1). Final implementation of FEMAs REP Program Manual to include the draft preliminary changes would require modifications, through a supplement, to associated guidance in NUREG-0654/FEMA-REP-1, Rev.1. FEMA, the NRC, and stakeholders will also continue to evaluate areas for the effective use of State and local resources in REP exercises, while ensuring continued reasonable assurance.
M. Fertel To accomplish these goals, a FEMA/NRC Exercise Task Force will be used, in conjunction with a separate FEMA/NRC Rulemaking Working Group, to facilitate communications with stakeholders and develop the final implementation guidance, including, but not limited to NUREG-0654/FEMA-REP-1, Rev. 1). This Task Force has proposed the following project milestones that offer multiple opportunities for comment and provide for a proactive engagement of stakeholders:
- Provide a summary of draft preliminary changes to REP Program Manual to stakeholders for an initial 90-day comment period.
- Use of multiple regional focus groups and public meetings to provide an opportunity to directly solicit stakeholder comment and discuss related issues and concerns, as well as alternative proposals;
- Use of various organizational groups (National Emergency Management Agency, Nuclear Energy Institute, etc.) to assist in reviewing comments received from their respective constituents and developing proposed changes or recommendations for FEMA/NRC Exercise Task Force consideration.
- FEMA observation of designated hostile action-based emergency preparedness drills in calendar years 2008 and 2009 to aid in validating proposed changes dealing with demonstration of National Incident Management System/Integrated Command Structure (NIMS/ICS) aspects.
- Provide a formal opportunity for public comment and engagement of stakeholders on the proposed changes to the FEMA REP Program Manual through a Federal Register Notice, along with an opportunity for public comment and engagement of stakeholders on proposed changes supplementing NUREG-0654/FEMA-REP-1, Rev. 1. Stakeholders will also have the opportunity to provide input as part of the proposed NRC emergency preparedness (EP) rulemaking addressing a broad spectrum of changes to the NRCs EP regulations, including REP exercises
- The FEMA/NRC Exercise Task Force will continue to involve the FEMA Regional Assistance Committee Chairs and NRC Regional State Liaison Officers to coordinate any activities within their respective regions and to maximize the use of regional FEMA and NRC expertise.
The availability of a summary of preliminary changes to REP Program Manual is intended to inform stakeholders of the current status of the FEMA/NRC Exercise Task Forces activities. The FEMA/NRC Exercise Task Force would not solicit formal public comments requiring responses on the preliminary draft changes to REP Program Manual. The draft preliminary changes may be subject to significant revisions during the final implementation process.
M. Fertel Your assistance is requested in distributing this letter to nuclear power plant licensees and coordinating industry comments on the enclosure. Specific questions on the draft preliminary changes to the REP Program Manual, associated with this initiative, should be directed to Mr. Craig Fiore (Deputy Chief, REP Branch/FEMA Technological Hazards Division/National Protection Directorate) at (703) 605-4218.
Enclosure:
As stated cc: NRC Regional State Liaison Officers
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual The following table is intended is intended to aid in engaging stakeholders in dialog, as part of proposed regional focus (discussion) groups, on preliminary changes being considered to the REP Program Manual. Stakeholders are also encouraged to provide comments on this table to Mr. Craig Fiore (Deputy Chief, REP Branch/FEMA Technological Hazards Division/National Protection Directorate) at (703) 605-4218.
Manual Section Section Comment Entire Changed: National Response Plan (NRP) to National Document Response Framework (NRF)
Part II.C Criterion N.1.a Deleted: The emergency preparedness exercise shall
- 14. Planning simulate an emergency that results in offsite radiological Standard N releases that would require response by offsite authorities.
Part III.B Criterion 1.a.1 Added: Criteria C.1 to NUREG-0654 Criteria Column Table 4:
Federal Evaluation Process Matrix Part III.B Sub-element Changed the title of Sub-element 2.b: Radiological Table 4: 2.b Assessment & Protective Action Recommendations &
Federal Decisions for the Plume Phase of the Emergency Evaluation Phase Process Matrix Part III.B Criterion 3.d.2 Changed Criterion 3.d.2 to: Impediments to evacuation Table 4: and/or response are identified and resolved Federal Evaluation Process Matrix Part III.B Footnotes Added footnote in reference to 1.b.1:
Table 4: Facilities will only be specifically evaluated for this Federal criterion if they are new or have substantial changes in Evaluation structure or mission.
Process Matrix Part III.B Footnotes Added footnote in reference to 5.a.3:
Table 4: The failure (or partial failure) of the primary alert and Federal notification system must be demonstrated once every six Evaluation years in conjunction with the required hostile action-based Process Matrix scenario in cases where plans require the deployment of resources to perform backup route alerting, which may also be detailed to respond to a hostile action-based event at the site (LLEA, etc). - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual Part III.B Exercise Changed to: The radiological data should be supported Task 6 Scenario by and compatible with plant conditions and the Guidance Guidance associated potential for releases or simulated releases should support and be compatible with the radiological data. In the absence of a simulated release, the extent-of-play committee should develop controller inject data should be developed to drive activities that require simulated exposure rates or concentrations in the environment.
Part III.B 1. Plume Added new sentence: However, radiological release Task 6 pathway conditions should be varied between biennial exercise Use of Decision exercise play scenarios within the 6-year cycle (refer to plume pathway criteria scenario options d & e below).
Part III.B 1. Plume Added text to sentence: (2) Scenarios should be Task 6 pathway designed to sustain potential projected doses for a Use of decision exercise play sufficient period of time to drive OROs to implement Criteria protective actions, as applicable (refer to additional options d & e below).
Part III.B 1. Plume Added text to sentence: (3) The scenario should contain Task 6 pathway simulated contamination or exposure rates in the form of Use of Decision exercise play controller injects to drive field exercise play components Criteria requiring them or allow for the evaluation during an out of sequence drill.
Part III.B Heading c: Added new paragraph: At least one biennial exercise per Task 6 Exercises may cycle should involve at a minimum an initial classification Use of Decision begin at any of at a Site Area Emergency or rapid escalation from an Criteria the four ECLs... Alert to a Site Area Emergency.
Part III.B Heading c: Added new paragraph: Organizations may design events Task 6 Exercises may triggering an offsite response to initiate exercise play at Use of Decision begin at any of any ECL and/or provide for the skipping of an ECL(s). In Criteria the four ECLs... many exercises, the scenario generally postulates a sequential escalation from an Unusual Event or Alert classification through a Site Area Emergency to a General Emergency classification, with appropriate time periods designated between classifications to allow for the systematic demonstration of response activities. This scenario does not reflect actual event classifications where licensees have initially classified at the Alert level or higher. Skipping ECLs can make for less predictability and as a result more realistic and challenging scenarios. - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual Part Iii.B Heading c: Changed paragraph to: Events triggering an offsite Task 6 Exercises may response may be designed to initiate exercise play at Use Of Decision begin at any of any ECL and/or provide for the skipping of an ECL(s).
Criteria the four ECLs... Skipping ECLs can make for more interesting and less predictable scenarios. To drive the offsite response, an event generally must reach the General Emergency classification. If the event does not result in a simulated release of radioactivity, the extent-of-play committee must provide controller injects must be provided to allow evaluation of field monitoring/dose projection and protective action decision-making/implementation activities.
Part III.B Heading c: Changed to: It is recommended that FEMA Task 6 Exercises may recommends that organizations scenarios for exercises Use of Decision begin at any of and drills be varied to enhance training and provide for a Criteria the four ECLs more realistic response.
Part III.B Heading c: Added new sentence: In addition, the advantages gained Task 6 Exercises may by not declaring the four ECLs in sequential order can be Use of Decision begin at any of lost if the dress rehearsal drill that is held at many sites Criteria the four ECLs.. employs the same use of ECLs out of their usual order.
The scenario for the dress rehearsal should not be the same scenario that is used during the evaluated exercise.
Part III.B Heading d: The Added new section:
Task 6 plume and post-Use of Decision plume phases d. Radiological release options should be varied Criteria may be separated by (1) No release. One biennial exercise per cycle will days or months. not be required to simulate a radiological release
.. to the environment. However, the scenario must postulate conditions that would warrant a protective action decision. This will require the escalation to a General Emergency classification (based on plant conditions) to drive a protective action decision, based on the licensee and state/local emergency plans, and reflect the potential for an imminent release if appropriate imitative actions are not taken. The scope of demonstration will include the capability to mobilize and control field teams and perform and coordinate dose assessments. - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual To allow for the evaluation of dose assessment and field monitoring activities for a postulated radiological release, either controller injects may be provided or biennial exercise will be supplemented by formal evaluation of the annual radiological monitoring drill and health physics drill by FEMA-REP Program.
Due to the impact on state and local resources, prior agreement of the use of the no release option must be reached between the licensee and respective offsite response organizations as part of the overall scenario development process.
(2) One biennial exercise per cycle will simulate dose levels to exceed EPA-400 Protective Action Guides (PAGs) beyond the site boundary, with the potential for dose levels to exceed EPA- 400 PAGs beyond two miles if prompt mitigative actions are not implemented.
(3) One biennial exercise per cycle will simulate dose levels to exceed EPA-400 PAGs beyond five miles, with the ability to determine and implement protective actions out to 10 miles based on release. This release option is required for all ingestion pathway exercise scenarios.
Part III.B Heading d: The Added new section:
Task 6 plume and post-Use of Decision plume phases e. Radiological release conditions should vary Criteria may be separated by Release and meteorological conditions will vary days or between exercise scenarios within a cycle (i.e., puffs months vs. continuous release, ground vs. elevated release, shifting wind direction and speed) to reflect plant design and historical site characteristics for a specific season. Controller injects may be needed to drive consideration of field monitoring and consideration of protective actions in other than prevailing downwind areas. - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual Part III.B Heading d: The Added new section:
Task 6 plume and post-Use of Decision plume phases f. The spectrum of scenarios will be varied to create Criteria may be more realistic and challenging exercises separated by days or (1) One biennial exercise per cycle must be driven by months... a hostile action-based scenario that focuses on unique response challenges posed to licensee and offsite response organizations (OROs).
- Scenarios will differ from cycle to cycle to reflect various attack scenarios considered applicable to the site (i.e., ground, waterborne, airborne, or a combination).
- Scenarios may include simultaneous attacks or threats to other facilities at the regional or local level that would impact ORO resource availability in responding to an event at the nuclear power plant (NPP) site.
- Scenarios may include equipment/component failures (i.e., failure of an emergency diesel generator or ECCS pump to start, failure of containment to isolate) to facilitate escalation in event classification or radiological release potential.
- Scenarios must not provide for a no release option for consecutive hostile action-based exercises.
(2) Natural phenomenon/all-hazard events should be considered as possible scenario initiating events, based on applicability to site:
- Natural events historically applicable to the regional area (hurricane, tornado, earthquake, flooding, etc.)
- Site-specific all-hazards events (accident involving near-site facility, train derailment on or adjacent to site owner controlled area, etc.)
These events should not be limited to the impact on NPP structures/ components but also consider the impact on ORO resources and command & control. However, event(s) should not be of sufficient magnitude to focus attention away from evaluating the response to the overall NPP emergency. - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual (3) Impact of seasonal conditions - guidance currently states that exercises should be conducted under various seasons and weather conditions. However, implementation has been impractical. As such, the focus should be on seasonal factors impacting the protective action recommendation/pad process, schools in/out of session, etc.
Part III.B Heading d: The Renumbered from d. to g: The plume and post-plume Task 6 plume and post- phases may be separated by days or months Use of Decision plume phases Criteria may be separated by days or months Part III.B Heading d: The Changed to: Organizations may separate plume and Task 6 plume and post- post-plume activities may be separated.
Use of Decision plume phases Criteria may be separated by days or months Part III.B Heading e: Renumbered from e to h: State, tribal, and local Task 6 State, tribal, governments...
Use of Decision and local Criteria governments may provide a representative...
Part III.C Sub-Heading: Reference added to NUREG-0654 Criterion: C.1 Evaluation Intent Area Sub-element 1.a Part III.C Sub-Heading: Added new sentence: As appropriate, the ability of local Evaluation Extent-of-Play responders to promptly notify the respective emergency Area management organizations of an event should be Criterion 1.a.1 demonstrated when the information is passed immediately from station security.
Part III.C Sub-Heading Added text to sentence: Activation of facilities, including Evaluation Extent-of-Play the incident command structure, should be completed Area in accordance with the plan and/or procedures.
Criterion 1.a.1 - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual Part III.C Sub-Heading: Added new paragraph: The incident command structure Evaluation Extent-of-Play and staging areas should be positioned far enough from Area the nuclear power plant site to preclude placing first Criterion 1.a.1 responders at risk due to any on-going threat. In addition, other factors, such as meteorological conditions, should be considered when initially positioning or repositioning the incident command structure and/or staging areas to minimize first responder exposure if the potential for an offsite radiological release at the nuclear power plant exists.
Part III.C Sub-Heading: Created a new paragraph starting with: Pre-positioning of Evaluation Extent-of-Play emergency personnel is appropriate, in accordance with Area the extent-of-play agreement, at those facilities located Criterion 1.a.1 beyond a normal commuting distance from the individuals duty location or residence Part III.C Sub-Heading: Added new sentences: Pre-positioning of emergency Evaluation Extent-of-Play personnel is appropriate, in accordance with the extent-of-Area play agreement, at those facilities located beyond a Criterion 1.a.1 normal commuting distance from the individuals duty location or residence. Further, pre-positioning of staff for out-of-sequence demonstrations is appropriate in accordance with the extent-of-play agreement. Pre-positioning must be negotiated during the extent-of-play meetings, including appropriate contingencies prior to arrival of exercise players. Consider delaying the arrival of players by ten minutes for every hour of travel time.
Part III.C Sub-Heading: Added new paragraph: Initial law enforcement, fire Evaluation Extent-of-Play service, and emergency medical service response to the Area nuclear power plant site may impact the ability to staff Criterion 1.a.1 REP functions. The ability to identify and request additional resources or identify compensatory measures should be demonstrated. Exercises should also address the role of mutual aid and the Emergency Management Assistance Center (EMAC) to the incident. An integral part of the response to a hostile action-based scenario at a nuclear power plant may also be within the auspices of the Federal government (i.e., FBI, NRC, DHS). Protocols for requesting Federal, State and local law enforcement support should be demonstrated, as appropriate. - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual Part III.C Sub-Heading: Added new paragraph: As appropriate, essential Evaluation Extent-of-Play functions of the response effort needed to effectively Area demonstrate the incident command structure will be Criterion 1.c.1 evaluated. The effective coordination of incident command with the nuclear power plant and state/local EOCs in support of event assessment and mitigative efforts would be the primary focus of this extent-of-play.
Responding agency/ jurisdiction representatives should be integrated into the incident command structure as needed. Personnel accountability is established and maintained at the incident command structure, and appropriate security measures are implemented and maintained according to the threat. Incident command structure (NIMS) principles shall apply.
Part III.C Sub-Heading: Added text to sentence: This sub-element is derived from Evaluation Intent NUREG-0654, which provides that Offsite Response Area Organizations (OROs) should establish reliable primary Sub-element 1.d and backup communication systems to ensure communications with key emergency personnel at locations such as the following: appropriate contiguous governments within the emergency planning zone (EPZ),
federal emergency response organizations, the licensee and its facilities, emergency operations centers (EOCs),
forward command centers/posts (including incident command structures), and field teams.
Part III.C Sub-Heading: Added new paragraph: As appropriate, capabilities to Evaluation Extent-of-Play provide for effective primary and backup communications Area between the incident command structure and the nuclear Criterion 1.d.1 power plant, first responders dispatched from staging areas or responding to the nuclear power plant site, and with EOCs should be demonstrated.
Part III.C Sub-Heading Deleted part of sentence: Responsible OROs should Evaluation Extent-of-Play demonstrate the capability to maintain inventories of KI Area sufficient for use by emergency workers, as indicated on Criterion 1.e.1 rosters. - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual Part III.C Sub-Heading: Added new paragraph: As appropriate, provisions to Evaluation Extent-of-Play make dosimetry and KI available to specialized response Area teams (i.e., civil support team, swat, urban search and Criterion 1.e.1 rescue, bomb squads, or other ancillary groups not currently identified within the plans and procedure(s))
should be demonstrated. In addition, equipment compatibility associated with law enforcement, fire service, and emergency medical services response from the incident command structure or staging areas should be demonstrated.
Part III.C Sub-Heading: Deleted part of sentence: Dosimetry: Sufficient Evaluation Extent-of-Play quantities of appropriate direct-reading and permanent Area record dosimetry and dosimeter chargers should be Criterion 1.e.1 available for issuance to all emergency workers either assigned to (if the facility is within the plume EPZ) or deployed from the facility.
Part III.C Sub-Heading: Added new 2nd sentence: Responsible OROs should Evaluation Extent-of-Play demonstrate the capability to make decisions concerning Area the authorization of exposure levels in excess of Criterion 2.a.1 preauthorized levels and to the number of emergency workers receiving radiation dose above pre-authorized levels. This would include emergency workers dispatched on-site to support plant accident assessment and mitigative actions.
Part III.C Heading Radiological Dose Assessment & Protective Action Evaluation Recommendations & Decisions for the Plume Phase of Area the Emergency Phase Sub-element 2.b Part III.C Sub-Heading: Added text to sentence: OROs base these choices on Evaluation Intent PAGs from the OROs plans and/or procedures or the Area Environmental Protection Agency (EPA) guidance Sub-element 2.b manual, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-400-R 001 (May 1992), and other criteria, such as, plant conditions, licensee protective action recommendations, coordination of protective action decisions with other political jurisdictions (e.g., other affected OROs),
availability of appropriate in-place shelter, weather conditions, and situations (to include hostile action-based events, the effects of the specific hostile action, and the affiliated response) that create higher than normal risk from evacuation. - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual Part III.C Sub-Heading: Added text to sentence: They should demonstrate the Evaluation Extent-of-Play capability to make initial PADs in a timely manner Area appropriate to the situation, based on notification from the Criterion 2.b.2 licensee, assessment of plant status and releases, available information related to the event, input from appropriate State and local authorities (i.e., the incident command structure), and PARs from the utility and ORO staff. In addition, a hostile action-based event or other incident may pose an undue risk to an evacuation and an alternate protective action decision may be required.
Part III.C Sub-Heading: Added new paragraph: Resources designated to support Evaluation Extent-of-play an immediate evacuation of the public may need to be Area augmented due to ORO law enforcement, fire service and Criterion 2.b.2 emergency medical services response to the nuclear power plant site or other key infrastructure.
Part III.C Sub-Heading: Added new 2nd sentence: The dose assessment Evaluation Extent-of-Play personnel may provide additional PARs based on the Area subsequent dose projections, field monitoring data, or Criterion 2.b.2 information on plant conditions. In addition, incident command structure may provide input regarding considerations for subsequent PARs based on the response and/or site conditions.
Part III.C Sub-Heading: Edited sentence: The decision-makers should Evaluation Extent-of-Play demonstrate the capability to change protective actions as Area appropriate based on these factors projections.
Criterion 2.b.2 Part III.C Sub-Heading: Added new 2nd sentence: If more than one ORO is Evaluation Extent-of-Play involved in decision-making, OROs should communicate Area and coordinate PADs with other affected OROs. In Criterion 2.b.2 addition, decisions should be coordinated with the incident command structure.
Part III.C Sub-Heading: Added new 3rd sentence: Usually, it is appropriate to Evaluation Extent-of-Play implement evacuation in areas where doses are projected Area to exceed the lower end of the range of PAGs, except for Criterion 2.c.1 situations where there is a high-risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are involved. In these cases, examples of factors that should be considered are: weather conditions, shelter availability, availability of transportation assets, risk of evacuation vs. risk from the avoided dose, and precautionary school evacuations. In addition, decisions should be coordinated with the incident command structure. 0 - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual Part III.C Sub-Heading: Added new paragraph: OROs may have administrative Evaluation Extent-of-Play limits considerably lower than EPA-400-R-92-001 dose Area limits for emergency workers performing various services Criterion 3.a.1 (i.e., life saving, protection of valuable property, all activities). OROs should ensure that their process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an event where life saving and/or protection of valuable property may require an urgent response.
Part III.C Sub-Heading: Added text to sentence: OROs should demonstrate the Evaluation Extent-of-Play capability to select, establish, and staff appropriate traffic Area and access control points, which may include Criterion 3.d.1 controlling access to areas affected by the events, consistent with the PADs (for example, evacuating, sheltering, and relocation), in a timely manner.
Part III.C Sub-Heading: Added text to sentence: Traffic and access control staff Evaluation Extent-of-Play should demonstrate accurate knowledge of their roles and Area responsibilities, including verifying emergency worker Criterion 3.d.1 credentials as per the extent-of-play agreement.
Part III.C Title Added text to Criterion 3.d.2
Title:
Impediments to Evaluation evacuation and/or response are identified and resolved.
Area Criterion 3.d.2 Part III.C Sub-Heading: Added text to sentence: OROs should demonstrate the Evaluation Extent-of-Play capability, as required by the scenario, to identify and take Area appropriate actions concerning impediments to Criterion 3.d.2 evacuation and/or response.
Part III.C Sub-Heading: Added sentences to the end of paragraph: Responsible Evaluation Extent-of-Play OROs should demonstrate the capability to brief teams on Area predicted plume location and direction, travel speed, and Criterion 4.a.1 exposure control procedures before deployment. During a hostile action-based event, the deployment of field teams should be coordinated with the incident command structure. In addition, field teams may be staged during the initial phase of a hostile action-based event until conditions surrounding the nuclear power plant site are understood.
Part III.C Sub-Heading: Added new sentence: Backup route alerting should also Evaluation Extent-of-Play be demonstrated in conjunction with hostile action-based Area event scenarios where resource restrictions in responding Criterion 5.a.3 to the event at the nuclear power plant site may impact the ability to perform backup route alerting. 1 - Revision 0
Summary of Draft Preliminary Changes to the Interim Radiological Emergency Preparedness (REP) Program Manual Part III.C Sub-Heading: Added new paragraph: The dissemination of information Evaluation Extent-of-Play dealing with specific aspects of nuclear power plant Area security capabilities, actual or perceived adversarial Criterion 5.b.1 (terrorist) force or threat, and tactical law enforcement response may be withheld. Pre-approved generic press statements may be utilized in order to initially address media inquiries, while not identifying specifics regarding the response and/or aspects of the crime scene investigation, as agreed upon by the extent-of-play agreement. 2 - Revision 0