ML20199A266
| ML20199A266 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1997 |
| From: | Kantor F NRC (Affiliation Not Assigned) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9711170126 | |
| Download: ML20199A266 (32) | |
Text
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g\ UNITED STATES .
g ; NUCLEAR REGULATORY COMMISSION [
wAssiwatow, o.c. souwees ;
%, /,y Novernber 14, 1997 I
MEMORANDUM TO: U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 ,
FROM:
Falk Emergency Kantor, Sr Emergency Preparedness Preparedness
& Environmental HP Sectl Specialist [n) i Emergency Preparedness and Radiation Protection Branch Office of Nuclear Reactor Regulation
SUBJECT:
DOCUMENTS FOR SUBMITTAL TO NRC PUBLIC DOCUMENT ROOM AND LOCAL PUBLIC DOCUMENT ROOMS Attached are four concept papers dated September 12,1997, developed by a Federal Emergency Management Agency (FEMA)/ Nuclear Regulatory Commission (NRC) Strategic Review Steering Committee in support of a review of offsite radiological emergency preparedness (REP) for nuclear power reactors. We request that the concept papers be placed in the NRC Public Document Room and in the Local Public Document Rooms.
The four concept papers are as follows:
!
- Exercise Streamlining (9 pages)
- Partnership in the REP Program (7 pages)
- Delegated State (11 pages)
A Federal Register Notice, a chy of which is attached, announcing the availability of the concept papers is scheduled to be issued on or about November 18,1997.
Your assistance in this matter is greatly appreciated, if any qu'estions, please call Falk Kantor, telephone number 301/415-2907.
Attachments: As stated cc: TKevorkian, FEMA g, y+3 WDY' g,?% ,. n 1
- t g i i N
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9711170126 971114 PDA ORG EUSFEMA PDR ,
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r 1 September 12,1997 2
3 REP Program Strategic Review Steering Cammittee 4 Coseept Paper: Esertise Streamlining 6
7 ISSUE j 8
9 in July 1996, a Federal Register notice announced the strategic review of FEMA's !
10 Radiological Emergency Preparedness (REP) program and requested comments. A majority ;
11 of the ccaments received indicated that the stakeholders and customers in the REP program "
12 are ner xisfied with FEMA-REP 14 (REP Exercise Manual) and REP-15 (REP Exercise 13 ' Methodology). Furthermore, the respondents indicated that the application of current
- 14 documents is not uniform and consistent during REP exercise evaluations and that the c$rrent l 15 sets ofEEMs and FEMA REP-14 should be reNed.
16 l
-17 BACKGROUND 18 19 The foundation for REP exercises can be located in 10 CFR 50 and 44 CFR 350,351, and i 20 352, and the NRC and FEMA Memorandum ofUnderstanding (MOU) datn! June 17,1993, 21 which is in 44 CFR 353.7, Appendix A. According to 10 CFR 50, Appendix E, a " Full ,
22 Participation" exercise is de5ned as the testing of the major observable portions of the onsite i 23 and offsite emergency plans and the mobilization of State, tribal, local and licensee personnel 24 and other resources in sufficient numbers to verify the capability to respond to the accident 25 scenario. 44 CFR 350, section 350.9, subparagraph (a) indicates that a jo' m t exercise (onsite 26 . and offsite) with full participation of appropriate State and local government authorities and i 27 the licensee would be conducted. The 1993 MOU, Section H,2. (2) states that the purpose 28 for an exercise is to provide reasonable assurance that the plans can be implemented. Section :
29 III, paragraph C of the MOU discusses the preparation for and evaluation ofjoint exercises, 30 but does not elaborate on methodology. The only mention ofFEMA-REP-14 is to indicate 31 the schedule for issuance of exercise reports 44 CFR 350, section 350.13, (a)(2) states that 32 the basis used for reviewing both plans and exercises is NUREG 0654/FEhWREP-1, Rev.t.
33 It is noted that the sixteen (16) planning standards ofNUREG-0654 are contained in both 44 34 CFR 350 and 10 CFR 50.
35 36 To clarify what constituted an exercise, and to develop a standardized evaluation 37 methodology, FEMA lasued Guidance Memorandum EX-3 in February 1988. This
' document provided guidance on the REP exercise process and introduced a set of25 standard 39 exercise objectives.. The 36 exercise objectives were based on the planning standards and 40 . evaluation criteria ofNUREG-0654/ FEMA-REP-1, Revision 1 and Supplement 1.
41-4 42 . Based on these exercise objectives, the original Exercise Evaluation Methodology (EEM) ,
- 43 was issued in May 1988 as an interim-use docun ent.- The 1988 edition ofEEMs was l a
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1 E ;:s as an obj-*!= *iven exercise evaluation instrument to replace the modular j 2 format issued in August 1983. l 3 1 4 t'an==ans were requested from FEMA Regions, states, local governments, NRC lir*namas, 5 and other Federal agencies for the refinement of the EEMs. Based on the comments 6 received. FEMA revised and issued FEMA REP 14 and REP-15 in September 1991. This ,
1
/ refinement included a reduction to 33 exercise objectives. These 33 objectives were meant to 8 represent a ibactional translation of the planning standards and evaluation criteria of 9 NUREG-0654 that could both be demonstrated and observed during REP esercises. In !
10 addition, many elements of various GMs that had been issued by FEMA were incorporated 11 into both REP 14 and REP-15.
12 13 ANALYSIS '
14 15 - The following discussion is based on the current REP guidance for exercise evaludon. It 16 also identifies several new methods to confirm the existence ofroasonable assurance that 17 appropriate protective measures can be taken to protect the heahh and safety of the public 18 living in the vicinity of a nuclear power plant in the event of a radiological incident. The 19 purpose is to identify an acceptable approach to streamlining the exercise evaluation process 20 and supporting guidance. The concept paper also identifies additional methods, that if used 21 in conjunction with exercise evaluation, could also be used to establish and/or confirm that 22 reasonable assurance is being maintained. Some of the approaches that may be considered 23 are: concentration on a "resuhs oriented" evaluation process, con:entration on objectives 24 that are radiological in nature, expanded use of the Annual letter of Certification (ALC),
25 verification of ALCs through the use of random inspections, development of a more flexible 26 credit policy for participation in other natural hazard exercises and for response to real 27 incidents, etc. These and other approaches are addressed in more detail in the Discussion ,
6 28 , section of this concept paper. The SRSC did not want to give the impression that, at this 29 point, the resulting exercise guidance and evaluation methodology would be interpreted as a 30 revision to REP-14/15, since it might take an entirely difTerent form. Thus the paper is titled Exercise Streamlining. ;
31 32 33 DISCUSSION 34 35 36 1. FEMA-REP-14 and 15 should be revised to support a "results oriented" exercise 37 evaluation proesss.
38 39 At the present time, exercises are evaluated in an " objective based" format with a 40 methodology that includes a sizeable number of Points ofReview that must be 41 satisfactorily demonstrated to successfully meet the requirements of the objective.1his 42 system is very structured and leaves little latitude for satisfying the objective by ahernate 43 means. "Resuhs oriented" exercises allow the players to complete an activity without 44 following a specific checklist. This approach will provide the exercise players much
- 45 more latitude to reach the desired results. It will also allow state and local govarnment
i l
3 I the flexibility to concentrate training activities in the taeas where responders feel 2 additional reinforcement is needed.
3 4 Evaluators will then concentrate on the results of exercise participation, not the means to 5 reach a result. If a player uses an alternate means to complete a task and there is no 6 negative effect because of this, there should not be an exercise issue.
7 8 2. Concentrate more on radiological aspects of REP and less on "All Hazartis" 9 response aspects. Derefore, unnecessary objectives and Points of Review could be 10 eliminated.
11 12 Recommendations have been made to streamline the REP Exercise Program to 13 concentrate more on specific radiobgical aspects of REP and less on the "All-Hazards" 14 aspects. Currently, REP 14 and REP 15 contain several objectives and Points ofReview, 15 which are designed to evaluate portions of an offsite response organization's overall 16 preparedness and response capability. Some of these objectives and points of review 17 focus on response procedures and capabilities which are applicable to any type of 18 emergency such as fires, chemical spills, flooding, tomadoes, and other natural or 19 technological hazards. Yet, it is conceded that jurisdictions with REP programs are better 20 prepared than most to meet the demands of other disaster events.
21 22 Some specific areas of REP 14 and REP-15 that focus on 'All Hazards' response 23 procedures and capabilities are: Objective 1, Mobilization; Objective 2, Facilities and 24 Equipment; Objective 3, Direction and Control; Objective 4, Communications; Objective 25 17, Traffic and Access Control; Objective 19, Congregate Care; Objective 30,24-Hour 26 Sta!!ing; Objective 32, Unannounced Exercise; and Objective 33, Off Hours Exercise.
27 Many of the Points of Review (PORs) evaluated within these objectives involve activities 28 that are routinely conducted by ernergency responders during various non-REP disaster 29 responses or exercises. Therefore, some of these PORs, and in some cases objectives, 30 which are not REP specific could be eliminated from the REP exercise evaluation 31 process. However, the objectives would still need to be evaluated by some other means.
32 33 3. Several objectives and Points of Review (PORs) are closely related; REP-14 and 34 REP-15 could be streamlined by combining similar objectives and PORa.
35 36 Comments from numerous state and local., utility, and federal organizations have 37 indicated a desire to streamline REP 14 and REP-15 objectives. Obvious similarities 38 between objectives and repeated experience in exercise evaluations provide strong 39 evidence that several objectives can easily be combined without harming the evaluation 40 process. By combining objective *., duplicate points ofreview, and in some cases, entire 41 objectives may be eliminated. The evaluation document will become le:is prescriptive i 42 and more supportive of the outcome based approach (see 1. Above).
l 43 44 Some examples of objectives which should be combined are: Objectives 1 (Mobilization) 45 and 30 (24-Hour Staffing); Objectives 2 (Facilities),3 (Direction and Control), and 4 46 (Communications); Objectives 5 (Exposure Control) and 14 (KI); Objectives 6 (Ambient l
4 1 M--4) and 8 (Airborne Radiolodine Monitoring); Objectives 11 (Public 2 lastructions),12 (Media Information) and 13 (Rumor Control); Objectives 15 (Special 3 Populations) and 16 (Schools); and Objectives 18 (Reception Center) and 22 (Emergency 4 Workers).
5 6 4. FEMA REP-14 and REP 15 must be updated to imelade/ reflect numerous changes 7 is Federal guidance which have occurred since publiestion of the doenments and to 8 resolve necessisteseles with other guidasee. l 9
10 Subsequent to the publication of FEMA REP-14 and 15 in September 1991, several 11 major changes in Federal guidance have occurred which significantly impact the REP 12 program FEMA REP 14 and 15 must be updated to ensure that they are current a.ed 13 consistent with other Federal regulations and guidance.
14 15 Some examples of changes which are required for REP-14 and 15 include: update to 16 reflect the Emergency Alert System (EAS) and the use of "Special News Broadcasts";
17 update to ensure consistency with the current EPA 400 Manual of Protective Action .
18 Ouldes; and to reflect the current philosophy of using " Total Eff'ective Dose Equivalent >
19 (TEDE)* to determine radiation exposure.
20 21 5. The required demonstration frequency of objectives should be reevaluated. Some 22 objectives should be demonstrated more frequently and others less frequently.
23 ,
- a. Several comments regarding the Strategic Review have indicated a desire for more l 24 25 frequent demonstration of Relocation, Re-entry, and Return and Ingestion hthway 26 objectives (Objective numbers: 23,24,25,26,27,28, and 29). As these objevives 27 represent a significant portion of the response process, increasing the demonstra:lon 28 requirements to something more frequent than every six years is advisable. This may 29 be a misunderstanding of the intent of the guidance. Currently the requirement calls 30 for the demonstration ofingestion and recovery functions at a minimum, every six 31 years. The state and local government officials may choose to demonstrate these 32 functions more often if they choose.
33 34 One concept presented is to have an option to start the exercise at the post emergency 35 phase (Recovery and Ingestion) thus eliminating the emergency phase. This would 36 allow full concentration by the players on the Relocation and Ingestion objectives.
37 This option could be supported if there has been a series of successful Emergency 38 Phase exercises.
39 40 There are several objectives that could be demonstrated less frequently than the 41 current guidance requires. One example is to require the evaluation of Medical Drills -
42 every two years instead of annually.
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1 I 2 i 3 6. FEMA-REP-14 should contals additional guidance coseersing out-of-sequence !
4 evaluations.
6 a. It is possible to perform numerous exercise demonstrations out-of sequence from the 7 biennial exercises. Out of sequence demonstrations may be scheduled during the 8 non-exercise year, other times during the exercise year, and/or another day during the 9 exercise week.
10 11 Examples of some facilities or functions that may be conducted out-of sequence 12 include:
13 14 1. School drills should be conducted during the school year. Exercises are 15 conducted many times when schools are out of session. This drill could be 16 evaluated out of sequence to the fSil scale exercise, during the school year.
17 18 2. Medical Services drills are currently conducted out of sequence most of the time.
19 The current requirement to demonstrate once every year may be relaxed. (See 20 MS-1 paper).
21 22 3. Reception / Mass Care demonstrations may be more beneficial to the players and 23 the schools if these evaluations were conducted outside of the exercise. The 24 FEMA evaluator and jurisdiction stascould visit all school facilities to be used as 25 mass care centers. The county officials / players can provide a schematic of the 26 monitoring / decontamination area of the school. The FEMA staff person may be 27 able to offer constructive ideas to improve the layout. Once a reception / mass care 23 center has been visited and evaluated, there should not be a need to revisit the 29 same center until centers are changed (or if there have been physical changes to 30 the facility). The abilities of the monitoring and decontamination teams staffing 31 the reception / mass care centers during an incident would need periodic 32 evaluation, either during the scheduled exercise or out-of-sequence, at the county 33 or at places of employment. There is no need to evaluate stafrmg and running of 34 these centers since they are normally activated for all-hazard disasters. See Credit 35 under Discussion Item No. 8.
l 36 l 37 4. Other activities that may be evaluated out-of-sequence include:
38 l 39 a. Nursing Honus 40 b. Correctional Centers 41 c. RadiologicalLaboratories 42 d. Ingestion Pathway Field Teams 43 e. Traffic and Access Control L 44 f. Dose Calculations for Recovery and Ingestion Phases l 45 g. Monitoring and Decontamination Facilities i 46
i 6
1 5. It may be possible to play the Plume Phase of an Ingestion exercise out-of-2 sequence. De Plume Phase could stop with the protective actions and the .
3 Ingestion phase could be conducted up to several months later beginning with the '
4 general emagency and protective actions This was done as a pilot study and as a 5 tabletop ingestion exercise.
6 i 7 b. Evaluators should provide direct feedback to exercise par +W* Immediately 8 following the exercise. These " critiques" should not attempt to detail the seriousness 9 of any inadequacies observed, but should allow the evaluators to provide positive 10 feedback and general recommendations for impica.
11 '
12 c. Immediate correction ofissues identified should be allowed following completion of 13 the exercise. For example, ifinepprepchte monitoring techniques were 14 demonstrated, the evaluator could provide instruction on proper mouitoring and then 15 allow for immediate re-demonstration. The issue would be documented as an Area 16 Requiring Corrective Action (ARCA) in the Standard Exercise Report Format 17 (SERF), with the appropriate statement documenting the completion of corrective 18 action.
19 20 7. Dere are additional objectives that could be satisfactorily demonstrated by 21 response to an actual emergency or other hazard esereises.
22 23 At the present time, FEMA REP-14 and 15 indicate that demonstration ofobjectives 32 24 and 33,imannounced and off hours exercises and drills, may be satisfied by a response to 25 an actual emergency. However, there are other objectives that, although there are some 26 radiological aspects to them, contain major generic emergency or -Jons for which 27 credit could be granted. The objectives identified below are demonstrated during any 28 disaster response. Objectives that could qualify for credit are:
29 30 Objective 1 (Mobilization) 31 Objective 2 (Facilities) 32 Objective 3 (Direction and Control) 33 Objective 4 (Communications) 34 Objective 12 (Media Information) 35 Objective 13 (Rumor Control) 36 Objective 15 (Special Populations) 37 Objective 16(Schools) 38 Objective 17 (Traffic and Access Control) ,
39 Objective 19 (Congregate Care) '
40 Objective 20 (Medical Services - Transponation) '
41 Objective 21 (Medical Services - Facilities) 42 Objective 23 (Supplementary Assistance) 43 Objective 30 (2d Hour Stamng) 44 Objective 31 (Offsite Suppon for Onsite Personnel) 45 Objectives ",2 and 33 (Unannounced and Off Hours Exercises and Drills). -
l - _46
7 I 8. Attemative appresebes that esa be used la conjusetion wkh a stressalised enestise ;
2 to demienstrate and confirma reasosakle assermace.
3 !
4 All nuclear power pl* .t sites arrently have findings of reasonable assurance that have 5 been confirmed in ' merous exercises since the initial determination. The proposed ;
-6 exercise streamlining position paper allows for other, alternative approaches to be used, 7 in combination with a streamlined full participation exercise, to demonstrate and confirm 8 reasonable assurance. Dismssed below are traditional &= of a ibil-participation 9 exercise that can be evaluated in an ahernate way outside of the exercise. Other i 10 approaches may include, but are not limhed to, the following: >
11 12 > Staff Assistance Visits 13 14 a. States and Utilities conduct many different training sessions duririg the year, ,
15 FEMA staff could attend these sessions and provide immediate foodback to the l 16 attendees FEMA would be providing on the spot feedback rather than 17 identifying issues in an evaluation report. This approach would build a better 18 relationship among REP partners and stakeholders (See Ps.etnership Paper).
19 20 b. States and Utilities are required to conduct a variety of drills during the year. - If 21 FEMA staff were to attend the drills, such as, communication drills, etc., ,
22 evaluation of these activities could be included in the final exercise report. Again, 23 this would result in some cost during work hours or evenings; however, it would 24 reduce the cost of evaluators / contractors during full participation exercises.
25 26 27 c. Personal interviews with players can be used in staff assistance visits, training 28 sessions, and out-of sequence drills, to verify credit for objectives demonstrated 29 during other activities, etc. l 30 31 > Out of Sequence Demonstrations (See Discussion Iteas 6).
32 33 > Credit for Actual Events or Exercises including Non Radiological Events.
34
. 35 Many REP objectives are demonstrated all the time during natural disasters and ,
36 exercises for other hazards. The following list identifies those exercise objectives
- 37 for which we should allow credit:
38 39 a. Mobilization, Objective 1, during any emergency this objective is 40 demonstrated. In addition, most emergencies involve 24-hour staffing 41 (Objective 30). Therefore, both objectives could be given credit. 'Ihese two 42 objectives could be merged into one objective.
43 44 - b. Facilities, Objective 2, especially those fixed facilities that we see during 45 every exercise. (EOCs, Mass Care Centers, etc.) -
46 i
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! c. Diremion and Control, Objective 3, the areas not involved in radiologloal j 2 d=4alaan. i 3 !
4 d. Ca==anale=tions, Objealve 4, we should see -nate=*iana during any i 5 anarcise. OAen cornmunications is the Srst thing that fhits it t disaster. All l 6 communloation equipment and backup systems will be used during any :
.7 response activities. If documented appropriately, credit could be given for !
8 this objective.
9 10 The personal laterview with players will be important in technical assistance 11 visits, training sessions, and outer sequence drills, to verifj' credit for objectives l 12 demonstrated during other acsivities, etc. .
l 13 :
14 For additional objectives, please see Discussion Item 7 under FEMA REP 14-15 -
15 Analysis.
16
- 17 > AnanalIAttert of CortlSeation [
18 19 The Annual Letter of Certi6 cation (ALC) is the perfect tool for state and local 20' goverwnent to document self-assenments. Already, annual public information 21 requirements, tralning completions, siren operability and maintenance verifications 22 are submitted through this document. The ALC is certined by the Governor or his 3 23 designes a to its accuracy, it could be expanded very easily to include information i 24 such as the following:
25 ;
26 s. Monitoring equipment maintenance and calibration dates. :
27 b. Dosimeter operability and maintenance records documentation. i L 28 c. KI requirements and shelflife.
29 d. Communications drill results. !
30 e. Plan updates }
31 f. EvaluationReports ,
32 33 Verification of the documentation submitted in the ALC may be accomplished by i 34 site-visits.
35 36_ a. There are several objectives geared to the vetification that appropriate equipment 37 is available for emergency workers. Potassium 1odide (Objective 14) calls for the 38 evaluator to conArm that sufficient doses exist to be given te all emergency 39 workers and institutionalized individuals. 'Ihis process could be verified during a p - 40 site visit by REP staff during normal duty hours. Contract evaluttor costs would ,
41 - be cut; however, additional costs could be incuned for additional travel, etc. as '
42 this would be done outside the exercise process.
43
- 44 b. Monitoring equipment and dosimetry operation / maintenance verification is
_45 required on a regular basis (See FEMA Rep 14-15). Inspections of this equipment i 46 outside the exercise timeframes can easily be accomplished. FEMA Regional
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i I maff would save money by performing these inspeatons during regular work 2 hours, when maisenance is being performed on the equipment, A W 9 .there 3 would be some com for FEMA maff there would be a com naving by reducing the 4 amount of evaluator / contractor time during exercises. Also, see Annuallatters 5 of Certifica: ion and Out-of Sequence Demonstrations.
6 7 > Self Assessments 8
9 For those mates where localjurisdictions are regulred to play, mate evaluators could .
10 be utilized for thosejurisdictions below the county level. The one problem with this 11 approach is staffing. Many states may not have the resources necessary to perform 12 this function. There may be other areas where state evaluation may be viable. When 13 evaluations are performed by a state, response capabilities should be documented and 14 provided to FEMA.
15 16 RECOMMENDATIONS 17 r
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! September 12,1997 ;
2 i 3 REP Prograiu Strategie Review Steering Cosamittee I 4 Concept paper: Partnership In he Rep Program !
6 !
7 ISSUE 8
9 Should the role traditionally assumed by FEMA in its interaction with the States, in the REP l
i
.10 program be modirmi auch that a greater FEMA / State pannership is achieved?
11-12 BACKGROUND I 13 i
, 14 Over the sixteen years of the REP program, FEMA's role has traditionally been that of ;
- 15. evaluator of the State and local ability to implement emergency response plans, With :he _ i 16 evolution of Performance Partnership Agreements and FEMA's strategic review ofits REP 17 program, a de: Ire has arisen to reevaluate this traditional relationship and determine if a ,
18 relationship defined more in terms of a State, Tribal Nations and local government 19 pannership is appropriate, .
20 21 ANALYSIS :
- 22. I 23 nose advocating this approach propose that all partners have the same goal of protecting 24 health and safety of the public Further, the rationale continues, State, Tribal Nations and 25 local govemment have the primary rv.sponsibilhy for protective action decisions and 26 . implementation, and, in combination with local responders, first line response. As such, 27 their role is integral to effective emergency preparedness and response and on this basis they 28 should be considered partners with FEMA in accomplishing this end.
29-30 There are several concepts that can be considered related to achieving an enhanced 31 partnership. In general, a greater partnership may be described as one that is less 32 paternalistic, one in which each partner recognizes each other's strengths (and weaknesses),
=33 : one in which FEMA exerts leu oversight, one in which there is a greater emphasis on resuhs 34 rather than the proceu used to get there, and one in which open communication is practiced.
35 36 There are numerous initiatives, which might be undenaken in the name of developing a 37 _greater level ofpannership in the REP program. For ease of evaluation :t this point, they are 38 - fouped into primary topics.
39 !
'40 (A) Performance 41
'42 - A number of comments centered on giving more latitude to the States, Tribal Nations and - <
=43 local governments and reducing Federal oversight in the performance ofREP programs. De !
44 : guiding principle for the Federal government as part of the National Performance Review is '
l * *Ihe roles and responsibilities assumed ty Tribal Nations in the REP Program may wy from site to site. i
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-I to develop performance partnerships with State and local governments to promote both 2 inweased nexibility and accountability. The key feature of the partnership is the .
3 encouragement of multiple approaches to meetingjointly designed objectives. j 4 i 4 5 Within the context of the REP program, certain specific performance themes related to 6 incesasing partnership are hAped below. ;
7 +
8 1. Increase flexibility / latitude for partners in how to carry out REP requirements.
9 :
~
10 The maturity of the REP program has allowed an excellent de6nition of the basic i
lI areas of capability (i.e. public educatica and infonnation, emergency theilities and equipment, emergency classification, etc.) necessary to protect the public f>om a a 12_
13 serious nuclear power plant accident. NEMA and others make the case that the States 14 have an established record of perforraance in REP which verifies their capabilities to 15- control the execution of their own programs. Increased flexibility would also allow '
16 differences to be recognized in program implementation.
17 18 This combination of matured program definition along with increased experience (
19 levels lends itself to the next level of delegating more responsibility. For further 20 discussion, refer to the Delegated State Program Issue Paper. Alternately, a revised 21 - REP 14/15 could recognize a greater flexibility / latitude, as could training evalustors .
22 to focus on outcomes rather than process. t 23 24 2. FEMA, States, Tribal Nations and locals, in addition to utilities, would work together ,
25 to determine the appropriate Goals and Objectives to support the ultimate Mission of ;
26 protection of the public. !
3 27 28 Overarching REP Goals could be jointly established (Federal, State, Tribal Nation, 29 local, utility) to drive the activities at all levels. Then, objectives with specific, 30 measurable results would be agreed to by all parties on a uniform, national basis. i 31 These objectives provide a checkpoint to assess whether the program is achieving the 32 consensus goals and define the actual impact on the public being served, rather than 33 measuring the level of effort expended by the particular organization.
34 35 3. Methods of accomplishing goals lea to the discretion of States, Tribal Nations and 36 local governments.
37 38 After developing goals and objectives as discussed in item 2. above, States, Tribal 39 Nations and local governments would then work with FEMA to develop measurable 40 outcomes to assess achievement of these goals and objectives. These are quantitative 41 indicators uniquely developed to.each jurisdiction and many are aircady in place.
42 States, Tribal Nations and local governments would be given flexibility in how they L . 43 - carry out guidance within the context of meeting goals and objectives. !
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I 4. Incorporate REP goals into the Performance Partnership Agr=== anes (Tbs PPAs are 2 5 year strategic plans which the States broker with FEMA. The PPAs are '
3 impla=anand by States and their goal is to provide greater state Sexibilky in 4 achieving goals, while at the same time improving accountability.1he ibcus is on j 5 resuhs rather than the process.) ;
6 7 1he use of the PPA process allowa States to be treated u emergency management l
, 8 partners. Inclusion of REP goals and performance measures in se PPA will !
9 encourage the integrotion of REP into the overall State emergency p.-g# :: !
10 mission. Since mon States are required by their own legislatures to have a strategic _ l 11 plan, this will permit the States to present all aspects of their emergency management !
- 12 mission in one strategic document, irrespective of fbnding source. Note though that .
13 actual use of a PPA document would be optional because if what is outlined in hems l 14 2. and 3. above has been accomplished, the underlying basis of a PPA has been done l T
15 also.
16 17 Advantages to this' type of performance spproach include increased flexibility in carrying out l 18 REP programs, including the ability to ensure that plans and exercises apply to real events 19 rather than sirrply to achieve a goal of passing an exercise. A potential disadvantage of this
- 20 approach is that the development of REP goals and performance naasures (and their i 21 assessment per performance indicators) are time consuming.
22 23 (B) Evaluation- !
24 25 Note: This section, which was previously included in the July 3,1997 version of the .
26 Partnership Concept Paper, has been consolidated in the Exercise Streamlining rw 27 Paper.
28 29 (C) Policy 30 31 Partnership in the policy area effectively means greater stakeholder involvement in its .
32 development. This policy involvement thus can be divided into two distinct areas: the :'
3 33 strategic review process itself and guidance and policy developed as part of the ongoing 34 program. The former will be considered in detail as part of the evolving strategic review 35 process. The latter will be the focus of the discussion here.
36 ,
37 A greater partnership in the policy area could be accomplished through a variety of means
- 38. Including discussion of policy issues during workshops, conferences, or specially gathered ,
- meetings. The success of the Standardized Exercise Report format development could serve 40 ~ as a model for future endeavors (a first draR was provided for comment with the resulting ,
41 second draA discussed at a meeting of State, utility, FEMA and NRC regional !
42 representatives). Whatever stakeholder involvement is put in place for the Strategic Review ,
- 43 process would provide valuable lessons learned for what might be viable on a more ,
44 permanent basis. Naturally, consideration of FACA would continue. In any case, for ;
s 1 :
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i I partnership to evolve in the policy area, the concept must be given more than " lip service';
2 ma% must be made to feel that their vi i are given bil consideration. At the same :
3 tis , FEMA must remain objective concerning the goals of the program and ensure that 4 stakeholder self interest does not become the driving force in ibture policy development.
5 6 'N pros of continuing stakeholder involvement in the REP program policy area include: (1) 7 greater ownership of policy changes and thus improved acceptance of such changes, (2) 8 improved expediency ofFEMA becoming aware ofimplementation issues and proposed ,
9 altamatives, (3) a resulting greater consistency among FEMA regions of the developed !
10 policy, and (4) increased FEMA access to a broader base of technical expertise and :
11 experience. In contrast, cons include the need for greater in depth analysis of stakeholder !
12 positions (perhaps using individuals with the appropriate technical expertise) to ensure 13 appropriate policy is accepted.
, 14 15 (D) Technical Assistance 16 17 Numerous comments were received about FEMA increasing the technical assistance it 18 provides to shifting its emphasis &om prescriptive evaluation to technical assistance to 19 States, Tribal Nations and local govemments. For the purposes of this discussion, " technical 20 assistance" herein refers to both planning and programmatic assistance and specific .
21 assistance on radiologicalissues.
22 ,
' 23 The benefits ofincreasing such technical assistance include Authering the partnership .
24 relationship because the assistance would be offered in a non-evaluative fomm. FEMA's role 25 would move away from being primarily an evaluator toward being a greater fhcilitator and .
26 educator. FEMA would in an expanded way assist and support the States, Tribal Nations and 27 local governments. The idea ofincreased technical assistance is closely tied to the idea of 28 !mproved customer service. l 29 30 From a resource standpoint, FEMA may have to shift resources from other areas (evaluation 31 perhaps) in order to provide a greater level of technical assistance.
32 33 Means ofincreasing FEMA's technical assistance could include:
34 35 1. FEMA could sponsor technical assistance conferences throughout the year. Such a
- 36 conference could allow FEMA the opportunity to share its observations gathered 37 Rom years ofREP exercises. This type ofconference with a national reach could be 38 supplemented by regional or local seminars.- !'
' 39 40 2. FEMA could prepare an internet web site for technical assistance, 41 42 3. More emphasis could be placed on the process used in correcting issues raised during 43 drills and exercises and less on simply grading. Redemonstration during drills would p
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5 1 provide a better learning environment and pressat an increased collaborative 2 relationship between FEMA and the State, Tribal Nation asd local organizations.
l 3
4 4. FEMA's courtesy evaluations during rehearsals could be continued or perhaps i 5 expanded. They are especially helpfbl in training and ge;==-ir:: because they 6 allow evaluators to share their extensive experience. At the same time, the courtesy
- 7 evaluations are not threatening absent the evaluation and are thus conducive to 8 learning and exchanging information.
l 9
10 5. FEMA could encourage more conference calls as a means to address issues rather 11 than relying on written communications. This more open form of communication 12 will increase partnership and the efficiency of the REP program through more 13 expedient resolution ofissues and answers to questions.
14 15 6. FEMA cou4d take a more active role in implementation of the Emergency Alert 16 System (EAS).
17 18 7. FEMA could assist in obtaining data on special needs populations (privacy issue).
19 20 8. FEMA could provide a greater level of assistance to States, Tribal Nations and local .
21 governments in improving their emergency preparedness plans.
22 23 9. FEMA liaisons could spend more time in the field to become more familiar with 24 particular sites and in the process achieve better relationships with various levels of 25 government. Such increased number of site visits would serve to provide ongoing 26 technical assistance. Funding would be a consideration.
27 28 10. FEMA could provide greater evaluation and insights into how the continuing fast 29 pace of technological changes impacts tl.e REP program. ,
30 31 11. FEMA could participate in State, Tribal Nation and local training programs.
32 33 12. FEMA could provide technical assistance to States, Tribal Nations and local
-34 governments in implementing corrective actions resulting from exercises.
35 36 13. FEMA could work with other Federal agencies to identify key radiologi al ;
37 monitoring and assessment capabilities, determine where additional effort is needed, 38 and work to accomplish those activities, needs and then satisfy those needs.
39 40 It is interesting to note that the types of technical assistance suggested are largely in the 41 programmatic or planning areas. Assistance of a clear technical nature is absent. In fact, 42 comments received suggested either that FEMA refrain from providing technical radiological
-43 information or expand its own expertise in health physics and radiation sciences. FEMA can 44- improve its technical guidance by (a) ensuring that cognizant RAC members are utilized for
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I this purpose, (b) lasuirig guidance as joint FEhWNRC/ EPA guidance, and (c) including 2 stakeholders in its development. Should FEMA radiological expertise be cultivated, FEMA 3 could pisAde names ornaw=va that could be called witt, questions on guidance. Even if ;
4 FEMA obtains in house technical expertise, serious consideration should be given to the 5 appropriateness of FEMA developing technical standards in areas, which impirige on other 6 agencies' statutory responsibilities. FRPCC<leveloped materials may be incorrectly 7 interpreted to be solely FEMA documents because FEMA prints and distributes them so 8 there may be merit in obtaining FRPCC letterhead and issuing documents under the auspices ,
9 of the FRPCC, when appropriate. .
10 11 The major pros ofincreased technical assistance would be providing States, Tribal Nations 12 and local governments more of the type of assistance they need firom FEMA in order to 13 improve their radiological emergency preparedness programs. The primary con of this shift 14 in emphasis is the FEMA resource issue, it becomes less onerous if resource savings can be 15 found in the evaluation area or elsewhere. The other resource component of course is the 16 level of radiological expertise residing at FEMA.
17 '
18 (E) Federal Exercise Participation 19 20 increased Federal participation in REP exercises would give partners the needed experience 21 of operating with the various Federal agencies and knowing what resources are available in 22 radiological emergencies. Criticism includes that the Federal government has a algnificant 23 role in response but does not subject itself to the same expectations which it places on States, 24 Tribal Nations and local governments. By participating in REP exercises (specifically 25 greater participation in ingestion and relocation, reentry, and re:overy exercises), the Federal 26 agencies allow themselves to be critiqued (refer to Sectica (B), item 1.) and learn from the 27 process as do the States, Tribal Nations and local governments. Partnership would be 28 fbrthered by such increased Federal involvement. Lack of participation in exercises past the 29 plume phase leaves players wondering whether the Federal agencies are indeed prepared to 30 deliver assistance and whether plans to accomplish and coordinate assistanu are in place.
31 The benefit to the Federal government of fuller participation is to uncover those 32 shortcomings in our own preparedness schemes (in particular with our interrelationships with 33 each other) which could prove disastrous and/or embarrassing in a real event. Federal 34 participation would also allow testing of the FRERP organization and the exercising of 35 interagency cooperation.
36 37 A fbrther benefit ofFederal participation is the increased realism in the scenario. Negative 38 training is a likely result when appropriate Federal participation is lacking and thus one could 39 argue that there is little value to post-plume phase exercises which lack appropriate Federal
- 40 participation. FEMA could take a lead role in assisting the States, Tribal Nations and local 41 governments to use FRMAC most effectively.
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l 1 Naturally, the biggest drawback to increased Federal participation is resources. The i 3
l appropriate management level of each affected agency (FEMA, DOE, NRC, EPA, USDA, 2
3 HHS) would have to agree to make this a priority by providing the required staff. In <
4 addition, any internal agency procedures not developed would require resources to complete. ;
$ Resources would also be required for interagency coordination to achieve esercise l 6 participation and for addressirig outstanding issues associated with exercising the Federal 7 role, 3
s 9 The above elements do not represent an all or nothing proposition. All or some of the -
10 conceptual items can be implemented deperding on how partnership is to be defined in REP '
s 11 and the degree of partnersidp desired.
12 13: Areas of overlan w;th rehar maa-aen helaa ruptored 14 15 1. _'!he Performance element of this paper is closely related to the PPA concept and the 16 results vs. outcome paper, 17 2. The Policy element is tied to the stakeholder involvement in the SRSC process itself is and indeed that is one component of the Policy element. What is determined 19 applicable for this process can certainly serve as a 1 t ot program of sorts for fbture 20 involvement of stakeholders in policy development endeavors.
21 3. The Technical Assistance element is tied to the resource question, and specifically the 22 radiological assistance component relates to the use ofcontractors and whether i 23 FEMA rhould obtain in-house health physics and radiological expertise.
24 4. The Federal Exercise Participation element is related to questions concerning Federal 25 coordination both in obtaining agreement to increase Federal participation and in 26 actually implementing this policy in exercises. Federal resource constraints will .
27 presumably be a_ major factar. _ _ .
28 5. In addition, partnership type elements may be used as incentives for participation in ,
29 Delegated State program For example, Delegated States may be given a priority for 30 technical assistance and/or participation in policy development.
31 32 RECOMMENDATIONS 33 34 To be determined.
35 .
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1 September 12,1997 2
3 FEMA Strategic Review Steering Cossaittee ' !
4 Concept Paper: Focus em Rad! $=1 Aspects of REP 5 vis-a vis AB-Hazards Aspects of REP ;
6 7 ISSUE e
9 Would the Radiological Emergency Preparedness (REP) Program be more efective and to streamlined by focusing more on radiological activities and less on non-radiological activit!es?
11 l 12 BACKGROUND 13 14 During the course of the review of the issue ofinclusion of REP in the All Hazards (generic) 15 approach to amargency planning, a related issue was identi5ed by the Steering Committee 16 concerning whether the esorts of State and local governments as well as FEMA should be 17 focused on those activities in REP unique to radiological emergencies and less on the non.
le radiological aspects common to all emergencies. The issue was approached by Srst 19 identifying those planning standards and evaluation criteria in NUREG-0654/ FEMA-REP-1, '
20 Rev.1, and the Exercise Objectives in FEMA-REP-14 which could be considered unique to 21 ndiological emergencies and those activities common to d emergencies. Secondly, the 22 regulatory basis for REP as presented in NRC and FEMA regulations and the NRC/ FEMA 23 Memorandum of Understanding (MOU) was examined to determin6 Jthere were any 24 regulatory impediments to emphasizing the radiological aspects of REP while shiAing the
- 25 preparedness for the non-radiological aspects of REP to other all hazards plans. Finally, the 26 cxtent of changes that would be required in FEMA planning and exercise guldenen documents l 27 to e.eommodate this change in REP program emphasis were examined. The Steering 2e Committee was cognizant in its review and analysis that, although a shiR in emphasis might 29 occur, the bottom line remains that all EP planning studards must still be met and the 30 resulting REP program must continue to provide reasonable assurance. However, how this 31 would be accomplished may difer Rom what is currently in place.
l 32 ANALYSIS 33 34
- 35 In the analysis of the All Hazards issue, the subject of plan format was addressed. Several States have mow their plans and " integrated" the REP specific elements into the general l 36 l 37 body of the plan, the result being that such a format resembles the function-based, all-hazards se Emergency Operations Plan (EOP) format recommended in SLG 101, Guldmcefor All'
,. 39 Hazards Dnergency Planning (September 1996). However, if the all hazards approach is 4o simply perceived as a re-formatting of the REP plans to 6t the all haurds EOP format, then 41 there is little to be gained, Aom a strategic viewpoint, by considering REP under all hazards.
42 Regardless of the plan's format, the emergency management personnel working with it saust 43 be knowledgeable in its contents and procedures and be able to demonstrate the plan's :
44 efectivenen in an exercise, ,
1 g i Review of Planning Standards and Exarcise Otfactives 2
3 A review of the Planning Standards indicated to the Steering Committee that it is not useful to 4 try to ascrLe Planning Standards as being radiological or non-radiological its scope. The 5 P'- '; Standards usually contain aspects of both. The Steering Committee determined it ,
s would be more useful to look at the Exercise Objectives in FEMA-REP 14 and, within those 7 Objectives, to the Demonstration Criteria.
e 9 The Committee's initial review indicated that Objectives 15,16,17 and 19 appear to be non-10 radiological ibnctions. Objectives 1 4,10 - 13,23,30,32 and 33 appear to be All-Hazards, 11 but contain radiological components. Objectives 5 9,18,20 - 22,24 29 and 31 appear to 12- have only radiologicalihnetions.
13 14 Emphasizing the radiological aspects ofREP, however, does not eliminate the non-15 radiological aspects firom concern. The non-radiological activities would still need to be is veri 6ed as adequate, even if demonstrated in an all-hazard framework.
17 le The States, including those with all-hazards plans, have been demonstrating the capability to 19 meet the REP-14 Objectives in exercises. The question is whether it is practicable, with the 20 maturity of the REP Program, to separate the Objectives, Demonstration Criteria and Points 21 of Review that are considered non-radiological, and, if so, which oncs? It could be 22 problematic. For example, Objective 4, Communications, appears to be a generic 23 preparedness and response Ametion. However, closer ivion of some of the 24 Demonstration Criteria reveals speci3c radiological functions, e.g., communications between 25 plant operators and the Emergency Operations Center and communications from the EOC to 26 Field Teams monitoring the environment. Another example is the NUREG-0654 element '
27 which requires continuous 24-hour emergency operation, and therefore staffing. This elemed 2e is described in Objective 30, where once every six years a shiR change is demonstrated with 29 ShiA 1 briefing ShiR 2 on the status of the emergency and the emergency response. A 30 fundamental question for these Objectives, if they were under consideration for separation, 31 would be: how important are these activities in connection with ensuring an adequate level of .
- 2 preparedness? Would separating these activities reduce preparedness?
33 34 There is also a much larger consideration, and that is the fundamental concept of the 35 integrated exercise. NRC and FEMA regulations require an exercise to test the integrated
, 36 capabilities of appropriate State and local government authorities and utility emergency 37 personnel, and include testing the major observable portions of the onsite and offsite se emergency plans, and mobilizations of State, local and licensee personnel and other resources 39 in sufficient numbers to verify the capability to respond to the accident scenario, in order to 4o conduct a truly integrated exercise and test real-time capability, it is ===='y to evaluate 41 generic response functions such as Emergency Communications, Direction and Control, and 42 Alert and Notification (EBS/EAS) along with the radiological functions. It would be difficult 43 to have an exercise that only involves radiological activities when the " glue" for demonstrating 44 an integrated response to a simulated emergency lies in the non radiological fimetions. -
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3 1 Emphasizing the non radiological aspects of REP may require some ibndamental changes in ,
3 2 the current REP Program, it may be dif5 cult to separate some of the all-hazards / generic ;
3 response A=w*laan Rom the radiological fbactions. Issues which need to be addressed include
^
4 such activities as mahilimlaa of speci6c response staff with capable back-up for continuous ,
5 24-hour operations; activation of an Emergency Operations Center with apprgriate !
6 equipment to provide for esse.stial emergency communications; and supporting decision- !
7 makers with suf5cient information for developing and implementing protective actions for the L e public. -
9 to Perhaps an alternative approach in separating the radiological aspects Rom the non.
11 radiological aspects would be do'ng the radiological response activities in discrete drills and 12 combining these drills with "readine'es appraisals," expanded exercise credit, and an expanded is Annual IAtter of Certi6 cation. Under this approach, Discrete Drills would entail:
14 -
15
- Field Monitoring Teams demonstrating their expertise in using survey meters and 16 taking samples; i 17 is *- Emergency workers demonstrating their capability and knowledge in using dosimetry, 19 in radiological exposure control and decontamination and in KI use; 20 21
- Those with Direction and Control responsibilities showing an understanding of the 22 technical information coming kom the utility, radiological health ofBeials, etc. !
23 24 . Emergency medical staff (ambulance and hospital staff) demonstrating their capability, 25 and the medical protocols for treating contaminated individuals; and 26 27
- Health Physics Drills including demonstration by the staff of their capability to do dose 2e projections and dose assessments.
29 30 In conjunction with these discrete drills, there would be " readiness appraisals," that is, walk. '
31 throughs, inspections, inventory / roster reviews, etc. Such a " readiness appraisal" could apply .
32 to an Emergency Operations Center, and may rBfy many of the non-radiological 33 requirements in FEMA REP 14. In some situas.4, exercise credit may be given to State and 34 local organizations that respond to real emergencies or certain non-radiological response 35 activities. And the State assessment of plans and preparedness would be reported in an 36 expanded Annual Letter of Certification. The non radiological objectives could be 37 demonstrated in all-hazards exercises, with the results coordinated with the evaluations of the se - discrete drills involving the radiological functions. -
39 4o This alternative approach may permit FEMA to make findings on the adequacy of offsite plans 4 41 and preparedness. Such an approach could, perhaps, provide an opportunity for requiring less 42 hequent integrated REP exercises.
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1 Review of Ragulatory Basis 2
3 A review was cWed of the regulatory basis for REP iWag the NRC and FEMA 4 regulations and the NRC/ FEMA Memorandum of Understanding (MOU) to determine if there s were any regulatory impediments to focusing on those activities unique to radiological s emergencies in REP and less on those aspects common to all emergencies. Emergency 7 pt=r+4::: (EP) is coveral in NRC regulations 10 CFR 50.33, 50.47, 50.54, and Appendix n E to 10 CFR 50, and in FEMA regulations 44 CFR 350,351, and 352. FEMA is responnble s for manaaning the adequacy of offsite EP and providing its nadinga and determinations to the to NRC. For operating nuclear power plants, the NRC bases its findings on the overall state of 11 emergency preparedness on a review of FEMA's Sndings and determinations as to whether 12 State and local emergency pims are adequate and capable of being implemented and on the 13 NRC's assessment of the ad'aquacy of the licensee's onsite emergency plans. (50.54(s)(2)(ii))
14 The MOU indicates th;:t W.MA's findings on preparedness are based on an assessment that is . the offsite plans are (1) adequate as measured against the planning standards and evaluation 16 criteria of NUREG-0654 and (2) that there is reasonable assurance the plans can be 17 implemented as demonstrated in exercises. This assumes that a periodic exercise (now 1e biennial) will be conducted to test the plan and to verify its implementab'dity.
~- . . , . -. n , - . , . . , . .- . .
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. f 1 Septesnbar 12,1997 2 l 3 REF Program Strategie Review Steering Committee !
4 Cescept paper: Delegated State !
6 7 ISSUE S
9 Can a structured program within which States are delegated exercise evaluation :
10 responsibilities traditionally performed by FEMA be developed such that reasonable 11 assurance can continue to be assured and emeiencies through streamlining achieved? l 12 13 In any restructured REP program, FEMA must continue to provide the NRC with its ;
14 determinktions on reasonable assurance unless there is a change in NRC regulations (10 CFR 15 50.47). This regulation, however, does not specifically state how FEMA will make 16 reasonable assurance determinations. 'the operative question is the method ofgathering 17 information which FEMA uses to make these site specific reasonable assurance findings.
18 The current M =4 h is outlined in 44 CFR 350 and the FEMA NRC Memorandum of 19 Understanding. -
20 ,
21 Reasonable assurance findings are comprised of two components: !
22 23 (1) FEMA must determine that plans and preparedness are adequate to protect the heshh 24 and safety of the public living in the vicinity of the nuclear power theility by 25 providing reasonable assurance that appropriate protective measures can be taken 26 offsite in the event of a twiiological emergency.
27 28 (2) FEMA must determine that plans and preparedness are capable of being implemented 29 (e.g., adequacy and maintenance of procedures, training, resources, staffing levels and 30 qualifications, and equipment adequacy.)
31 32 BACKGROUND 33 34 In an effort to restructure the FEMA REP program to make it more efficient and effective, 35 during the initial SRSC meeting, a working group was tasked to explore the feasibility of 36 FEMA modeling the REP program on aspects of the NRC agreement State program.
37 38 Members of the SRSC pointed out that several other Feder al agencies / departments have 39 programs which are implemented by the States with oversight provided by the Federal 40 government. In addition to the NRC Agreement State program, examples are: the EPA 41 permitting programs for the Clean Air and Clean Water Acts; the OSHA safety and heahh 42- program; the USDA meat and poultry inspection program; and the FDA mammography
- 43. program.
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2 1 ANALYSIS / DISCUSSION 2
3 Baaic Proaram Outline 4
Under a Delegated State Program, FEMA would continue to make site specific 5 (1) 6 reasonable assurance determinations and provide those findings to the NRC.
7 8 (2) States would apply to become Delegated States on a voluntary basis and FEMA 9 would review and approve (or deny) such requests.
10 11 (3) A Delegated State would assume responsibility for exercise evaluation and provide a 12 detailed Annual Letter of Certification (ALC) each year.
13 :
14 (4) FEMA would provide a limited oversight role to the State's activities which would 15' include supplemental verifica.lons and review of the ALC.
16 17 A discusslor. ofImpact is included in Appendix 1, and a summarization of the NRC 18 Agreement State Program is included in Appendix 2.
19 20 Recommended Aoplication TTocess 21 22 The Delegated State Program would be a voluntary program, but 44 CFR 350 approval 23 would be required of States that apply. By definition, this approval means that reasonable 24 assurance exists regarding a State's capabilities. Requiring 350 plan approval for each 25 entrant to the Delegated State program provides a common foundation for all applicants.
26 Such a requirement further lends a tangible benefit to obtaining a 350 plan approval. FEMA
- 27 should work with States that are interested in obtaining 44 CFR 3SO approval for the purpose 28 of gaining Delegated State status.
29 30 NUREG-0654/ FEMA-REP-1 would continue to be the basic guidance document for the REP 31 program, for both Delegated States and other REP States. Thus, a State's adherence to 32 NUREG-0654/ FEMA-REP-1 and having plans consistent with it would remain unchanged.
33 34 To initiate the process, the Governor, or designee, would request approval to be a Delegated 35 State from FEMA. The State would have to meet certain criteria outlined by FEMA for 36 participation. The original application could include:
37 (1) a commitment to use REP 14/15 (or the applicable variant endorsed by FEMA),
38 (2) an exercise / drill schedule in conformance with NUREG-0654/ FEMA-REP-1, .
39 Planning Standard N, 40 (3) a commitment to use e v.andard exercise report format, 41 (4) a commitment to hold a peblic meeting in the vicinity of tne plant to discuss exercise 42 results following a full scale exercise,
3
[
1 (5) a discussion of the corrective action program to resolve drill and exercise deficiencies ;
2 (i.e., inadequacies which directly affect the hashh and safety of the public) within 120 >
3 days (Note: It may be usefbl for FEMA to compile muhlple examples of deficiencies 4 and areas requiring corrective action (ARCA) for use by Delegated States in an
- 5 attsmpt to achkw consistency among them), 1 6
(6) a commhment to maintain plans and procedures in conformance with 7 NUREG-0654/ FEMA-REP 1, Planning Standard P, 8 (7)- a commitment to use a standard format for the Annual Letter of Certification, 9 (8) information regarding the appropriate level of staffing and training for evaluation of i 10 exercises, 11 (9) a statement that in state coordination has occurred among stated departments, 12 including emergency management, radiological hoahh (responsible for dose 13 assessment / projection), and otherjurisdictions within the 10 mile EPZ, and 14 , (10) a commitment to apply exercise credit consistent with FEMA's prdicy (see discussion 15 later in paper).
16 17 Past performance could also be considered in granting Delegated
- tate status. For example, 18 there should be no outstanding exercise deficiencies at the time of the applicatiori to the 19 program and an acceptable Annual Letter of Certification should have been submitted for the 20 previous year.
21 22 Based upon FEMA's approval of the State's proposal, a State would be designated a 23 Delegated State. If there is a shortfall in the application package, FEMA would identify it to 24 the State and provide assistance in improving the shortfalls.
25 26 Pronram Imolementation 27 28 Once the State receives approval, it would begin its own planning for conducting and
! 29 evaluating its own exercises. No extent-of-play agreements would nood to be negotiated with 30 FEMA. Each year, the State would be required to provide an ALC with details on 31 - completion ofperiodic requirements and changes to the prog,am. The ALC would also 32 contain the exercise report with issues explained and discussion of correaive actions taken.
-33 A stand:rd ALC format would be required for all Delegated States, perhaps requiring an 34 update to Guidance Memorandum PR-1.
35 36 The ALC with cover letter from the appropriate State official would become the non-exercise
.37 tehicle for documenting compliance with periodic requirements and continued reasonable 38 assurance. The appropriate State official would certify in each ALC cover letter that (1) 39 reasonable assurance continues to exist, (2) there has been no loss of the ability to meet 40 planning standards, and (3) the program does not contradict any regulatory requirements.
41 These assertions would be based on compliance with periodic requirements, correction of I 42 exercise issues, and/or no programmatic changes that affected reasonable assuance, and this 43 basis would be provided in the ALC.
l l
- m. _ . _ _ _ _ . _ _ . _ . _ _ _ . _ . _ . . . _ _ _ . _ _ _ _ _ _ _ _ .
i 4
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'2 . In examining the ALC, FEMA could rate each function as outlined in the Alf (defined in i 3 Section C, page 8, of Guldsace Memorandum PR-1, " Policy on NUREG 0654/ FEMA-REP. l 4
1/ FEMA-REP.1 and 44 CFR 350 Periodic Requirements," or its revisbo). Suggested ratings ;
5 could be acceptable, acceptable with recommendations for imgwer.t, or unacceptable. l 6 Once each Ametion is rated, there would be an overall finding provided on raamaanhle l 7 assurance. ;
8 9 The reasonable assurance finding could be described in one of three ways: (1) reasonable 10 assurance exists (consider decrearing verification frequency; State continues to evaluate its 11 own exercises), (2) reasonable assu*ance exists but program needs improvement (State 12 continues to evaluate its own exercises), or (3) reasonable assurarse does not exist. FEMA's 13 review of the ALC would determine whether followup discussions are required with the State 14 as REP pw.ers. In the latter instance, the State would develop improvement strategy / tactics
.15 in cooperation with FEMA, NRC, and other cognizant RAC agencies to upgrade its program 16 with timing consistent with 44 CFR 350 to reestablish reasonable asanunce. FEMA could 17 perform an oversight role by assisting in evaluation at the next exercise to ensure program 18 adequacy. If the deficiencies are severe enough or not appropriately corrected, FEMA could 19 take other action up to and including removing delegated State status.
20 21 These findings could be made using in-house staffwith assistance from appropriate FRPCC 22 agencies and with minimal contractor support for technical areas FEMA would need to 23 ensure consistency in REP regional staff review.
24 25 The ALC would also contain the changes to the State's and locals' plans. (These chs.nges 26 are required to be submitted by 44 CFR 350, Section 350.14(c) and (d).) In this way, FEMA 27 would remain aware of how pl ns are evolving and allow FEMA to provide any nected 28 overview in this regard.
29 30 Delenatinn the Evaluation Function
-31 .
32 The primary function that would be delegated and which is central to the Delegated State 33 program is the evaluation function. The basic premise would be that States would evaluate 34 their own exercises utilizing the current FEMA-endo. sed methodology (e.g., a revised REP
! 35 14/15 or appicable variant endorsed by FEMA). In doing their own evaluations, States 36 could utilize other StMe and local personnel as their evaluators as long as these persons meet 37 the evaluator criteria dermed for the program. Stata may also request supplemental 38 assistance by FEMA if they desire; FEMA participation would be based on its interest and 39 availability. The program may also contain provisions that FEMA provide a smal' cadre of 40- evchators to observe an exercise or assist in evaluation based on lack of reasonable 41- assurance arising from earlier exercise findings.
42
4 ,
t 5
1 Any evaluation methodology utilized by a State would require trained evaluators and an .
2 exercise report (e.g., the SERF as potentially modified for Delegated States) that describes 3: issues !dentified and proposed corrective actions.
4-4 5 Evaluated aspects of the REP program would be included in delegated responsibilities even if -
6 done out of pequence from a regularly scheduled exercise (e.g., medical drills or alert and 7 notification tests).
8 '
9 Delegated State Program and Credit Poliev 10 11 A recommendation resuhing from the Strategic' Review may be that FEMA implement a !
12 standard national policy outlining under what circumstances responses to actual events can 13 be granted credit for REP-required activities. Delegated States following this to-be-
. 14 developed national credit policy would be permitted to apply it to their exercises. States 15 would document an after-the-fact discussion of how they applied the credit policy as part of 16 their ALC submittal. (The original application package would also include a commitment to 17 adhere to the national FEMA credit policy.) FEMA, in its review of the ALC, would have an 18 opportunity to review the use of the credit policy. Any questions could be addressed to the 19 State. IfFEMA identifies inadequacies in the application of the credit policy, FEMA could 20 opt to require some remedial action.
21 2?, Sunnlemental Verifications by FC.MA of Aspects of Delenated State Procrama
- 23 24 FEMA may opt on a two- to the-year basis to verify limited portions of a Delegated State's 25 program. Potential areas for verification include:
26 27 (1) the trr.ining plan for responders to ensure conformance with NUREG-0654/ FEMA-28 REP-1, Planning 29 Standard O, 30 (2) the drill / exercise evaluation plan (e.g., evaluator locations, source of evaluators) and 31 methodology which utilizes REP 14/15 (or its revision),
32- (3) the plan and procedure maintenance program in conformance with 33 NUREG-0654/ FEMA-REP-1, Planning Standard P, 34 (4) the roster of key staff for each responding offsite response organization, and 35 (5) periodic visits to assess facilities, equipment,' and training.
36 37 This aspect of the program could be tailored such that States with positive performance 38 history could have verifications performed less frequently than other States and conversely 39 those not performing as well as could have verifications performed more frequently.
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3 REP propam ihnding is provided by utilities in the form ofuser fees to FEMA. In the 4 Delected State program, Amding could be modified auch that (1) FEMA passes through 5 some of this money which could be earmarked for the REP program in Delegated States to 6- the Delegated States or (2) the utilities provide money directly to the States which could have been provided to FEMA otherwise. Option (1) may not be a viable option because if the
- 8. amount of money provided to FEMA by utilities is based on the anhunt of REP hours spent 9 on a particular facility, the number of FEMA REP hours could decrease in a Delegated State.
10 Derefore, FEMA would not have the REP money to pass through to the State.
11-12 REP and the Perfonnance Partnernhlp Agreement (PPA) 1
, 13 114 Inclusion of the REP program in a State's PPA for a Delegated State could remain oftaal
.15: analogous to the current option of States to either include or not include their REP program 16 into the PPA. Therefore, the Delegsted State choice would not affect the State's choice 17 regarding including REP in its PPA.
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18 .
Non-Delegated has 19 20 21 States other than Delegated States would continue to be evaluated by FEMA in a revised 22 REP program FEMA would continue to evaluate the State offsite exercises and produce the 23 exercise report with recommendations to correct identified w ;knesses. Non-delegated states 24 would require a similar level of effort as currently expended ' , FEMA to assess r===anahle 25 assuance. If a non-delegated State did not submit an ALC, FEMA would have to collect 26 data which would normally be included in an ALC (now typically done when State
- 27 performance is an issue).
28 l
29 Advantages of the Delegated State Program 30 31 Assuming the proper controls are in place, what could i e advantages to the States for FEMA s 32. to offer a Delegated State Program?
l 33 34 -(1) States would have much greater flexibility in conducting their radiological emergency 35- preparedness program. Once the State meets specific criteria and is designated a- .
36 Delegated State, it would still be responsible for offsite preparedness. However, their
. 37- methods and procedures would not be prescribed by FEMA (beyond basic program 38 requirements). Therefore, Delegated States would have' greater control over how they
'39 -implement the REP Program. Delegated States could focus more on results. The
-40' Delegated State Program provides the possibility for flexibility in exercise evaluation
- 41 (no Federally-negotiated extent of play agreements) and correction of exercise issues 42 (not responding to FEMA recommendations). Delegated States would have more '
y 'L43' . ownership of the program. -
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1 3 - . 7 1 (2) _ One of the conditions for Delegated State approval could be that the site must have 2 been granted 44 CFR 350 approval. His could be a minimum threshold indicative of 3 FEMA having completed and accepted a review of their plans. Therefore, the 44 4 CFR 350 approval process could take on greater importance and more States may be 5 interested in seeking this approval. 6 7 (3) De Annual L,etter of Certification would take on increased importance as the primary 8 document FEMA wodd review to assess reasonable assurance. The Delegated State 9 would be required to submit the ALC documenting exercise evaluation and other 10 aspects of their program. 11 l ' 12 The Delegated State program could reduce FEMA resources needed for the REP
.(4).
13 program because those Delegated States would be doing their own exercise 14 evaluations. This could be a significant streamlining of the REP program and 15 associated resources while allowing a greater leve! ofREP staff assistance and REP 16 policy work. 17 18 (5) In a Delegated State program, the individuals most knowledgeable about a program 19 would be evaluating it. This could be a significam advantage in terms ofprogram . 20 efficiency and identification of meaningful findings (as well as ownership of those 21 findings). 22 23 Potentini Disadvantanes of a Deleonted State Pronram 24 25 (1) States would be evaluating their own programs and thus evaluating themselves. If not 26 properly implemented, this could be detrimental to the REP program. 27 28 (2) States would not have ready access to FEMA experience and knowledge. (Although 29 an increase in staff assistance may alleviate tids disadvantage.) 30 31 (3) Without additional funding, State resources may not be sufficient to implement a 32 Delegated State program
-33 34 (4)- FEMA could be administering a " dual system" including delegated and non-delegated 35 states.
36 37 Pilot Pronram 38 39 ' Because of the significant change envisioned by the Delegated State concept, a pilot program 40 would be implemented. Lessons learned from the pilot program would determine if and how 41 the Delegated State program would be fully implemented. l i
a l' --Appendix 1 , 2 Impact 3 4 5 If the model of the NRC Agreemerd State program (or other similar Federal agency program) 6 is adopted in whole or in pet, FEMA's oversight role in the REP program could change 7 significantly Roles of the FEMA headquarters and regional REP staff, and States would be - 8 redefmed. Additional training would probably be required at all levels. 9 10- Should the Agreement State model be adopted, in whole or la pet, h is likely that numerous 11 guidance documents would need revision as well as 44 CFR 350 and the NRC-FEMA MOU. 12 13 As with the NRC Agreement State program and other similar Federal programs, there is _ 14 potential that some States, by not having 350 approval for all or some plans (i.e., those with
- 15 interim findings), would not become REP " Agreement States," thus there would need to be a 16 parallel REP program administered by FEMA for those States (or sites because 350 approval
- 17 is site specific).
l l I c i l l r h 1 -- . . . ..
9 1 Appendix 2 2 Summary of NRC Agreement State Program 3
--4 5 Authority 6
7 The NRC Agreement State program is legislatively authorized by the Atomic Energy Act, as 8 amended. W OSHA, EPA, and USDA programs are also legislatively authorized. 9 10 NRC Agreement State Program 11 12 The NRC program is designed to relieve the NRC of regulating certain classes of radioactive 13- materials licenses among Agreement States. States voluntarily submit their programs for
-141 Asi T. cat State status (voluntary submission is also found in the OSHA and Cleu Water 15- Act programs). In Agreement States, the States issue licenses, assen fees to licensees, and 16 inspect licensees. Regulation of nuclear power plants is not included in the Agreement State
~
17 program In those States which are not Agreement States, the NRC regional office regulates 18 the licensees The NRC does not provide funding to Agreement States and in some cases 19 will charge an Agreement State for technical assistance. The NRC Agreement State program 20 is not a delegated program, that is, the NRC " cedes" its regulatory authority. Funding is not
-21 provided the Agreement States, training is not funded and is only provided ch a space 22 available basis in NRC courses. OSHA and EPA difTer in that they do provide some funding, 23 specific direction to their programs, and training.
24 25 Program Characteristics 26-27 How does a State become an Agreement State? This is a voluntary program. States must 28 have a " compatible" (with NRC standards) and " adequate" (to protect public health and 29 safety) radiation control program. This includes State statutes, regulations, and trained staff.
-30 The NRC reviews the State program and, if approved, there is a signing ceremony and 31 phased-in State regulation.
32 33 Number ofNRC Agreement States: There are currently 29 NRC Agreement States. This 34 represents approximately 15,000 radioactive materials licenses, which is about 70 percent of 35' all the radioactive materials licenses issued in the United States. 36 37 Advantages of Agreement State status: 38-39 1) fulfills intent of Atomic Energy Act, as amended 40 2) State radiation control agencies have the option to regulate almost all radiation
-41 sources normally regulated by the NRC (except nuclear power plants)
. -42 3) Regulatory agency is closer to licensees and can generally be more responsive to 43 licensees -
10 1 4) enhances core of knowledgeable persons at State level 2 5) single regulatory agency for most users . 3 6) in general, fees charged to licensees are lower 4 7) decreased requirements placed on NRC ' 5 6 - Disadvantages of Agreement State status: 7 8 1) States must fund program administration 9 2) some licensees may still be subject to more than one regulatory agency , 10 3) requires coordination between NRC and States 11 4) requires parallel program administered by NRC h non-agreement States 12-13 Methods ofNRC Oversight 14 :
-15 The NRC maintains oversight using the following methods:
16 17 1)NRC approves new Agreement States 18 19 2) Assesses compatibility and adequacy of Agreement States periodically, using the 20 Integrated Material Performance Evaluation Program (IMPEP). This is a team (a national 21 cadre which includes both Federal and State staff) which performs evr.luations of the 22 program periodically (anywhere som 2-4 years - based on past perforn:ance record of the 23 state). NRC has developed measurable performance indicators related to 5 areas: status of 24 materials inspection program, technical staffing and training, technical quality of ficensing 25 actions, technical quality ofinspections, and response to incidents and allegations. 26 27 3) Exchanges regulatoiy and safety information wid Agreement States, e.g., telephone, 28 conferences, correspondence, workshops) 29 30 4) provides technical assistance, as deemed appropriate (there are some cases where the NRC 31 will charge the Agreement State for this service) l 32 33 5) trains State personnel on s space available basis 34: 35 Other Federal programs similar to the NRC Agreement State program use similar means to 36 -- provide oversight (e.g , redew/ approve plans, on-site visits, review various state reports).
-37 38 Possible Aeolication of Agreement State Concent to FEMA REP Pronram 39 i
40 Most states have voluntarily submitted their plans for 350 approval. Such approval would be ! '41 a prerequisite for entry to the " Agreement State" program Of the 69 sites, there are currently , L 42 only 12 sites for which a State does not have 350 approval. Those sites are: 43 .
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*2 Sesrook(MA.) Three MileIsland .
l 3 Pilgrim Susquahmana l 4 ArtificialIsland (NJ) Diablo Canyon l J 5 Beaver Valley (PA) San Onofire 6 Peach Bottom WNP-2 7 i 8 These sites without 350 approval (interim findings) would be evaluated by FEMA in a 9= parallel program. FEMA would evaluate all exercius and produce the report with 10 recommendations to correct identified weaknesses. FEMA would increase its role in 11 monitoring State programs which do not have 350 approval (i.e., actually document first- ' 12 hand State compliance with periodic requirements), . 13-14' There are certain aspects of the current FEMA REP program which could possibly be used to _15 restructure the REP prograra along the lines of the NRC Agreement State program and other 16- similar Federal programs However, there is a significant difference between the REP-17 Program and the other agency programs. The other agency programs involve State oversight 18 of third parties, like hospitals, private huiustrieg etc., not the States themselves. IfFEMA 19 were to relinquish some ofits REP authority to the states, the States would essentially be 20 monitoring themselves. This distinction needs to be kept in mind when examining parts of 21 the REP program that could be devolved to tim states.
+
3 1 4 i l lv
11/13/1997 81:83 2026463500 PTEXRG PAGE 03 Billing Code 6718-06
- FEDERAL EMERGENCY MANAGEMENT AGENCY Public Meetings; Radiological Emergency Preparedness (REP) Program Strategic Review AGENCY: Federal Entergency Management Agency (FEMA).
ACTION: Notice of Public Meetmgs.
SUMMARY
- FEMA announces the following public meetings:
NAME: REP Program Strategic Review At-Large Stakeholder Meetings DATES: The public meetings will be held in San Francisco, Califomia, on December 2, 1997; St. Louis, Missouri, on December 4,1997; and Washmgton, DC on December 5, 1997. Any individuals or organizations interested in attending one of the public meetings
- or m=Wg oral presentations must so indicate by 5:00 PM, November 26,1997.
TIME OF MEETINGS: 9:00 AM - 4:00 PM. LOCATIONS: Post neatre, Building 99, Pasidio of San Francisco, California 94129; St. Louis University, Bush Memorial Center, St. Louis Room 210 N. Grand, St. Louis, Missouri 63101; and the University of the District of Columbia, Main University Auditorium,4200 Connecticut Avenue, NW, Washmgton , DC . PROPOSED AGENDAt The public meetings will begin at 9:00 AM vdth a presentation by the Strategic Review Steering Committee (SRSC) on the background of the REP Program Strategic Revievi, including concept papers developed during the review. The meeting will then turn to attendees who have indicated that they want to make oral presentations, and the SRSC will respond to any questions that may be asked. The meeting will adjourn after the attendees have completed their presentations and any 1
11/13/1997 21:23 2026463500 PTN PAGE 03 interaction on the subject matter, but in any event, no later than 4:00 PM. SUPPLEMENTARY INFORMATION: The REP Program Strategic Revie s was announced in the Federal Register on July 8,1996. Comments from 60 entities were received and reviewed by the SRSC. Concept papers developed by the SRSC were reviewed by Govemment Stakcholders in September and will be reviewed by Federal Stuahniders in November. These documents are available in the U.S. Nuclear Regulatory Commission's Public Docket Rooms and the commercial nuclear power plants utilities' Public Docket Rooms and on FEMA's website (www. fema. gov). All three meetings will be open to the public. Individuals or representatives of orgamzations who plan to attend the meeting or make oral presentations should call 1-800-814-0338 on or before 5:00 PM, November 26, 1997. Please leave your name and telephone number, which meeting you wish to attend, and whether you will make a presentation. We ask that you limit your presentations to five minutes,. Written comments are also invited and may be sent to Nancy H. Goldstein, Federal Emergency Management Agency,500 C Street, SW: room 514, 'l+ shington, DC 20472. Dated: n
/(
Kay C. Ofw, \ AssociatcNDirector fM Preparedness, Training and Exercises. er 2
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