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REP Program Manual Page i October 2011

ADMINISTRATOR’S FOREWORD
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CONTENTS

Part I: Introduction to the Radiological Emergency Preparedness Program Manual...................... I-1

A. Purpose ............................................................................................................................................I-1

B. Scope................................................................................................................................................I-3

C. Basis of the REP Program ...............................................................................................................I-4

1. Establishment of the REP Program.........................................................................................I-4

2. Programmatic Changes............................................................................................................I-5

D. Evaluation of Radiological Emergency Preparedness.....................................................................I-9

1. NRC-FEMA Memorandum of Understanding........................................................................I-9

2. Specific FEMA Review and Approval Procedures.................................................................I-9

3. Alternative Approaches and Methods...................................................................................I-11

4. Federal Delegation of Tasks..................................................................................................I-11

5. Planning and Preparedness Assessment Strategy..................................................................I-12

E. Technical Basis for the REP Program............................................................................................I-13

1. Nature of the Hazard .............................................................................................................I-13

2. Protective Actions to Reduce Exposure to Radiation............................................................I-14

3. Protective Action Guides.......................................................................................................I-15

4. Emergency Planning Zones...................................................................................................I-16

5. Radiological Incident Phases.................................................................................................I-17

Part II: REP Program Planning Guidance...........................................................................................II-1

A. Introduction ................................................................................................................................... II-1

1. Purpose and Scope................................................................................................................. II-1

2. Contents and Organization .................................................................................................... II-1

B. Planning Standards ........................................................................................................................ II-2

C. Planning Guidance......................................................................................................................... II-3

1. Planning Standard A – Assignment of Responsibility (Organization Control)..................... II-3

2. Planning Standard B – On-site Emergency Organization ................................................... II-12

3. Planning Standard C – Emergency Response Support and Resources................................ II-15

4. Planning Standard D – Emergency Classification System.................................................. II-21

5. Planning Standard E – Notification Methods and Procedures ............................................ II-23

6. Planning Standard F – Emergency Communications.......................................................... II-35

7. Planning Standard G – Public Education and Information.................................................. II-41

8. Planning Standard H – Emergency Facilities and Equipment............................................. II-54

9. Planning Standard I – Accident Assessment....................................................................... II-61
REP Program Manual Page iv October 2011

10. Planning Standard J – Protective Response......................................................................... II-70

11. Planning Standard K – Radiological Exposure Control ...................................................... II-94

12. Planning Standard L – Medical and Public Health Support.............................................. II-107

13. Planning Standard M – Recovery and Reentry Planning and Post-Accident 

Operations ......................................................................................................................... II-113

14. Planning Standard N – Exercises and Drills...................................................................... II-117

15. Planning Standard O – Radiological Emergency Response Training ............................... II-130

16. Planning Standard P – Responsibility for the Planning Effort: Development, 

Periodic Review and Distribution of Emergency Plans .................................................... II-137

Part III: REP Program Demonstration Guidance.............................................................................III-1

A. Introduction ..................................................................................................................................III-1

1. Contents and Organization ...................................................................................................III-1

2. Background ..........................................................................................................................III-1

B. REP Exercise Process...................................................................................................................III-2

1. Scheduling REP Activities...................................................................................................III-4

2. Conducting Pre-planning Activities...................................................................................III-12

3. Developing REP Exercise Documents...............................................................................III-16

4. Holding Exercise Planning Meetings.................................................................................III-17

5. Conducting REP Exercises.................................................................................................III-18

6. Documenting REP Exercises..............................................................................................III-20

7. REP Program Credit for Participation in Actual Incidents.................................................III-27

C. Exercise Demonstration..............................................................................................................III-29

D. Evaluation of Medical Services Drills........................................................................................III-63

Part IV: FEMA REP Program Administration................................................................................. IV-1

A. Introduction ..................................................................................................................................IV-1

B. Regulatory Summary ....................................................................................................................IV-2

1. 44 CFR Part 350 – Review and Approval of State and Local Radiological 

Emergency Plans and Preparedness .....................................................................................IV-2

2. 44 CFR Part 351 – Radiological Emergency Planning and Preparedness............................IV-9

3. 44 CFR Part 352 – Commercial NPP: Emergency Preparedness Planning .......................IV-10

4. 44 CFR Part 353 – Fee for Services in Support, Review, and Approval of State and 

Local Government or licensee Radiological Emergency Plans and Preparedness.............IV-10

5. 44 CFR Part 354 – Fee for Services to Support FEMA‘s Offsite REP Program ...............IV-10

C. Non-participating State, Tribal, and Local Governments (NUREG-0654/FEMA-REP-1, 

Supplement 1)...........................................................................................................................IV-11

D. Early Site Permit Applications (NUREG-0654/FEMA-REP-1, Supplement 2) ........................IV-11
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E. Protective Action Strategies (NUREG-0654/FEMA-REP-1, Supplement 3).............................IV-12

F. Exercise Methodology, More Challenging Drills and Exercises, and Backup Alert and 

Notification Requirements (NUREG-0654/FEMA-REP-1, Supplement 4)............................IV-12

G. Target Capabilities List ..............................................................................................................IV-14

H. Integration of REP Demonstration Criteria and HSEEP Capabilities........................................IV-15

1. Criteria-Capability Crosswalk............................................................................................IV-15

2. Exercise Evaluation Guides................................................................................................IV-18

3. Customizing EEGs for an Exercise ....................................................................................IV-32

I. Emergency Planning Zone Boundary Changes............................................................................IV-33

J. Credentialing Framework ............................................................................................................IV-34

K. Use of State, Local, and Tribal Personnel as REP Exercise Evaluators.....................................IV-35

1. Administrative Process.......................................................................................................IV-35

2. Host Region Responsibilities .............................................................................................IV-35

3. Evaluator Responsibilities..................................................................................................IV-35

4. Evaluator Employer Commitment:.....................................................................................IV-35

5. Conditions ..........................................................................................................................IV-35

L. Tribal Policies and Procedures....................................................................................................IV-36

1. Federally Recognized Tribal Nations and the REP Program .............................................IV-36

2. Definitions..........................................................................................................................IV-36

3. Policy..................................................................................................................................IV-36

M. Staff Assistance Visits...............................................................................................................IV-36

N. Evacuation Time Estimates........................................................................................................IV-37

O. Potassium Iodide for the Public..................................................................................................IV-38

P. Conducting Plan Reviews ...........................................................................................................IV-39

1. Radiological Emergency Preparedness Plans/Procedures..................................................IV-39

2. Division of Functions and Applicability of Criteria...........................................................IV-40

3. Format for Plan Reviews....................................................................................................IV-41

Q. Conducting Scenario Reviews....................................................................................................IV-45

1. Scenario Review Preparation .............................................................................................IV-45

2. Radiological Emergency Preparedness Exercise Scenario Review Checklist ...................IV-47

R. Annual Letter of Certification.....................................................................................................IV-49

1. Guidance.............................................................................................................................IV-49

2. Sample Annual Letter of Certification Cover Letter..........................................................IV-50

3. Annual Letter of Certification Review Guide ....................................................................IV-51
REP Program Manual Page vi October 2011

S. Public Information Guide and Process........................................................................................IV-58

1. Guidance.............................................................................................................................IV-58

2. Review Steps......................................................................................................................IV-58

3. Foreign Language Translation – Legal Requirements and Location of Information .........IV-62

T. Disaster Initiated Review............................................................................................................IV-63

U. List of Commercial Nuclear Power Plants.................................................................................IV-64

LIST OF APPENDICES

Appendix A: Abbreviations and Acronyms Used in the REP Program....................................................A-1

Appendix B: Glossary of REP Terms.......................................................................................................B-1

Appendix C: REP Guidance References...................................................................................................C-1

Appendix D: Historical REP Guidance References..................................................................................D-1

LIST OF EXHIBITS

Exhibit I-1: Probable Early Effects of Acute Radiation............................................................................I-14

Exhibit I-2: EPZ Characteristics...............................................................................................................I-16

Exhibit II-1: Sample Functional Responsibilities Matrix/Table ............................................................... II-8

Exhibit II-2: Design Objectives for Alert and Notification of the Public* ............................................. II-29

Exhibit III-1: Milestones for the REP Exercise Process..........................................................................III-3

Exhibit III-2: Federal Evaluation Process Matrix ....................................................................................III-7

Exhibit III-3: Illustration of the Standard Exercise Issue Number ........................................................III-22

Exhibit III-4: Evaluation Standards for Alert and Notification Systems...............................................III-53

Exhibit IV-1: Plan Review Responsibilities for RAC Agencies..............................................................IV-3

Exhibit IV-2: Criteria-Capability Crosswalk .........................................................................................IV-16

Exhibit IV-3: Sample Exercise Evaluation Guide .................................................................................IV-19

Exhibit IV-4: Plan Review Responsibility.............................................................................................IV-40

Exhibit IV-5: Portion of Sample Plan Review Format for ―Franklin County‖......................................IV-42

Exhibit IV-6: Scenario Review Process.................................................................................................IV-45

Exhibit IV-7: Public Information Review Checklist..............................................................................IV-58
REP Program Manual Page vii October 2011

DISCLAIMER

This policy represents the Federal Emergency Management Agency (FEMA) Radiological Emergency 

Preparedness (REP) Program‘s interpretations of a statutory or regulatory requirement. The policy itself 

does not impose legally enforceable rights and obligations, but sets forth a standard operating guideline or 

agency practice that FEMA employees follow to be consistent, fair, and equitable in the implementation 

of the Agency‘s authorities.

FEMA undertook substantial efforts to ensure that this manual incorporated all applicable Radiological 

Emergency Preparedness Program policy and guidance.1 However, the possibility remains that FEMA 

overlooked some source(s). For any relevant policy or guidance not incorporated into this manual, the 

REP Program will regard the subject material, in its current format, as the currently held position on the 

referenced matter until FEMA can appropriately revise the manual.

In addition, FEMA will review changes to other Federal Agency guidance that impacts the REP Program 

and issue amendments to this manual as warranted.

 

1 Exception: The current FEMA-REP series and related guidance documents are listed in Appendix C and cited in the applicable parts of this 

manual. The retired guidance documents are listed in Appendix D for historical purposes. Submit comments and changes to the REP Manual to 

FEMA for consideration. To the greatest extent possible, FEMA will issue all future REP Program guidance as amendments to the applicable 

parts of this manual.
REP Program Manual Page viii October 2011

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REP Program Manual Page I-1 October 2011

Part I: INTRODUCTION TO THE

RADIOLOGICAL EMERGENCY PREPAREDNESS

PROGRAM MANUAL

A. PURPOSE

This manual serves as the principal source of 

policy and guidance for the Federal 

Emergency Management Agency (FEMA) 

Radiological Emergency Preparedness (REP) 

Program. 

Federal regulations in 44 Code of Federal 

Regulations (CFR) Part 350 address FEMA‘s 

role in conducting assessments and issuing 

findings regarding offsite emergency 

plans/procedures for responding to radiological 

emergencies at commercial nuclear power plants 

(NPPs). 

State, tribal, and local government participation 

in offsite radiological emergency planning and 

preparedness is voluntary. However, 

participation in the REP planning and 

preparedness process necessitates adherence to 

the program requirements as set forth in 44 CFR 

Part 350, the joint Nuclear Regulatory 

Commission (NRC)/FEMA document NUREG0654/FEMA-REP-1

2

, and this REP Program 

Manual. If state, local, or tribal governments 

choose not to participate in REP planning, 44 

CFR Part 352 outlines the licensee‘s obligation 

to develop offsite plans/procedures to protect the 

public health and safety.

The elements of NUREG-0654/FEMA-REP-1 

are REP Program requirements for offsite 

response organizations. In addition to the 16 

Planning Standards for radiological emergency 

preparedness, 44 CFR § 350.5 incorporates by 

 

2 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, 

cited herein as ―NUREG-0654/FEMA-REP-1.‖

reference NUREG-0654/FEMA-REP-1, which 

includes associated Evaluation Criteria that 

further define the Planning Standards. The 16 

Planning Standards and associated Evaluation 

Criteria set the standard that FEMA uses to 

assess offsite planning and preparedness. 

Shall and should: Language in the REP 

Program Manual quoted directly from regulatory 

material uses both shall and should to denote 

requirements. The remaining text in the REP 

Program Manual uses the terms shall, must, and 

require to denote mandatory items originating in 

regulatory material including NUREG0654/FEMA-REP-1 and the CFR. The terms 

should, suggest and recommend denote guidance 

outlining a Federally-approved means of 

meeting the intent of the REP regulations. The 

term may denotes an option, neither required nor

necessarily recommended.

Alternative approaches. The Evaluation 

Criteria listed in NUREG-0654/FEMA-REP-1, 

as clarified, interpreted, and applied by the 

NRC, FEMA, and other Federal agencies, 

represent Federally-approved approaches for 

meeting the intent of the regulatory 

requirements. Offsite response organizations 

(OROs) may propose alternative approaches to 

meeting those requirements in writing to the 

NUREG-0654/FEMA-REP-1 Requirement

It is FEMA’s position that, unless an alternative 

approach is proposed and accepted for 

meeting the intent of the Planning Standards of 

NUREG-0654/FEMA-REP-1, the associated 

Evaluation Criteria must be met.
PART I: INTRODUCTION

REP Program Manual Page I-2 October 2011

appropriate FEMA Regional Office. Part I.D.3 

provides a detailed discussion of alternative 

approaches.

Reasonable Assurance. In the communities 

surrounding commercial nuclear power plants, 

44 CFR 3S0.S (b) directs FEMA's REP Program

to review state and local radiological emergency 

plans and preparedness. Approved plans and 

preparedness "must be determined to adequately 

protect the public health and safety by providing 

reasonable assurance that appropriate protective 

measures can be taken offsite in the event of a 

radiological emergency."

FEMA defines reasonable assurance as a 

determination that state, local, tribal, and utility 

offsite plans and preparedness are adequate to 

protect public health and safety in the

emergency planning areas of commercial 

nuclear power plants. FEMA shall take into 

consideration plans, procedures, personnel, 

training, facilities, equipment, drills, and 

exercises, which in its professional judgment are 

important to the effective implementation of 

protective measures offsite in the event or any 

incident at a commercial nuclear power plant.

FEMA shall make its adequacy determination, 

supported by other Federal agencies, as 

necessary, by conducting inspections, providing 

staff assistance visits, organizing, conducting 

and reviewing training, participating in, 

observing and evaluating drills and exercises, 

and by being an engaged partner with Federal, 

state, local, and tribal government officials and 

industry stakeholders. 

In making its reasonable assurance

determination, FEMA shall be guided by the 

standards, criteria, and policy found in 

applicable laws, regulations, and contemporary 

emergency preparedness guidance. Where 

improvements or corrections arc needed, FEMA 

will work closely with Federal, state, local, and 

tribal government officials and industry 

stakeholders to resolve the issue(s).

10 CFR 50 and 10 CFR 52, 44 CFR 350 and 44 

CFR 353, NUREG-0654/FEMA-REP- I, Rev. 1 

(and Supplements), and the REP Program

Manual. Contemporary emergency preparedness 

guidance includes the National Response

Framework (NRF), Community Planning 

Guidance (CPG) 101, the Target Capabilities 

List (TCL), the National Incident Management 

System (NIMS) and Incident Command System 

(ICS), the Homeland Security Exercise and 

Evaluation Program (HSEEP) and the Integrated 

Planning System.

Planning and Preparedness Assessment 

Strategy. The REP Program currently relies on 

a combination of exercises, SAVs, plan reviews, 

and an Annual Letter of Certification (ALC) to 

develop a recommendation of reasonable 

assurance. Over the course of the last 30 years, 

the reasonable assurance assessment began to 

rely on the biennial exercise over the other 

components. This edition of the REP Program 

Manual introduces multiple policy changes that 

allow an ongoing assessment approach through 

evaluation of a broader range of activities than 

those previously used. These changes are 

consistent with national preparedness initiatives 

and HSEEP, and continue the streamlining of 

Federal, state, and local efforts and resources 

and the goal of employing a common assessment 

strategy.

One-stop reference guide. FEMA maintains 

this document for use by its stakeholders as a 

desk reference when they need to answer 

questions or receive clarification on REP 

planning, exercises, and administrative 

procedures. This version of the REP Program 

Manual incorporates previously issued FEMA 

guidance memoranda, policy memoranda, and 

some FEMA-REP series documents. This 

updated manual effectively retires incorporated 

documents from use as independent resources. 

Retired guidance documents appear in Appendix 

D as historical resources. The REP Program 

Manual retains active guidance documents on 

specific technical areas such as the FEMA-REP 

series documents and other REP Program 

documents too lengthy to incorporate as standalone references. Appendix C lists these standalone references, and the manual cites them 

where applicable. To the greatest extent 

possible, FEMA will issue all future REP 

Program guidance as amendments to the 

applicable parts of this manual.
PART I: INTRODUCTION 

REP Program Manual Page I-3 October 2011

B. SCOPE

This manual provides FEMA guidance that 

interprets the Planning Standards and Evaluation 

Criteria in NUREG-0654/FEMA-REP-1 and 44 

CFR Part 350. This guidance provides additional 

detail to OROs on what FEMA expects them to 

include in their radiological emergency response 

plans. This manual also provides the 

Demonstration Criteria that FEMA uses to 

evaluate the ability of the OROs to implement 

their radiological emergency response plans. 

Lastly, this manual provides additional 

information and guidance to help FEMA staff 

and OROs perform various REP Program 

functions (e.g., checklists, templates, references, 

etc.). 

Communities potentially affected by a 

radiological incident at a nearby commercial 

NPP benefit from essential planning and 

preparedness activities. FEMA created the REP 

Program to address the unique needs of OROs.

FEMA reviews and approves ORO planning and 

preparedness activities before the NRC issues a 

license to operate an NPP. FEMA also provides

ongoing certifications that planning and 

preparedness efforts remain effective and 

consistent with relevant regulations.

This manual is divided into four main parts and 

includes additional appendices. 

Part I introduces the REP Program and provides 

an overview. It provides the history and 

establishment of the REP Program, a description 

of the review process, and the technical basis for 

the program. This section provides a base 

knowledge about the REP Program and 

describes current operations through a synopsis 

of its evolution.

Part II contains the NUREG-0654/FEMA-REP1 Planning Standards and Evaluation Criteria, 

along with explanations and guidance on 

materials to be included in ORO plans/

procedures. These explanations are solely 

guidance and neither exceeds nor replaces any 

FEMA or NRC regulations. 

Part III of the REP Program Manual 

supplements the HSEEP process and provides 

specific guidance unique to the design, 

development, conduct, evaluation, and 

improvement planning associated with REP 

exercise activities. FEMA created this guidance 

for REP controllers, evaluators, contractors, and 

any Federal, state, local, or tribal agencies 

responsible for planning, preparing, and 

executing exercises that are used to validate REP 

Program requirements. This section provides 

licensee partners with guidelines regarding how 

the Federal government will coordinate exercise 

activities in conjunction with the REP Program.

Part IV presents supporting reference 

documentation, where specific information is 

found in support of the program. It includes 

information on Potassium Iodide and Disaster 

Initiated Reviews, scenario reviews, plan 

reviews, the Annual Letter of Certification 

(ALC), and other topics. 

The appendices include acronyms, a glossary, 

additional REP reference documents (active and 

retired), plant site identifier numbers and the 

TCL. 

The term ―ORO‖ refers to a state, tribal, and/or 

local government, a licensee emergency 

response organization (in certain circumstances), 

and any other supporting organization acting to 

protect the health and safety of the public offsite 

(beyond the NPP site boundary). Only the 

licensee emergency response organization is 

responsible for activities onsite (within the NPP 

site boundary). The REP Program Manual uses

the term ―ORO‖ or ―OROs‖ instead of 

specifying state, tribal, and/or local 

governments, because FEMA acknowledges that 

local authorities vary from state to state; certain 

REP activities may be the responsibility of the 

state in one instance and local jurisdictions in 

another. The REP Program Manual guidance 

applies to the entities responsible for the 

function being discussed. 
PART I: INTRODUCTION 

REP Program Manual Page I-4 October 2011

The term ―plans/procedures‖ as used in this 

manual includes radiological emergency 

preparedness and response plans, associated 

implementing procedures such as Standard 

Operating Guidelines (SOGs), and other 

supporting and referenced materials. FEMA may 

review all of these documents to the extent 

necessary determining whether they meet the

intent of the requirements. FEMA uses the 

generic term ―plans/procedures‖ specifically for 

flexibility. The ORO may either incorporate 

procedural detail into its main plans or into 

separate procedural documents at its discretion.

C. BASIS OF THE REP PROGRAM

This section provides an overview of the 

legislative mandates and guidance for the REP 

Program, describes its establishment, and details 

the impact of post-September 11, 2001 and postKatrina programmatic changes.

1. ESTABLISHMENT OF THE REP

PROGRAM

The NRC is responsible for emergency 

preparedness at the nation‘s commercial NPPs. 

Following the March 1979 Three Mile Island 

accident, Executive Order 12148 and the 

Presidential Directive of December 7, 1979 

transferred the Federal lead role in offsite 

emergency planning and preparedness activities 

from the NRC to FEMA. This assignment 

aligned with FEMA‘s statutory role in 

promoting, funding, coordinating, and providing 

technical assistance for disaster preparedness, as 

defined in Section 201 of the Disaster Relief Act 

of 1974.3 FEMA established the REP Program to 

manage its responsibility for ORO emergency 

planning and preparedness in areas around 

commercial NPPs. The NRC retained 

responsibility for onsite activities.

The NRC Authorization Acts of 1980 (Pub.L. 

96-295) and 1982-1983 (Pub.L. 97-415) directed 

the NRC to establish emergency preparedness as 

a criterion for licensing commercial NPPs. 

Specifically, the NRC Authorization Acts 

prohibit the NRC from issuing an operating 

license for an NPP unless it finds that ―there 

 

3

42 USC 5131, as amended by the Robert T. Stafford Disaster 

Relief and Emergency Assistance Act, Public Law (Pub.L.)100-

707, 102 Stat. 4689 (1988). This Act constitutes the statutory 

authority for most Federal disaster response activities, especially 

as they pertain to FEMA and FEMA programs.

exists a state, local, or utility4 plan which 

provides reasonable assurance that public health 

and safety is not endangered by operation of the 

facility concerned.‖5The acts also provide for 

the NRC to consult FEMA in developing 

standards for evaluating plans/procedures and in 

making individual determinations that the 

plans/procedures provide reasonable assurance 

for protecting public health and safety.6 The 

NRC revised its regulations in 10 CFR Part 50 

to incorporate additional emergency 

preparedness requirements, including 16 

Planning Standards for onsite and offsite 

emergency response plans/procedures. 

In 1980, the NRC and FEMA jointly issued 

NUREG-0654/FEMA-REP-1 to provide onsite 

and offsite planning guidance to protect public 

health and safety in the event of an incident at an 

NPP. This document includes the 16 Planning 

Standards and associated Evaluation Criteria for 

assessing whether the licensee and the affected 

OROs have plans/procedures in place that 

provide a reasonable assurance that adequate 

protective measures can and will be taken. 

FEMA regulations in 44 CFR Part 350 address 

the review and approval of ORO emergency 

plans/procedures for responding to radiological 

emergencies at commercial NPPs. These 

regulations also include the 16 Planning 

Standards and incorporate by reference the joint 

 

4

44 CFR Part 352 allows for the submission of offsite emergency 

response plans/procedures by a licensee in those instances where 

OROs, either individually or together, decline or fail to prepare 

commercial NPP offsite radiological emergency preparedness 

plans/procedures that are sufficient to satisfy NRC licensing 

requirements or to participate adequately in preparation, 

demonstration, testing, exercise, or use of such plans/procedures.

5

Pub.L. 97-415, section 5, 96 Stat. 2067, 2069 (1983).

6

Pub.L. 96-295, section 109(b), 94 Stat. 80, 784 (1980).
PART I: INTRODUCTION

REP Program Manual Page I-5 October 2011

NRC-FEMA guidance document NUREG0654/FEMA-REP-1. 

In June 1996, FEMA initiated a Strategic 

Review of the REP Program in order to improve

its efficiency and effectiveness.7 FEMA worked 

with internal and external stakeholders 

nationwide and published five major 

recommendations in September 1998.

8These

recommendations were:

1. Streamline the REP Program;

2. Increase Federal Participation in REP 

Exercises;

3. Use State, Local, and Tribal Personnel 

as Exercise Evaluators;

4. Include Native American Tribal Nations 

in the REP Preparedness Process; and

5. Enhance the REP Training Program.

Each recommendation included initiatives for 

implementation. 

2. PROGRAMMATIC CHANGES

The lessons learned from events of September 

11, 2001 and Hurricane Katrina compelled all 

Federal agencies – particularly those that have a 

mission to protect public health and safety – to 

look at their programs to ensure adequate 

preparation existed for catastrophic and 

unanticipated incidents. This section describes 

how the resulting programmatic changes 

impacted the REP Program. 

a. Department of Homeland Security

National Preparedness Initiatives

After September 11, Congress passed the 

Homeland Security Act of 2002 (Pub.L. 107-

296, 116 Stat. 2135) to establish the Department 

of Homeland Security (DHS) to lead emergency 

prevention and preparedness efforts for terrorist 

acts and other catastrophic incidents. A 

 

7

61 FR 35733, Notice of the Federal Emergency Management 

Agency‘s Intent to Conduct a Strategic Review of Its 

Radiological Emergency Preparedness Activities, July 8, 1996.

8

63 FR 48222, Publication of Radiological Emergency 

Preparedness (REP) Program Strategic Review Draft Final 

Recommendations, September 9, 1998. This notice also 

summarized several short-term improvements implemented at 

that time.

Reorganization Plan submitted to the President 

pursuant to Section 1502 of the DHS Act of 

2002 transferred FEMA to DHS. With this 

reorganization, FEMA actively directed its "allhazards" disasters approach toward homeland 

security issues. 

DHS‘ overriding mission is to lead a unified 

national effort to prepare for and respond to all 

hazards and disasters. To address this need for a 

unified and coordinated approach, Homeland 

Security Presidential Directive (HSPD)-5: 

Management of Domestic Incidents and 

Presidential Policy Directive (PPD)-8: National 

Preparedness9established national initiatives for 

a common approach to preparedness and 

response. These initiatives include: 

 National Incident Management System –

NIMS provides a systematic, proactive 

approach to guide all jurisdictional levels 

and the private sector to work seamlessly to 

prevent, protect against, respond to, recover 

from, and mitigate the effects of incidents, 

regardless of the cause, size, or complexity. 

Building upon the Incident Command 

System (ICS), NIMS provides the Nation‘s

first responders and authorities with a 

common foundation for incident 

management for terrorist attacks, natural 

disasters, and other emergencies. NIMS 

complements the NRF. 

 National Response Framework10 – the NRF 

is an all-discipline, all-hazards plan for the 

management of domestic incidents. Using 

the incident management template 

established by NIMS, the NRF provides the 

structure and mechanisms to coordinate and 

integrate incident management activities and 

emergency support functions (ESFs) across 

Federal, state, local, and tribal government 

 

9 On March 30, 2011, PPD-8 on National Preparedness was signed. 

This directive replaces Homeland Security Presidential Directive 

(HSPD)-8 (National Preparedness), issued December 17, 2003, 

and HSPD-8 Annex I (National Planning), issued December 4, 

2007, which are hereby rescinded, except for paragraph 44 of 

HSPD-8 Annex I. Individual plans developed under HSPD-8 and 

Annex I remain in effect until rescinded or otherwise replaced.

10 The NRF replaced the National Response Plan effective March 

22, 2008. 
PART I: INTRODUCTION

REP Program Manual Page I-6 October 2011

entities, the private sector, and nongovernmental organizations.

 National Preparedness Guidelines – the 

Guidelines define what it means for the 

Nation to be prepared. DHS established 

several key elements under the Guidelines. 

These elements include the TCL, which 

defines 37 specific capabilities that 

communities, the private sector, and all 

levels of government should strive to 

collectively possess in order to respond 

effectively to disasters. DHS also 

established a National Exercise Program to 

test and evaluate preparedness 

plans/procedures and strategies under the 

circumstances of actual emergencies. The 

National Exercise Program incorporates 

HSEEP as the policy and guidance for 

exercise design, conduct, and evaluation.

 Comprehensive Preparedness Guide –

The FEMA Comprehensive Preparedness 

Guide (CPG 101) provides general 

guidelines on developing emergency 

operations plans.11 It promotes a common 

understanding of the fundamentals of 

planning and decision making to help 

emergency planners examine a hazard and 

produce integrated, coordinated, and 

synchronized plans. FEMA encourages 

OROs to use CPG 101 for all-hazards 

planning. CPG 101 is the first in a series of 

publications developed through the FEMA 

Protection and National Preparedness 

Directorate‘s (PNPD) CPG Initiative. Future 

CPGs will discuss planning considerations 

for a variety of emergency functions, 

hazards, and special preparedness programs. 

 Post-Katrina Emergency Management 

Reform Act (PKEMRA) – On October 4, 

2006, the President signed PKEMRA into 

law, which reconfigured FEMA to include 

consolidated emergency management 

functions, including national preparedness 

functions. The REP Program was 

incorporated into the FEMA PNPD, which 

 

11 FEMA, Comprehensive Preparedness Guide 101: Developing 

and Maintaining Emergency Operations Plans, Version 2.0,

November 2010.

provides strategy, policy, and planning 

guidance to build prevention, protection, 

response, and recovery capabilities among 

all levels of government throughout the 

Nation. One new capability mandated by 

PKEMRA is the National Exercise 

Simulation Center, which provides a means 

to incorporate increased levels of Federal 

interagency participation into ongoing REP 

exercise activities. 

b. Initiatives in the REP Program Manual

Revisions to the REP Program Manual address 

alignment and integration of the REP Program 

with two specific initiatives: (1) NIMS and (2) 

HSEEP.

(1) NIMS

The REP Program Manual incorporates NIMS 

features, such as standard terminology and the 

Incident Command System, to ensure 

consistency with the National Exercise Program. 

It also provides a flexible management template 

that can be scaled appropriately to any incident, 

regardless of cause, size, location, or 

complexity. 

(2) HSEEP Methodology

DHS uses HSEEP methodology for the 

development, conduct, and evaluation of 

emergency response exercises to test and 

evaluate preparedness plans/procedures and 

strategies at all levels of government. Integrating 

HSEEP methodology into the REP Program will 

achieve program efficiencies by: (1) ensuring 

REP Program compliance with elements of 

HSPD-5, PPD-8, and PKEMRA; (2) 

standardizing exercise design, conduct, 

evaluation, and improvement planning activities 

among all FEMA Regions and evaluation team 

members; (3) reducing scheduling conflicts by 

bringing the REP Program into the National 

Exercise Schedule; (4) reducing exercise fatigue 

by combining multiple requirements into fewer 

total exercises; and (5) providing a suite of 

standardized tools for scheduling, planning, 

information sharing, and evaluation/corrective 

action. As discussed in more detail in Part III of 

this Manual, HSEEP does not supersede any 
PART I: INTRODUCTION

REP Program Manual Page I-7 October 2011

applicable legislation, regulations, or guidance 

for the REP Program. 

c. REP Exercise Scenario and Security

Incident Preparedness Enhancements

Following the events of September 11, 2001, the 

NRC reviewed the emergency preparedness 

basis for commercial NPPs to assess whether the 

program could adequately address hostile action 

contingencies (e.g., terrorist attacks), given the 

programmatic basis on accidental releases. The 

NRC determined that potential radiological 

exposure to the public during a hostile actionbased (HAB) incident is no more severe than in 

other accident sequences considered in the 

radiological emergency preparedness basis. 

However, the NRC and FEMA recognized that 

HAB incidents could present unique challenges 

to emergency preparedness programs because 

they differ from the accident-initiated incidents 

for which licensees and OROs typically plan, 

train, and exercise.

In July 2005, the NRC issued Bulletin 2005-02, 

―Emergency Preparedness and Response 

Actions for Security-Based Events‖ to collect 

data on program enhancements undertaken by 

licensees in order to address potential hostile 

actions. In 2006, the NRC issued Regulatory 

Issue Summary 2006-1212 as an acceptable 

implementation methodology for the emergency 

preparedness program enhancements discussed 

in Bulletin 2005-02. The NRC also 

recommended pursuing rulemaking for 

emergency preparedness program enhancements 

for several security incident-related and nonsecurity incident-related topics. Additionally, the 

NRC‘s comprehensive review identified several 

other areas for potential emergency preparedness 

program improvement and areas requiring 

increased clarity based on technological 

advances, and lessons learned from drills, 

exercises, and actual incidents.

 

12 RIS 2006-12, ―Endorsement of Nuclear Energy Institute 

Guidance  ̳Enhancements to Emergency Preparedness Programs 

for Hostile Action,‘‖ July 19, 2006. This document endorsed the 

Nuclear Energy Institute (NEI) White Paper titled 

―Enhancements to Emergency Preparedness Programs for 

Hostile Action,‖ issued May 2005 (revised November 18, 2005).

In 2007, FEMA and the NRC established an 

Exercise Scenario Task Force to identify, 

coordinate, and promulgate appropriate changes 

to FEMA and NRC regulations, exercise 

participation, and guidance to make REP 

exercises more realistic and challenging, and 

less predictable. The Task Force identified 

proposed changes to the REP Program in three 

areas:

1. Reducing response organizations‘ 

exercise pre-conditioning by increasing 

the variability of exercise events.

2. Enhancing security response capabilities 

based on post-September 11 security 

initiatives by introducing HAB 

scenarios into the REP exercise cycle.

3. Providing guidance for varying the 

amount and type of simulated 

radioactive releases during exercise 

play.

Parts II and III of this manual reflect changes 

resulting from these efforts.

d. Special Information Regarding Service

Animals and Household Pets

This manual provides general guidelines for 

expanding ORO plans/procedures in response to 

regulatory changes13 regarding service animals. 

Plans/procedures reflect how a jurisdiction will 

provide care to service animals, including the 

identification of resources it has or can readily 

obtain through existing mutual aid agreements. 

The term ―service animal,‖ refers to any dog that 

has been individually trained to do work or 

perform tasks for the benefit of an individual 

with a disability. The rule states that other 

animals, whether wild or domestic, do not 

qualify as service animals. Dogs that are not 

trained to perform tasks that mitigate the effects 

of a disability, including dogs that are used 

purely for emotional support, are not service 

animals. The final rule also clarifies that 

individuals with mental disabilities who use 

 

13 Sections 403 and 502 of the Robert T. Stafford Disaster Relief 

and Emergency Assistance Act, 42 U.S.C. 5170b, 42 U.S.C. 

5192; the Pets Evacuation and Transportation Standards Act 

(PETS Act) of 2006, P.L. No. 109‐308, § 4, 120 Stat. 1725 

(2006).
PART I: INTRODUCTION

REP Program Manual Page I-8 October 2011

service animals that are trained to perform a 

specific task are protected by the ADA. The rule 

permits the use of trained miniature horses as 

alternatives to dogs, subject to certain 

limitations. To allow flexibility in situations 

where using a horse would not be appropriate, 

the final rule does not include miniature horses 

in the definition of "service animal."14 Service 

animals are permitted in all places that serve the 

public as long as the animal is not out of control. 

This access includes transportation with their 

owners/handlers during evacuations. 

OROs can find planning guidance for evacuation 

and sheltering of household pets in CPG 101;

however no specific guidance on the 

radiological monitoring and decontamination of 

household pets currently exists.

e. Functional Needs Service Support 

(FNSS)

In October 2006, PKEMRA provided a mandate 

to integrate the needs of people with disabilities 

and those with access and functional needs into 

general emergency management planning, 

response, and recovery. The thorough 

integration of and participation by people with 

disabilities in local planning helps ensure that 

misleading stereotypes do not dilute emergency 

plan effectiveness. Historically, resource gaps in 

planning for and meeting access and functional 

needs in general population shelters, resulted in 

disparate treatment and the denial of full and 

equal services. FEMA developed Guidance for 

Planning for Integration of Functional Needs 

 

14 The Department of Justice published revised final regulations 

implementing the Americans with Disabilities Act (ADA) for 

title II (State and local government services) and title III (public 

accommodations and commercial facilities) on September 15, 

2010, in the Federal Register. These requirements, or rules, 

clarify and refine issues that have arisen over the past 20 years 

and contain new, and updated, requirements, including the 2010 

Standards for Accessible Design (2010 Standards).

Support Services in General Population Shelters

to support Federal, state, local, and tribal

governments with the integration of children and 

adults with and without disabilities who have 

access and functional needs into every aspect of 

emergency shelter planning and response. 

Communities can use this document in 

conjunction with general population shelter 

Standard Operating Procedures (SOP) to ensure 

that all shelter residents benefit equally from 

programs, services, and activities. This 

document provides a context for FNSS 

integration in light of other existing plans and 

describes a process to use in any planning effort. 

The scalability of these guidelines enables their 

application to urban, suburban, and rural 

localities with multiple or limited resources. 

Children and adults with disabilities have the 

same right to services in general population 

shelters as other residents. Emergency managers 

and shelter planners have the responsibility of 

planning to ensure that sheltering services and 

facilities are accessible. The decisions made in 

the planning process determine whether 

integration or segregation occurs during 

response. Although FEMA geared the FNSS 

guidance toward emergency managers and 

shelter planners, it is a document that local 

communities can utilize as a shelter planning 

tool.

The planning guidance ensures that general 

population shelters do not turn away individuals 

and inappropriately place them in other 

environments (e.g., ―special needs‖ shelters, 

institutions, nursing homes, and hotels and 

motels disconnected from other support 

services). Addressing these gaps benefits the 

entire community and maximizes resources.

Guidance on Household Pets 

Under Development

Although provisions for household pets are not 

currently required, FEMA encourages OROs to 

plan for the reality that in an emergency, many 

evacuees will arrive at reception centers with 

their pets.
PART I: INTRODUCTION

REP Program Manual Page I-9 October 2011

D. EVALUATION OF RADIOLOGICAL EMERGENCY

PREPAREDNESS

To facilitate participant adherence to REP 

Program requirements and policies, this manual 

provides clarifying guidance from FEMA. The 

planning guidance contained in Part II of this 

manual further explains the NUREG0654/FEMA-REP-1 Planning Standards and 

associated Evaluation Criteria that apply to 

OROs. Certain Evaluation Criteria in NUREG0654/FEMA-REP-1, including all of those in 

Planning Standard B, Onsite Emergency 

Organization, do not pertain to offsite planning 

and preparedness; however, this manual 

incorporates all of the Planning Standards and 

Evaluation Criteria to maintain consistency with 

NUREG-0654/FEMA-REP-1.

1. NRC-FEMA MEMORANDUM OF

UNDERSTANDING

FEMA and the NRC entered into a 

Memorandum of Understanding (MOU) 

(contained in Appendix A to 44 CFR Part 353) 

to detail their respective authorities and 

responsibilities for radiological emergency 

response planning and preparedness. The MOU 

outlines FEMA‘s responsibilities in evaluating 

offsite emergency preparedness and details the 

procedures under which the NRC requests, and 

FEMA provides, preparedness findings.

Under the MOU, FEMA may review 

radiological emergency planning and 

preparedness and provide its findings to the 

NRC under various circumstances:

 FEMA will review ORO plans/procedures 

when the Governor of a state submits them

for formal review.

 FEMA will provide interim findings on the 

current state of preparedness based on its 

review of site-specific plans/procedures 

and, if appropriate, exercise performance. 

For example, the NRC may request an 

interim finding in connection with an 

application for an Early Site Permit under 

10 CFR § 52.17(b)(2). 

 FEMA may review offsite emergency 

preparedness on its own initiative or at the 

request of the NRC to develop a finding, if 

there is reason to believe that reasonable 

assurance may no longer exist at a 

particular site 

 FEMA may initiate a Disaster Initiated 

Review (DIR) in the event of a disaster that 

may affect emergency preparedness and 

response in the vicinity of an NPP (e.g., a 

hurricane or earthquake that disrupts roads 

used for evacuation), to determine whether 

the disaster significantly degraded 

preparedness. FEMA will forward the 

results of such a review to the NRC for its 

consideration in making decisions on the 

restart or continued operation of the 

affected facility.

FEMA-NRC Steering Committee: Section IX 

of the MOU also describes the joint NRCFEMA Steering Committee, which is the ―focal 

point for coordination of emergency planning 

and preparedness‖ and will ―assure coordination 

of plans and preparedness evaluation activities 

and revise, as necessary, acceptance criteria for 

licensee, state, and local radiological emergency 

planning and preparedness.‖ Questions about the 

interpretation of the criteria used for evaluating 

offsite plans/procedures and preparedness may 

be referred to FEMA Headquarters and, when 

appropriate, to the FEMA/NRC Steering 

Committee to assure uniform interpretation.

2. SPECIFIC FEMA REVIEW AND

APPROVAL PROCEDURES

This section provides an overview of how 

FEMA conducts its reviews of ORO 

preparedness under 44 CFR Part 350. These 

regulations define procedures for submitting 

plans/procedures for formal review and 
PART I: INTRODUCTION

REP Program Manual Page I-10 October 2011

approval, as well as other requirements (e.g., 

public meeting and exercise) for establishing 

reasonable assurance of public health and safety. 

Responsibilities are defined at the FEMA 

Regional and Headquarters level for evaluating 

and approving ORO preparedness, including 

procedures for withdrawing approval if 

subsequent information indicates that 

preparedness is no longer adequate to 

demonstrate reasonable assurance.

Pursuant to FEMA policy and procedures, 

FEMA Regional Office personnel evaluate 

plans/procedures with assistance from Regional 

Assistance Committee (RAC) members. The 

RACs consist of representatives of Federal 

agencies with special authorities, missions, and 

expertise that have agreed to assist FEMA in 

providing technical assistance to OROs and in 

evaluating REP plans/procedures and exercises. 

FEMA Regional Offices review REP 

plans/procedures and forward their 

recommended findings to FEMA Headquarters 

for final determination by the Deputy 

Administrator of PNPD, or designee. FEMA 

Headquarters forwards its reviews of the 

adequacy of the REP plans/procedures and 

findings to the NRC for its use in making 

licensing decisions.

State submittal: The process for initial 

approval, outlined in 44 CFR § 350.7 through 

350.14, begins when a state applies to the 

appropriate FEMA Regional Administrator for 

approval of its planning and preparedness at a 

particular commercial NPP. The state submittal 

covers both the state and appropriate local 

governments. In states with multiple commercial 

NPP sites, the state must submit separate 

plans/procedures for each site. FEMA approval 

of planning and preparedness is specific to the 

site. The Governor or designee signs a letter 

declaring that, in the opinion of the state, the 

plans/procedures are ―adequate to protect the 

health and safety of its citizens...by providing 

reasonable assurance that state, local, and tribal

governments can and intend to effect appropriate 

protective measures offsite in the event of a 

radiological emergency.‖ (44 CFR § 350.7(d))

With assistance from the RAC, the Regional 

Administrator makes a detailed review of the 

plans/procedures according to the Planning 

Standards and Evaluation Criteria outlined in 10 

CFR § 50.47(b), 44 CFR § 350.5, and NUREG0654/FEMA-REP-1 and assesses factors such as 

adequacy and maintenance of procedures, 

training, resources, staffing, and equipment. The 

Regional Administrator works with the state to 

resolve any inadequacies identified in this 

review.

Qualifying exercise: In addition to submitting 

plans/procedures for review, the state, together 

with all appropriate OROs, must demonstrate the 

ability to implement their plans/procedures by 

conducting at least one joint, full-participation 

exercise that includes participation by the 

licensee. After the exercise, the state must hold a 

public meeting in the vicinity of the plant to 

review the plans/procedures and exercise. Based

on a review of the plans/procedures, exercise, 

and public meeting, the Regional Administrator 

submits the plans/procedures and his or her 

evaluation to the Deputy Administrator of

PNPD. The Regional Administrator forwards 

materials including an evaluation of each 

Planning Standard set out in 44 CFR § 350.5, 

the results of any REP exercise(s), a summary of 

any deficiencies identified during the exercise(s) 

or public meeting(s), recommendations made to 

the state for improvements, and commitments 

made by the state for effecting improvements.

Approval: The Deputy Administrator of PNPD 

reviews the plans/procedures submitted by the 

Regional Administrator, with assistance from 

the Federal Radiological Preparedness 

Coordinating Committee (FRPCC) and other 

FEMA offices. The Deputy Administrator of 

PNPD approves the plans/procedures if he or she 

determines they provide reasonable assurance 

and are therefore adequate, and that OROs are 

capable of implementing them. FEMA 

communicates approval or disapproval to the 

appropriate Governor, the NRC, and the 

appropriate Regional Administrator, and 

publishes the decision in the Federal Register.

Withdrawal of approval: If, at any time, the 

Deputy Administrator of PNPD determines that 
PART I: INTRODUCTION

REP Program Manual Page I-11 October 2011

the plans/procedures are no longer adequate or 

no longer capable of implementation, he or she 

advises the Governor of the affected state, the 

appropriate Regional Administrator, and the 

NRC. The Deputy Administrator of PNPD must 

spell out in detail the reasons for this 

determination. The state then has 120 days to 

either correct the Deficiencies noted or submit 

an acceptable plan for correcting them. If a plan 

for correcting Deficiencies is submitted, the 

Deputy Administrator of PNPD negotiates with 

the state regarding the schedule for 

implementing the corrective action plan. If state

does not correct the Deficiencies and does not 

submit an acceptable plan after 120 days, or if 

the state submits an acceptable plan but failed to 

correct the Deficiencies by the agreed-upon date, 

the Deputy Administrator of PNPD may 

withdraw FEMA approval of the 

plans/procedures and proceed to notify the 

appropriate Governor, the NRC, and the 

appropriate Regional Administrator.

3. ALTERNATIVE APPROACHES AND

METHODS

The Evaluation Criteria listed in NUREG0654/FEMA-REP-1, as clarified, interpreted, 

and applied by the NRC, FEMA, and other 

Federal agencies, represent Federally-approved 

approaches for meeting the intent of the 

regulatory Planning Standards outlined in 44 

CFR § 350.5 and 10 CFR § 50.47. OROs may 

propose alternative approaches to meeting those 

standards in writing to the appropriate FEMA 

Regional Office. The FEMA Regional Offices 

will review the alternative approaches and 

forward their recommendations on such 

proposals to FEMA Headquarters for review and 

approval. FEMA will coordinate the review of 

proposals with RAC members and their 

agencies‘ headquarters staff when the issues 

presented involve their agencies‘ areas of 

expertise and missions. FEMA will also 

coordinate with the NRC and licensees when 

offsite planning and preparedness issues affect 

onsite planning and preparedness. When 

appropriate, OROS demonstrate proposed 

alternative approaches during an exercise. 

FEMA will then approve successfully performed 

alternative approaches. Once approved, the 

OROs integrate the alternative approaches into 

their radiological emergency response 

plans/procedures.

4. FEDERAL DELEGATION OF TASKS

44 CFR Part 351 delineates the responsibilities 

of supporting Federal departments and agencies 

and assigns tasks for providing Federal 

assistance in radiological emergency planning 

and preparedness on the basis of each agency‘s 

mission, role, and expertise. The regulation 

establishes the FRPCC and the RACs and 

delineates their functions. 

The FRPCC consists of FEMA, NRC, 

Environmental Protection Agency (EPA), 

Department of Health and Human Services 

(HHS), Department of Energy (DOE), 

Department of Transportation (DOT), 

Department of Defense (DOD), United States 

Department of Agriculture (USDA), Department 

of Commerce (DOC), and other Federal 

departments where appropriate and on an ad hoc 

basis. FRPCC functions include: 

 Assist FEMA in providing policy direction 

for the REP Program and other Federal 

assistance to OROs in their radiological 

emergency planning and preparedness 

activities;

 Establish subcommittees to aid in carrying 

out its functions (e.g., research, training, 

emergency instrumentation, transportation, 

information, education, and Federal 

response);

 Assist FEMA in resolving issues related to 

granting final FEMA approval of state or 

tribal plans/procedures; and

 Coordinate research and study efforts of its 

member agencies related to ORO 

radiological emergency preparedness to 

assure minimum duplication and maximum 

benefits to OROs.

The RACs convene in every FEMA Region. A

FEMA Regional representative chairs the RAC. 

Other departments and agencies represented on 

the RACs include the NRC, EPA, HHS, DOE, 

DOT, USDA, DOC and other departments and 
PART I: INTRODUCTION

REP Program Manual Page I-12 October 2011

agencies as appropriate. The RACs assist ORO 

officials in developing and reviewing their 

plans/procedures and observe exercises to 

evaluate the plans‘ adequacy. 

Additional information on Federal agency roles 

and responsibilities in responding to radiological 

incidents appears in the Nuclear/Radiological 

Incident Annex of the NRF.15

5. PLANNING AND PREPAREDNESS

ASSESSMENT STRATEGY

Significant plan changes: After FEMA‘s initial 

determination of reasonable assurance, it 

continues to monitor preparedness at each site. 

FEMA must receive any significant change to 

previously approved plans/procedures for review 

and approval. A significant change is one 

involving the evaluation and assessment of a 

Planning Standard or a matter which, if 

presented with the plan, would require 

consideration by the Deputy Administrator of 

PNPD (or designee) in order to decide that ORO 

plans/procedures and preparedness are 1) 

adequate to protect the health and safety of the 

public living in vicinity of the commercial NPP 

by providing reasonable assurance that OROs 

can take appropriate protective measures in the 

event of a radiological emergency; and 2) 

capable of being implemented. However, the 

Regional Administrator may determine that 

certain procedures, such as holding a public 

meeting or a complete exercise, are unnecessary 

when reviewing these changes. In this case, the 

existing approval remains in effect during 

review of the change. OROs review plans 

annually to ensure that all information is current, 

regardless of whether any changes require 

approval.

 

15 June 2008. See 

http://www.fema.gov/pdf/emergency/nrf/nrp_nuclearradiological

incidentannex.pdf

Periodic requirements: In addition to 

approving significant changes, FEMA employs 

an assessment strategy to ensure maintenance of 

reasonable assurance. This strategy includes

biennial evaluation of specified exercises and 

drills, assistance visits, the annual plan review, 

and an annual letter from the state to FEMA 

certifying the completion of other elements 

required by NUREG-0654/FEMA-REP-1 such 

as training and the updating of public emergency 

information. 

Ongoing assessment: FEMA supplements these 

―snapshot‖ assessments with the evaluation and 

observation of ongoing activities including fullscale, functional, and tabletop exercises; other 

types of drills; seminars; training activities; 

interviews; and responses to actual events. In 

addition, FEMA employs a dedicated Site 

Specialist for each NPP, whose responsibilities 

include maintaining an ongoing assessment 

record that reflects the status of offsite 

preparedness and training. This approach allows 

FEMA to maintain a more up-to-the-minute 

assessment of reasonable assurance throughout 

the year and provide increased integration with 

other Federal, state, and local preparedness 

activities. 

The HSEEP methodology supports the use of a 

variety of activities to assess response 

capabilities. HSEEP also facilitates activity 

planning and scheduling coordination. Part III of 

this Manual discusses the HSEEP methodology 

in detail as it applies to the REP Program.
PART I: INTRODUCTION

REP Program Manual Page I-13 October 2011

E. TECHNICAL BASIS FOR THE REP PROGRAM

This section presents a brief overview of the 

science, pathways of exposure, and biological 

effects of radiation, as well as the protective 

actions used to minimize exposure. This section 

serves only as a basic introduction to the topics 

of radiation and nuclear science.

1. NATURE OF THE HAZARD

Radiation is any form of energy that travels 

through space or matter. As the radiation travels 

through matter, it deposits its energy in that 

matter. The radiation emitted by many 

radioactive isotopes contains enough energy to 

change the physical state of the material through 

which it passes. This causes the atoms of that 

material to become electrically charged, or 

ionized. The ―exposure,‖ expressed in the unit 

Roentgen (R)16, is the amount of ionization 

produced by x- or gamma rays as they travel 

through air. 

If the radiation deposits its energy in human 

tissue, the resulting ionized atoms may damage 

human cells. The quantity of radiation or energy 

absorbed is the ―dose‖ and is expressed in 

Roentgen-absorbed-dose (rad). For a person, the 

dose is usually given in units of Roentgenequivalent-man (rem) and includes the 

biological effect of the radiation received (rem = 

rad x radiation weighting factor17). 

If an accidental airborne release of radioactive 

material occurs from an NPP, three main 

pathways exist for a person to receive a radiation 

dose during the release period: 

 External exposure to the released plume;

 

16 Some countries use the Standard International Units of Coulomb 

per kilogram (C/kg) instead of R (1 C/kg = 3876 R); Gray (Gy) 

instead of rad (1 Gray = 100 rad); and Sievert (Sv) instead of rem 

(1 Sv = 100 rem).

17 Radiation weighting factor is the factor by which the absorbed 

dose (rad) must be multiplied to obtain a quantity that expresses, 

on a common scale for all ionizing radiation, the biological 

damage (rem Sievert) to the exposed tissue. It is used because 

some types of radiation, such as alpha particles, are more 

biologically damaging to live tissue than other types of radiation 

when the absorbed dose from both is equal.

 External exposure from any radioactive 

material deposited on the ground from the 

plume; and

 Inhalation of radioactive material from the 

plume.

After the release stops and the plume dissipates, 

external exposure from deposited materials and 

ingestion of materials through the food chain

represent the main pathways for a person to 

receive a radiation dose. Another possible source 

of exposure would be from inhalation of 

materials if the ground deposition is resuspended into the air.

The following three basic types of ionizing 

radiation could pose a radiological hazard during 

an unexpected release at an NPP: 

 Alpha radiation is a positively charged 

particle emitted from the unstable nucleus 

of a radioactive isotope when the neutronto-proton ratio in the nucleus is too low. 

Alpha particles are highly ionizing, but the 

particles travel short distances in air (4 

centimeters) before being absorbed. Alpha 

particles have a very low ability to penetrate 

objects; a few sheets of paper or the outer 

layers of skin can stop them. The external 

hazard from alpha particles is minimal, 

while the internal hazard, when they are 

inhaled or absorbed, may be significant.

 Beta radiation is a negatively charged 

particle emitted from the unstable nucleus 

of a beta-unstable radioactive atom. Beta 

particles usually travel greater distances in 

Exposure vs. Contamination

It is important to distinguish between direct 

exposure to radiation and exposure through 

radiological contamination. A person exposed 

to a medical X-ray receives direct radiation, 

but the body is not radioactively 

contaminated. Radioactive contamination 

occurs when radioactive particles are 

deposited on a person’s skin and can be 

absorbed through the skin or by inhalation or 

ingestion.
PART I: INTRODUCTION

REP Program Manual Page I-14 October 2011

air than alpha particles (about 2 meters) 

before being absorbed. Beta particles are 

more penetrating than alpha particles – they 

can pass through an inch of water or human 

tissue – but a thin sheet of aluminum can 

stop them. Depending on the radionuclide, 

beta particles may pose an external 

radiation hazard, such as skin burns.

 Gamma radiation is electromagnetic 

radiation emitted from the nucleus of a 

radionuclide. It travels a greater distance in 

air than alpha or beta particles before being 

absorbed. Gamma-ray radiation is similar to 

X-rays; dense shielding material, such as 

lead, is needed to absorb it. Gamma-ray 

radiation is the most common external 

radiation hazard encountered in a radiation 

incident. Because of their high penetrating 

power, high-energy gamma rays can 

irradiate the entire human body almost 

uniformly, and they pose a serious external 

and internal hazard. 

Excessive exposure of the whole body (or large 

part) to ionizing radiation causes the complex of 

symptoms characterizing the disease known as 

radiation injury. The earliest of these symptoms 

are nausea, fatigue, vomiting, and diarrhea, 

which may be followed by loss of hair 

(epilation) hemorrhage, inflammation of the 

mouth and throat, and general loss of energy. In 

severe cases, where the radiation exposure has 

been relatively large, death may occur within 2 

to 4 weeks. Those who survive 6 weeks after the 

receipt of a single large dose of radiation may 

generally be expected to recover.

These considerations form the basis of

emergency planning, along with actions

implemented to protect the health and safety of

the public after a radiological release.

2. PROTECTIVE ACTIONS TO REDUCE

EXPOSURE TO RADIATION

An ORO conducts protective actions in response 

to an incident or potential incident to prevent or 

minimize the projected radiation dose, when the 

benefits of the action are sufficient to offset any 

undesirable consequences. Each action seeks to 

implement one of the following radiation 

protection principles: decrease time of exposure, 

increase distance from the source, provide 

shielding from the plume, or limit ingestion of 

contaminated foodstuffs. 

Exhibit I-1: Probable Early Effects of Acute 

Radiation

The protective actions that offsite authorities 

may implement include the following:

 Evacuating from areas of projected plume 

passage;

 Sheltering in homes or other structures;

 Controlling access to areas near the NPP;

 Administering potassium iodide (KI) to 

emergency workers, populations who cannot 

be evacuated, and, where included in the 

emergency plans/procedures, the general 

public;

 Controlling surface contamination;

 Placing livestock on stored feed and 

protected water;

 Quarantining or excluding foodstuffs from 

consumption; and

 Relocating populations from areas where 

radiation levels exceed the relocation 

protective action guide (PAG).

The appropriate protective action will depend on 

a number of factors, including projected 

beginning of the radiological release, projected 

duration of the release, composition and 

direction of the release, weather conditions, and 

Whole Body Doses

Acute 

Doses Probable Effect

0 to 25 R No obvious injury

25 to 50 R Possible blood changes, but no 

serious injury

50 to 100 R Blood cell changes, some injury, 

no disability

100 to 200 R Injury, possible disability

200 to 400 R Injury and disability certain, death 

possible

400 R Fatal to 50%

600 R or 

more 

Fatal
PART I: INTRODUCTION

REP Program Manual Page I-15 October 2011

time of day (e.g., day versus night). All 

protective actions have the common goal of 

preventing or minimizing exposure of the public 

to radiation

3. PROTECTIVE ACTION GUIDES

In an unexpected release of radioactive material, 

the licensee calculates a projected dose to 

estimate the potential level of exposure an 

individual would receive if no protective actions 

were taken. This future dose is determined for a 

specific period of time, using estimated or 

measured initial concentrations of radionuclides 

or exposure rates. A PAG is a number 

representing the projected dose to individuals 

that triggers the need for protective actions from 

a release of radioactive material. Decisionmakers compare estimates of projected dose 

with the appropriate PAG to determine what 

actions to take. 

A PAG does not imply an acceptable level of 

exposure risk; it is used only to minimize the 

risk from an incident that is occurring or has 

already occurred. The following criteria were 

used to establish PAGs:

 Avoid acute health effects;

 Keep the risk of delayed health effects 

within upper bounds that adequately protect 

public health and are reasonably achievable; 

and

 Ensure that the health risk from protective 

actions does not exceed the health risk from 

the dose that would be avoided.

a. General Public

Separate PAGs have been developed for the 

early (plume) and the intermediate (ingestion 

and relocation) phases of an incident. EPA 

recommends early (plume) phase PAGs of 1 to 5 

rem for evacuation (if possible) or sheltering (if 

evacuation is not possible); evacuation is usually 

initiated at 1 rem. EPA also established PAGs 

for administering KI based on projected doses to 

thyroid. These PAGs appear in the EPA 

guidance manual, Manual of Protective Action 

Guides and Protective Actions for Nuclear 

Incidents, EPA-400-R-92-001 (May 1992), cited 

herein as ―EPA-400-R-92-001.‖ The Food and 

Drug Administration (FDA) also established 

guidance for the use of KI in its Federal Register 

notice Guidance on Use of Potassium Iodide as 

a Thyroid Blocking Agent in Radiation 

Emergencies, December 11, 2001.

PAGs provide a threshold dose limit to assist 

decision-makers in determining whether 

protective actions need to be taken for food or 

used during the intermediate phase. HHS and the 

FDA developed ingestion PAGs of 0.5 rem 

projected dose limit for the whole body or a 5 

rem limit to the most exposed organ or tissue.18

If one of these thresholds is met, responsible 

officials take protective actions to prevent or 

reduce the concentration of radioactivity in food 

or animal feed or isolate any food containing 

radioactivity to prevent its introduction into 

commerce.

EPA also established an intermediate-phase 

relocation PAG19 of 2 rem whole body exposure 

in the first year. The long-term objectives are to 

keep doses at or below 0.5 rem for each 

subsequent year after the release, and the total 

dose at or below 5 rem over 50 years. The 

relocation PAG addresses direct exposure to 

deposited radioactive materials and inhalation of 

re-suspended radioactive materials that were 

initially deposited on the ground or other 

surfaces. 

b. Emergency Workers

In addition to the PAGs, EPA established 

separate guidance on dose limits for emergency 

workers, as provided in EPA-400-R-92-001. The 

dose limits for emergency workers performing 

 

18 Guidance on Accidental Radioactive Contamination of Human 

Food and Animal Feeds, Recommendations for state and Local 

Agencies, 63 Fed. Reg. 43402 (August 13, 1998).

19 EPA-400-R-92-001, Manual of Protective Action Guides and 

Protective Actions for Nuclear Incidents, May 1992.

PAGs for the General Public

 Evacuation/sheltering:1-5 rem

 Ingestion: 0.5 rem projected whole body or 5 

rem to most exposed part 

 Relocation:2 rem whole body in first year
PART I: INTRODUCTION

REP Program Manual Page I-16 October 2011

emergency services are different from those for 

the general population, because they take into 

account all doses received during an emergency. 

The EPA-400 guides for emergency workers are 

shown in the box below. 

Radiological emergency response 

plans/procedures generally include the EPA 

limits. However, an organization may decide to 

adopt more restrictive administrative limits as a 

conservative measure or in special cases.

4. EMERGENCY PLANNING ZONES

The Emergency Planning Zone (EPZ) is the area 

surrounding an NPP for which plans/procedures 

exist to ensure that prompt and effective actions 

occur to protect the health and safety of the 

public in case of an incident at the NPP. FEMA 

recognizes two types of EPZs for planning 

purposes: the plume exposure pathway EPZ and 

the ingestion exposure pathway EPZ. Exhibit I-2 

summarizes the characteristics of these two 

types of EPZs. Each EPZ is a roughly circular 

area, with the NPP at the center. 

The EPZ sizes represent a technical judgment 

based on the type and quantity of hazardous 

materials present (source term) and the potential 

risks where detailed planning is needed to ensure 

adequate response to an emergency. An EPZ 

may include more than one state. ―Split‖ 

jurisdictions (i.e., part of the jurisdiction is 

included in the EPZ and part is not) also exist. In 

these cases, EPZ boundaries are determined 

based on consultation with all parties involved, 

including OROs, FEMA, and the NRC. In some 

cases, the entire jurisdiction is included in the 

EPZ.

The size of the plume exposure pathway EPZ,

about 10 miles in radius, is based on the

following considerations from NUREG0654/FEMA-REP-1:

 Projected doses from traditional design-basis

accidents/incidents would not exceed the

PAG levels outside the zone;

 Projected doses from most core damage

sequences would not exceed PAG levels

outside the zone;

 For the worst-case core damage sequences,

immediate life-threatening doses would

generally not occur outside the zone; and

 Detailed planning within approximately 10

miles would provide a substantial base for

expansion of response efforts to a larger

area, if necessary.

Exhibit I-2: EPZ Characteristics

The size of the ingestion exposure pathway EPZ,

about 50 miles in radius, including the 10-mile

radius plume exposure pathway EPZ, is based

on the following considerations:

Plume Exposure 

Pathway

Ingestion 

Exposure Pathway

Exposure 

Sources

 Whole-body 

external 

exposure to 

gamma radiation 

from the passing 

plume and from 

deposited 

material

 Thyroid exposure 

through 

inhalation from 

the passing 

plume

 Committed 

effective dose 

equivalent 

exposure to other 

critical organs 

through 

inhalation

 Ingestion of 

contaminated 

water or foods, 

such as milk, 

fresh 

vegetables, and 

aquatic 

foodstuffs, may 

result in 

increased risk of 

radiationinduced cancer 

to the thyroid, 

bone marrow, 

and other 

organs

Size Approximately 

10-mile radius

Approximately 50-

mile radius

PAGs for Emergency Workers

 A limit of 5 rem for any emergency activity.

 A limit of 10 rem for protecting valuable 

property (when a lower dose is not 

practicable).

 A limit of 25 rem for life-saving activities or 

protection of large populations (where a 

lower dose is not practicable).

 A dose greater than 25 rem for life-saving 

activities or protection of large populations 

when an emergency worker volunteers for 

the mission and is fully aware of the risks 

involved. 
PART I: INTRODUCTION

REP Program Manual Page I-17 October 2011

 The downwind range within which

contamination may potentially exceed the

PAGs is limited to about 50 miles from an

NPP because of wind shifts during the

release and travel periods;

 Atmospheric iodine (i.e., iodine suspended

in the atmosphere for long periods) may be

converted to chemical forms that do not

readily enter the ingestion pathway; and

 Much of the particulate material in a

radioactive plume would have been

deposited on the ground within about 50

miles from the NPP.

The likelihood of exceeding ingestion exposure

pathway PAG levels at 50 miles is comparable

to the likelihood of exceeding plume exposure

pathway PAG levels at 10 miles.

5. RADIOLOGICAL INCIDENT PHASES

An incident involving a radiological release

contains three general phases:

The early phase (also referred to as the plume 

or emergency phase) is the period at the 

beginning of a nuclear incident requiring 

immediate decisions for effective use of 

protective actions and must therefore usually 

employ the status of the NPP and the prognosis 

for worsening conditions as their primary basis. 

When available, decision makers may use 

predictions of radiological conditions in the 

environment based on the condition of the 

source or actual environmental measurements. 

Precautionary actions may precede protective 

actions based on the PAGs. This phase lasts 

hours to several days and ends when the 

radioactive release ends.

The intermediate phase is the period beginning 

after the utility verifies the termination of the 

release. Decisions on additional protective 

actions may use reliable environmental 

measurements as a basis. This phase extends 

until the termination of these additional 

protective actions. This phase may overlap the 

late phase and may last from weeks to many 

months. The intermediate phase encompasses 

REP activities associated with both ingestion 

and relocation.

The late phase is the period beginning when 

recovery action designed to reduce radiation 

levels in the environment to acceptable levels for 

unrestricted use are commenced, and ending 

upon completion of all recovery actions. This 

period may extend from months to years. REP 

activities associated with return and recovery 

occur during the late phase.
PART I: INTRODUCTION

REP Program Manual Page I-18 October 2011

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PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-1 October 2011

Part II: REPPROGRAM PLANNING GUIDANCE

A. INTRODUCTION

1. PURPOSE AND SCOPE

This part of the REP Program Manual is the

primary source of guidance pertaining to

radiological emergency response planning. This

guidance is intended for use by OROs for

developing, reviewing, and revising radiological

emergency response plans/procedures in support

of the licensing and maintenance of a license for

commercial NPPs. It is also intended for use by

FEMA staff members responsible for evaluating

plans/procedures and by other Federal staff who

assist FEMA as members of the RACs.

FEMA has provided guidance to interpret,

clarify, and apply the Planning Standards and

Evaluation Criteria through this manual, FEMA

policy, and the FEMA-REP series documents.

This part of the REP Program Manual

consolidates all previously issued and current

FEMA REP Program planning guidance

developed by FEMA and other Federal

departments and agencies. However, it does not

include all the detailed and technical information

on Planning Standards contained in the

documents of the FEMA-REP series. For a list

of the FEMA-REP series guidance documents

and further detailed technical guidance, see

Appendix C.

2. CONTENTS AND ORGANIZATION

In addition to this introduction, this Part has four

major Subparts:

Subpart B, Planning Standards, is a one-page

listing of the 16 Planning Standards from 44

CFR Part 350, 10 CFR § 50.47, and NUREG0654/FEMA-REP-1.

Subpart C, Planning Guidance, lists the

Planning Standards and Evaluation Criteria per

NUREG-0654/FEMA-REP-1 and official

revisions as footnoted. Subpart C also provides

interpretation and application of the guidance,

including the following:

 A listing of Evaluation Criteria related to

each Planning Standard.

 An explanation of each Evaluation Criterion

based on current guidance.

 Checkmarks indicating to which

plans/procedures (i.e., licensee, state, or

local) each NUREG-0654/FEMA-REP-1

Evaluation Criterion is applicable.

NOTE: While the NRC is responsible for

Evaluation Criteria specific to the activities of

nuclear utility licensees (e.g., B.1), these criteria

have been included in the REP Program Manual

to maintain continuity with the Planning

Standards as set forth in 44 CFR Part 350, 10

CFR § 50.47, and NUREG-0654/FEMA-REP-1.

Although there is no requirement for OROs to

demonstrate these activities, it is important that

they understand the onsite organization‘s

structure and responsibility. Although many

Evaluation Criteria are applicable to the licensee

as well as OROs, the explanation provided by

FEMA in this guidance is intended only for use

by and applies only to OROs.

Subpart D, Conducting Plan Reviews, briefly

describes FEMA‘s process for conducting its

review of offsite REP plans/procedures under 44

CFR Part 350.

Subpart E, Annual Letter of Certification,

briefly describes the annual reporting process

and the minimum documentation included with

the ALC.

The guidance in this manual applies only to 

offsite response organizations.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-2 October 2011

B. PLANNING STANDARDS

Planning Standard A – Assignment of Responsibility (Organization Control)

Planning Standard B – On-site Emergency Organization

Planning Standard C – Emergency Response Support and Resources

Planning Standard D – Emergency Classification System

Planning Standard E – Notification Methods and Procedures

Planning Standard F – Emergency Communications

Planning Standard G – Public Education and Information

Planning Standard H – Emergency Facilities and Equipment

Planning Standard I – Accident Assessment

Planning Standard J – Protective Response

Planning Standard K – Radiological Exposure Control

Planning Standard L – Medical and Public Health Support

Planning Standard M – Recovery and Reentry Planning and Post-Accident Operations

Planning Standard N – Exercises and Drills

Planning Standard O – Radiological Emergency Response Training

Planning Standard P – Responsibility for the Planning Effort: Development, Periodic Review,

and Distribution of Emergency Plans
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-3 October 2011

C. PLANNING GUIDANCE

1. PLANNING STANDARD A – ASSIGNMENT OF RESPONSIBILITY (ORGANIZATION

CONTROL)

Primary responsibilities for emergency response by the nuclear facility licensee and by

State and local organizations within the Emergency Planning Zones have been assigned,

the emergency responsibilities of the various supporting organizations have been

specifically established, and each principal response organization has staff to respond and

to augment its initial response on a continuous basis.

NUREG CRITERION A.1.a

Each plan shall identify the State, local, Federal, and private sector organizations

(including utilities), that are intended to be part of the overall response organization

for Emergency Planning Zones (See [NUREG-0654/FEMA-REP-1] Appendix 5).

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION A.1.a, ORO PLANS/PROCEDURES SHALL:

 Describe all Federal, state, local, tribal, and private-sector organizations comprising the overall ORO.

Tribal governments submit their own plans/procedures or may choose to be included as part of the state

plans/procedures within which the tribal land falls.

 Identify the principal response organizations.

EXPLANATION

Principal OROs: The plans/procedures document all Federal, state, local, tribal, and private-sector

organizations that comprise the overall response organization and the responsibilities each assumes. The

plans/procedures identify principal OROs (e.g., emergency management, fire/HAZMAT, law

enforcement) and nuclear facilities (the licensees) having lead roles in emergency planning, preparedness,

and response.

Support OROs: The plans/procedures also identify all other organizations having a supporting role to the

principal or lead organization(s) in emergency planning, preparedness, and response. This includes any

Federal departments and agencies (e.g., FEMA, the NRC, Federal Bureau of Investigation [FBI]) or

private-sector or volunteer organizations (e.g., American Red Cross, Radio Amateur Civil Emergency

Services) that have response or support roles.

NIMS: HSPD-5 requires Federal departments and agencies to make the adoption of NIMS by OROs a

condition for Federal preparedness assistance, through grants, contracts, and other activities. HSPD-5 and 

PKEMRA do not apply to private sector entities, such as NPP licensees. Licensees are encouraged, but

not required, to adopt NIMS. However, offsite response concepts (based on ORO plans/procedures)

should be coordinated with licensee plans/procedures to ensure effective response and communications

between the licensee and OROs. NRC regulations in 10 CFR § 50.47(b)(3) & (b)(6) require licensees to

ensure that their programs integrate with those of the OROs.

Although HSPD-5 does not require the adoption of NIMS for those OROs who do not seek Federal

preparedness assistance, the integration of NIMS/Incident Command System into ORO emergency

plans/procedures for NPPs will provide greater consistency across response jurisdictions and facilitate
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-4 October 2011

integration of response elements during an incident that affects a NPP (e.g., HAB incident or catastrophic

natural disaster). During such incidents, the OROs would establish Incident Command to facilitate the

coordination and subsequent response operations between multi-jurisdictional organizations (i.e., both

onsite and offsite organizations).

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION A.1.b

Each organization and suborganization having an operational role shall specify its

concept of operations and its relationship to the total effort.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION A.1.b, ORO PLANS/PROCEDURES SHALL:

 Specify the organization‘s role in an emergency.

 Specify how the organization will carry out its role in an emergency.

EXPLANATION

The plans/procedures describe exactly what the organization or sub-organization20 plans to do in a

radiological emergency, how this will be accomplished, and by whom. For those OROs that have adopted

NIMS, the concept of operations is consistent with the core set of doctrines, concepts, principles,

terminology and organizational processes of NIMS. The description of an organization‘s operation also

includes a discussion of how the organization contributes to the overall emergency response (e.g., how a

local ORO‘s plans/procedures relate to the state‘s plans/procedures).

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION A.1.c

Each plan shall illustrate these interrelationships in a block diagram.

Applicability and Cross Reference to Plans: Licensee X State X Local X

 

20 A sub-organization is defined as any organization (e.g., agency, department, office, or local jurisdiction) having a supporting role to the 

principal or lead organization(s) in emergency planning and preparedness. 
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-5 October 2011

TO MEET THE INTENT OF CRITERION A.1.c, ORO PLANS/PROCEDURES SHALL:

 Include an illustration of each organization and its relationship to the total emergency response effort.21

EXPLANATION

The block diagram indicates the functional area assignments of each response organization. For those

OROs that have adopted NIMS, an incident command structure has five major functional areas:

command, operations, planning, logistics, and finance/administration.

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION A.1.d

Each organization shall identify a specific individual by title who shall be in charge

of the emergency response.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION A.1.d, ORO PLANS/PROCEDURES SHALL:

 Identify a specific individual, by title/position, who is in charge of the emergency response.

 Specify who, by title/position, coordinates response activities under the authority of the person in

charge.

EXPLANATION

The plans/procedures identify the person in charge by title/position (i.e., who has the authority to direct

emergency response activities). The plans/procedures also include the chain of command for this

authority and how these individuals interact with incident command.

At the state level, the person in charge is typically the Governor; however, the Governor‘s designee (e.g.,

the state emergency management director) usually implements the emergency response. At the local level,

the person in charge of emergency operations is typically the highest elected official (e.g., mayor or

chairman of the county board of supervisors); however, this person usually delegates the operational

authority to a director or coordinator of emergency management.

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 

21 For a sample Incident Command System organization chart, see ICS Form 207, Organizational Chart. 

http://training.fema.gov/EMIWeb/IS/ICSResource/ICSResCntr_Forms.htm
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-6 October 2011

NUREG CRITERION A.1.e

Each organization shall provide for 24-hour per day emergency response, including

24-hour per day manning of communications links.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION A.1.e, ORO PLANS/PROCEDURES SHALL:

 Specify who, by title/position, is responsible for managing the communications center.

 Describe the procedures to provide for 24-hour emergency response.

 Specify where the 24-hour communications center is located.

 Refer to a personnel roster for maintaining 24-hour communication.

 Specify primary and backup means of notification.

EXPLANATION

The intent of this criterion is to ensure that organizations are capable of responding to an emergency and

maintaining communications capabilities on a 24-hour basis. Organizations document and describe their

procedures for activating their emergency response organization at any time and specify the individual, by

title/position, responsible for maintaining 24-hour communications.

In the plans/procedures, organizations specify the location of the communications center (e.g., warning

point or 911 center), describe the primary and backup means of notification, and identify the

individual(s), by title/position, or organization(s) responsible for this emergency response function.

Backup means of notification refers to whatever secondary communication systems are in place to

execute notification if the primary communication link fails. These could include, but are not limited to,

commercial telephones, fax, and emergency radio frequencies.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-7 October 2011

NUREG CRITERION A.2.a

Each organization shall specify the functions and responsibilities for major elements

and key individuals by title, of emergency response, including the following:

Command and Control, Alerting and Notification, Communications, Public

Information, Accident Assessment, Public Health and Sanitation, Social Services,

Fire and Rescue, Traffic Control, Emergency Medical Services, Law Enforcement,

Transportation, Protective Response (including authority to request Federal

assistance and to initiate other protective actions), and Radiological Exposure

Control. The description of these functions shall include a clear and concise

summary such as a table of primary and support responsibilities using the agency

as one axis, and the function as the other. (See Section B for licensee.)22

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION A.2.a, ORO PLANS/PROCEDURES SHALL:

 Identify key individuals, by title/position, who have emergency response roles.

 Describe the responsibilities by functional areas

 Include a matrix of these responsibilities by functional area that identifies organizations responsible for

primary and support roles. A sample matrix/table is shown in Exhibit II-1.

EXPLANATION

Both primary and support organizations describe their responsibilities and functions for major elements.

For those OROs that have adopted NIMS/Incident Command System, these descriptions identify who will

carry out the five Incident Command System functions.

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010

 

22 NUREG-0654/FEMA-REP-1, Revision 1, Section II. Planning Standards and Evaluation Criteria, Part B – Onsite Emergency Organization, 

October 1980.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-8 October 2011

Exhibit II-1: Sample Functional Responsibilities Matrix/Table

Agency

County 

Commissioners

Dispatch

Health District

County Emergency 

Management

Fire Services

City Police

County Sheriff’s 

Office

County Public Works

School Districts

Red Cross

EAS Radio

Communication 

Coordinator

City Officials

Public Information 

Officer

Incident Command System

Functional Area and Function

Command & 

Control

Command & Control P C A A

Alerting & Notification P S S S S

Communications S A P

Public Information C S P

Operations

Fire & Rescue P S S

Traffic Control S S P A

Emergency Medical 

Service P

Law Enforcement A P

Logistics

Public Health P S

Sanitation P A

Social Services C P A

Transportation C P

Mass Care Facility C S P

Evacuation P S C S S S S S

Planning

Radiological Exposure 

Control S P C S S S S

Public Education S S C S S S S S S P

Prevention & 

Preparedness S S P S S S S S S S

Protective Response 

Training S S S P S S S S S S S S S S

KEY: P = Primary Agency/Organization C = Coordinating Agency

S = Supporting Agency A = Alternate Agency
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-9 October 2011

NUREG CRITERION A.2.b

Each plan shall contain (by reference to specific acts, codes, or statutes) the legal

basis for such authorities.

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION A.2.b, ORO PLANS/PROCEDURES SHALL:

 Identify the legal authority to assign lead responsibility for emergency preparedness to a particular state

agency.

 Indicate who (e.g., the Governor) may declare a ―state of emergency‖ (or ―state of disaster

emergency‖) and what special powers may ensue.

 Identify the legal authority to delegate responsibility and authority for preparedness and response at the

local level.

 Identify any limitations on the authority of Letter of Agreement signatories.

EXPLANATION

The plans/procedures give the citation from the relevant state, local, or tribal statute(s).

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION A.3

Each plan shall include written agreements referring to the concept of operations

developed between Federal, State, and local agencies and other support

organizations having an emergency response role within the Emergency Planning

Zones. The agreements shall identify the emergency measures to be provided and

the mutually acceptable criteria for their implementation, and specify the

arrangements for exchange of information. These agreements may be provided in an

appendix to the plan, or the plan itself may contain descriptions of these matters and

a signature page in the plan may serve to verify the agreements. The signature page

format is appropriate for organizations where response functions are covered by

laws, regulations, or executive orders where separate written agreements are not

necessary.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION A.3, ORO PLANS/PROCEDURES SHALL:

 Identify assisting organizations and the type of assistance (capabilities and resources) they will provide.

 Specify for each organization identified whether the aid is covered under an inter-governmental mutual

assistance compact or whether a Letter of Agreement (LOA) is needed.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-10 October 2011

 Include LOAs by reference or in a suitable appendix.

 Include or reference applicable LOAs between the licensee and ORO including arrangements for

access to the NPP site, if appropriate.

 State that the LOAs include details on what services will be provided and how the agreements will be

activated.

 State that LOAs are reviewed annually to verify their validity. (See also Criterion P.4)

EXPLANATION

Types of support: Supporting an emergency response involves a variety of capabilities. Licensees and

OROs may establish agreements with government or private-sector providers to delineate the type of

support and assistance they can provide. Intergovernmental support is increasingly being secured through

mutual assistance compacts supported by legislation. However, for those support arrangements between

jurisdictions that are not covered by mutual assistance compacts, and for support arrangements with

private-sector entities, LOAs are needed.

Examples of assisting organizations include: OROs; the licensee; laboratories; transportation providers

(e.g., bus companies, ambulances); vendors providing resources or other commercial services (e.g., tow

trucks); and medical facilities (see Criterion L.1. for additional information on LOAs for medical

facilities).

LOA contents: ORO plans/procedures contain summaries of the capabilities and resources available

through support organizations. The LOA contents indicate what service(s) will be provided, what

organization will provide the service(s), and the point of contact. The agreements also state that OROs

ensure vehicle operators and/or other emergency response personnel receive radiological emergency

response training. The agreements state that the provider will supply the services as described for

emergencies and for training, drills, and exercises, as necessary. In addition, agreements identify the

location of the resources to be provided, the 24-hour points of contact for notification and mobilization,

and include the signatures of the parties authorized to execute the LOA, and the date. As appropriate,

agreements also refer to procedures for authorizing ORO responders to access the NPP site and other

areas affected by events.

LOA organization: The plans/procedures may incorporate the required LOAs by reference and catalog

them by title, type of agreement, and government level, including signatories and effective dates. If the

plans/procedures incorporate LOAs by reference, they include a signed cover sheet certifying the validity

of the materials referenced. OROs keep the actual LOA on file available for inspection by FEMA, or they

may include the LOAs in an appendix to the plans/procedures.

Annual review: Regardless of how the plans/procedures include the LOAs, states certify their current

status annually. LOAs either specify an expiration date or contain a statement that the agreement remains

in effect until canceled by one of the parties. OROs maintain a list of all LOAs and ask for new LOAs or

updated signatories if: (1) the LOA expires or (2) the authorities of the signatories are foreclosed by

reorganizations or statutory limitations. The state reports on existing or new LOAs in the ALC

submission with a statement that LOAs have been reviewed for accuracy and completeness of

information. (See Part IV, Annual Letter of Certification, for additional guidance on ALC reporting

requirements.) FEMA may also review LOAs during SAVs and/or plan reviews.

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-11 October 2011

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION A.4

Each principal organization shall be capable of continuous (24-hour) operations for a

protracted period. The individual in the principal organization who will be

responsible for assuring continuity of resources (technical, administrative, and

material) shall be specified by title.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION A.4, ORO PLANS/PROCEDURES SHALL:

 Identify key individuals, by title/position, who are responsible for ensuring continuity of resources in

support of 24 hour operations.

 Include a reference to a roster that identifies at least two shifts of key staff, as well as provisions for its

maintenance.

 Identify who is responsible, by title/position, for maintaining the roster and where the roster is located.

 Indicate the shift period (e.g., 8 or 12 hours), and specify that the outgoing staff will brief the incoming

staff on the status of the emergency and the response activities occurring.

 Describe the responsibilities by the functional areas listed above.

FEMA HIGHLY RECOMMENDS THAT PLANS/PROCEDURES:

 Describe responsibilities by the five Incident Command System functions.

EXPLANATION

Emergency response activities for a commercial NPP incident may last longer than one day. The

plans/procedures describe provisions for maintaining the following essential emergency functions around

the clock: communications, command and control of operations, alert and notification of the public,

accident/incident assessment, information dissemination for the public and media, radiological

monitoring, protective response, security, provision of transportation resources, and medical and public

health support. The plans/procedures contain the procedures that will ensure continuity of operations

throughout one or more change in emergency response personnel.

References

 National Incident Management System, December 2008

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-12 October 2011

2. PLANNING STANDARD B – ON-SITE EMERGENCY ORGANIZATION

On-shift facility licensee responsibilities for emergency response are unambiguously

defined; adequate staffing to provide initial facility accident response in key functional

areas is maintained at all times; timely augmentation of response capabilities is available;

and the interfaces among various onsite response activities and offsite support and

response activities are specified.

NOTE: Although there is no requirement for offsite organizations (i.e., OROs) to address this Planning

Standard, it is important that OROs understand the onsite response organization‘s structure and authority.

NUREG CRITERION B.1

Each Licensee shall specify the onsite emergency organization of plant staff

personnel for all shifts and its relation to the responsibilities and duties of the

normal staff complement.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION B.2

Each licensee shall designate an individual as emergency coordinator who shall be

on shift at all times and who shall have the authority and responsibility to

immediately and unilaterally initiate any emergency actions, including providing

protective action recommendations to authorities responsible for implementing

offsite emergency measures.

Applicability and Cross Reference to Plans: Licensee X State Local

NUREG CRITERION B.3

Each licensee shall identify a line of succession for the emergency coordinator

position and identify the specific conditions for higher level utility officials assuming

this function.

Applicability and Cross Reference to Plans: Licensee X State Local 
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REP Program Manual Page II-13 October 2011

NUREG CRITERION B.4

Each licensee shall establish the functional responsibilities assigned to the

emergency coordinator and shall clearly specify which responsibilities may not be

delegated to other elements of the emergency organization. Among the

responsibilities which may not be delegated shall be the decision to notify and to

recommend protective actions to authorities responsible for offsite emergency

measures.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION B.5

Each licensee shall specify the positions or title and major tasks to be performed by

the persons to be assigned to the functional areas of emergency activity. For

emergency situations, specific assignments shall be made for all shifts and for plant

staff members, both onsite and away from the site. These assignments shall cover

the emergency functions in Table B-1

23 entitled,“Minimum Staffing Requirements for

Nuclear Power Plant Emergencies.” The minimum on-shift staffing levels shall be as

indicated in Table B-1. The licensee must be able to augment on-shift capabilities

within a short period after declaration of an emergency. This capability shall be as

indicated in Table B-1. The implementation schedule for licensed operators, auxiliary

operators, and the shift technical advisor on shift shall be as specified in the July 31,

1980, letter to all power reactor licensees. Any deficiencies in the other staffing

requirements of Table B-1 must be capable of augmentation within 30 minutes by

September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION B.6

Each licensee shall specify the interfaces between and among the onsite functional

areas of emergency activity, licensee headquarters support, local service support,

and State and local government response organizations. This shall be illustrated in a

block diagram and shall include the onsite technical support center and the

operational support (assembly) center and the licensee’s Emergency Operations

Facility (EOF).

Applicability and Cross Reference to Plans: Licensee X State Local 

 

23 NUREG-0654/FEMA-REP-1, Revision 1, Table B-1, page 37, October 1980.
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REP Program Manual Page II-14 October 2011

NUREG CRITERION B.7

Each licensee shall specify the corporate management, administrative, and technical

support personnel who will augment the plant staff as specified in the table entitled

“Minimum Staffing Requirements for Nuclear Power Plant Emergencies,” (Table B-1)

and in the following areas:

a. logistics support for emergency personnel, e.g., transportation,

communications, temporary quarters, food and water, sanitary facilities in

the field, and special equipment and supplies procurement;

b. technical support for planning and reentry/recovery operations;

c. management level interface with governmental authorities; and

d. release of information to news media during an emergency (coordinated

with governmental authorities).

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION B.8

Each licensee shall specify the contractor and private organizations who may be

requested to provide technical assistance to and augmentation of the emergency

organization.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION B.9

Each licensee shall identify the services to be provided by local agencies for

handling emergencies, e.g., police, ambulance, medical, hospital, and fire-fighting

organizations shall be specified. The licensee shall provide for transportation and

treatment of injured personnel who may also be contaminated. Copies of the

arrangements and agreements reached with contractor, private, and local support

agencies shall be appended to the plan. The agreements shall delineate the

authorities, responsibilities, and limits on the actions of the contractor, private

organization, and local service support groups.

Applicability and Cross Reference to Plans: Licensee X State Local 
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REP Program Manual Page II-15 October 2011

3. PLANNING STANDARD C – EMERGENCY RESPONSE SUPPORT AND RESOURCES

Arrangements for requesting and effectively using assistance resources have been made,

arrangements to accommodate State and local staff at the licensee’s Emergency

Operations Facility have been made, and other organizations capable of augmenting the

planned response have been identified.

NUREG CRITERION C.1

The Federal government maintains in-depth capability to assist licensees, States,

and local governments through the National Response Framework.

24 Each State and

licensee shall make provisions for incorporating the Federal response capability into

its operation plan, including the following:

NUREG CRITERION C.1.a

Specific persons by title authorized to request Federal assistance; see A.1.d and

A.2.a.

Applicability and Cross Reference to Plans: Licensee X State X Local 

TO MEET THE INTENT OF CRITERION C.1.a, ORO PLANS/PROCEDURES SHALL:

 Identify, by title/position, the key officials authorized to request Federal assistance.

EXPLANATION

The key officials authorized to request Federal assistance may be at the state, local, or tribal level. The

Nuclear/Radiological Incident Annex of the NRF describes available Federal assistance.

References

 NUREG-1442/FEMA-REP -17, Revision 1, Emergency Response Resources Guide for Nuclear 

Power Plant Emergencies, July 1992.

 NUREG-0654/FEMA-REP-1, Revision 1, Addenda, dated March 2002.

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008

 National Response Framework, Mass Evacuation Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 

24 Per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 2002, the Federal Radiological Emergency Response Plan (FRERP) 

superseded the original reference to ―a Federal Radiological Monitoring and Assessment Plan, the former Radiological Assistance Plan 

(RAP), and the Interagency Radiological Assistance Plan (IRAP).‖ However, the FRERP has since been superseded by the National Response 

Framework.
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REP Program Manual Page II-16 October 2011

NUREG CRITERION C.1.b

Specific Federal resources expected, including expected times of arrival at specific

nuclear facility sites;

Applicability and Cross Reference to Plans: Licensee X State X Local 

TO MEET THE INTENT OF CRITERION C.1.b, ORO PLANS/PROCEDURES SHALL INCLUDE:

 A process for identifying potential shortfalls in resources.

 Information on and a list of resources that an ORO can expect to receive from the Federal government.

 An estimate of how long it will take those resources to arrive at the desired location.

EXPLANATION

The plans/procedures include an assessment of potential shortfalls in resources (e.g., equipment,

personnel, and facilities), indicate how those requirements can be met using outside resources,25 and

include an estimate of the expected time of arrival of Federal resources in order to provide a general

planning timeframe. Planning is one of the five Incident Command System functions and its role includes

the process of identifying resources that can be provided by Federal agencies.

References

 NUREG-1442/FEMA-REP-17, Revision 1, Emergency Response Resources Guide for Nuclear 

Power Plant Emergencies, July 1992.

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION C.1.c

Specific licensee, State, and local resources available to support the Federal

response, e.g., airfields, command posts, telephone lines, radio frequencies, and

telecommunications centers.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION C.1.c, ORO PLANS/PROCEDURES SHALL:

 Describe the facilities that may be made available to Federal response personnel.

 Identify the general geographical areas for the locations of these facilities and the unique features of the

area.

 Describe the interoperable communications plans/procedures, equipment, and protocols that may be

made available to Federal response personnel.

EXPLANATION

When Federal personnel arrive to assist the OROs in response to an incident, they need access to certain

resources, such as clearance into and use of airfields, telephones, and radio communications. In addition,

 

25 NUREG-1442, Rev. 1/FEMA-REP-17, Revision 1, Emergency Response Resources Guide for Nuclear Power Plant Emergencies, 1, July 

1992, is a good resource for this.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-17 October 2011

arriving outside Federal personnel need local personnel to provide information on and assistance with the

unique features of the area.

References

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION C.2.a

Each principal offsite organization may dispatch representatives to the licensee’s

Emergency Operations Facility. (State technical analysis representatives at the EOF

are preferred.)

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION C.2.a, ORO PLANS/PROCEDURES SHALL:

 Indicate whether the ORO plans to send a representative to the licensee‘s emergency operations facility

and if so, which person, by title/position, would be dispatched.

EXPLANATION

During an incident, OROs may send personnel to the licensee‘s emergency operations facility to act as

liaisons. Typically, these are technical liaisons to coordinate/communicate dose assessment and field

monitoring activities with licensee personnel.

References

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION C.2.b

The licensee shall prepare for the dispatch of a representative to principal offsite

governmental emergency operations centers.

Applicability and Cross Reference to Plans: Licensee X State Local 
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REP Program Manual Page II-18 October 2011

NUREG CRITERION C.3

Each organization shall identify radiological laboratories, their general capabilities,

and expected availability to provide radiological monitoring and analyses services

which can be used in an emergency.

Applicability and Cross Reference to Plans: Licensee X State X Local 

TO MEET THE INTENT OF CRITERION C.3, ORO PLANS/PROCEDURES SHALL:

 List the laboratories that are qualified to analyze samples of materials that may have been contaminated

with radionuclides.

 Indicate the radiochemical and analytical capabilities of each laboratory (e.g., the ability to analyze

milk and other foodstuffs, soil samples, and water samples).

 Indicate the number of samples the laboratories would be able to process in a given period.

 Include the location and potential availability of the laboratories.

EXPLANATION

OROs with responsibility for arranging laboratory services identify available laboratories and their

capabilities.

References

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION C.4

Each organization shall identify nuclear and other facilities, organizations, or

individuals that can be relied upon in an emergency to provide assistance. Such

assistance shall be identified and supported by appropriate letters of agreement.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION C.4, ORO PLANS/PROCEDURES SHALL:

 Meet the requirements specified in Criterion A.3.

EXPLANATION

See explanation for Criterion A.3.

References

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-19 October 2011

NUREG CRITERION C.5

The offsite response organization* shall identify liaison personnel to advise and assist State

and local officials during an actual emergency in implementing those portions of the offsite

plan where State and local response is identified.

Applicability and Cross Reference to Plans: Licensee X State Local 

*FEMA and the NRC developed this criterion as part of Supplement 1 to NUREG-0654/FEMA-REP-1,

Rev. 1 to address emergency preparedness when state, tribal and/or local governments decline to

participate in emergency planning. In this criterion only, ―offsite response organization‖ refers to ―utility 

offsite emergency response organization comprised of other participating voluntary and private 

organizations, and local, state and Federal governments engaging in the development of offsite 

emergency plans and preparedness for a nuclear power plant.‖ In such cases, these organizations develop, 

review, and evaluate offsite emergency plans/procedures and preparedness.

NUREG CRITERION C.6

Each organization shall make provisions to enable onsite response support from

OROs in a hostile action-based incident as needed.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION C.6, ORO PLANS/PROCEDURES SHALL:

 Include provisions to allow ORO law enforcement and other initial first responders prompt access to

the NPP site.

 Include provisions for coordination between in-bound response resources and evacuation efforts.

 Identify any mutual aid agreements for alternate personnel to supplement local resources (see also

Criterion A.3).

 Address radiological training requirements for the primary and alternate personnel, including just-intime training.

 Include procedures for activating qualified alternate personnel.

EXPLANATION

Functionally, licensees establish relationships with OROs to coordinate emergency response efforts in 

case they are needed. The scope of ORO support includes the implementation of ORO radiological 

response plans to protect public health and safety in the event of a severe reactor accident and to provide 

fire, medical, and local law enforcement support to the NPP site. The NRC inspects and FEMA evaluates 

those relationships and their coordinated response in REP exercises.

An HAB incident involving an NPP, however, could place multiple simultaneous demands on ORO

response that need to be considered in radiological plans/procedures.

Coordination between Licensee and OROs: OROs and licensees work together to

coordinate/communicate and update emergency plans/procedures as needed to provide prompt access to

the NPP site for in-bound first responders. Licensee agreements with OROs (e.g., MOUs or LOAs) are

updated to reference the arrangements for access to the NPP site, including during HAB incidents.
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REP Program Manual Page II-20 October 2011

In addition, ORO plans/procedures include provisions to ensure that inbound response resources do not

become an impediment to evacuation and vice versa. This could include altering evacuation efforts. ORO

plans/procedures also include provisions for removal of impediments to in-bound responders.

Alternate Resources: An HAB incident could take ORO

resources away from normally assigned radiological response

roles and responsibilities in the emergency plan and detract

from ORO emergency response capability if plans/procedures

do not address this contingency. For example, OROs may not

have sufficient personnel to support onsite law enforcement and

offsite alert and notification at the same time. 

Licensees and OROs work together to identify solutions that

will ensure timely implementation of emergency response

plans/procedures in the event that ORO resource demands are

unusually high. For example, an ORO may enter into mutual

aid agreements with neighboring jurisdictions and private sector

entities, including both for-profit and not-for-profit

organizations (sometimes called non-governmental

organizations), to identify alternate personnel to supplement local resources.

Rosters: ORO plans/procedures address timely activation of qualified alternate personnel through callout

rosters or other methods. The emergency action level and incident classification may indicate that the 

radiological incident includes HAB elements that would take ORO resources away from normally 

assigned radiological emergency response roles and responsibilities. In these cases, OROs activate

alternate personnel to supplement or backfill, as needed.

Training: The revised ORO plans/procedures address the training for primary and alternate personnel

necessary to ensure adequate response when alternate personnel must be mobilized. Radiological training

that would be necessary for some functions can be delivered through an online course or in the classroom

at a frequency determined in ORO plans/procedures. ORO plans/procedures also include provisions for

just-in-time training updates as the incident progresses. FEMA encourages participation in drills and

exercises to reinforce and to validate planning.

References

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

Evaluation Limited to REP 

Activities

REP exercises and drills are designed 

to test the capability of OROs to protect 

public health and safety through 

implementation of their radiological 

emergency response plans/procedures 

in simulated emergencies. FEMA’s REP 

Program does not evaluate security and 

law enforcement tactical response 

capabilities related to site security 

contingency plans/procedures. This 

ensures the confidentiality of sensitive 

security information.
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REP Program Manual Page II-21 October 2011

4. PLANNING STANDARD D – EMERGENCY CLASSIFICATION SYSTEM

A standard emergency classification and action level scheme, the bases of which include

facility system and effluent parameters, is in use by the nuclear facility licensee, and State

and local response plans call for reliance on information provided by the facility licensees

for determinations of minimum initial offsite response measures.

NUREG CRITERION D.1

An emergency classification and emergency action level scheme as set forth in

[NUREG-0654/FEMA-REP-1] Appendix 1 must be established by the licensee. The

specific instruments, parameters, or equipment status shall be shown for

establishing each emergency class in the in-plant emergency procedures. The plan

shall identify the parameter values and equipment status for each emergency class.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION D.2

The initiating conditions shall include the example conditions found in [NUREG0654/FEMA-REP-1]Appendix 1 and all postulated accidents in the Final Safety

Analysis Report (FSAR) for the nuclear facility.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION D.3

Each State and local organization shall establish an emergency classification and

emergency action level scheme consistent with that established by the facility

licensee.

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION D.3, ORO PLANS/PROCEDURES SHALL:

 Include reference to the standard Emergency Classification Levels (ECLs).

26

 Acknowledge that the ECL system will form the basis for determining the level of response to a

nuclear incident that will be consistent with the licensee.

EXPLANATION

Plans/procedures incorporate the ECL system used by the licensee. The purpose of the ECL system is to

classify the incident by level of severity to allow for greater levels of response as the seriousness of the

incident increases. The four ECLs are Notification of Unusual Event, Alert, Site Area Emergency, and

General Emergency.

 

26 NUREG-0654/FEMA-REP-1, Revision 1, Appendix 1 – Emergency Action Levels Guidelines for Nuclear Power Plants, October 1980 refers 

to Emergency Action Levels (EALs) rather than ECLs. Since publication of NUREG-0654, EALs have come to be considered in-plant

conditions that trigger declaration of various levels of emergencies. These levels of emergencies (NOUE, Alert, SAE, and GE) are referred to as 

ECLs.
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REP Program Manual Page II-22 October 2011

References

 NUREG-0654/FEMA-REP-1, Revision 1, Appendix 1 – Emergency Action Level Guides for Nuclear

Power Plants, 1980, as modified by Emergency Planning and Preparedness for Nuclear Power

Reactors, NRC Regulatory Guide 1.101, Revision 3, August 1992.

NUREG CRITERION D.4

Each State and local organization should have procedures in place that provide for

emergency actions to be taken which are consistent with the emergency actions

recommended by the nuclear facility licensee, taking into account local offsite

conditions that exist at the time of the emergency.

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION D.4, ORO PLANS/PROCEDURES SHALL:

 Indicate the emergency actions to be taken to protect the public at each ECL, given the local conditions

at the time of the emergency.

EXPLANATION

Appendix 1 to NUREG-0654/FEMA-REP-1 describes each ECL, its purpose, example initiating

conditions, and actions to be taken by the licensee and OROs. 27 For OROs, these are the minimum actions

taken at the time of the incident, after consideration is given to other factors (e.g., weather, road

conditions, and threats). Planners should be aware that guidance on preferred protective actions in a 

severe accident continues to evolve. For a General Emergency, Appendix 1 of NUREG-0654/FEMAREP-1 recommends sheltering within a 2-mile radius and 5 miles downwind. However, updated FEMA 

and NRC guidance in NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Guidance for Protective 

Action Strategies (October 2011) provides a protective action logic development tool that should be used 

by licensees to develop site specific protective action recommendation procedures and is recommended 

for use by OROs to develop protective action strategy guidance for decision makers.

References

 NUREG-0654/FEMA-REP-1, Revision 1, Appendix 1 – Emergency Action Level Guides for Nuclear

Power Plants, 1980, as modified by Emergency Planning and Preparedness for Nuclear Power

Reactors, NRC Regulatory Guide 1.101, Revision 3, August 1992.

 NUMARC/NESP-007, Revision 2 – Methodology for Development of Emergency Action Levels,

January 1992.

 NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants –

Guidance for Protective Action Strategies, October 2011.

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 

27 NUMARC/NESP-007, Revision 2, The Methodology for Development of Emergency Action Levels, January 1992, is considered an acceptable 

alternative to the method described in NUREG-0654/FEMA-REP-1, Revision 1, Appendix 1 – Emergency Action Levels Guidelines for 

Nuclear Power Plants. See also Nuclear Energy Institute (NEI) 99-01, Rev. 5, Methodology for Development of Emergency Action Levels.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-23 October 2011

5. PLANNING STANDARD E – NOTIFICATION METHODS AND PROCEDURES

Procedures have been established for notification by the licensee of State and local

response organizations and for notification of emergency personnel by all response

organizations; the content of initial and follow-up messages to response organizations and

the public has been established; and means to provide early notification and clear

instruction to the populace within the plume exposure pathway Emergency Planning Zone

have been established.

NUREG CRITERION E.1

Each organization shall establish procedures that describe mutually agreeable

bases for notification of response organizations consistent with the emergency

classification and action level scheme set forth in [NUREG-0654/FEMA-REP-1]

Appendix 1. These procedures shall include means for verification of messages. The

specific details of verification need not be included in the plan.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION E.1, ORO PLANS/PROCEDURES SHALL DOCUMENT THE

FOLLOWING NOTIFICATION PROCESSES:

 Initial notification from the licensee to a designated offsite 24-hour warning point (e.g., fire or police

department dispatch, 911 emergency center). Offsite plans/procedures indicate the location of the

warning point and the method of notification and backup (e.g., commercial telephone, dedicated

telephone, fax machine, or pager). If the initial notification from the licensee to the warning point is

over a non-secure system, the criterion requires message verification (e.g., via a return call). If the

primary means of notification from the licensee to the warning point is on a dedicated system (i.e., one

capable of being used only by a known, limited number of organizations), OROs may choose whether

to verify receipt of notification.

 Initial notification to licensee and the ORO when a notification originates from an entity other than the

licensee. The plans/procedures identify the points of contact for the licensee and ORO, method of

notification and backup, and method of verifying notification.

 Subsequent notifications from the licensee and/or ORO to other offsite organizations. The

plans/procedures may call for subsequent notifications to locations other than the warning point or

other designated entities. For example, after the EOC is operational, the plans/procedures may state

that all further notifications are made directly to the EOC rather than to the warning point.

EXPLANATION

Notification protocols: OROs have clear and consistent means for providing emergency notification to

all responding organizations. Notification of an emergency generally originates with the licensee and then

―fans out‖ to OROs, who then notify their component agencies and support organizations. Governmental

units may also be responsible for notifying one another (e.g., the licensee notifies the state, who notifies

the local governments; or a risk county notifies its host/support county).

Regulations in 10 CFR Part 50, Appendix E, Section IV.D.3 specify that a licensee is required to have the

capability to notify OROs within 15 minutes after declaring an emergency under the licensee‘s emergency

plans/procedures. Licensees make this notification to designated ORO initial warning points. The warning

points initiate the chain of notification to all appropriate agencies, as set forth in their notification
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-24 October 2011

protocols. The notification chain may include dedicated systems. In an HAB incident, a licensee notifies

OROs in accordance with onsite plans/procedures, irrespective of emergency classification level.

The criterion states that notification of response organizations shall be consistent with NUREG0654/FEMA-REP-1, Appendix 1 – Emergency Action Levels Guidelines for Nuclear Power Plants. This 

means that notification information includes the appropriate ECL and the plans/procedures indicate the 

person(s) by title/position who is notified at each ECL.

Information included in the notification from the licensee to the offsite 24-hour warning point is usually 

recorded on a notification form. The plans/procedures contain a copy of this form, if applicable.

Considerations for HAB incidents: During an HAB incident, these notifications may not follow

standard licensee-to-ORO methods. For example, local law enforcement agency points of contact may be

notified by the licensee‘s site security organization of an imminent or actual hostile action against the

NPP site prior to the declaration of an emergency by the licensee. In addition, OROs may receive ―preincident‖ information from various external sources (e.g., intelligence sources, airports, state/Federal law

enforcement agencies), rather than receiving initial notification from the utility. Plans/procedures include

methods for ORO notification to the licensee.

The licensee notification pathways (to initial warning points and to local law enforcement agencies) serve

different and distinct purposes and may not occur in parallel based on progression of the HAB incident. In

addition, licensee notifications to local law enforcement may include sensitive information. ORO 

plans/procedures address the challenge of ensuring that all appropriate parties required to take immediate 

action are included when notification through multiple pathways occurs. If local law enforcement 

agencies receive initial notification or the utility‘s initial response to an HAB incident at the NPP is direct

interaction with local law enforcement, this could result in inadvertent delays or bypassed notifications to

emergency management agencies and state/local warning points, especially if the incident is resolved

before any assistance is requested beyond local law enforcement agencies.

To prepare for HAB incidents, OROs ensure that emergency response plans/procedures include a

notification process that works in all directions (not just from the utility/licensee to NRC and OROs).

OROs develop procedures for verifying the information and initiating notifications from alternate entities

(e.g., the Joint Terrorism Task Force, Fusion Centers, 911, emergency management agencies, local law 

enforcement agencies). If law enforcement responds to an HAB incident that has the potential to impact

an NPP, plans/procedures include provisions to notify the site and the appropriate emergency

management agencies.

References

 NUREG-0654/FEMA-REP-1, Revision 1, Appendix 1 – Emergency Action Level Guides for Nuclear

Power Plants, 1980, as modified by Emergency Planning and Preparedness for Nuclear Power

Reactors, NRC Regulatory Guide 1.101, Revision 3, August 1992.

NUREG CRITERION E.2

Each organization shall establish procedures for alerting, notifying, and mobilizing

emergency response personnel.

Applicability and Cross Reference to Plans: Licensee X State X Local X
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-25 October 2011

TO MEET THE INTENT OF CRITERION E.2, ORO PLANS/PROCEDURES SHALL:

 Indicate who, by title/position, is responsible for notifying each staff member, either by including a

notification call list or making reference to such a list.

 Describe the process used to notify all applicable OROs once the 24-hour warning point, or other

designated entity, has received and verified the initial notification, if necessary.

 Describe who, by title/position, has the responsibility for notifying all appropriate organizations once

the initial notification to the 24-hour warning point has been made. For example, the responsibility of

the warning point for notifications may end after it places a call to the state and county emergency

management agencies. A diagram that shows how the notification process works (e.g., call-down) may

supplement a plan/procedure description.

 Indicate the specific notifications made at each ECL.

 Indicate the means by which notifications will be accomplished (e.g., pagers, telephones, radios, auto

dialers).

EXPLANATION

Offsite plans/procedures document the process by which the staff of appropriate response organizations

are alerted, notified, and mobilized to support the organizations‘ response roles.

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION E.3

The licensee, in conjunction with State and local organizations, shall establish the

contents of the initial emergency messages to be sent from the plant. These

measures shall contain information about the class of emergency, whether a release

is taking place, potentially affected population and areas, and whether protective

measures may be necessary.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION E.4

Each licensee shall make provisions for followup messages from the facility to

offsite authorities that shall contain the following information if it is known and

appropriate:

a. location of incident and name and telephone number (or communications

channel identification) of caller;

b. date/time of incident;

c. class of emergency;
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REP Program Manual Page II-26 October 2011

d. type of actual or projected release (airborne, waterborne, surface spill)

and estimated duration/impact times;

e. estimate of quantity of radioactive material released or being released and

the points and height of releases;

f. chemical and physical form of released material, including estimates of

the relative quantities and concentration of noble gases, iodines, and

particulates;

g. meteorological conditions at appropriate levels (wind speed, direction (to

and from), indicator of stability, precipitation, if any);

h. actual or projected dose rates at site boundary; projected integrated dose

at site boundary;

i. projected dose rates and integrated dose at the projected peak at 2, 5, and

10 miles, including sector(s) affected;

j. estimate of any surface radioactive contamination in the plant, onsite or

offsite;

k. licensee emergency response actions underway;

l. recommended emergency actions, including protective measures;

m. request for any needed onsite support by offsite organizations; and

n. prognosis for worsening or termination of event based on plant

information.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION E.5

State and local government organizations shall establish a system for disseminating

to the public appropriate information contained in initial and followup messages

received from the licensee, including the appropriate notification to appropriate

broadcast media, e.g., the Emergency Alert System (EAS.)28

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION E.5, ORO PLANS/PROCEDURES SHALL:

 List the broadcast stations and other systems (e.g., tone alert radios, route alerting) used to provide

emergency instructions to the public.

 Establish individual responsibilities for each broadcast station and system and document commitments

between them and the ORO (e.g., MOUs and/or LOAs) to honor these responsibilities in a radiological

emergency. (Also see Criterion A.3)

 Document or reference the broadcast stations‘ or systems‘ capability to participate in the public

notification process. A statement that the station participates in a ―Local Emergency Alert System

Operational Area Plan‖ is considered satisfactory.

 

28 Per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 2002, the Emergency Broadcast System was replaced by the Emergency Alert 

System by Report and Order 59 FR 67090, issued by the Federal Communications Commission on December 28, 1994.
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REP Program Manual Page II-27 October 2011

 Identify broadcast station and system points of contact, by title/position, who are accessible 24 hours a

day, 7 days a week. (Also see Criterion A.4)

 Establish the interval for broadcasting official information statements.

 Identify an alternate station, if a selected station does not have a backup power supply.

FEMA HIGHLY RECOMMENDS THAT PLANS/PROCEDURES:

 Establish protocols for broadcasting emergency instructions directly from an EOC through radio and

television stations, if this capability is available.

EXPLANATION

ORO plans/procedures describe the broadcast stations and other systems (e.g., tone alert radios, route

alerting) used to provide emergency instructions to the public. An acceptable system has the capability to

broadcast official information 24 hours a day, 7 days a week, notwithstanding adverse environmental

conditions, such as floods and power outages. Federal Communications Commission (FCC) regulations

require that Emergency Alert System (EAS) stations maintain 24-hour capability to interrupt broadcasts

regardless of whether they are broadcasting live or relaying programming.

To effectively notify the public, EAS repeat the EAS messages multiple times. Establishing set intervals

ensures maximum coverage. Plans/procedures address broadcast intervals, as well as the mechanism for

advising the EAS station to discontinue messages that no longer apply.

References

 FEMA-REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power 

Plants, November 1985.

 Federal Register, Volume 59, p. 67090, Federal Communications Commission Report and Order

replacing the Emergency Broadcast System (EBS) with the Emergency Alert System (EAS), December

28, 1994.

 NUREG-0654/FEMA-REP-1, Revision 1, Addenda, dated March 2002.

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, January

2008.

 National Response Framework, Public Affairs Support Annex, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION E.6

Each organization shall establish administrative and physical means, and the time

required for notifying and providing prompt instruction to the public within the

plume exposure pathway Emergency Planning Zone. (See [NUREG-0654/FEMA-REP1] Appendix 3) It shall be the licensee’s responsibility to demonstrate that such

means exist, regardless of who implements this requirement. It shall be the

responsibility of the State and local governments to activate such a system.

Applicability and Cross Reference to Plans: Licensee X State X Local X
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REP Program Manual Page II-28 October 2011

TO MEET THE INTENT OF CRITERION E.6, ORO PLANS/PROCEDURES SHALL:

 State that the alert and notification system (ANS) is capable of meeting the 15-minute design objective.

 Describe the primary and backup physical means of alert and notification, including the system(s) used

to alert and notify the general public, persons with disabilities and access/functional needs, and

exception areas, and their respective point(s) of activation.

 Describe the administrative means of alert and notification, including:

 The title of the organizations or individuals responsible for: (1) making the decision to activate

the ANS and (2) activating the system.

 The ANS activation procedures and time required to implement these procedures.

 A discussion of how the requirements for periodic siren testing will be accomplished.

EXPLANATION

This criterion addresses the means to alert and notify the public within the plume exposure pathway that

there is an incident at the NPP. ―Alert‖ refers to the process used to get the attention of the public.

―Notification‖ refers to the process used to supply detailed information and instructions following the

alert signal. The criterion covers both the administrative procedures and the physical means for alert and

notification of the public. The description of the physical means addresses the methods and equipment

incorporated for alerting the public. The administrative procedures describe the interaction of the various

organizations, as well as the responsibility of each organization involved in the alert and notification

sequence.

a. Design Objectives for Alert and Notification of the Public

NUREG-0654/FEMA-REP-1 Appendix 3 (as amended by Supplement 4), 44 CFR § 350.5(a), and

FEMA-REP-10 discuss ANS design objectives. The minimum acceptable design objectives for coverage

by an ANS – what the system must be able to do when speed is critical – include:

 The capability for: (1) providing an alert signal and

beginning an informational or instructional message to

the population in the 10-mile EPZ within 15 minutes and

(2) providing protective action recommendations

(PARs), if appropriate.

 The direct coverage of essentially 100 percent of the

population within 5 miles of the NPP site.

 The coverage of essentially 100 percent of the

population in the remaining areas of the plume exposure

EPZ (i.e., from 5 to 10 miles from the NPP) who may

not have received the initial notification (see the

―exception areas for primary alerting‖ discussion below).

This notification must occur within 45 minutes.

 A backup means of public alert and notification capable of covering essentially 100 percent of the

population in the plume exposure EPZ in the event the primary method is unavailable. The backup

means of alert and notification shall be conducted within a reasonable time, with a recommended goal

of 45 minutes (see the ―backup systems‖ discussion below).

Primary alert and notification: The ANS must be capable of providing alert signals and instructional

messages within 15 minutes to the entire 10-mile EPZ, including remote and low-population areas. The

requirements include alerting and notifying the transient population in remote rural areas, open water

Design Objectives Are for WorstCase Scenarios

The alert and notification system must be 

capable of meeting design objectives in the 

event of a rapidly-escalating incident. Even 

if the incident is not escalating rapidly, the 

initial notification of the affected populations 

within the plume exposure pathway EPZ 

must be completed in a manner consistent 

with assuring the public health and safety 

(i.e., in a timely manner and without undue 

delay).
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REP Program Manual Page II-29 October 2011

areas, rivers, hunting areas, recreational areas, and other low-population areas that may need special

alerting procedures.

Exceptions areas for primary alerting: In rural, low-population areas in the 10-mile EPZ that are

beyond 5 miles from the NPP, up to 45 minutes may be allowed for providing an alert signal and

instructional message to the permanent and transient populations. Such areas proposed for 45-minute alert

and notification status are called ―exception areas‖ and must be reviewed and approved by FEMA on a

case-by-case basis.

Backup systems: Supplement 4 to NUREG-0654/FEMA-REP-1 includes a new requirement for backup

ANSs. Backup means of alert and notification will differ from facility to facility. The backup means may 

be designed so that it can be implemented using a phased approach in which the populations most at risk 

(e.g., within 2 miles) are alerted and notified first, followed by alerting and notification of people in less 

immediately affected areas (e.g., 2 to 5 miles, followed by downwind 5 to 10 miles, and finally the

remaining population as directed by authorities). The backup method may have the additional capability 

of being employed only in the specific areas impacted when a portion of the primary ANS, such as a 

single siren or group of sirens within a community, fails and the extent of the affected area and population 

can be determined.

Topography, population density, existing ORO resources, and timing will be considered in judging the

acceptability of backup means of alert and notification. Although circumstances may not allow this for all

situations, FEMA and the NRC recommend that OROs and licensees attempt to establish backup means

that will reach those in the plume exposure EPZ within a reasonable time of receiving notice of failure of

the primary alert and notification system, with a recommended goal of 45 minutes.

Exhibit II-2: Design Objectives for Alert and Notification of the Public*

Design Objective: Within 15

minutes

Within 45

minutes

Within a

Reasonable

Time

Primary Alert and Notification

...covering essentially 100% of the 10-mile EPZ X

Primary Alert and Notification in Exception Areas

...covering FEMA-approved exception areas (rural,

low-population areas beyond 5 miles but less than 10

miles from the NPP)

X

Backup Alert and Notification

...covering the 10-mile EPZ X

* Demonstration standards for alert and notification of the public during evaluated REP exercises are discussed in Part III,

Assessment Area 5 – Emergency Notification and Public Information of this Manual.

b. Physical Means of Alert and Notification

Equipment: FEMA recognizes fixed sirens, route alerting, tone alert radios, and National Oceanic and 

Atmospheric Administration (NOAA) weather radio as approved primary and backup alert systems. The

EAS, NOAA weather radio, and route alerting are approved notification systems. OROs may submit

alternative systems for approval if they can document that the system meets the design objectives

specified above. OROs may use alternative systems that have not received FEMA approval concurrently

with approved systems to augment the alert and notification process.
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REP Program Manual Page II-30 October 2011

Route alerting: If route alerting is used, the plans/procedures describe the situations in which route

alerting would be used (primary, backup), methods of performance, travel routes, resource

coordination/allocation, public instructions issued, and the responsible personnel or organization(s).

Design report: Regardless of the physical means comprising the system, the licensee provides a design

report to FEMA describing the ANS. The design report contains sufficient information for FEMA to

conduct a review and make a determination as to its acceptability prior to activating the ANS for the

purposes of conducting a public telephone survey to satisfy the alert and notification requirements in 44

CFR § 350.9(a). 

Telephone survey: FEMA, in cooperation with the utility operator and/or state and local governments,

conducts telephone surveys immediately following activation of a newly developed and implemented

ANS, as described in Appendix 3 of NUREG-0654/FEMA-REP-1, prior to FEMA certification of the

ANS. At FEMA‘s discretion, a repeat telephone survey may be conducted as part of its review of any

―significant change‖ to an ANS. A ―significant change‖ involves a change in the method of primary

alerting used to alert the majority of the residents in an EPZ, or a change that calls into question the

validity of the telephone survey used to support the existing FEMA acceptance of the ANS.

A discussion of the physical means of public notification in OROs plans/procedures includes:

 A description of the primary alert system(s) used to provide an alert signal to the public (e.g., fixed

sirens, tone alert radios, route alerting), including systems for persons with disabilities and 

access/functional needs (e.g., telecommunication devices for the hearing-impaired). The description

also identifies any approved exception areas and the primary alert system(s) for those areas.

 A description of the backup alert system(s) used to provide an alert signal to the public in the event

of a partial or complete failure in the primary system. The backup system may be comprised of the

same types of systems approved for primary alerting, but is a redundant system.

 A description of the notification system(s) used to provide information and instructions to the public

once they have been alerted. These could include, but are not limited to, the EAS, NOAA weather

radio, special news broadcasts, etc.

c. Administrative Means of Alert and Notification

A description of the administrative procedures in OROs plans/procedures includes:

 The title of the organizations or individuals responsible for: (1) making the decision to activate the

ANS and (2) activating the system. The procedures also specify back-up organizations or individuals to

ensure timely notification and mobilization.

 The ANS activation procedures and an analysis of the time required to implement these procedures.

The discussion demonstrates that, once the designated official has made the decision to notify the

public of the status of the emergency and the possible need for protective actions, the 15-minute design

objective can be met if circumstances require it.

 The procedures and safeguards used to ensure that the appropriate officials send a legitimate and

clearly understood command to activate the ANS to the individuals responsible for physically

activating the system. The procedures and safeguards also ensure that these persons recognize,

understand, and take appropriate actions in response to such a command.

 A description of procedures and point(s) of activation for the: (1) system(s) to alert and notify the

general public, (2) system(s) to alert and notify persons with disabilities and access/functional needs

(e.g., telecommunication devices for the hearing impaired) and facilities for persons with disabilities 
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-31 October 2011

and access/functional needs, and (3) system(s) used to alert and notify transient populations (e.g.,

hunters, beach users, boaters).

 A discussion of how periodic siren testing will be accomplished. The types of tests and suggested

frequency are described in Appendix 3 to NUREG-0654/FEMA-REP-1. They include a silent test

every 2 weeks (log entry), a growl test quarterly and when preventive maintenance is performed, and a

complete cycle test at least annually.

The operability of a siren system is deemed acceptable when an average of 90 percent of the sirens is

functional in a given testing period. The licensee or the responsible ORO authority submits the results of

the siren system tests annually to the appropriate FEMA Region. This information may be submitted as

part of the ALC (see Part IV of this manual). The FEMA Region is responsible for reviewing the test

results to ensure that siren operability remains at or above 90 percent.29

References

 NUREG-0654/FEMA-REP-1, Revision 1, Appendix 3, Means for Providing Prompt Alerting and 

Notification of Response Organizations and the Population, October 1980.

 FEMA-REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power 

Plants, November 1985.

 FEMA GM AN-1, FEMA Action to Qualify Alert and Notification Systems Against NUREG0654/FEMA-REP-1 and FEMA-REP-10, Attachment 1, April 21, 1987.

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, January

2008.

 National Response Framework, Public Affairs Support Annex, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 NUREG-0654/FEMA-REP-1, Revision 1, Supplement 4, Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants –

Criteria for National Preparedness Initiative Integration, Exercise Enhancement, and Backup Alert 

and Notification Systems, 2011

 

29 Appendix 4 of FEMA-REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants, November 1985 

describes routine siren testing procedures and operability requirements.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-32 October 2011

NUREG CRITERION E.7

Each organization shall provide written messages intended for the public, consistent

with the licensee’s classification scheme. In particular, draft messages to the public

giving instructions with regard to specific protective actions to be taken by

occupants of affected areas shall be prepared and included as part of the State and

local plans. Such messages should include the appropriate aspects of sheltering, ad

hoc respiratory protection, e.g., handkerchief over mouth,30 thyroid blocking, or

evacuation. The role of the licensee is to provide supporting information for the

messages. For ad hoc respiratory protection see “Respiratory Protective Devices

Manual” American Industrial Hygiene Association, 1963, pp. 123-126.31

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION E.7, IF THE ORO COMPOSES MESSAGES FOR

DISTRIBUTION TO THE PUBLIC, PLANS/PROCEDURES SHALL INCLUDE AND/OR REFERENCE:

 EAS message templates that would be modified as necessary and sent to the EAS station(s) for

broadcast.

 Provisions for special news broadcasts as supplements to the EAS message.

 Provisions for foreign language translations of EAS messages and special news broadcasts, if required.

 The process for selecting, modifying, approving, and releasing messages.

 The methodology for EAS message re-broadcast, along with the frequency (how many times and at

what interval, such as every 15 minutes).

EXPLANATION

The first part of this criterion involves ensuring that the organization‘s plans/procedures include the

specified items. The second involves a review of EAS messages, if applicable to the organization

involved. When FEMA reviews the plans/procedures, the ORO provides a complete set of message

templates for analysis.

Initial messages: OROs responsible for developing public information messages create pre-scripted EAS

messages that can be modified as necessary and sent to the EAS station(s) for broadcast. Plans/procedures

discuss the process of transforming the Protective Action Decisions (PADs) made by responsible

authorities into a format understandable to the public. The description includes a means of translating the

area covered by PADs from the format used by the OROs into familiar landmarks and boundaries for use

in the messages. The messages used in an emergency include at minimum:

 Identification of the ORO and the official with authority for providing the EAS alert signal and

instructional message.

 Identification of the commercial NPP and a statement that an emergency exists at the NPP.

 Reference to REP-specific emergency information (e.g., brochures, calendars, information in telephone

books) for use by the general public during an emergency.

 A closing statement asking the affected and potentially affected populations to stay tuned for additional

information or tune to another station for more information, such as special news broadcasts.

 

30 Ad hoc respiratory protection is not generally recommended and should be used with caution.

31 The current Respiratory Protective Devices Manual (3rd Edition) does not contain a similar table for ad hoc respiratory protection; however, 

according to the American Industrial Hygiene Association, it is still correct to refer to the 1963 manual as the most recent version of the 

Respiratory Protective Devices Manual that contains the ad hoc respiratory protection table.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-33 October 2011

Plans/procedures discuss the process for modifying or selecting pre-scripted, including computergenerated, EAS messages for broadcast. They also address process of issuing messages to the EAS station

and the process by which messages are reviewed by a responsible official prior to being released to the

EAS station. In addition, ORO plans/procedures discuss the methodology for EAS message re-broadcast,

along with the frequency (how many times and at what interval, such as every 15 minutes). The memory

capacity of the EAS equipment is identified for each station if different from the 2-minute minimum

standard.

Follow-up messages: OROs also develop special news broadcasts as supplements to the EAS message.

These special news broadcasts are prepared and disseminated in a timely manner after the EAS message

is broadcast. If not already clearly mentioned in the EAS message(s), these broadcasts identify:

 Precautionary protective actions, if any, for persons with disabilities and access/functional needs (e.g.,

school children, transportation-dependent individuals) or by location (e.g., public parks, beaches).

 Any protective actions for the general public described using familiar landmarks (e.g., political

jurisdictions, major highways, rivers, railroads, zip codes).

 Evacuation routes by affected areas (e.g., area XYZ uses route ABC).

 Methods to maximize protection when requested to shelter-in-place (e.g., remain inside, close all

windows and doors, shut off any forced air systems [heating or air-conditioning]).

 Public inquiry telephone numbers available to the public, as well as appropriate responses to rumors

and public inquiries.

 Ingestion-related instructions and information, when applicable.

 What evacuees should or should not take with them when evacuating (e.g., livestock, household pets).

Plans/procedures describe the method used to release special news broadcasts, such as press releases read

over the air, live interviews by station personnel with ORO officials, or live or recorded messages from

the ORO‘s EOCs.

Plans/procedures discuss the process by which the contents of public information (e.g., EAS messages,

press releases, special news broadcasts, etc.) can be adapted to take into account and counter rumors that

may impact the public‘s willingness to follow instructions issued by authorities.

Non-English language messages: Section 203 of the Voting Rights Act requires that messages be prescripted in non-English languages that are spoken by more than 5 percent of the county population of

voting age, based on current demographic studies. For counties that lie only partially in the EPZ, this

applies to the population of the entire county, not just the portion in the EPZ. If required, plans/procedures

address the process of developing and broadcasting foreign language messages. OROs make

arrangements to ensure that the content of foreign-language messages is consistent with the English

messages. This may be accomplished by having the written foreign-language messages translated into

English and compared with the text of the original English messages. When foreign-language messages

are required, they are included in the plans/procedures or otherwise provided to the reviewer.

References

 Respiratory Protective Devices Manual, American Industrial Hygiene Association, 1963.

 Memorandum from Margaret Lawless to RAC Chairpersons, Guidance on Planning Requirements 

Whenever Changes Are Made to Existing 10-mile EPZs, June 25, 1993.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-34 October 2011

 Memorandum from Kay Goss to Regional Directors, Guidance for Providing Emergency Information 

and Instructions to the Public for Radiological Emergencies Using the New Emergency Alert System

(EAS), February 2, 1999.

 NUREG-0654/FEMA-REP-1, Revision 1, Addenda, dated March 2002.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-35 October 2011

6. PLANNING STANDARD F – EMERGENCY COMMUNICATIONS

Provisions exist for prompt communications among principal response organizations to

emergency personnel and to the public.

NUREG CRITERION F.1

The communication plans for emergencies shall include organizational titles and

alternates for both ends of the communication links. Each organization shall

establish reliable primary and backup means of communications for licensees, local,

and State response organizations. Such systems should be selected to be

compatible with one another. Each plan shall include:

NUREG CRITERION F.1.a

Provision for 24-hour per day notification to and activation of the State/local

emergency response network; and, at a minimum, a telephone link and alternate,

including 24-hour per day manning of communications links that initiate emergency

response actions;

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION F.1a, ORO PLANS/PROCEDURES SHALL:

 Describe the equipment used (e.g., dedicated telephone line or specific radio net) for notifying and

communicating with the organization‘s personnel and other response organizations. The equipment

must include a primary link and alternate means of communication.

 Describe the system used to ensure 24-hour availability to receive and pass along notifications. The

system is generally a continuously staffed warning point (e.g., a police dispatch center) or a duty

officer system in which the designated duty officer carries a pager.

FEMA HIGHLY RECOMMENDS THAT PLANS/PROCEDURES:

 Include a diagram depicting communication links.

EXPLANATION

This criterion addresses communication systems used to activate emergency response organizations and

communicate with them during a radiological emergency. The plans/procedures describe the

communication systems that are used to implement the organization‘s role in this process, including staff,

equipment, and procedures.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
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NUREG CRITERION F.1.b

Provision for communication with contiguous State/local governments within the

Emergency Planning Zones;

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION F.1.b, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Primary and backup communication capability between all local governments within the plume EPZ.

 Primary and backup communication capability between each local government and any associated

host/support counties located outside the plume EPZ.

 Primary and backup communication capability between each state government and all local

governments within its jurisdiction and with other state governments within the plume and/or ingestion

EPZ.

EXPLANATION

The plans/procedures describe the systems, both primary and backup, used to communicate with other

governments at the state, local, or tribal level, including communications to and from alternate EOCs, if

appropriate. The particular system(s) available are identified (e.g., ordinary [switched] commercial

telephone, dedicated telephone line, county law enforcement radio net, National Warning System).

All the above capabilities include at least two separate systems, at least one of which is independent of the

switched commercial telephone system.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION F.1.c

Provision for communications, as needed, with Federal emergency response

organizations;

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION F.1.c, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The system(s) available for communicating with Federal response organizations (e.g., ordinary

commercial telephone, dedicated telephone lines, or radio nets).

 The primary system and at least one backup system.

EXPLANATION

To ensure coordination with Federal support, OROs must be able to communicate effectively with

Federal emergency response organizations. The plans/procedures identify the particular system(s) that

will be used for this communication. Some plans/procedures may provide that some or all

communications with Federal response organizations will be relayed through another organization (e.g.,

local communications with Federal response organizations will be through the state).
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REP Program Manual Page II-37 October 2011

Response to an HAB incident may require expansion of the traditional REP communication capabilities.

Specific issues may include: 1) the need for interoperable, redundant, and reliable communication with

the licensee and among the EOC and Incident Command elements (Incident Command Post/Unified

Command and staging areas); 2) the need for interoperable, redundant, and reliable communication with

non-traditional REP entities and locations (e.g., staging areas, Incident Command Posts, FBI, FEMA, and

HHS); 3) the need for procedures (safeguards) for the sharing of sensitive information during HAB

incidents between and among Federal, state, local, and tribal agencies and the licensee; and 4) the need

for primary and backup communication (safeguards) to support the exchange of sensitive information.

To ensure effective communications during HAB incidents, communication protocols and methods are

designed to ensure effective and timely communications between command elements and, where

appropriate, tactical response elements.

References

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION F.1.d

Provision for communications between the nuclear facility and the licensee’s

Emergency Operations Facility, State and local emergency operations centers, and

radiological monitoring teams;

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION F.1.d, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The primary and backup communication systems that provide links to the emergency operations 

facility.

 For jurisdictions that deploy radiological monitoring and other field teams, the primary and backup

systems used to communicate with the teams.

EXPLANATION

Each jurisdiction‘s plans/procedures describe the specific systems used to communicate with the licensee

(e.g., ordinary commercial telephone, dedicated telephone line, or particular radio net). The

plans/procedures specify the primary system and at least one backup system for communication with the

emergency operations facility.

Plans/procedures describe primary and backup systems for interoperable communication among all

components of incident command. For jurisdictions that deploy radiological monitoring and other field

teams (e.g., law enforcement, fire/HAZMAT, emergency medical), the plans/procedures describe primary

and backup systems used to communicate with those teams. Typically, the system will be a radio net,

cellular telephones, or radios in the vehicles used by the field teams. The teams should generally be able
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REP Program Manual Page II-38 October 2011

to contact a base when operating within the plume EPZ.32 The plans/procedures indicate the location of

the base (or indicate mobile) and specify what organization operates it.

References

 FEMA-REP-2, Rev. 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 –

Airborne Release, June 1990.

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION F.1.e

Provision for alerting or activating emergency personnel in each response

organization;

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION F.1.e, ORO PLANS/PROCEDURES SHALL:

 Contain a general description of how personnel are activated (i.e., notified of an incident and requested

to report to their emergency duty station).

 Include or reference lists of names and phone numbers of personnel to alert or activate based on the

ECL.

EXPLANATION

The notification process will continue to the level of notifying specific personnel. For a given jurisdiction,

usually one person (e.g., a dispatcher) is responsible for either notifying all personnel or alerting a short

list of agency contacts, who in turn alert their agency staff.

The lists of response staff names and telephone numbers may be withheld from the plans/procedures and

replaced with a reference indicating where this information may be attained (e.g., EOC, county building,

or dispatch center).

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 

32 Hilly terrain may cause gaps or holes in radio coverage. These gaps should be kept relatively small so the teams need only drive a few minutes in 

order to make radio contact.
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REP Program Manual Page II-39 October 2011

NUREG CRITERION F.1.f

Provision for communication by the licensee with NRC headquarters and NRC

Regional Office Emergency Operations Centers and the licensee’s Emergency

Operations Facility and radiological monitoring team assembly area.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION F.2

Each organization shall ensure that a coordinated communication link for fixed and

mobile medical support facilities exists.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION F.2, ORO PLANS/PROCEDURES SHALL INCLUDE FOR ALL

PRIMARY AND BACKUP HOSPITALS/MEDICAL FACILITIES AND AMBULANCES WITH A ROLE IN

THE TRANSPORTATION AND TREATMENT OF CONTAMINATED INJURED INDIVIDUALS:

 Identification of communications links between the ambulance and the designated hospital/medical

facilities.

 A description of primary and backup communications among the hospital/medical facilities, the

jurisdiction‘s EOC, and the licensee.

EXPLANATION

This criterion is intended to ensure that an effective means of communication has been established among

the licensee, local emergency response organizations, and ambulances and hospitals/medical facilities

involved in transportation and treatment of contaminated, injured, or exposed individuals. The transport

crew is able to communicate directly with the receiving hospital/medical facility to provide information

such as the patient‘s condition, estimated exposure, presence of contamination, and estimated time of

arrival, and/or to seek medical advice on patient treatment. Local EOCs have procedures to coordinate

pickup of patients, routing of ambulances, and provision of assistance for radiological monitoring.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION F.3

Each organization shall conduct periodic testing of the entire emergency

communications system (see [NUREG-0654/FEMA-REP-1] Evaluation Criteria H.10

and N.2.a, and Appendix 3.)

Applicability and Cross Reference to Plans: Licensee X State X Local X
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REP Program Manual Page II-40 October 2011

TO MEET THE INTENT OF CRITERION F.3, ORO PLANS/PROCEDURES SHALL:

 Describe the test method and period (e.g., monthly, quarterly or annually) for each communication

system used for the functions identified in Criteria F.1. and F.2.

EXPLANATION

Periodic testing is conducted to ensure that emergency communications systems are available when

needed.

Systems used on a routine basis, such as commercial telephones and law enforcement and fire response

radio nets, do not need to be periodically tested. Periodic testing is described for systems that are used less

frequently or are limited to emergency use, such as dedicated telephone circuits, emergency-only radio

channels, or pagers used for personnel notification. Testing includes any associated electronic or

computer equipment (e.g., fax machines, auto-dial equipment, or computers used to store phone

numbers).

Minimum frequencies for testing certain communication links are described in Criterion N.2.a.

References

 NUREG-0654/FEMA-REP-1, Revision 1, Appendix 3 – Means for Providing Prompt Alerting and 

Notification of Response Organizations and the Population, October 1980.

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
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REP Program Manual Page II-41 October 2011

7. PLANNING STANDARD G – PUBLIC EDUCATION AND INFORMATION

Information is made available to the public on a periodic basis on how they will be notified

and what their initial actions should be in an emergency (e.g., listening to a local broadcast

station and remaining indoors), the principal points of contact with the news media for

dissemination of information during an emergency (including the physical location or

locations) are established in advance, and procedures for coordinated dissemination of

information to the public are established.

NUREG CRITERION G.1

Each organization shall provide a coordinated periodic (at least annually)

dissemination of information to the public regarding how they will be notified and

what their actions should be in an emergency. This information shall include, but not

necessarily be limited to:

a. educational information on radiation;

b. contact for additional information;

c. protective measures, e.g., evacuation routes and relocation centers,

sheltering, respiratory protection, radioprotective drugs; and 

d. special needs of the handicapped.

33

Means for accomplishing this dissemination may include, but are not necessarily

limited to: information in the telephone book; periodic information in utility bills;

postings in public areas; and publications distributed on an annual basis.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION G.1, ORO PLANS/PROCEDURES SHALL INCLUDE:

 A description of each item (e.g., brochure, calendar, utility bill insert) used to disseminate public

information annually. Copies of these items must be provided to FEMA for review on an annual basis

through the ALC. In addition to the ALC submission, materials may be reviewed during an SAV,

exercise, separate mailing, etc.

 Provisions for identifying individuals needing assistance with evacuation and how personal

information will be protected.

 A description of materials directed to transient populations.

 A description of materials addressing information for the ingestion pathway, if separate from the

general public information materials.

 A description of each item translated into non-English languages that are spoken within the EPZ by

more than 5% of the county population, as well as information accessible to other persons with 

disabilities and access/functional needs located within the EPZ.34

 

33 The Americans with Disabilities Act of 1990 (ADA), the Rehabilitation Act of 1973 (RA), and the Fair Housing Act (FHA), their regulations 

and agency guidance, as well as state counterparts, among others, define the scope of requirements for children and adults with and without 

access or functional needs. 

34 Refer to Executive Order 13407 (Public Alert and Warning System, June 26, 2006).
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REP Program Manual Page II-42 October 2011

FEMA HIGHLY RECOMMENDS THAT PLANS/PROCEDURES:

 Include provisions to provide some form of public information for non-English speaking populations

that comprise less than 5% of the county population.

EXPLANATION

This criterion addresses the contents of written information that is distributed annually to the public in the

plume EPZ. The information may take various forms including brochures (for both residents and visitors),

telephone book inserts, or calendars; this can be supplemented by an Internet-based system. The licensee

and OROs generally coordinate/communicate on the content and arrangements for distribution of this

material.

To avoid confusing the public, it is essential that the information in distributed materials be consistent

with information contained in the plans/procedures that will be used to make PADs and compose EAS

messages, particularly any pre-scripted material for EAS or tone-alert radio broadcasts. These materials

must be consistent with respect to:

 Descriptions and maps of protective action areas;

 Evacuation routes and relocation centers; and

 Protective measures for schools and licensed daycare centers.

a. Information for the General Public

The licensee and OROs must provide information annually to the general public located within the plume

EPZ. All information is written in ―plain language‖ and is clear, accurate, consistent, and complete to

ensure it is easily understood by members of the public. The same ―plain language‖ principle is applied to

all information translated into non-English languages provided to the public. The information provided

annually to the public includes:

 A clear statement of purpose.

 Date (year) of issue and issuing agency(ies).

 A statement instructing the recipients to keep the information.

 Detailed information on how the public in the EPZ will be notified and where to turn for emergency

information and instructions. This includes call signs and frequencies or channel numbers of radio and

television stations that have been designated to provide emergency instructions to the public, consistent

with emergency response plans/procedures.35

 Information on protective actions, including:

 Specific and logically presented instructions for actions to take when sheltering-in-place. The

instructions provided must be consistent with the emergency response plans/procedures.

 Instructions on evacuation including securing the home, a list of evacuation supplies,

suggestions for notifying neighbors and friends, transportation assistance information,

 

35 As a condition of licensing, all radio and television stations were mandated by the Federal Communications Commission (FCC) to purchase 

and install XC-certified equipment for implementation of the EAS by January 1, 1997. However, radio and television stations are not required

to broadcast alerts and messages initiated by OROs. Under FCC authorities, the final authority for the broadcast of messages initiated by OROs 

resides with the broadcaster, not the ORO. The FCC, however, encourages licensees to broadcast emergency alerts as a public service. The use 

of emergency system broadcasting through the EAS is considered part of this service. Thus, if the EAS is used, it is critical that OROs work 

closely with their local broadcast industry representatives and state and local emergency Communication Committees to establish agree upon 

protocols to avoid problems in communicating emergency messages to the public during actual emergencies. Reference: Guidance for 

Providing Emergency Information and Instructions to the Public for Radiological Emergencies Using the New Emergency Alert System (EAS). 

[Memorandum from FEMA Associate Director for Preparedness, Training, and Exercises to FEMA Regional Directors. February 2, 1999.]
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REP Program Manual Page II-43 October 2011

suggested evacuation destination including the need, if any, to report to reception or relocation

centers, and clearly defined evacuation routes and written directions.

 If state and/or tribal governments have authorized the use of radioprotective drugs by the

general public in the EPZ, information on the distribution and use of KI. However, in some

cases, state and/or tribal governments within an EPZ may have different policies and

procedures for distribution and use of KI by the general public. In such cases, information

provided annually by all OROs within the EPZ address all policies for the distribution and use

of KI across the EPZ, noting the differences between such policies and procedures across

jurisdictions.

 An easy-to-read EPZ map that highlights the evacuation routes and location of reception centers and

other centers used for public services during an emergency (e.g., places for parents to pick up their

children, locations of any facilities set up to provide care for household pets). The map must be

consistent with the plans/procedures and include a simple legend and compass direction.

 Provisions for persons with disabilities and access/functional needs, including a method for individuals

within the EPZ in need of assistance during an evacuation to contact authorities regarding planning for

assistance in an emergency. 

 Policies and provisions for service animals.

 Information consistent with the plans/procedures regarding the care of children at public and private

schools and licensed daycare centers (child and adult), mobility- and hearing-impaired persons, and

those needing transportation assistance.

 Information on the evacuation routes leading to reception/relocation centers.

 Information on other centers used for public services during an emergency, congregate care, and the

services and supplies provided by those centers (e.g., information about which facilities accept

household pets).

 Educational information that includes basic information on radiation, how the NPP produces

electricity, and the ECLs.

 Agricultural information, if appropriate to the area, including information or instructions regarding

protection of livestock and commercial agricultural or home garden products. This may include

references to additional sources of information.

b. Identification of Individuals Who Need Assistance during an Evacuation

Plans/procedures describe a method for identifying individuals who need assistance when evacuating.

Such individuals include those with physical or mental limitations and the transportation-dependent. For

example, the material could include a card to be completed and returned to the appropriate agency by

residents needing special assistance during an emergency. However, recent studies have shown that the

response to self-registration cards is historically very low. OROs that use this method should consider

supplemental venues for self-registration and identification of individuals.

FEMA has developed guidance to support Federal, state, local, and tribal, governments in the integration 

of children and adults with and without disabilities who have access and functional needs into every 

aspect of emergency shelter planning and response.36

c. Special Information for Transient Populations

The licensee and OROs may also develop separate public information directed at transient populations.

These abbreviated forms (e.g., signs, decals, notices, visitor brochures, etc.) must be consistent with the

 

36 For additional guidance see Guidance on Planning for Integration of Functional Needs Support Services in General Population Shelters,

Federal Emergency Management Agency, November 2010. 
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REP Program Manual Page II-44 October 2011

plans/procedures and contain at least the following information: 1) channels/frequencies of local EAS

radio and television stations and 2) reference to a source for further information, such as a brochure,

website or telephone book page.

d. Information for the Ingestion Pathway

Materials include information on the ingestion pathway. This information is either included as a section in

the annual public information materials published and distributed by the state and/or licensee or presented

as fact sheets summarizing recommended protective actions for applicable agricultural industries

including milk, livestock, and crops produced for human consumption. The information covers the

following subjects:

 Effects of radiation and radioactive material deposits on the human food supply;

 Explanation of ORO ingestion PAGs;

 How farmers, food processors and distributors will be notified of when and which protective actions

are taken in an emergency;

 Identification of sources where further information may be obtained during an emergency, such as

NOAA Weather Radio and the EAS; and

 Identification of possible preventive protective actions taken for food and water, including livestock,

poultry, fruits, vegetables, and other crops. Examples of preventive protective actions are:

 Milk – Removing all lactating dairy animals from pasture and placing them on

uncontaminated feed and water;

 Vegetables and Fruits – Washing, brushing, scrubbing or peeling fruits and vegetables to

remove surface contamination;

 Meat and Meat Products – If levels of radioactive cesium in milk approach the preventive

PAG ―response level,‖ surveillance and protective actions for meat are recommended (e.g.,

placing meat animals on uncontaminated feed and water);

 Poultry and Poultry Products – Monitoring poultry if they are raised outdoors and especially if

they are used for egg production. If poultry live indoors and are fed stored rations,

contamination is unlikely;

 Soils – If soil problems occur, proper soil management procedures could be implemented to

reduce contamination: (1) Idling (i.e., non-use of the land) may be necessary in some cases;

however, in a worst case situation, removal and proper disposal of soil would be more

appropriate; (2) Alternating types of crops may be beneficial in some situations. Planting crops

that would contribute little or no radioactive material to the human diet could be substituted for

other food crops. For example, fiber crops such as cotton and flax might be substituted for fruit

and vegetable crops; (3) Deep plowing may keep radioactive substances below the plant root

zone where these substances can decay and (4) Liming to limit absorption of specific

radioactive substances by the crops.

 Grains – Permitting grain to grow to maturity, with subsequent milling and polishing to

remove most of the radioactive contamination; and

 Water – Covering open wells, rain barrels, and tanks to prevent contamination of water

supplies. For storage containers which are supplied by runoff from roofs or other surface drain

fields, the filler pipe is disconnected to prevent contaminants from being washed into the

storage container. Unless soils are highly permeable, contaminants deposited on the ground

will normally travel very slowly into the aquifer. In addition, radionuclides may be released

directly into surface water bodies and into groundwater. Streams and lake currents can

transport these radionuclides many miles in a few hours.
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REP Program Manual Page II-45 October 2011

 Other emergency protective actions which may involve the interdiction or condemnation of foods,

feeds or other contaminated products.

e. Foreign Language Translation of Public Information Materials

At a minimum, public information materials shall be translated into any non-English language

spoken by more than 10,000 individuals or more than 5% of the county population of voting age

(based on current demographic studies).37 For counties that lie only partially in the EPZ, this applies to

the population of the entire county, not just the portion in the EPZ. All translated information is clear,

accurate, consistent, and complete, as appropriate, to ensure that it is easily understood by members of the

public. Additionally, as appropriate, public information materials are developed for those such as the

visually impaired.

As appropriate, contacts and service contracts are established to translate emergency information

disseminated to the public prior to, as well as during, an emergency. Additionally, consideration is given

to identifying existing local media and/or community organizations (e.g., specialized newspapers, radio or

TV stations, and volunteer organizations active in disasters) that reach specific non-English-speaking

audiences. These audiences may need to be targeted during awareness/preparedness campaigns.

For any non-English language that is spoken in the EPZ by less than 10,000 individuals or 5 percent of

the county population of voting age (based on current demographic studies), if translations of public

information materials are not provided in that language, then FEMA highly recommends that OROs make

other efforts to afford that population information similar to that provided to the general population within

the EPZ. Such efforts might include the following activities:

 Special courses of instruction for the non-English language community leaders.

 Public meetings featuring a speaker trained in the relevant non-English language.

 Training leaders of neighborhood organizations.

 Advertisements in non-English language newspapers.

 Providing oral assistance to individuals who lack English language proficiency through a ―buddy‖

system.

These efforts are adapted to local circumstances to achieve the purpose of the Public Information

Program: ensuring that the population within the EPZ is knowledgeable regarding how they will be

alerted and provided instructions about what they are supposed to do in the event of a radiological

emergency.

References

 Policy Statement on Respiratory Protection, November 22, 1985.

 National Incident Management System, December 2008.

 Executive Order 13407, Public Alert and Warning System, June 26, 2006.

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, January

2008.

 National Response Framework, Public Affairs Support Annex, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 

37 See the National Voting Rights Act of 1965, section 203, including its text, a list of covered jurisdictions, and the Attorney General‘s Minority 

Language Guidelines, http://www.usdoj.gov/crt/voting/sec_203/activ_203.htm. Also see Part IV, Public Information Guide and Process. 
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REP Program Manual Page II-46 October 2011

NUREG CRITERION G.2

The public information program shall provide the permanent and transient adult

population within the plume exposure EPZ an adequate opportunity to become

aware of the information annually. The programs should include provision for

written material that is likely to be available in a residence during an emergency.

Updated information shall be disseminated at least annually. Signs or other

measures (e.g., decals, posted notices, or other means placed in hotels, motels,

gasoline stations, and phone booths) shall also be used to disseminate to any

transient population within the plume exposure pathway EPZ appropriate

information that would be helpful if an emergency or accident occurs. Such notices

should refer the transient to the telephone directory or other source of local

emergency information and guide the visitor to appropriate radio and television

frequencies.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION G.2, ORO PLANS/PROCEDURES SHALL INCLUDE:

 Methods used to disseminate public information, assuring that all residences in the plume EPZ will be

covered, and that written material will likely be available in a residence during an emergency.

 Methods for distributing ingestion exposure pathway information annually within the 10-mile EPZ,

and provisions for distribution within the 50-mile EPZ if needed.

 Methods used to disseminate and maintain public information for transient populations.

EXPLANATION

This criterion pertains to the methods of dissemination of public information aimed at the permanent and

transient adult populations within the plume EPZ. The distribution may take various forms including a

brochure, telephone book insert, or calendar; this can be supplemented by an Internet-based system. The

licensee and OROs generally coordinate/communicate on the content and arrangements for distribution of

this material.

Information on the ingestion exposure pathway is disseminated at least annually to farmers, processors

and distributors in the food production process located within the 10-mile EPZ. The licensee and/or

OROs are prepared to disseminate information for implementing protective actions within the entire 50-

mile ingestion pathway in the event of a Site Area Emergency or General Emergency.

Distribution of public information materials directed at transient populations may take various forms,

including the posting of visible information (e.g., signs, decals, notices, visitor brochures, etc.) in places

that are likely to be frequented by transients, such as gas stations, motels and hotels, phone booths,

Automatic Teller Machines, parks and recreation areas, marinas, shopping malls, major employers,

community shelters, and social service agencies. Plans/procedures include a list of the locations where

information for transient populations is posted, as well as a mechanism for annual update. New signs need

not be posted every year, provided none of the displayed information has changed. However,

plans/procedures specify an annual procedure for: (a) determining whether any of the notices require

updating; and (b) if so, replacing old materials with new. In addition, OROs annually audit locations

where information is posted to determine whether it is still there and still legible, or whether it needs to be

replaced.
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REP Program Manual Page II-47 October 2011

References

 National Incident Management System, December 2008.

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, January

2008.

 National Response Framework, Public Affairs Support Annex, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION G.3.a

Each principal organization shall designate the points of contact and physical

locations for use by news media during an emergency.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION G.3.a, ORO PLANS/PROCEDURES SHALL:

 Identify the location where the jurisdiction will brief the media, whether at a Joint Information Center

(JIC), separate facility, or both.

 Include a physical description of the facility, including its location and size, and any steps necessary to

activate it for use (e.g., coordination with other organizations consistent with Incident Command 

System, installation of equipment, and rearranging of furnishings), for jurisdictions that operate a

media facility.

 If the primary facility is located within the EPZ, identify an alternate facility located outside the EPZ

available to provide the same capabilities, and describe the facility with the same level of detail

specified for the primary facility.

 Describe the organization‘s capability to answer media telephone inquiries.

 Describe the mechanism for coordination between the team of personnel designated to answer media

calls and the organization‘s public information officer (PIO), as well as with points of contact located

at other facilities supporting the JIC.

EXPLANATION

Location: during a radiological emergency, large numbers of media representatives are expected to

congregate in the area seeking information about the emergency and response efforts. To minimize

confusion and promote organized release of information, suitable locations for briefing the media are

designated in advance. At most locations, the licensee and involved governmental jurisdictions have

designated a single facility for joint use. However, contact with the media does not need to be limited to

the JIC. A given jurisdiction may send a representative to the JIC and provide separate media briefings at

its own facility. This criterion addresses physical requirements of a media facility, whether joint or

separate.

Responsible parties: the facility description includes a statement indicating at what point in time the

media facility will be activated and who, by title/position, will be responsible for staffing and operating

that facility. For jurisdictions whose contact with the media is limited to a JIC operated by another

organization, the plans/procedures need to identify only the JIC, the organization responsible for that

facility, and the method for contacting that organization.

Telephone inquiries: in addition to face-to-face interactions, each principal organization needs the

capability to respond to media inquiries over the telephone. To perform that function effectively on a
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large scale, a multi-line phone setup and team of personnel is designated to handle media calls. An

appropriately staffed Internet-based system may be used to complement this capability.

Plans/procedures describing telephone interactions with the media include, at minimum, a telephone

number that is not given out to the general public, but is designated solely for incoming media inquiries,

and identify the team of personnel, by title/position, designated to answer media calls and respond to

incoming inquiries. If an Internet-based system is used to complement this capability, the description also

includes details of that system‘s capabilities.

Recommended features: certain features are recommended for supporting JIC operations. FEMA 

recommends that jurisdictions with limited resources that perform small-scale media functions at their

own facilities (e.g., towns, small municipalities) provide these features to the extent possible given their

resources. The recommended features of the JIC include:

 A briefing room to accommodate members of the media;

 Private (i.e., media-free) work areas for public information personnel;

 Effective communications systems to enable the PIOs to maintain contact with EOCs and all other

relevant response locations;

 Sufficient equipment to support operations such as computers, fax machines, and copiers;

 Sufficient electrical service to support the surge in demand from computers, lights, cameras, public

address systems, radio equipment, etc.;

 Office furniture, equipment, and supplies;

 Parking;

 Telephones for media use;

 Internet connectivity;

 Provision to control access to the facility (e.g., security personnel, a sign-in desk, ID badges);

 Work area for a public inquiry telephone team;

 Work area for a media inquiry telephone team; and

 A media monitoring area.

References

 National Incident Management System, December 2008.

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, January

2008.

 National Response Framework, Public Affairs Support Annex, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION G.3.b

Each licensee shall provide space that may be used for a limited number of the news

media at the Emergency Operations Facility.

Applicability and Cross Reference to Plans: Licensee X State Local 
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NUREG CRITERION G.4.a

Each principal organization shall designate a spokesperson who should have

access to all necessary information.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION G.4.a, ORO PLANS/PROCEDURES SHALL:

 Identify who, by title/position, will serve as the main PIO for the organization and where the PIO will

be located. If media interaction is planned for more than one location, a main PIO is designated for

each location.

 Describe how the PIO will obtain access to information about the emergency and the organizations‘

response efforts, gather and verify such information, and coordinate/communicate with the appropriate

personnel for approval in advance of disseminating any information to the public and/or the media.

 If the PIO will be operating at a location remote from the EOC, describe:

 Who, by title/position, will be the main point of contact in the EOC for exchanging

information with the PIO.

 What physical means (e.g., telephone, fax, or computer network) will be used for

communicating information between the EOC and the PIO.

 Include procedures for authorizing release of information and, in particular, for control and release of

sensitive information.

EXPLANATION

Roles and responsibilities: to ensure that interaction with news media is effective, the role and function

of the PIO (a.k.a., media director/coordinator, public affairs officer, spokesperson) is defined in advance.

This element entails designating a PIO for the organization and ensuring he or she has access to the

information necessary to perform the job effectively. The PIO for public entities is someone who is

trained and experienced in dealing with the media. Using a specialist for this role also avoids tying up key

response officials.

To perform his or her role effectively, the PIO has direct access to the latest official information

concerning the emergency and response efforts. Procedures for accessing this information should be

consistent with Incident Command System. If the PIO is unable to be at or function at the planned

location(s), then a mechanism is developed for forwarding key information to the PIO and allowing him

or her to approach response officials for answers to specific questions in advance of releasing any

information to the public and/or media.

Considerations for HAB incidents: in an HAB incident, additional governmental agencies that do not

normally participate in the REP Program may become involved in the response. These agencies include

the FBI, local law enforcement, and additional components of DHS. The presence of these agencies will

require additional coordination and may require different procedures regarding the sharing and

dissemination of public information. FBI and other law enforcement agencies responding to the hostile

action may need to withhold sensitive information from public release to protect the integrity of the

criminal response and evidence collection process.

To address these issues, OROs establish a process to coordinate the timely sharing and release of public

information with the FBI and law enforcement during an HAB incident. Roles and responsibilities for

release of public information in an HAB incident are defined in ORO plans/procedures (particularly

between the FBI and response organizations, including the Incident Command). States with multiple
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NPPs may have to interact with multiple FBI field offices that may have different response times or

different approaches to sensitive information. Guidelines may be needed to determine what is withheld

for security reasons and what information is released to protect the public. 

Information release procedures: all organizations establish formal control mechanisms on the release of

information (e.g., use of pre-approved generic press statements and a procedure requiring that information

be approved by a responsible official, consistent with Incident Command System, before being released).

Such mechanisms help control the reliability and consistency of the information released. The

organizations also have specific policies and procedures for controlling and releasing sensitive

information (e.g., information about injuries, private information about persons with disabilities and 

access/functional needs, sensitive law-enforcement information). Such plans/procedures address the types

of sensitive information subject to redaction, limited release, and/or withholding (e.g., certain information

dealing with specific aspects of NPP security capabilities, actual or perceived adversarial/terrorist force or

threat, tactical law enforcement response, and/or crime scene investigation). Pre-approved generic press

statements may be used to initially address media inquiries, while not identifying specifics regarding

response and/or aspects of crime scene investigation.

References

 National Incident Management System, December 2008.

 FEMA-517 – Basic Guidance for Public Information Officers (PIOs).

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, January

2008.

 National Response Framework, Public Affairs Support Annex, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION G.4.b

Each organization shall establish arrangements for timely exchange of information

among designated spokespersons.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION G.4.b, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The exchange, discussion, and coordination of information among PIOs, if information is provided to

the media primarily through a JIC (e.g., meetings to coordinate and share information prior to press

briefings/conferences, circulation of press releases among the PIOs and their staffs).

 If the jurisdiction has a PIO at a separate facility (in addition to or instead of the JIC), equipment and

procedures for timely exchange of information with other PIOs, including:

 Who, by title/position, is responsible for ensuring that the exchange takes place.

 What physical communication means (e.g., telephone, fax, computer network, electronic mail, video,

or Internet-based teleconference system) will be used.

EXPLANATION

Joint information system: a joint information system is an effective tool to achieve public information

goals. A joint information system is designed to provide the necessary structure and mechanisms for

organizing, developing, integrating, and delivering coordinated interagency messages; developing,

recommending, and executing public information plans/procedures and strategies on behalf of senior
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emergency response officials; advising senior emergency response officials concerning public affairs

issues that could affect a response effort; and controlling rumors and inaccurate information that could

undermine public confidence in the incident response effort. The JIC is a physical facility that supports

the implementation of the joint information system.

Information exchange: PIOs for different organizations and levels of government (i.e., Federal, state, 

local, or tribal) need to coordinate/communicate to ensure that information disseminated to the public is

accurate, consistent, timely, and easy to understand. They may exchange information verbally, either

face-to-face or by telephone, video, or Internet-based teleconferences and/or by exchanging electronic or

hard copies of press releases and other information. The goals of accuracy, consistency, timeliness, and

accessibility are best served if PIOs exchange, discuss, and coordinate information to be disseminated to

the public prior to its release.

References

 National Incident Management System, December 2008.

 FEMA-517, Basic Guidance for Public Information Officers (PIOs).

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, January

2008.

 National Response Framework, Public Affairs Support Annex, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION G.4.c

Each organization shall establish coordinated arrangements for dealing with rumors.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION G.4.c, ORO PLANS/PROCEDURES SHALL:

 Describe the capability to receive and effectively respond to numerous simultaneous telephone calls

from the general public and respond to questions, requests, or comments posed by the public.

 Identify the method for publicizing the dedicated telephone number(s) and other contact information

(e.g., website address) for public inquiries and/or media information.

 Include or describe procedures to effectively monitor media information messages to identify

incomplete, inaccurate, or ambiguous information related to the emergency in the public domain.

 If a jurisdiction sends a delegate to a joint public inquiry program or relies on another organization to

answer public inquiries, identify which organization provides or coordinates the public inquiries

program and the method for contacting that organization.

EXPLANATION

An effective public inquiry program serves two purposes, both of which are addressed by this

criterion. First, it allows the public to have direct access to a knowledgeable official source for answers to

their questions during a response effort. Second, it serves as a feedback mechanism that provides response

officials with an indication of patterns or trends in public inquiries that may indicate the presence of

unconfirmed reports, rumors, and/or incomplete, inaccurate, or ambiguous information that needs to be

addressed in news releases and briefings.
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The media monitoring function complements the public inquiry program to identify incomplete,

inaccurate, or ambiguous information related to the emergency being disseminated the public domain.

Location: At many locations, public inquiry is conducted as a joint operation, often co-located with the

JIC, or by one principal organization on behalf of all the EPZ organizations.

Activation: Plans/procedures of organizations responsible for the function of public inquiry include a

statement indicating at what point in time the public inquiries center will be activated and who, by

title/position, will be responsible for staffing and operating the center. Telephones and staff are designated

for a public inquiries center. Internet-based discussion forums (e.g., instant messaging, blogs, and/or

electronic bulletin boards) supported by designated personnel, identified by title/position, may be used to

complement this capability.

Message monitoring and analysis: Plans/procedures address the methods to provide staff with current

information about the emergency and response efforts in a timely manner. Staff is alert for patterns or

trends in inquiries that may suggest the presence of unconfirmed reports, rumors, misinformation, or

confusion, and reports such patterns or trends to the PIOs for clarification.

Plans/procedures also describe the method the PIO uses to analyze any patterns or trends reported by the

public inquiry staff, as well as any incomplete, inaccurate, or ambiguous information related to the

emergency identified by the media monitoring staff. Such analysis is accomplished in coordination with

response officials and other PIOs, as appropriate, prior to the release of any clarifying and/or corrected

information to the public and the media. The PIO promptly addresses such issues, as appropriate, in

subsequent press releases and/or press briefings.

Finally, the plans/procedures discuss the method used to notify public inquiry and media monitoring staff

about the release of any clarifying and/or corrected information to the public and the media.

Scope: The scope of media monitoring includes, as appropriate, print, radio, television, cable, and

Internet-based media. Internet-based media (e.g., web logs or blogs) are periodically updated journals that

provide online commentary with minimal to no external editing. Media institutions have adopted this

format, with many television networks, newspapers, and opinion journals now hosting blogs on their

websites. PIOs need to be aware that blogs are a part of social media reporting virtually 24/7 throughout

their area of responsibility.

References

 National Incident Management System, December 2008.

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, January

2008.

 National Response Framework, Public Affairs Support Annex, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION G.5

Each organization shall conduct coordinated programs at least annually to acquaint

news media with the emergency plans, information concerning radiation, and points

of contact for release of public information in an emergency.

Applicability and Cross Reference to Plans: Licensee X State X Local X
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REP Program Manual Page II-53 October 2011

TO MEET THE INTENT OF CRITERION G.5, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Provisions for an annual media briefing.

 Distribution of written materials (media kits) covering topics described below.

 Each item provided as baseline information about REP to the local media.

EXPLANATION

This criterion is intended to provide a baseline of information about REP to the local media. The purpose

of this baseline is to prepare local media for their potential role as conduits of emergency information and

to promote accurate, objective reporting on radiological emergencies. Furthermore, positive media

relationships built during normal day-to-day activities will be valuable during an incident.

OROs hold an annual briefing, workshop, mailing, or other means of providing information to news

media on the following topics:

 An overview of the joint information system and emergency plans/procedures, including organizational

roles and authorities, ECLs, and protective actions.

 Points of contact and locations for release of public information during an emergency, including media

center locations and alternate facilities, as well as telephone numbers for media inquiries.

 General information concerning radiation exposure and health effects, as well as the distribution and

use of KI by the general public, as appropriate. Consistent with the explanation provided under

Criterion G.1, information about the distribution and use of KI is included only if state and/or tribal

governments have authorized the use of radioprotective drugs by the general public in the EPZ.

However, in some cases, state and/or tribal governments within an EPZ may have different policies and

procedures for distribution and use of KI by the general public. In such cases, information provided to

the media by all OROs within the EPZ as part of their outreach and awareness efforts addresses all

policies for the distribution and use of KI across the EPZ, noting the differences between such policies

and procedures across jurisdictions.

OROs provide copies of materials used for media briefing to FEMA for review on an annual basis 

through the ALC. In addition to the ALC submission, materials may be reviewed during an SAV, 

exercise, separate mailing, etc. To avoid confusing the public, it is essential that the information provided 

to the local media be consistent with the information contained in plans/procedures that will be used to 

make PADs and compose EAS messages, particularly any pre-scripted material for EAS or tone-alert 

radio broadcasts.

NOTE: In instances of poor attendance, in lieu of a meeting, a statement that program materials covering 

requisite topics were mailed to media representatives must be provided.

References

 National Incident Management System, December 2008.

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, January

2008.

 National Response Framework, Public Affairs Support Annex, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and

Local Government Emergency Plans, Version 2, November 2010.
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8. PLANNING STANDARD H – EMERGENCY FACILITIES AND EQUIPMENT

Adequate emergency facilities and equipment to support the emergency response are

provided and maintained.

NUREG CRITERION H.1

Each licensee shall establish a Technical Support Center and an onsite operations

support center (assembly area) in accordance with NUREG-0696.38

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION H.2

Each licensee shall establish an Emergency Operations Facility from which

evaluation and coordination of all licensee activities related to an emergency is to be

carried out and from which the licensee shall provide information to Federal, State,

and local authorities responding to radiological emergencies in accordance with

NUREG-0696.39

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION H.3

Each organization shall establish an emergency operations center for use in

directing and controlling response functions.

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION H.3, ORO PLANS/PROCEDURES SHALL INCLUDE:

 A description of or reference to the location and layout of the EOC.

 A listing of facility equipment necessary to support operations.

 The EOC‘s backup power capability, if available.

 Details and methods for access control to the facility.

 Reference to the location of the alternate EOC, if applicable.

 The organization and official, by title/position, responsible for maintaining the operational readiness of

the EOC.

EXPLANATION

ORO plans/procedures include or reference the location of the EOC for directing and controlling

emergency response functions. The plans/procedures also include or reference an EOC layout diagram, a

list of facility equipment (e.g., telephones, displays, fax machines, computers), and the source(s) of

backup power (if available at an EOC). Plans/procedures also state that access to the facility is limited to

those individuals who have functional responsibilities required for EOC operations.

 

38 ―Revision 1‖ was deleted: NUREG-0696 has not been revised as per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 2002.

39 ―Revision 1‖ was deleted: NUREG-0696 has not been revised as per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 2002.
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If there is an alternate EOC, the plans/procedures identify or reference its location and include or

reference the layout diagram and the facility equipment (see Criterion F.1.b. for a discussion regarding

alternate EOC communication links). The plans/procedures identify the organization and official, by

title/position, responsible for maintaining the operational readiness of the EOC.

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION H.4

Each organization shall provide for timely activation and staffing of the facilities and

centers described in the plan.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION H.4, ORO PLANS/PROCEDURES SHALL INCLUDE:

 Detailed procedures for activation and staffing of all emergency facilities.

 Criteria used for declaring facilities operational.

 A list of staff, by title/position, assigned to each facility and rosters of key positions.

EXPLANATION

Plans/procedures describe timely activation and staffing of any facilities needed to support an emergency

response and specify how these facilities would be set up. Plans/procedures address the timing of facility

activation (e.g., concurrent with initial emergency personnel notification or at a specific ECL).

Plans/procedures list specific criteria for declaring a facility operational. These criteria might include

completion of the physical setup of the facility, the presence of specific emergency staff at the facility,

setup of key communication links, or a combination of these conditions.

The plans/procedures also identify, in an appendix, staff members by title/position, assigned to each

facility, rosters of key positions (i.e., those essential to support EOC operations), and the number of

personnel needed to support operations in each role or position. Plans/procedures also contain information

on methods for alerting emergency staff.

References

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
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NUREG CRITERION H.5

Each licensee shall identify and establish onsite monitoring systems that are to be

used to initiate emergency measures in accordance with [NUREG-0654/FEMA-REP1] Appendix 1, as well as those to be used for conducting assessment.

The equipment shall include:

a. geophysical phenomena monitors (e.g., meteorological, hydrologic,

seismic);

b. radiological monitors (e.g., process, area, emergency, effluent, wound and

portable monitors and sampling equipment);

c. process monitors (e.g., reactor coolant system pressure and temperature,

containment pressure and temperature, liquid levels, flow rates, status or

lineup of equipment components); and

d. fire and combustion products detectors.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION H.6

Each licensee shall make provision to acquire data from or for emergency access to

offsite monitoring and analysis equipment, including:

a. geophysical phenomena monitors (e.g., meteorological, hydrologic,

seismic);

b. radiological monitors, including rate meters and sampling devices.

Dosimetry shall be provided and shall meet, as a minimum, the NRC

Radiological Assessment Branch Technical Position for the

Environmental Radiological Monitoring Program; and

c. laboratory facilities, fixed or mobile.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION H.7

Each organization, where appropriate, shall provide for offsite radiological

monitoring equipment in the vicinity of the nuclear facility.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION H.7, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Radiological monitoring equipment, by type and number, that is located or stored near the NPP or that

will be brought in by the ORO.

 Fixed radiological monitoring stations near the NPP.
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EXPLANATION

Plans/procedures identify any offsite radiological monitoring equipment that is located or stored near the

NPP (e.g., at staging areas, ICPs, the EOF) and monitoring equipment to be brought to the vicinity by the

ORO. The plans/procedures include written descriptions of the types and quantities of equipment

available at each location. If there are radiation detectors, permanent record dosimeters, and/or air

sampling pumps at fixed stations located near the NPP, the plans/procedures identify them as potential

resources and include written descriptions and maps of the fixed stations.

References

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION H.8

Each licensee shall provide meteorological instrumentation and procedures that

satisfy the criteria in [NUREG-0654/FEMA-REP-1] Appendix 2 and provisions to

obtain representative current meteorological information from other sources.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION H.9

Each licensee shall provide for an onsite operations support center (assembly area)

that shall have adequate capacity and supplies, including, for example, respiratory

protection, protective clothing, portable lighting, portable radiation monitoring

equipment, cameras, and communications equipment for personnel present in the

assembly area.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION H.10

Each organization shall make provisions to inspect, inventory, and operationally

check emergency equipment/instruments at least once each calendar quarter and

after each use. There shall be sufficient reserves of instruments/equipment to

replace those that are removed from emergency kits for calibration or repair.

Calibration of equipment shall be at intervals recommended by the supplier of the

equipment.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION H.10, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The organization(s) responsible for maintenance of all radiological equipment.

 Specifics regarding the inventory, operational checks, and calibration for dosimetry, portal monitors,

radiological survey equipment, air sampling equipment, and laboratory equipment.
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EXPLANATION

Plans/procedures identify the organization(s) responsible for maintaining radiological equipment,

including inventory, inspections, calibration, and operational checks. Plans/procedures include provisions

to ensure sufficient equipment for all emergency workers responding to an incident at an NPP. The

plans/procedures discuss the following equipment types, as appropriate:

a. Dosimetry

Dosimeters are available in two basic types: permanent record dosimeters (PRDs) (e.g., film badges and

thermoluminescent dosimeters [TLDs], which have to be read by a laboratory) and direct-reading

dosimeters (DRDs) (e.g., ion chamber electroscope and electronic dosimeters, which can be read by the

user) (see Evaluation Criterion K.3.a for more detail).

The plans/procedures identify the dosimetry, including DRDs and PRDs, used by emergency workers and

include quantities of items required, based on the number of emergency workers; quantities of equipment

available, by type and model; and information regarding backup equipment (i.e., how many items are

available by type/model and where they are stored). Also, if dosimetry will be provided from remote

locations, the plans/procedures describe methods for obtaining the dosimetry, including what organization

will supply the equipment, how much is available, and its estimated arrival time.

Plans/procedures include instructions for checking DRDs before operation. Emergency workers check

dosimeters for initial readings and re-zero them, if necessary. Plans/procedures include information about

PRDs, including where the PRDs would be turned in for processing and instructions for handling and

storing control badges. Plans/procedures address the methods and frequency for inspection of DRDs (i.e.,

checks for electrical leakage and calibration). New types of dosimeters (e.g., electronic) may be used as

long as recommended manufacturers‘ instructions are followed.

b. Portal Monitors

If portal monitors are used, the plans/procedures provide inventory information, including equipment

models, types, quantities, and locations. The plans/procedures also include information on backup

equipment (i.e., how many items are available by type/model and where they are stored) as well as

backup electrical power for portal monitors without an independent backup supply.

Plans/procedures discuss instructions for operational checks of portal monitors including the frequency

and method used for such checks (e.g., electrical operational check and radioactive check source). OROs 

complete portal monitor operational checks prior to initial use in the field and before operation in

accordance with guidance in Contamination Monitoring Standard for a Portal Monitor Used for

Emergency Response, FEMA-REP-21 (March 1995). The plans/procedures indicate that each monitor

will be labeled with the date of the last operational check and date of the next calibration. Calibration is at

intervals recommended by the manufacturer of the equipment.

c. Radiological Survey Instruments

Plans/procedures provide separate lists of the radiological survey instruments used by field monitoring

teams (FMTs) and those used by emergency workers at reception centers. The equipment lists include

quantities of instruments required, based on the number of FMTs and reception center requirements, and

quantities available by model. The plans/procedures identify backup equipment, including how many

items are available by type/model and where they are stored.
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Plans/procedures discuss instructions for operational checks of radiological survey instruments, including

the frequency and method used for such checks (e.g., battery checks and radioactive source checks).

OROs complete operational checks on a quarterly basis and before deployment into the field. Instruments

being used to measure activity have accompanying documentation and/or a sticker affixed to the

instrument indicating the effective range of readings. The range of readings documentation indicates the

acceptable range of readings that the meter should indicate when it is response-checked using a standard

test source. The plans/procedures also address the frequency of instrument calibration; calibrations are

performed at least annually unless otherwise specified by the manufacturer.

d. Air Sampling Equipment

The plans/procedures include an inventory of air sampling equipment, with model types, numbers, and

storage location for each organization(s) responsible for air sampling. The plans/procedures identify

backup equipment (i.e., how much is available and where it is stored) Plans/procedures also identify the

source of power needed to drive the equipment.

Plans/procedures discuss methods for operational checks of air sampling equipment. OROs complete 

operational checks quarterly and before FMTs are deployed. The plans/procedures also provide for

calibrating air sampling equipment at least annually.

e. Laboratory Equipment

The plans/procedures include inventory information on laboratory equipment (e.g., gamma spectrum,

liquid scintillation) for each organization(s) responsible for laboratory analysis. If backup equipment is

provided by another laboratory, the plans/procedures include the name of the laboratory and provide a

summary of its capabilities. The plans/procedures discuss methods and frequency of calibration for all

types of laboratory equipment being used.

References

 FEMA-REP-2, Rev. 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 –

Airborne Release, June 1990.

 FEMA-REP-21, Contamination Monitoring Standard for a Portal Monitor Used for Radiological 

Emergency Response, March 1995.

 FEMA-REP-22, Contamination Monitoring Guidance for Portable Instruments Used for 

Radiological Emergency Response to Nuclear Power Plant Accidents, October 2002.

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION H.11

Each plan shall, in an appendix, include identification of emergency kits by general

category (protective equipment, communications equipment, radiological

monitoring equipment, and emergency supplies).

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION H.11, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The number and contents of emergency kits by location and general category.
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 The quantity of each item per kit.

EXPLANATION

The plans/procedures identify sufficient supplies of emergency equipment by category of kit and quantity

of each item per kit. Protective equipment refers essentially to clothing (e.g., booties, gloves, coveralls,

rain suits, helmets). Communications equipment includes hand-held/field radios, cellular telephones, and

any communications equipment essential for field operations. Radiological monitoring equipment

includes the equipment discussed in Criterion I.8. Emergency supplies include any type of equipment that

might be necessary for emergency response (e.g., barricades, plastic cones, flashlights).

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION H.12

Each organization shall establish a central point (preferably associated with the

licensee’s Emergency Operations Facility), for receipt and analysis of all field

monitoring data and coordination of sample media.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION H.12, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The organization(s) responsible for assessing radiological data.

 The location of the central point for compiling and analyzing all field monitoring data, including the

means used by FMTs to relay information to the central point.

 The coordination and analysis of sample media, including procedures for transporting samples and

transferring the data from the laboratory to the central point.

EXPLANATION

Plans/procedures identify the organization(s) responsible for assessing radiological data, the central point

for compiling and analyzing all field monitoring data, methods used by FMTs to relay information to the

central point, and the means by which it is processed (e.g., computer model).

Plans/procedures also address coordination and analysis of sample media and describe methods for

transporting samples, including identification of: (1) laboratories involved, (2) predetermined transfer

points, if used, and (3) the individual, by title/position, responsible for deciding which samples are sent to

which laboratory. The plans/procedures also describe the methods for analyzing the data and transferring

the data from the laboratory to the central point. If a privately owned lab is used, an LOA is necessary.

References

 FEMA-REP-2, Rev. 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 –

Airborne Release, June 1990.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.
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9. PLANNING STANDARD I – ACCIDENT ASSESSMENT

Adequate methods, systems, and equipment for assessing and monitoring actual or

potential offsite consequences of a radiological emergency condition are in use.

NUREG CRITERION I.1

Each licensee shall identify plant system and effluent parameter values

characteristic of a spectrum of off-normal conditions and accidents and shall

identify the plant parameter values or other information that correspond to the

example initiating conditions of [NUREG-0654/FEMA-REP-1] Appendix 1. Such

parameter values and the corresponding emergency class shall be included in the

appropriate facility emergency procedures. Facility emergency procedures shall

specify the kinds of instruments being used and their capabilities.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION I.2

Onsite capability and resources to provide initial values and continuing assessment

throughout the course of an accident shall include post-accident sampling

capability, radiation and effluent monitors, in-plant iodine instrumentation, and

containment radiation monitoring in accordance with NUREG-0737,

40 as elaborated in

the NRC letter to all power reactor licensees dated October 30, 1979.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION I.3

Each Licensee shall establish methods and techniques to be used for determining:

a. the source term of releases of radioactive material within plant systems.

An example is the relationship between the containment radiation

monitor(s) reading(s) and radioactive material available for release from

containment.

b. the magnitude of the release of radioactive materials based on plant

system parameters and effluent monitors.

Applicability and Cross Reference to Plans: Licensee X State Local 

 

40 NUREG-0737, Clarifications of TMI Action Plan Requirements, November 1980, and Requirements for Emergency Response Capability, 

NUREG-0737, Supplement 1, January 1983, superseded the original reference to NUREG-0578 per NUREG-0654/FEMA-REP-1, Revision 1, 

Addenda, March 2002.
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NUREG CRITERION I.4

Each licensee shall establish the relationship between effluent monitor readings and

onsite and offsite exposures and contamination for various meteorological

conditions.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION I.5

Each licensee shall have the capability of acquiring and evaluating meteorological

information sufficient to meet the criteria of [NUREG-0654/FEMA-REP-1] Appendix 2.

There shall be provisions for access to meteorological information by at least the

near-site Emergency Operations Facility, the Technical Support Center, the Control

Room and an offsite NRC center. The licensee shall make available to the State

suitable meteorological data processing interconnections which will permit

independent analysis by the State, of facility generated data in those States with the

resources to effectively use this information.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION I.6

Each licensee shall establish the methodology for determining the release

rate/projected doses if the instrumentation used for assessment is off-scale or

inoperable.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION I.7

Each organization shall describe the capability and resources for field monitoring

within the plume exposure Emergency Planning Zone that are an intrinsic part of the

concept of operations for the facility.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION I.7, THE ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Which organizations have primary responsibility for field monitoring activities.

 The capabilities and resources state, local, tribal, and non-governmental organizations will contribute.

EXPLANATION

The plans/procedures identify the organizations that will contribute to the field monitoring effort. This

information includes the number of FMTs per shift and specific functions of each FMT (e.g., ambient

monitoring or field sampling). The plans/procedures identify arrangements for the timely exchange of

field measurement data and coordination of monitoring activities. If non-governmental (e.g., licensee,

university, contractor, mutual-aid) FMT resources are used, LOAs need to be established, as referenced in

Criterion A.3. The plans/procedures and LOAs clearly delineate activities performed by these nongovernmental FMTs, such as collection of air samples within the plume and determination of the airborne

radioiodine concentrations present.
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References

 FEMA-REP-2, Revision. 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 

1 – Airborne Release, June 1990.

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION I.8

Each organization, where appropriate, shall provide methods, equipment, and

expertise to make rapid assessments of the actual or potential magnitude and

locations of any radiological hazards through liquid or gaseous release pathways.

This shall include activation, notification means, field team composition,

transportation, communication, monitoring equipment, and estimated deployment

times.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION I.8, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The process for activating and notifying field teams.

 The composition of the FMTs (e.g., organizations involved, number of teams [two or more], number of

members on each team).

 The types and sources of transportation resource(s) for FMTs and estimated deployment times to reach

a site from various locations, if applicable.

 The location of any staging areas.

 The title/position of the person responsible for directing FMTs to proper locations for monitoring and

air sampling.

 The monitoring, sampling, and communications equipment that will be used by FMTs.

 The procedures that will be followed for field monitoring, sample collection, and field sample analysis.

 The laboratories to which specific samples will be sent for analysis, including estimated delivery and

analysis times, transportation and temporary storage arrangements, and procedures for chain-ofcustody records.

 How the ORO will obtain centerline measurements.

EXPLANATION

a. Activation and Notification

The plans/procedures describe the activation processes for FMTs (two or more), including identifying the

organization(s) and individual(s), by title/position, that will receive the initial information.

Plans/procedures also specify the designated ECL at which the FMTs will be mobilized or deployed.

FMTs may be activated at a different time than EOCs.

The plans/procedures specify the means of notification (e.g., pager or telephone calls), the individual, by

title/position, responsible for contacting personnel, the notification process (e.g., telephone tree or

multiline automatic ring-down system), and a list of personnel, including alternates, to be contacted for

FMT activities. The plans/procedures indicate whether repeat attempts will be made to reach those who

do not initially respond or whether alternates will be used.
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b. Field Team Composition

The plans/procedures identify how many teams will be deployed for field monitoring and sampling (two

or more) and describe their compositions (e.g., a health physicist or health physics technician and a driver

who is a nontechnical local person familiar with the area). The plans/procedures provide LOAs for FMTs

that are composed of a mixture of government representatives and non-governmental resources such as

licensee or private representatives (e.g., university, contractor, or mutual-aid).

c. Transportation

The plans/procedures identify types and sources of transportation provided for the FMTs. Means of

transportation is appropriate for the assignment to be carried out (e.g., four-wheel drive vehicles or boats

where needed to reach monitoring or sampling locations)and is large enough to carry all supplies,

equipment, and personnel required to support the field monitoring operation.

d. Estimated Deployment Times

The plans/procedures identify the time it takes the activated teams to prepare and leave the point of origin.

FEMA recommends that plans/procedures include the estimated time of arrival at the monitoring

locations. The plans/procedures also identify any staging areas near each reactor site that will be used as

initial deployment points for the teams.

e. Communications

The plans/procedures indicate what equipment (e.g., radios and cellular telephones) the FMTs will use to

communicate with their base, with each other, and with FMT support personnel (e.g., sample couriers).

The plans/procedures also address how communication would be accomplished if the primary

communication system were to fail.

f. Direction of Field Teams

The plans/procedures identify how the FMTs will be directed and coordinated, including identifying the

individual, by title/position, responsible for coordination and where this individual will be located. The

sampling strategy is a condition of the emergency, thus, the plans/procedures specify the decision-making

process for placement and movement of FMTs, including procedures for determining the locations, within

the plume pathway, suitable for collecting air samples via open- and closed-window ambient exposure

rate measurements. ORO teams obtain peak plume measurements (centerline measurements) according to

their plans/procedures. FMTs may accomplish this by traversing the plume to obtain peak plume

measurements (centerline measurements), or by making mathematical calculations from measurements

taken off centerline, as agreed in plans/procedures or LOAs. FMTs will obtain plume-edge measurements.

In addition, the plans/procedures address whether FMTs coordinate/communicate with other FMTs in the

field (e.g., Federal, ORO, or licensee) and how they share duties, resources, and measurement data.

The plans/procedures include locations of any predetermined field monitoring points and instructions on

the use of ad hoc monitoring points during an incident. The plans/procedures also address how the FMTs

will be directed to those points (e.g., use of familiar landmarks or global positioning system [GPS]

equipment).

g. Field Monitoring Equipment

The plans/procedures contain lists of monitoring and sampling equipment to be used by the FMTs,

including the following:
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(1) Ambient Monitoring Equipment

 Low-Range Survey Meters – capable of making both gamma and beta-plus-gamma

readings; the upper limit of the gamma range is in the tens of mR/hr.

 High-Range Survey Meters – overlaps the low range instrument and has an upper limit of

the gamma range capable of measuring the exposure rate limit defined in the

plans/procedures. If no exposure rate limit is defined, an instrument capable of measuring in

the tens of R/hr is generally adequate.

(2) Air Sampling Equipment

 Air Sampler – calibrated to flow rate and capable of being powered by the transportation

vehicle or other portable electrical source. The air sampler is capable of providing a

sampling flow rate compatible with the type of adsorbent cartridge being used, typically 2

cubic feet per minute (cfm) or 5 cfm, depending on adsorbent cartridge geometry.

 Cartridges – silver zeolite, silver alumina, or silver silica gel.

 Particulate Filters – high-efficiency particulate air (HEPA) or equivalent.

 Counting Equipment – count rate meter or scaler capable of processing data from a suitable

radiation detection probe. Probe selection will depend on adsorbent geometry.

 Miscellaneous Supplies – tweezers, plastic bags, gloves, markers, labels, etc.

(3) Environmental Media Sampling Equipment

 Collection Equipment – shovel or trowel, shears or other cutting devices, bucket or bottles

for liquid samples, and distance measuring device.

 Monitoring Instrument – μR meter and/or count rate meter with thin-window GeigerMueller (G-M) probe.

 Miscellaneous Supplies – plastic bags, gloves, shoe covers, markers, labels, etc.

h. Field Team Procedures

The plans/procedures describe the methods for monitoring, collecting, and analyzing samples, including

the following:

(1) Equipment Checks: Prior to using an instrument(s) for monitoring, the FMT members verify

that calibration stickers are current and then check the instrument(s) for proper operation.

This would involve checking the battery and, for a low-range instrument, measuring the

radiation from an accompanying check source. Operational checks are conducted according

to the procedures and guidance in the explanation under Criterion H.10. The results of this

check-source measurement are compared to the proper reading for the source, as stated on the

calibration label.

(2) Communication Protocols: The plans/procedures emphasize the need for clear

communication of the units used for measured values and the time, place, and person making

the measurements.

(3) Ambient Radiation Measurements: The procedures state that open- and closed-window

readings are taken at waist level (approximately 1 meter) or higher and at near-ground levels

(e.g., 5-7 centimeters). When conducting open-window readings, it is recommended that that

the beta window on the instrument‘s probe point up for waist level or higher readings and

down for near-ground readings. Taking multiple readings helps identify changes in the

plume.
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(4) Air Sampling Procedures: If the radiological release is a particulate release, the procedures

indicate that the number of air samples required may be increased to clearly define the

particulate distribution within the plume. For example:

 Sampling Locations – The procedures stipulate how to choose a suitable location(s) to

collect an air sample. Some of the air samples would preferably be collected near a peak

exposure rate reading acquired while traversing the plume. Additional samples are taken at

other locations, including areas near the plume edge. In the case of no release, several

locations may be used to confirm the absence of a release.

 Monitoring – Waist level or higher ambient radiation readings are taken at the beginning,

middle, and end of the sampling period

 Flow Rate – The flow rate and total volume collected are appropriate to allow the collection

and analytical system to assure capability to detect 10-7 microcuries per cubic centimeter

(Ci/cc) of radioiodine.

 Cartridge/Filter – The type of cartridge and particulate filter used are noted.

 Counting – Counting procedures for field measurements are noted, such as:

 Traveling to a low background area.

 Obtaining gross count or using a single-channel analyzer.

 Counting the cartridge and particle filter.

 Using reproducible geometry when measurements are taken.

 Bagging/Labeling – Methods are described for bagging and labeling samples, including the

information that will be provided on the label (e.g., location, time, date, sample or ambient

exposure rate, name of collector). The plan/procedures also include instructions for a chainof-custody form.

 Transfer – The plan/procedures include the method for transferring and dispatching samples

to the laboratory for isotopic analysis of particulates and for radionuclides, especially if only

gross measurements were taken on the cartridge.

(5) Environmental Sampling Procedures: Procedures for collecting samples to support both

ingestion and relocation decisions describe the following:

 The media to be sampled.

 Methods for obtaining samples (e.g., tools to use, size of the sampling area, weight or

volume of samples collected).

 Methods for bagging and labeling samples, including a chain-of-custody form.

 Information to be included on labels.

 Methods for determining sampling locations (e.g., exposure rates).

 Methods to prevent cross-contamination.

(6) Other information collected on samples taken to support the relocation decision includes the

following:

 Size of the area from which the sample was taken and procedures for selecting sampling

locations (e.g., exposure rates).

 Transfer and dispatch of samples to the laboratory.

 Ambient radiation exposure rate, which is taken for each sample and recorded on its label.
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i. Laboratories

The plans/procedures indicate the laboratory(ies) to which specific samples will be sent. The capability of

each laboratory to analyze various radioisotopes is addressed in Criterion C.3. In addition, the procedures

describe the arrangements for transporting samples and temporary storage of samples when needed. The

plans/procedures clearly identify the estimated times required to transport collected air samples to the

designated laboratory(ies), perform the required analyses, and transmit the results to the appropriate

locations (e.g., dose assessment group). Transportation of plume phase samples to the laboratory is

completed within 4 hours. Finally, the procedures indicate the capability to ensure the security and

integrity of collected samples through documentation and maintenance, such as chain-of-custody forms.

Fixed laboratories or (if available) mobile laboratories can be used in lieu of portable instruments for the

FMT to perform an early assessment, provided that: (1) the laboratory is equipped with appropriate

counting equipment and (2) the laboratory is able to provide analysis of air samples for airborne

radioiodine and particulates in a time comparable to the FMT. If applicable, plans/procedures indicate the

placement of mobile laboratories at pre-designated staging areas. In addition, if the plans/procedures state

that an additional private laboratory(ies) will be used in support of the state in sample analysis or that the

licensee‘s laboratory will be used, appropriate LOAs are referenced in the plans/procedures, as described

in Criterion A.3.

j. Radiological Exposure Control

The plans/procedures identify the requirements for FMT members‘ radiological exposure control (see

Planning Standard K).

References

 FEMA-REP-2, Revision 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 

– Airborne Release, June 1990.

 FEMA-REP-12, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 2 – The 

Milk Pathway, September 1987.

 FEMA-REP-13, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 3 – Water 

and Non-Dairy Food Pathway, May 1990.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 Federal Register, Volume 63, No. 156, pp.43402-43403, Accidental Radioactive Contamination of 

Human Food and Animal Feeds: Recommendations for State and Local Agencies, Food and Drug 

Administration, August 13, 1998..

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION I.9

Each organization shall have a capability to detect and measure radioiodine

concentrations in air in the plume exposure EPZ as low as 10-7Ci/cc (microcuries

per cubic centimeter) under field conditions. Interference from the presence of noble

gas and background radiation shall not decrease the stated minimum detectable

activity.

Applicability and Cross Reference to Plans: Licensee X State X Local X
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TO MEET THE INTENT OF CRITERION I.9, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The capability to collect air samples within the plume and perform analysis that will detect radioiodine

concentrations as low as 10-7Ci/cc under field conditions.

 The process used for collecting air samples, including location of sampling points, timing of sample

collection, and techniques used to collect and count (see Criterion I.8).

EXPLANATION

Early determination of the potential thyroid dose will be needed. An activity level of about 10-7Ci/cc of

radioiodine is required to make a thyroid dose calculation. Some procedures call for the FMTs to make

this measurement using portable instrumentation. The procedures allow for collection of sufficient

quantities of radioiodine in a reasonable sampling time to permit field measurement in the presence of

noble gases. Those organizations that deploy mobile laboratories can use them to measure the radioiodine

concentrations; nonetheless, they still need to maintain the ability to use portable detection equipment to

meet this standard. The plans/procedures also state that interference from noble gas and background

radiation does not decrease the stated minimum detectable activity. See Criterion I.8 for field monitoring

and sampling procedures and equipment.

Reference:

 FEMA-REP-2, Revision 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 

– Airborne Release, June 1990.

NUREG CRITERION I.10

Each organization shall establish means for relating the various measured

parameters (e.g., contamination levels, water, and air activity levels) to dose rates for

key isotopes (i.e., those given in [NUREG-0654/FEMA-REP-1] Table 3, page 18) and

gross radioactivity measurements. Provisions shall be made for estimating

integrated dose from the projected and actual dose rates and for comparing these

estimates with the protective action guides.41 The detailed provisions shall be

described in separate procedures.

Applicability and Cross Reference to Plans: Licensee X State X Local 

TO MEET THE INTENT OF CRITERION I.10, ORO PLANS/PROCEDURES SHALL ADDRESS THE

FOLLOWING POINTS FOR THE EARLY, INTERMEDIATE, AND LATE PHASES:

 Personnel and equipment that will be involved in dose assessment.

 Computer software and documentation, including data input procedures, that will be used.

 Alternate methods that may be used (e.g., hand calculations).

 Information/variables to run the model, including proper units of measure.

 Means for obtaining initial information (e.g., from licensee monitors or inventory estimates).

 Use of field data to verify and modify model results.

 Procedures for comparing dose results with those of other organizations that perform dose assessments.

 

41 The FDA revised guidance refers to DILs.
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EXPLANATION

The plans/procedures for the state (and for local governments, if applicable) describe the methods to

estimate actual or potential doses to the public in terms that may be compared with both the EPA-400

PAGs and FDA derived intervention levels (DILs). The plans/procedures also identify that there are three

phases: early (plume activities), intermediate (ingestion/relocation activities), and late (return/recovery

activities).

References

 NUREG-0654/FEMA-REP-1, Revision 1, Table 3, page 18, October 1980.

 FEMA-REP-2, Revision 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 

– Airborne Release, June 1990.

 FEMA-REP-12, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 2 – The 

Milk Pathway, September 1987.

 FEMA-REP-13, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 3 – Water 

and Non-Dairy Food Pathway, May 1990.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 Federal Register, Volume 63, No. 156, pp.43402-43403, Accidental Radioactive Contamination of 

Human Food and Animal Feeds: Recommendations for State and Local Agencies, Food and Drug 

Administration, August 13, 1998.

NUREG CRITERION I.11

Arrangements to locate and track the airborne radioactive plume shall be made,

using either or both Federal and State resources.

Applicability and Cross Reference to Plans: Licensee State X Local 

TO MEET THE INTENT OF CRITERION I.11, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The planned use of any outside resources to locate and track the plume, including taking measurements

and collecting air samples from or near the plume‘s peak concentration, if applicable.

EXPLANATION

Criterion I.8 requires detailed description of FMT procedures for plume monitoring. If the state plans to

track and define only the outer edges of the plume, plans/procedures reference arrangements for the use of

outside resources to take measurements and collect air samples from peak exposure rate areas near the

plume‘s peak concentration. For example, organizations may rely on Federal, licensee or other (e.g.,

university, contractor, mutual-aid) FMT data. These arrangements are established in LOAs, as

appropriate.

References

 FEMA-REP-2, Revision 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 

– Airborne Release, June 1990.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.
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10. PLANNING STANDARD J – PROTECTIVE RESPONSE

A range of protective actions have been developed for the plume exposure pathway EPZ for

emergency workers and the public. In developing this range of actions, consideration has

been given to evacuation, sheltering, and as a supplement to these, the prophylactic use of

potassium iodide (KI), as appropriate.42 Evacuation time estimates have been developed by

applicants and licensees and must be updated on a periodic basis.43 Guidelines for the

choice of protective actions during an emergency, consistent with Federal guidance, are

developed and in place, and protective actions for the ingestion exposure pathway EPZ

appropriate to the locale have been developed.

NUREG CRITERION J.1

Each licensee shall establish the means and time required to warn or advise onsite

individuals and individuals who may be in areas controlled by the operator,

including:

a. Employees not having emergency assignments;

b. Visitors;

c. Contractor and construction personnel; and

d. Other persons who may be in the public access areas on or passing

through the site or within the owner-controlled area.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION J.2

Each licensee shall make provisions for evacuation routes and transportation for

onsite individuals to some suitable offsite location, including alternatives for

inclement weather, high traffic density, and specific radiological conditions.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION J.2, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Assistance that will be provided to licensees during an evacuation of the site or a statement that no

assistance is required.

 The alternatives that will be implemented during inclement weather and/or high traffic densities.

 Provisions for coordinating arrangements with other offsite organizations to expedite evacuation of

onsite personnel.

EXPLANATION

The plans/procedures describe how OROs (e.g., state, local, or tribal police) will provide assistance to

licensees in managing the flow of traffic from the NPP in cases where the licensee evacuates nonessential onsite personnel. These procedures take into account conditions such as inclement weather, high

 

42 Sentence added per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 2002.

43 Sentence added per NRC rule revision, 2011.
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traffic density, and/or threat conditions. Plans/procedures also describe provisions for coordinating

arrangements with other offsite organizations to expedite the evacuation of onsite personnel.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION J.3

Each licensee shall provide for radiological monitoring of people evacuated from the

site.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION J.4

Each licensee shall provide for the evacuation of onsite non-essential personnel in

the event of a Site or General Emergency and shall provide a decontamination

capability at or near the monitoring point specified in J.3.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION J.5

Each licensee shall provide for a capability to account for all individuals onsite at the

time of the emergency and ascertain the names of missing individuals within 30

minutes of the start of an emergency and account for all onsite individuals

continuously thereafter.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION J.6

Each licensee shall, for individuals remaining or arriving onsite during the

emergency, make provisions for:

a. Individual respiratory protection;

b. Use of protective clothing; and

c. Use of radioprotective drugs (e.g., individual thyroid protection).

Applicability and Cross Reference to Plans: Licensee X State Local 

NOTE: Although this criterion is the responsibility of the licensee, OROs that expect to provide

onsite support in an emergency should be aware of the licensee‘s arrangements regarding provision of

additional protective equipment and radioprotective drugs.
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NUREG CRITERION J.7

Each licensee shall establish a mechanism for recommending protective actions to

the appropriate State and local authorities. These shall include Emergency Action

Levels corresponding to projected dose to the population-at-risk, in accordance with

[NUREG-0654/FEMA-REP-1] Appendix 1 and with the recommendations set forth in

Tables 2.1 and 2.2 of the Manual of Protective Actions for Nuclear Incidents (EPA400-R-92-001).

44 As specified in NUREG-0654/FEMA-REP-1] Appendix 1, prompt

notification shall be made directly to the offsite authorities responsible for

implementing protective measures within the plume exposure pathway Emergency

Planning Zone.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION J.8

Each licensee’s plan shall contain time estimates for evacuation within the plume

exposure EPZ. These shall be in accordance with [NUREG-0654/FEMA-REP-1]

Appendix 4.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION J.9

Each State and local organization shall establish a capability for implementing

protective measures on the basis of Protective Action Guides and other criteria. This

shall be consistent with the recommendations of the EPA regarding exposure

resulting from passage of radioactive airborne plumes, (EPA-400-R-92-001)

45 and

with those of DHEW (HHS)/FDA regarding radioactive contamination of human food

and animal feeds as published in the Federal Register of August 13, 1998 (63 FR

4340246).

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION J.9, ORO PLANS/PROCEDURES SHALL INCLUDE:

 The organization‘s procedures for making PADs and implementing protective actions based upon

PAGs that are consistent with EPA recommendations.

 The process followed to ensure coordination of PADs with all appropriate jurisdictions.

EXPLANATION

The plans/procedures describe the process and timeframe for making and implementing initial PADs on

the basis of licensee notification of plant status, licensee PARs, and input from appropriate ORO

authorities. The plans/procedures also describe the capability to respond to a rapidly escalating incident

 

44 Original reference to EPA-520/1-75-001 replaced with EPA-400-R-92-001 per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 

2002.

45 Original reference to EPA-520/1-75-001 replaced with EPA-400-R-92-001 per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 

2002.

46 Original reference to 43 FR 58790 (December 15, 1978) replaced by the Department of Health and Human Services (HHS) and the Food and 

Drug Administration (FDA) guidance, Guidance on Accidental Radioactive Contamination of Human Food and Animal Feeds, 

Recommendations for state and Local Agencies, (August 13, 1998) (63 FR 43402) per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, 

March 2002.
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and contain predetermined PADs to protect the public in these situations.

47 The plans/procedures may

allow for precautionary evacuation of persons with disabilities and access/functional needs if the OROs

choose to do so and include precautionary or protective actions for schools, hospitals/medical facilities,

nursing homes, and other facilities if the ORO decision-makers elect this option.

a. Protective Action Guides

The plans/procedures include the PAGs; these may be expressed as a range as stated in EPA 400-R-92-

001, and the capability to determine the PAG value appropriate for the incident. Usually, it is appropriate

to evacuate areas where doses are projected to exceed 1 rem total effective dose equivalent (TEDE) or 5

rem committed dose equivalent thyroid, the lower end of the PAG range (1-5 rem or 5-25 rem), except for

incidents that involve a high-risk environment or high-risk groups (e.g., mobility-impaired). In these

cases, the plans/procedures provide for flexibility where doses up to the upper end of the PAG range may

be the preferred decision criterion.

Since the EPA performed risk evaluations during the development of the PAGs, it is not normally

necessary to calculate the risk trade-offs among evacuation, sheltering, and radiation dose during an

emergency response. For areas not being recommended for evacuation, ORO plans/procedures include

instructions for the public to stay indoors and await additional instructions in areas downwind of the EPZ

at distances beyond the areas designated for evacuation. The decision to substitute shelter for evacuation

at projected doses up to 5 rem TEDE is based upon whether the risk of evacuation is significantly higher

than normal. Sheltering, rather than evacuation, should be chosen in any incident where sheltering would

provide overall greater protection, provided that adequate information is available to make this judgment.

For further guidance, see NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Guidance for 

Protective Action Strategies, October 2011.

b. Protective Action Decision Making

For an incident involving actual or significant potential for offsite consequences, it may be appropriate to

immediately take protective actions (e.g., evacuation or sheltering), without waiting for release rate

information or environmental measurements. Weather conditions, the direction of the plume, an HAB

incident, or other circumstances may pose an undue risk to evacuation. The decision process takes into

account the onsite officials‘ uncertainty on plant conditions and uncertainty or unfavorable prognosis of

events controlling the incident. In some situations, sheltering may be the preferred protective action. For 

supplementary guidance on the development of predetermined PADs that take into account multiple 

variables, see NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Guidance for Protective Action 

Strategies, October 2011.

In an HAB incident, the protective action decision-making process is complicated by the potential risks

posed by the hostile activities themselves (i.e., more harm could be caused to individuals being evacuated

if they are being moved into or through an area affected by a terrorist threat or act or an evacuation may

disrupt the efforts to respond to a hostile action). Actions taken by the Incident Commander, such as

closing major roadways or implementing a precautionary evacuation or sheltering close to the NPP site,

may also significantly impact protective action considerations.

To account for these potential risks, PADs are closely coordinated/communicated between appropriate

ORO decision-makers, and include consideration of the risk of evacuation against the risk of sheltering in

place. If the decision is to evacuate some or all of the population in the EPZ, ORO decision-makers plan

 

47

 Updated FEMA and NRC guidance in NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Guidance for Protective Action Strategies, 

2011, provides a protective action logic development tool that should be used by licensees to develop site specific protective action 

recommendation procedures and is recommended for use by OROs to develop protective action strategy guidance for decision makers.
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for contingencies that would minimize congestion caused by emergency workers entering the area at the

same time that the public is evacuating.

The plans/procedures may call for joint decision-making with other jurisdictions. In such cases, the

plans/procedures describe the process for communicating/coordinating with all affected jurisdictions to

arrive at mutually acceptable PADs. If joint decision-making is not required, the plans/procedures

describe the capability to communicate the essential contents of PADs to all affected jurisdictions.

c. Subsequent Protective Action Decisions

After initial PADs have been made and additional information becomes available regarding potential or

actual releases, the dose assessment group may provide additional PARs based on dose projections. When

field monitoring data become available, they are used as a basis for making decisions concerning

protection of the public in additional locations. In general, protective actions that have been implemented

should not be reversed based on revised dose assessments or early field measurements.

d. Protective Action Decisions for the Ingestion Exposure Pathway

In addition, the plans/procedures identify the protective actions and radiation dose or concentration levels

that will be used in making decisions about the ingestion exposure pathway. If doses other than those

recommended by HHS and FDA guidance are adopted by OROs, the plans/procedures provide an

adequate justification for not following the FDA guidance. The approach adopted by the FDA uses DILs

(derived intervention levels), measured concentrations of specific radionuclides in foods in lieu of the

PAGs. In order to characterize the extent of the problem, many laboratory analyses may be required. The

plans/procedures specify the actions that will be taken prior to the determination of the actual levels of

contamination in the food produced in the impacted area.

References

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 EPA 400-R-92-001, The Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 Federal Register, Volume 63, No. 156, pp.43402-43403, Accidental Radioactive Contamination of 

Human Food and Animal Feeds: Recommendations for State and Local Agencies, Food and Drug 

Administration, August 13, 1998.

 NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants –

Guidance for Protective Action Strategies, October 2011.

NUREG CRITERION J.10

The organization’s plans to implement protective measures for the plume exposure

pathway shall include the following:
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NUREG CRITERION J.10.a

Maps showing evacuation routes, evacuation areas, pre-selected radiological

sampling and monitoring points, relocation centers in host areas, and shelter areas

(identification of radiological sampling and monitoring points shall include the

designators in [NUREG-0654/FEMA-REP-1] Table J-1 or an equivalent uniform

system described in the plan);

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION J.10.a, ORO PLANS/PROCEDURES SHALL:

 Include clearly legible maps of all evacuation routes, evacuation areas, pre-selected radiological

sampling and monitoring points (including water supplies), reception and congregate care centers in

host/support jurisdictions, decontamination facilities, and shelter areas.

 Describe the procedures and organization(s) responsible for updating and maintaining maps, as

necessary, using the most current and accurate data (e.g., census data, state and county records, etc).

EXPLANATION

The plans/procedures contain, possibly in a separate appendix, clear, legible maps and displays showing

features or landmarks important to emergency response during the early phase of the emergency.

Approved geographic information systems data and products, as outlined by plans/procedures, may be

used. Examples of map data include the plume exposure pathway EPZ and its various sectors and

planning areas (may be referred to as Emergency Response Planning Areas); roads; streams; towns;

evacuation routes; reception and congregate care centers; decontamination facilities; special facilities

such as schools, nursing homes, and hospitals; and radiological monitoring points. The plans/procedures

describe the procedure for updating maps, as necessary, and identify the organization(s) responsible for

map maintenance. The maps are updated using the most current and accurate data (e.g., census data, state

and county records, etc.).

References

 NUREG-0654/FEMA-REP-1, Revision 1, Table J-1, page 62, October 1980.

 FEMA GM-21, Revision 1, Acceptance Criteria for Evacuation Plans, February 29, 1984.

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION J.10.b

Maps showing population distribution around the nuclear facility. This shall be by

evacuation areas48 (licensees shall also present the information in a sector format);

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION J.10.b, ORO PLANS/PROCEDURES SHALL INCLUDE:

 Clear, legible maps showing population distribution around the NPP, possibly in a separate appendix.

 

48 The term ―evacuation areas‖ used in this criterion corresponds to the term ―planning areas‖ used throughout this document.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-76 October 2011

EXPLANATION

ORO maps of population distribution are by planning areas. Approved geographic information system

data and products, as outlined by plans/procedures, may be used. These maps also identify school

populations, including licensed daycare centers and other agencies and organizations that provide FNSS,

or provide reference to where the information may be found, and include the maximum anticipated

population at recreation areas.

References

 FEMA GM-21, Revision 1, Acceptance Criteria for Evacuation Plans, February 29, 1984.

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION J.10.c

Means for notifying all segments of the transient and resident population;

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION J.10.c, ORO PLANS/PROCEDURES SHALL:

 Meet the requirements listed under Criteria E.5, E.6, and E.7

EXPLANATION

Specifics regarding means for notifying all segments of the transient and resident population are discussed

in Criteria E.5, E.6, and E.7. Refer to these criteria for detailed guidance.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION J.10.d

Means for protecting those persons whose mobility may be impaired due to such

factors as institutional or other confinement;

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION J.10.d, ORO PLANS/PROCEDURES SHALL:

 Describe the means to protect those persons whose mobility may be impaired because of institutional

or other confinement (e.g., children in schools and licensed daycare centers and persons in nursing

homes, hospitals, and correctional facilities).

 Describe the methods for determining the number of persons who may need assistance and the type of

assistance, per planning area.

 Reference lists of documented individuals who need assistance in an evacuation of the EPZ and

processes for keeping the lists up to date.
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REP Program Manual Page II-77 October 2011

 Describe processes for evacuating persons with disabilities and access/functional needs and for

sheltering in place those who cannot be moved.

 Describe any special transportation needs for these groups and the transportation resources, including

types and quantities of vehicles, used to move them.

EXPLANATION

There are multiple subsets of persons whose mobility may be impaired during evacuations that are

addressed in ORO plans/procedures.

a. Schools

The plans/procedures identify schools (i.e., public and private, kindergartens, pre-schools, and licensed

daycare centers) within the plume exposure EPZ, as well as the persons responsible for planning and

implementing protective actions for them. The plans/procedures stipulate that OROs, as appropriate, will

take the initiative to identify and contact all schools within the plume EPZ to ensure that officials have

plans/procedures in place for protecting the health and safety of the children under their care. Protective

action options in the plans/procedures include provisions for notifying parents and guardians of the status

and location of their children during a radiological emergency.

For schools, plans/procedures include:

 Identification of the organization and officials responsible for both planning and implementing the

protective actions.

 Institution-specific information (e.g., name and location, type of institution and age grouping, total

population, means for implementing protective actions, transportation resources, name and location of

relocation centers and, if applicable, host schools and the methods for contacting the relocation centers

and host schools).

 Time frames for implementing protective actions.

 Means for alerting and notifying schools, including:

 Identification of the organization responsible for providing emergency information to the

schools.

 Methods (e.g., siren or telephone calls) for contacting and providing the emergency

information to school officials.

 Methods (e.g., tone alert radios or telephone calls) for contacting and activating designated

transportation resources (e.g., dispatchers or school bus drivers).

 Methods (e.g., EAS messages or special news broadcasts) for notifying parents and guardians

of the status and location of their children.

b. Daycare Centers

The licensing of daycare centers by governmental organizations places them under government regulation

and standards. The licensing standards establish the legal responsibilities of the managers of the centers

for the care, health, and safety of persons under their care, both for routine and emergency situations. In 

some states, certain types of daycare facilities are exempt from licensing requirements (e.g., if the daycare

center is located within the physical structure of a religious building or under a certain size). Exempt

facilities are considered part of the general population for planning purposes. When possible, FEMA

encourages OROs to work with known unlicensed and exempt daycare providers.49

 

49 A daycare center is any facility that provides care for children outside of a school classroom and is located either within or at a facility separate 

from the provider‘s permanent residence.
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c. Health Care Facilities

The plans/procedures describe the means of evacuating patients in hospitals, nursing homes, and other

healthcare facilities, and the actions required to protect those patients who cannot be relocated out of the

hazard area.

d. Documented individuals who need assistance in an evacuation

The plans/procedures provide for a means of protecting all categories of individuals needing assistance

during an evacuation present in the EPZ. These persons may include, but are not limited to, residents with 

disabilities, access or functional needs, or those who may live in a facility such as an assisted living 

community or skilled nursing home , children and adults whose mobility is impaired due to institutional

or other confinement, and the transportation-dependent. For each resident needing assistance during an

evacuation, plans/procedures include or reference contacts to provide communication and physical

assistance, as well as agreements with transportation providers. For those individuals requiring the

assistance of service animals, the plans/procedures also include provisions for the animals‘ protection and

accommodation. Agreements are made with hospitals/medical facilities, mental hospitals, adult care

facilities, and community mental health centers outside the EPZ to receive the severely mobility-impaired

and emotionally disabled.

For documented individuals who need assistance in an evacuation, ORO plans/procedures include:

 Reference to a list of all individuals within the EPZ needing assistance during an evacuation and the

process for keeping the list current (e.g., working with those organizations that provide assistance to

individuals who may need special assistance in an evacuation). This list is maintained at the local risk

government EOC and may be included by reference.

 Means to protect those persons whose mobility may be impaired because of institutional or other

confinement, including those who cannot be evacuated and must be sheltered. A means of informing

these individuals of planned emergency procedures is addressed.

 An up-to-date estimate of transportation needs and list of potential resources, including types and

quantities, to move the mobility impaired.

e. Correctional Facilities

The plans/procedures identify correctional facilities located in the plume EPZ and the persons responsible

for planning and implementing protective actions for the correctional facility populations. Planned

protective actions are also described.

References

 National Response Framework, Mass Evacuation Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 Pub.L. 109-295, October 4, 2006.
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NUREG CRITERION J.10.e

Provisions for the use of radioprotective drugs, particularly for emergency workers

and institutionalized persons within the plume exposure EPZ whose immediate

evacuation may be infeasible or very difficult, including quantities, storage, and

means of distribution;50

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF J.10.e, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 What groups might be advised to take KI.

 Adequate supply of radioprotective drugs for each individual, including quantities, storage locations,

and means of distribution.

 Adequate maintenance, shelf life extensions, and timely replacement of radioprotective drugs.

 Means for communicating a recommendation to take radioprotective drugs to emergency workers,

institutionalized persons, and (if included as an option in the plans/procedures) the general public.

EXPLANATION

The plans/procedures describe the jurisdiction‘s policies on the use of radioprotective drugs, including

what groups might be advised to use KI, how the decision to use KI would be made, and how KI would

be implemented. This criterion focuses on implementation of KI use, including maintenance of KI

supplies, distribution, and record keeping. Criterion J.10.f. focuses on the decision-making processes

leading to KI use.

The plans/procedures identify what groups might be instructed or advised to use KI, including emergency 

workers, particular institutions within the plume EPZ whose populations could not be evacuated quickly,

and, if applicable, the general population. In planning for the use of KI by institutionalized populations,

such as hospital/medical facility patients, OROs also consider provisions for the use of KI by the

institutional staff that will care for them. OROs plan for and maintain an adequate supply for each

individual,

51 and plans/procedures identify quantities, storage locations, and means of distribution. For

those emergency response organizations that do not routinely distribute KI to emergency workers, but

rather distribute KI based on incident and release characteristics, the plans/procedures clearly identify the

method and time required to complete the distribution. The plans/procedures also identify how

recommendations to take the drugs will be communicated to emergency workers and institutionalized

persons. The plans/procedures include the forms used for documenting ingestion of radioprotective drugs,

as well as information regarding emergency workers and others who have declined the use of KI in

advance. OROs document procedures for maintaining a radioprotective drug supply, including acceptable

storage conditions, obtaining shelf life extensions, and replacement.

The plans/procedures include a statement that the manufacturer‘s instructions will be provided with KI. 52

Those organizations that have chosen to acquire KI for use by the general public must incorporate

distribution procedures into the plans/procedures within one year of receiving the KI.

 

50 The NRC has ruled that the use of KI for the general public be considered during the planning process according to Consideration of Potassium 

Iodide in Emergency Plans, Final Rule, 66 FR 5427, (January 19, 2001). 

51 For additional guidance, see Distribution and Administration of Potassium Iodide in the Event of a Nuclear Incident, Board on Radiation 

Effects Research, National Research Council of the National Academies, 2004.

52 Manufacturer‘s patient information is available on the ―Drugs@FDA‖ Approved Drug Products database website at 

http://www.accessdata.fda.gov/scripts/cder/drugsatfda/ . 
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References

 Federal Register, Vol. 67, No. 7, pp.1355-1357, Federal Policy on Use of Potassium Iodide (KI), 

Federal Emergency Management Agency, January 10, 2002.

 Policy Paper: Federal Emergency Management Agency‘s Radiological Emergency Preparedness

Program Guidance to States and Local Governments for Shelf Life Extension of Potassium Iodide

(KI), April 12, 2007.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 Federal Register Volume 66, No. 13, pp. 5427-5440, Consideration of Potassium Iodide in 

Emergency Plans, Final Rule, Nuclear Regulatory Commission, January 19, 2001.

 Federal Register, Volume 66, No. 238, pp.64046-64047, Guidance on Use of Potassium Iodide as a 

Thyroid Blocking Agent in Radiation Emergencies, Food and Drug Administration, December 11, 

2001.

 Distribution and Administration of Potassium Iodide in the Event of a Nuclear Incident, Board on 

Radiation Effects Research, National Research Council of the National Academies, 2004.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION J.10.f

State and local organizations’ plans should include the method by which decisions

by the State Health Department for administering radioprotective drugs to the

general population are made during an emergency and the pre-determined

conditions under which such drugs may be used by offsite emergency workers;53

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION J.10.f, ORO PLANS/PROCEDURES SHALL:

 Identify, by title/position, those who will make decisions regarding the use of KI during an emergency.

 Describe the criteria and decision-making processes for recommending the use of KI.

EXPLANATION

The plans/procedures identify the decision-makers, by title/position, and describe the decision-making

processes used by the state health department or appropriate government agencies for recommending

administration of radioprotective drugs, such as KI, during an emergency. The plans/procedures describe

the criteria for determining whether KI is administered, including criteria for emergency workers,

institutionalized persons, and the general population, if applicable.

Guidance on the criteria for decisions to administer KI varies. EPA 400-R-92-001 recommends a

projected dose of 25 rem committed dose equivalent thyroid as warranting KI for the general public if

administration of KI is included in the plans/procedures. For emergency workers, EPA 400-R-92-001

recommends KI if atmospheric releases include radioiodine. The most recent guidance issued by the

FDA, Potassium Iodide as a Thyroid Blocking Agent in a Radiation Emergency, (66 FR 64046, 

December 11, 2001) discusses the administration of KI if the projected dose to the thyroid exceeds 5 rem,

without regard to the population group. The documents leave the decision on conditions that warrant

 

53 See FDA Federal Register notice 66 FR 64046 Potassium Iodide as a Thyroid Blocking Agent in a Radiation Emergency December 11, 2001. 

The FDA document replaces the original footnote reference to DHEW document 43 FR 58798 per NUREG-0654/FEMA-REP-1, Revision 1, 

Addenda, dated March 2002.
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administration of KI to state medical officials. FDA guidance describes varying levels of projected doses,

depending on age of the recipient, that warrant the use of KI.

References

 Federal Register, Vol. 67, No. 7, pp.1355-1357, Federal Policy on Use of Potassium Iodide (KI), 

Federal Emergency Management Agency, January 10, 2002.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 Federal Register, Volume 66, No. 238, pp.64046-64047, Guidance on Use of Potassium Iodide as a 

Thyroid Blocking Agent in Radiation Emergencies, Food and Drug Administration, December 11, 

2001.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION J.10.g

Means of relocation;54

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION J.10.g, ORO PLANS/PROCEDURES SHALL DESCRIBE HOW

THE PUBLIC WITHIN THE PLUME EXPOSURE PATHWAY EPZ WILL BE EVACUATED, INCLUDING:

 Means for controlling traffic to assure a safe and efficient evacuation.

 Procedures for implementing alternate evacuation routes, if warranted.

 Transportation resources, including drivers.

 The methods for determining the number of persons without private transportation, per planning area.

 Designated pickup points for persons without private transportation.

EXPLANATION

The plans/procedures identify how the general public within the 10-mile EPZ will be evacuated if

necessary. This includes individuals who are capable of using public transportation; the evacuation of

individuals who need special assistance in an evacuation due to physical or mental disability or

institutional or other confinement is addressed in Criterion J.10.d. The plans/procedures include measures

to promote smooth flow of evacuation traffic and assist persons who have no means of transportation.

Measures to promote smooth flow of evacuation traffic include designation of evacuation routes and

establishment of traffic control points (TCPs) along these routes, as necessary. OROs identify personnel

and equipment for traffic control. In some cases, plans/procedures may call for converting two-way roads

to one-way in order to increase their traffic capacity. During HAB incidents, OROs may need to use

alternate evacuation routes to avoid areas of hostile activity or to facilitate in-bound response.

The process for assisting persons without transportation include: (1) determining transportation resources,

(2) determining the number of persons who may need assistance per planning area, and (3) designating

pickup points for individuals without transportation. This criterion does not include transportation of the

mobility-impaired; see Criterion J.10.d. for this discussion. The plans/procedures provide, in a separate

appendix or in appropriate sections, any LOAs that have been established to obtain these resources, as

described in Criterion A.3.

 

54 In current terminology, this refers to ―evacuation.‖ Relocation is a non-urgent action during the post-emergency phase.
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References

 National Incident Management System, December 2008.

 National Response Framework, Mass Evacuation Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION J.10.h

Relocation centers in host areas which are at least 5 miles, and preferably 10 miles,

beyond the boundaries of the plume exposure emergency planning zone (see

[NUREG-0654/FEMA-REP-1 Criterion] J.12);

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION J.10.h, ORO PLANS/PROCEDURES SHALL IDENTIFY:

 All relocation centers and host schools for evacuees and students by name and address.

 Organizations responsible for managing the centers and staffing requirements for each center.

 Arrangements for handling students at relocation centers and/or host schools.

 Arrangements for handling service animals.

 Hospitals, correctional facilities, and nursing homes that will receive evacuees.

 Provisions for the radiological monitoring of evacuees, service animals, and evacuee vehicles,

according to the plans/procedures. If students are taken to host schools where monitoring capabilities

are not present, the plans/procedures address any special considerations for radiological monitoring of

student evacuees following a release.

 Provisions for students at schools outside the EPZ who reside within the EPZ.

EXPLANATION

The plans/procedures identify relocation centers in host/support jurisdictions. These centers are located at

least 5 miles and preferably 10 miles beyond the boundaries of the plume exposure pathway EPZ. The

plans/procedures provide information on all relocation centers, including name, specific location (e.g.,

address, city), capacity, organization managing the center, and accessibility to persons with disabilities 

and access/functional needs, including those persons requiring the assistance of service animals. The

plans/procedures also identify how evacuee vehicles will be handled at reception centers. Additionally,

the plans/procedures address the LOAs that have been established with all resources and facilities, either

in a separate appendix or in appropriate sections, as described in Criterion A.3.

The plans/procedures also identify, if possible, which schools will be directed to which relocation centers

and/or host schools (located beyond the plume exposure pathway EPZ boundary). The plans/procedures

describe arrangements for handling the students, including the initial assignment of students to specific

areas within the centers, as well as the arrangements for the pickup of students by parents or guardians.

The plans/procedures identify any hospitals, correctional facilities, and nursing homes that will receive

evacuees.

The plans/procedures also describe the process for the radiological monitoring of evacuees and service

animals sent to these facilities.
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Some evacuees may need congregate care after arriving at a relocation center. Current FEMA policy 

requires that the planning basis for monitoring personnel and equipment needs be 20 percent of the EPZ

population (See Criterion J.12). OROs also use this 20 percent of the EPZ population as a planning basis

for determining the number of congregate care centers needed to accommodate evacuees from the EPZ.

While the actual proportion of individuals seeking congregate care could be more or less than 20 percent,

it is prudent to incorporate a planning basis that can be modified as the incident warrants.

References

 Pub.L. 109-295, October 4, 2006.

NUREG CRITERION J.10.i

Projected traffic capacities of evacuation routes under emergency conditions;

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION J.10.i, ORO PLANS/PROCEDURES SHALL:

 Reference the evacuation time estimate (ETE) studies and include the results of the ETEs.

 Reference the traffic capacities of the evacuation routes.

 Discuss the potential need to use alternate routes because of traffic impediments, adverse weather

conditions, an airborne radioactive plume, areas affected by hostile actions, or other factors that might

hinder a timely, safe evacuation.

 Provide maps as described in Criterion J.10.a.

EXPLANATION

The licensee is responsible for conducting and updating the ETE; review of ETE studies is generally

performed by transportation experts contracted by the NRC. OROs use ETE information to plan for

evacuation. Population and roadway capacity, the primary elements in the ETE, are periodically evaluated

and updated to determine if there is an impact on the ETE. The population review not only addresses

increases in population, but also assesses the age demographics and persons with disabilities and 

access/functional needs as well. The roadway capacity assessment includes review of transportation

improvements, constraints, traffic flow, and changes in transient traffic flow through the EPZ.

Licensees update the ETE in accordance with current NRC guidance. As a general rule, the ETE is 

revised every 10 years following the U.S. census. In addition, an ETE update must be performed at any 

time during the decennial period if the EPZ permanent resident population estimate increases such that it 

causes the longest ETE value for the 2-mile or 5-mile zone, including affected emergency response 

planning areas, or for the entire 10-mile EPZ to change by 25 percent or 30 minutes, whichever is less, 

from the licensee‘s currently approved ETE.

References

 NUREG/CR7002, Criteria for Development of Evacuation Time Estimate Studies

 National Incident Management System, December 2008.

 National Response Framework, Mass Evacuation Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
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NUREG CRITERION J.10.j

Control of access to evacuated areas and organization responsibilities for such

control;

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION J.10.j, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Procedures for controlling road access to sheltered and/or evacuated areas, including organization(s)

responsible for staffing TCPs and Access Control Points (ACPs).

 Maps identifying TCPs/ACPs (may be incorporated by reference).

 Equipment and resources needed (e.g., cones or barricades).

 Procedures and responsibilities for controlling access via other transportation modes.

 Procedures and responsibilities for controlling ingress and egress to other areas affected by an incident.

 Procedures for providing TCP/ACP staff with the status of emergency response activities.

EXPLANATION

The plans/procedures identify the various transportation modes (e.g., air, rail, water, and highway) in the

plume EPZ and the organization(s) responsible for controlling each mode. Plans/procedures identify the

means for controlling access to sheltered and/or evacuated areas and other areas affected by an incident.

OROs describe roles and responsibilities for TCP and ACP personnel, including procedures for verifying

emergency worker identification and authorizing access to the affected areas. The plans/procedures

include or reference maps identifying the locations of TCPs and ACPs. The plans/procedures contain

information relevant to TCP/ACP setup and implementation, including equipment and resources (e.g.,

cones and barricades). The plans/procedures also include contingency measures if it becomes necessary to

have additional staff and/or equipment available for traffic and access control. In addition, the

plans/procedures address the means and frequencies for providing TCP/ACP staff with the status of

emergency response activities.

References

 NUREG/CR7002, Criteria for Development of Evacuation Time Estimate Studies

 National Incident Management System, December 2008

 National Response Framework, Mass Evacuation Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION J.10.k

Identification of and means for dealing with potential impediments (e.g., seasonal

impassability of roads) to use of evacuation routes, and contingency measures;

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION J.10.k, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Resources available (e.g., personnel and equipment) to clear impediments to evacuation and

emergency response in areas affected by incidents.

 Responsibility for directing resources and rerouting traffic, as needed.
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EXPLANATION

The plans/procedures identify resources, including personnel and equipment (e.g., tow trucks and snow

plows), that may be called on to clear impediments to evacuation and emergency response in areas

affected by an incident. Where outside resources will be used, the plans/procedures include or reference

LOAs as described in Criterion A.3. The plans/procedures also designate, by title/position, who will be

responsible for directing such resources and for rerouting traffic as necessary.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION J.10.l

Time estimates for evacuation of various sectors and distances based on a dynamic

analysis (time-motion study under various conditions) for the plume exposure

pathway emergency planning zone (see [NUREG-0654/FEMA-REP-1] Appendix 4);

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET INTENT CRITERION J.10.l, ORO PLANS/PROCEDURES SHALL DESCRIBE OR

REFERENCE:

 Time estimates for evacuation of various sectors or evacuation areas.

 The times required for the movement of school children and other persons with disabilities and 

access/functional needs.

EXPLANATION

The plans/procedures contain or reference a concise summary of ETEs for general and persons with 

disabilities and access/functional needs under various conditions. ETEs are defined as the time it will take

each population to move from the point of notification to the outer boundary of the 10-mile EPZ. Also see

discussion under Criterion J.10.i.

References

 NUREG/CR7002, Criteria for Development of Evacuation Time Estimate Studies

NUREG CRITERION J.10.m

The bases for the choice of recommended protective actions from the plume

exposure pathway during emergency conditions. This shall include expected local

protection afforded in residential units or other shelter for direct and inhalation

exposure, as well as evacuation time estimates.55

Applicability and Cross Reference to Plans: Licensee X State X Local 

 

55 The following reports may be considered in determining protection afforded: EPA 400-R-92-001, Manual of Protective Action Guides and 

Protective Actions for Nuclear Incidents, May 1992. EPA 400-R-92-001 replaced the original reference to three older documents per NUREG0654/FEMA-REP-1, Revision 1, Addenda, dated March 2002.
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TO MEET THE INTENT OF CRITERION J.10.m, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The rationales for any pre-planned precautionary actions, including the triggering events that would

lead to the decision to implement these actions.

 The rationales used to make initial PADs.

 The rationales used for subsequent PADs, including the consideration of various possible options.

EXPLANATION

PADs are measures taken in anticipation of, or in response to, a release of radioactive material to the

environment. Sheltering and evacuation are the two PADs that are relied upon for limiting the direct

exposure of the general public within the plume exposure EPZ. The plans/procedures describe the

methods for determining which PAD, evacuation or sheltering (or some combination thereof, including 

evacuation in stages), will provide the overall greater protection.56 Initial PADs for the general public may

be based on plant status information; it is not necessary to wait for calculations of projected dose.

It is also possible to implement PADs for selected portions of the population prior to the need for

protective actions for the general population; if such precautionary actions are being considered for use,

the plans/procedures explain the rationale for this decision.

During the planning process, it is appropriate to review factors that may affect evacuation, including the

characteristics of the area and population groups requiring special assistance. This process considers

protection factors for direct exposure and from inhalation exposure in shelters. Conclusions based on

these reviews are included in the plans/procedures. The following considerations are important in the

process of deciding between evacuation and sheltering:

 A GE is the first ECL where protective actions would be required. The NUREG-0654/FEMA-REP-1,

Appendix 1, definition of a GE includes the statement that ―Releases can be reasonably expected to

exceed the EPA Protective Action Guideline exposure levels offsite for more than the immediate site

area‖.

 The May 1992 EPA plume PAGs already discount the reduction in average dose that results from

sheltering. Therefore, the projected dose that will be compared to the PAGs does not take into account

dose reduction that results from sheltering. Consideration of sheltering effectiveness in reducing dose is

appropriate only for evaluating whether sheltering will provide overall greater protection than

evacuation.

 The protection factor for wood frame houses is 0.9. Because there are no known plume-exposure EPZs

without any wood frame houses, the dose reduction compared to direct exposure would be only 10

percent for at least a portion of the shelters.

 Air infiltration into shelters, even if the windows and doors are closed and heating and ventilating

systems are shut down, rapidly decreases the effectiveness of the shelter if it is exposed to the plume

for more than 2 hours. Also, unless there is a mechanism to establish when the plume has left the area

so that shelters can be promptly ventilated, much of any dose reduction achieved when the plume

arrived will be lost after the plume has departed.

 There will be significant uncertainty associated with the various parameters needed to make any dose

projection (e.g., the radionuclide release rate, the radionuclide release duration, the time of the start of

any radionuclide release, and meteorological conditions including wind speed and wind direction).

 

56 Updated FEMA and NRC guidance in NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Guidance for Protective Action Strategies,

October 2011, provides a protective action logic development tool that should be used by licensees to develop site specific protective action 

recommendation procedures and is recommended for use by OROs to develop protective action strategy guidance for decision makers.
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 For the worst core melt sequences, immediate life-threatening doses would generally not occur outside

the EPZ.

 There may be site- and incident-specific conditions that affect evacuation, including traffic

impediments, adverse weather conditions, an airborne radioactive plume, or areas affected by hostile

actions.

Because of the significant uncertainties in the potential source term (i.e., the amount of radioactive

material released to the environment following an accident), the minimal dose reduction available from

sheltering, and the possibility of high doses near the site, evacuation usually is the prudent initial

protective action at the time of the incident, based solely on plant status information without dose

projection calculations.

OROs that elect to follow alternate approaches must include sufficient detail to explain their rationale.

For subsequent PADs, if source term or environmental data are available, the results of dose projection

calculations are considered in the decision process. The methodology used for such dose projections is

covered under Criterion I.10. The plans/procedures delineate the decision processes leading to the choice

of a protective action. It may be helpful to include a ―decision tree‖ or graphic illustration of the variables

and trade-offs associated with the various protective action options.

Along with any evacuation decision, the plans/procedures provide for establishing access control to

prevent unnecessary entry into the evacuated areas (see Criterion J.10.j.). In addition, if possible, the

plans/procedures provide for the use of traffic control to assist with the flow of evacuation traffic.

References

 NUREG-0654/FEMA-REP-1, Revision 1, Part I.D, Planning Basis.

 NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants –

Guidance for Protective Action Strategies, October 2011.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 NUREG-0654/FEMA-REP-1, Revision 1, Addenda, dated March 2002.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 National Response Framework, Mass Evacuation Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION J.11

Each State shall specify the protective measures to be used for the ingestion

pathway, including the methods for protecting the public from consumption of

contaminated food-stuffs. This shall include criteria for deciding whether dairy

animals should be put on stored feed. The plan shall identify procedures for

detecting contamination, for estimating the dose commitment consequences of

uncontrolled ingestion, and for imposing protection procedures such as

impoundment, decontamination, processing, decay, product diversion, and

preservation. Maps for recording survey and monitoring data, key land use data

(e.g., farming), dairies, food processing plants, water sheds, water supply intake and

water treatment plants and reservoirs shall be maintained. Provisions for maps

showing detailed crop information may be made by including reference to their
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availability and location and a plan for their use. The maps shall start at the facility

and include all of the 50-mile ingestion pathway EPZ. Up-to-date lists of the name

and location of all facilities which regularly process milk products and other large

amounts of food or agricultural products originating in the ingestion pathway

Emergency Planning Zone, but located elsewhere, shall be maintained.57

Applicability and Cross Reference to Plans: Licensee State X Local 

TO MEET THE INTENT OF CRITERION J.11, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The individual(s), by title/position, and organization with the authority to make decisions in the

ingestion pathway planning zone.

 The ingestion protective actions planned and the rationale for the selection of actions, also see Criteria

J.9. and J.10.m.

 The methodology used to designate the areas of concern where monitoring and sampling will be

implemented.

 The methodology for collecting agricultural samples, including identifying field team members,

providing necessary supplies, names and addresses of contact points to obtain permission to collect

samples, and chain of custody procedures.

 The analytical laboratory capability to analyze various samples and the procedure for reporting

analytical results to the appropriate organization.

 The location and means of obtaining up-to-date information on permanent agribusiness facilities within

the EPZ. This information includes dairies, food processing plants, surface water supplies, water

intakes, and other permanent facilities. Information also includes facilities outside the EPZ that could

receive potentially contaminated products from within the EPZ, including names and telephone

numbers for points of contact.

 The location and means of obtaining up-to-date information on land use (i.e., which crops are being

grown in which areas). This information includes the status of harvesting.

 The DILs that would warrant implementation of protective actions and the rationale and assumptions

used to develop the DILs.

 The availability of suitable maps for recording various data. The use of electronic means to capture and

map survey and dose data (e.g., geographic information systems) are acceptable.

 The means by which the agribusiness person will be notified of a PAD that would affect his/her ability

to sell or move food or agricultural products.

EXPLANATION

The plans/procedures identify, by title/position, the person who makes the PADs for the ingestion

exposure pathway. The recommendations on incidental radioactive contamination of human food and

animal feeds advise that public health risk be averted by limiting the radiation dose received from eating

contaminated food.58 This goal will be accomplished by:

 Setting DILs on the radionuclide activity concentration permitted in human food. A DIL corresponds to

the radiation concentration in food throughout the relevant time period that, in the absence of any

 

57 The Emergency Response Resources Guide for Nuclear Power Plant Emergencies, NUREG-1442, Rev. 1/FEMA-REP-17, Rev.1 (July 1992), 

identifies resources available to principal participants in an emergency response to a major nuclear emergency at a commercial NPP and 

contains general functional areas that would need to be considered in responding to this type of incident.

58 For further information, see the HHS/FDA guidance, Accidental Radioactive Contamination of Human Food and Animal Feeds: 

Recommendations for state and Local Agencies, August 13, 1998.
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intervention, could lead to an individual receiving a radiation dose equal to the PAG or, in international

terms, the intervention levels of dose; and

 Taking precautionary or protective actions to reduce the amount of contamination.

PADs for the ingestion exposure pathway are actions taken to limit the radiation dose from ingestion by

avoiding or reducing the contamination that could occur on the surface of, or be incorporated into, human

food and animal feeds. Such actions can be taken prior to and/or after confirmation of contamination. The

protective actions for a specific incident are determined by the particulars of the incident and, once

initiated, they continue at least until the concentrations are expected to remain below the DILs.

For the ingestion exposure pathway, there are two categories of PADs: (1) preventive protective actions

and (2) emergency protective actions. Preventive protective actions are taken to prevent or reduce

contamination of milk, food, and drinking water. Emergency protective actions are taken to isolate food to

prevent its introduction into commerce and to determine whether condemnation or other disposition is

appropriate. Both preventive and emergency protective actions are considered ―precautionary‖ if they are

undertaken before verifying radionuclide measurements by field monitoring or laboratory analysis.

a. Precautionary Actions

Precautionary actions taken prior to confirmation of contamination include:

 Simple precautionary actions to avoid or reduce the potential for contamination of food and animal

feeds. These will not guarantee that contamination in food will be below the DILs, but the severity of

the problem should be significantly reduced. Typical precautionary actions include covering exposed

products, moving animals to shelter, corralling livestock, and providing protected feed and water.

 Temporary embargoes to prevent food that is likely to be contaminated from entering into commerce.

Because of potential economic impacts, OROs must take care when determining the area for a

temporary embargo prior to determining the levels of contamination in food.

Precautionary actions can be taken before the release or arrival of contamination if officials have advance

knowledge that radionuclides may contaminate the environment. Determinations of what protective

actions would be taken, and when, may be based on the ECLs. OROs may consider precautionary actions

before declaration of a Site Area Emergency or General Emergency if predictions of the extent and

magnitude of the offsite contamination are persuasive.

b. Determination of Contamination in Food

The plans/procedures identify how the levels of contamination in food will be determined. This includes

sampling and analysis capability.

c. Protective Actions for Foods Confirmed to be Contaminated

Protective actions when the contamination in food equals or exceeds the DILs include:

 Temporary embargoes to prevent contaminated food from entering into commerce from a

contaminated area when the presence of contamination is confirmed, but the concentrations are not yet

known. The temporary embargo would continue until measurements confirm that concentrations are

below the DILs.

 Normal food production and processing actions that reduce the amount of contamination in or on food

to below the DILs.
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 Condemnation of foodstuff. The foodstuff would not be allowed into commerce and would be disposed

of in accordance with state and/or Federal regulations.

d. Protective Actions for Animal Feeds Confirmed to be Contaminated

Protective actions to reduce the impact of contamination in or on animal feeds, including pasture and

water, are taken on a case-by-case basis. Protective actions when animal feeds are contaminated include:

 Substituting uncontaminated water for contaminated water.

 Removing lactating dairy animals and meat animals from contaminated feeds and pasture.

 Substituting uncontaminated feed for contaminated food.

Putting dairy animals on stored feed and protected water does not imply that the structure needs to be

closed to outside air, as is the case when discussing sheltering for the general population. If a suitable

structure is not available, provision of stored feed and protected, and therefore uncontaminated, water is

adequate. Testing will be necessary to ensure the foodstuff is not contaminated.

e. Sampling and Analysis

The plans/procedures describe the rationale for selecting the sampling areas. The plans/procedures also

describe resources for collecting food and agricultural product samples in the areas of concern, including

use of chain-of-custody documentation. The plans/procedures provide information about the laboratory‘s

capability to analyze the various samples and list DILs (i.e., concentration levels of various radionuclides

in various foods that would be equivalent to the PAGs, which are expressed in rem). The specified

sampling protocols and laboratory analysis methods must be capable of determining concentrations at

levels at least as low as the DILs.

f. Maps

Maps are maintained and available for recording a variety of data. The plans/procedures make provisions

for recording field survey readings and projected ingestion doses on appropriate maps. The use of 

electronic means to capture and map survey and dose data (e.g., geographic information systems) is 

acceptable. Also, the plans/procedures make provisions for recording land use information, such as the

location of agribusiness activities (e.g., dairies, food processing plants, surface water supplies, water

supply intakes, and other permanent activities). Processing plants that are located within the EPZ are

identified. Plans/procedures further delineate those plants that receive potentially contaminated products

from inside the EPZ and those that receive products from outside of the EPZ. The plans/procedures

describe a means to access information regarding the location of various crops. This information changes

frequently and the plans/procedures specify where up-to-date information is available and how it can be

obtained. The plans/procedures include provisions for obtaining information, from county or local

agriculture extension offices, on the status of harvesting operations within the areas of concern (i.e.,

which crops are being harvested or are near harvesting).

g. Decision Making

The plans/procedures specify the individual, by title/position, and organization authorized to make

decisions regarding any of the protective actions outlined above.

The plans/procedures include specific steps necessary to implement PADs. The plans/procedures identify

the organization(s) that have the authority to prohibit the sale or movement of food or agricultural

products and describe the process to prevent the sale or movement of products of concern.
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References

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 NUREG-1442, Revision 1/FEMA-REP-17, Revision 1, The Emergency Response Resources Guide 

for Nuclear Power Plant Emergencies, July 1992.

 Federal Register, Volume 63, No. 156, pp.43402-43403, Accidental Radioactive Contamination of 

Human Food and Animal Feeds: Recommendations for State and Local Agencies, Food and Drug 

Administration, August 13, 1998.

NUREG CRITERION J.12

Each organization shall describe the means for registering and monitoring of

evacuees at relocation centers in host areas. The personnel and equipment available

should be capable of monitoring within about a 12-hour period all residents and

transients in the plume exposure EPZ arriving at relocation centers.

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION J.12, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Radiological monitoring of evacuees, service animals, vehicles, and possessions. OROs need to be

capable of monitoring 20 percent of the EPZ population (including transients) assigned to each facility

within a 12-hour period.

 Decontamination procedures, including the trigger/action levels that indicate the need for 

decontamination activities and procedures for medical attention referral.

 Contamination control measures, such as safety requirements, decontamination site layout, and

decontamination protocol.

 The physical layout of the area, with diagrams that show the flow and layout of operations, including a

description of the means for separating contaminated, uncontaminated, and unscreened individuals,

vehicles, and service animals.

 The processes for registering evacuees and service animals in host/support jurisdictions, including

documentation of monitoring for referral to temporary care facilities.

EXPLANATION

a. Monitoring

The plans/procedures provide for adequate resources, including trained personnel and functional, up-todate equipment, for radiological monitoring of a minimum of 20 percent of the total EPZ population at

reception/relocation centers in host/support jurisdictions. The 20 percent planning basis does not include 

re-monitoring of persons who have been decontaminated. This monitoring is conducted within about a

12-hour period.

―Total EPZ population‖ includes residents, estimated number of commuters, anticipated seasonal

transient populations, and special facility populations (e.g., nursing home residents and school children).

The estimated number of persons to be monitored will indicate the personnel and equipment resource

requirements at each reception/relocation center. The FEMA guidance document Contamination 

Monitoring Guidance for Portable Instruments Used for Radiological Emergency Response to Nuclear 

Power Plant Accidents, FEMA-REP-22 (October 2002), indicates the time it takes to monitor an
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individual, vehicle, and equipment and other possessions using hand-held instruments. For hand-held

equipment, the number of monitoring kits needed is one-half the number of monitors needed since the

equipment can be used for both shifts. The plans/procedures indicate the types of monitoring equipment

that will be used.

If portal monitors are used, the plans/procedures indicate the types of monitors, monitoring capacity in

persons per hour, and number of trained personnel required to operate the equipment.

The plans/procedures indicate the triggers/action levels requiring decontamination.59 For trigger/action

levels for portal monitors, refer to FEMA-REP-21. The trigger/action level is reported in units appropriate

for the type of monitoring instrument.

Service animals accompanying evacuees with disabilities and access/functional needs are monitored in

accordance with the same standards and trigger/action levels for decontamination as humans.

The plans/procedures also indicate how monitoring data will be documented. OROs keep a list or other

record of all persons, vehicles, and service animals monitored, and whether contamination was detected.

Forms are typically used for recording monitoring results and should be included in the plans/procedures.

b. Decontamination

Good health physics practices and the philosophy of ―as low as reasonably achievable‖ require that the

plans/procedures provide for decontamination of individuals, vehicles, and service animals found to be

contaminated during the monitoring process.

Decontamination capabilities available at a reception or relocation center include, at a minimum, sinks

and showers with soap and water and changes of clothing. Localized contamination (e.g., hands or face)

can be removed by washing in a sink; contamination in other areas may require a shower.

Decontamination methods for equipment and vehicles may include: (1) using vacuum cleaners, preferably

with high-efficiency particle filters; (2) scrubbing contaminated areas with soap and water; (3) generously

applying low-pressure water and soap solutions to affected areas; and (4) applying organic solvents on

greasy or waxed surfaces.

Plans/procedures describe equipment and processes for addressing contaminated individuals, personal

items, vehicles, and equipment. The plans/procedures provide for re-monitoring of individuals, vehicles,

and equipment after decontamination. Same-sex monitors are available for re-monitoring of individuals

after decontamination. Individuals who cannot be decontaminated with simple soap and water washing

are referred to the care of qualified medical or health physics personnel for further evaluation and/or

decontamination measures.

The plans/procedures indicate the number of decontamination attempts to be made before an individual is

sent to a medical facility, as well as which medical facilities will receive persons who could not be

decontaminated. Vehicles and equipment that cannot be decontaminated are held in an appropriate

location with restricted access until further instructions and/or monitoring/decontamination measures are

authorized.

 

59 ―Trigger/action level‖ is a designated value whereby an individual is directed to perform a specific action. This term is used in 

plans/procedures synonymously with the terms ―trigger level,‖ ―action level,‖ or ―decision criterion.‖
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c. Contamination Control

The plans/procedures describe contamination control methods (e.g., proper floor coverings, personal

protective equipment worn by trained emergency personnel). Plans/procedures show the physical layout

of the monitoring and decontamination center in diagrams, including the number of personnel, and flow

of evacuees and vehicles through designated zones of operation. The flow ensures that individuals,

vehicles, and service animals that have been monitored and found to be uncontaminated are kept separate

from contaminated and unmonitored individuals, vehicles, and service animals. Individuals, service

animals, and vehicles exiting the monitoring and decontamination area are provided with means (e.g.,

hand stamp, sticker, bracelet, form, etc.) indicating that they and their service animals, and vehicles,

where applicable, have been monitored, cleared and found to have either no contamination or

contamination below the trigger/action level.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have

their vehicle monitored, nor do they require confirmation that their vehicle is free from contamination

prior to entering the congregate care areas. However, those individuals who are found to be contaminated

and are then decontaminated will have their vehicles monitored and decontaminated (if applicable) and do

require confirmation that their vehicle is free from contamination prior to entering the congregate care

areas.

Plans/procedures indicate the agency or organization responsible for handling contaminated waste (e.g.,

clothing and personal articles) at reception centers, as well as the location where the wastes will be

initially stored and how the storage areas will be marked and secured. The plans/procedures also discuss

facilities for handling evacuees‘ service animals, contaminated vehicles, and possessions, including

storage, security, and owner identification. Waste water from decontamination operations does not need

to be collected.60

d. Registration

The plans/procedures identify the means for registering evacuees and their service animals. Forms or

electronic means (e.g., audio, audio/video) may be used. Registration forms include name, address, family

members, and time of arrival at the facility. If American Red Cross personnel assist in this process, their

registration forms may be used. Plans/procedures describe the types of data to be collected and method

(e.g., form or ticket provided to evacuee) of verifying that they have been monitored and found to be

uncontaminated.

References

 FEMA-REP-2, Revision 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 

– Airborne Release, June 1990.

 FEMA-REP-21, Contamination Monitoring Standard for a Portal Monitor Used for Radiological 

Emergency Response, March 1995.

 FEMA-REP-22, Contamination Monitoring Guidance for Portable Instruments Used for 

Radiological Emergency Response to Nuclear Power Plant Accidents, October 2002.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 National Response Framework, Mass Evacuation Annex, June 2008.

 Pub.L. 109-295, October 4, 2006.

 

60 FEMA Policy statement, Policy statement on Disposal of Waste Water and Contaminated Products from Decontamination Activities, January 

1989.
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11. PLANNING STANDARD K – RADIOLOGICAL EXPOSURE CONTROL

Means for controlling radiological exposures, in an emergency, are established for

emergency workers. The means for controlling radiological exposures shall include

exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity

Protective Action Guides.

NUREG CRITERION K.1

Each licensee shall establish onsite exposure guidelines consistent with EPA

Emergency Worker and Lifesaving Activity Protective Action Guides (EPA

520/1-75/00161) for:

a. removal of injured persons;

b. undertaking corrective actions;

c. performing assessment actions;

d. providing first aid;

e. performing personnel decontamination;

f. providing ambulance service; and

g. providing medical treatment services.

Applicability and Cross Reference to Plans: Licensee X State Local 

NOTE: When state exposure limits differ from EPA emergency worker and lifesaving activity PAGs,

OROs should obtain agreements between the state and licensee regarding administrative dose limits and

turn back values for all ORO emergency workers responding on site.

NUREG CRITERION K.2

Each licensee shall provide an onsite radiation protection program to be

implemented during emergencies, including methods to implement exposure

guidelines. The plan shall identify individual(s), by position or title, who can

authorize emergency workers to receive doses in excess of 10 CFR Part 20 limits.

Procedures shall be worked out in advance for permitting onsite volunteers to

receive radiation exposures in the course of carrying out lifesaving and other

emergency activities. These procedures shall include expeditious decision making

and a reasonable consideration of relative risks.

Applicability and Cross Reference to Plans: Licensee X State Local 

 

61Original reference to EPA-520/1-75-001 replaced with EPA-400-R-92-001 per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 

2002.
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NUREG CRITERION K.3.a

Each organization shall make provision for 24-hour-per-day capability to determine

the doses received by emergency personnel involved in any nuclear accident,

including volunteers. Each organization shall make provisions for distribution of

dosimeters, both self-reading62 and permanent record devices.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION K.3.a, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Methods or options for emergency worker exposure control, to include exposure from inhalation.

 Dose limits for emergency workers.

 Types and quantities of dosimeters and dosimeter chargers available per location and the number of

emergency workers needing dosimetry devices.

 Process for reading PRDs and any early reading of PRDs (e.g., when an emergency worker‘s task

assignment is completed or as otherwise specified).

 Specific dosimetry instructions, including when, where, and to whom individuals return their dosimetry

devices.

 Dosimetry storage locations.

 Distribution of dosimetry to all emergency workers and, when permitted, members of the public

needing access to the restricted area.

 Proper documentation of authorization to exceed administrative dose limits.

EXPLANATION

The plans/procedures include provisions for maintaining 24-hour capabilities to determine radiation doses

to any emergency worker who may be potentially exposed to ionizing radiation as a result of an incident.

These provisions also address access to and distribution of personal monitoring equipment (i.e.,

dosimetry) to the emergency workers.

a. Definition of Emergency Worker

In the REP program an emergency worker is an individual who has an essential mission to protect the

health and safety of the public and could be exposed to ionizing radiation from the plume or its

deposition. Emergency workers include, but are not necessarily limited to, radiological field monitoring

personnel; traffic control personnel; law enforcement personnel; fire and rescue personnel; emergency

medical services personnel; evacuation vehicle (e.g., buses, vans, etc.) drivers; back-up route alerting

personnel; EOC personnel, where the EOC is within the EPZ; personnel who may deal with potentially

contaminated individuals or objects, such as reception center personnel, medical facility personnel, and

emergency worker decontamination center personnel; and essential services or utility personnel (e.g.,

electricity, gas, water, water treatment, telephone, etc.). Note that evacuation vehicle drivers who will be

transporting individuals or groups out of the EPZ and who are not expected to return to the EPZ are not

considered ―emergency workers.‖

 

62 Self-reading dosimeters are now referred to as ―direct-reading‖ dosimeters.
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b. Dosimeters

Dosimeters are instruments for measuring external exposure to ionizing radiation. They do not measure

internal committed dose from inhaled or ingested materials. Dosimeters are available in two basic types:

permanent/non-direct-reading and direct-reading.

 PRDs. The plans/procedures describe capability to provide a PRD to each emergency worker. The

dosimeter will provide an accurate record of the ionizing exposure received by the emergency worker

over the duration of the incident. The thermoluminescent dosimeter or film badge is read by a

processor accredited by the National Voluntary Laboratory Accreditation Program or other

accreditation program in accordance with American National Standards Institute, Standard N13.11-

1983, Personal Dosimetry Performance Criteria for Testing. Accreditation is for the specific type of

dosimetry in use and is for the type of radiation(s) for which the individual wearing the dosimeter is

monitored.

 DRDs. The plans/procedures describe the capabilities to provide DRDs to emergency workers who

could be exposed to ionizing radiation. Two major types of DRDs are acceptable for use in emergency

response: (1) the ion chamber electroscope and (2) the electronic dosimeter with an LED display and

alarm circuit. Either type allows the emergency worker real-time access to information concerning

gamma exposure incurred since the device was last zeroed. Electronic dosimeters could be subject to

some degree of radio frequency interference. The amount of radio frequency interference depends on

the amount of shielding in the dosimeter design and the frequency range. The electronic dosimeters

used are tested with any hand-held radios or cellular telephones that may be used by the emergency

responders to determine whether the dosimeter will be affected by radio frequency interference.

EPA 400-R-92-001 calculates dose to both the emergency workers and the general public. The dose that

is compared to emergency worker dose limits or early-phase PAGs is the sum of the external dose from

gamma radiation and the committed effective dose equivalent from internal exposure caused by inhalation

of radioactive material. This combined total measurement is referred to as the TEDE.

Dosimeters measure external exposure to gamma radiation, but not the dose from airborne radioactive

material that is inhaled and that may contribute a major portion of the TEDE. Dose to the thyroid from

uptake of radioiodines is mitigated by the correct and timely administration of KI. Although dose from

inhalation of particulate materials could be controlled by properly fitted respirators, respirators are not

generally practical for radiological emergency response. DRDs are commonly used, along with

appropriate adjustment factors to account for the inhalation portion of the dose, to estimate the TEDE

during the emergency phase. Assessment of the actual TEDE

received by individual emergency workers is conducted after

the emergency is over.

Since the dose that emergency workers read on their DRDs in 

units of R is not directly comparable to the TEDE 

administrative dose limits they are given in units of rem, any

discussion of a recommended system or a minimum

acceptable system for dosimetry needs to be coupled with the

methodology adopted by the state for the conversion of DRD 

readings into estimated TEDE. The dosimetry OROs issue to 

emergency workers must be capable of measuring dose in the 

appropriate range to allow emergency workers to determine 

whether they have reached the administrative limits. The 

EPA-400-R-92-001 guidance is to use a factor of 5 for this 

Issuing the Right Dosimetry

A mathematical conversion factor is used 

to translate DRD readings in units of R into 

applicable dose limits in units of rem. 

For example, if the state uses a 

conversion factor of 5, emergency workers 

multiply the reading on their DRD by 5 and 

compare the result to the administrative 

limits in the plans/procedures. 

Therefore, if the applicable dose limit is 5 

rem, the minimum acceptable dosimetry 

issued to emergency workers must be 

capable of reading 1 R to provide the 

information needed to accurately 

monitor their exposure.
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conversion (see dose control discussion in the next section); however states may be more conservative. If

the state adopts administrative dose limits or turn-back values that are more restrictive than EPA dose

limits, the DRDs provided to emergency workers must be able to read R in the range that will correspond 

to the administrative limit when the selected factor is applied.

While using one dosimeter is acceptable and meets the minimum criteria, it is better to ensure the ability

to measure a wide range of exposure, either by using two DRDs (one low-range and one high-range) or a

low-to-high-range electronic personal dosimeter. The use of the high-range DRD is appropriate because

of the potential for doses greater than 25 rem during life-saving missions and missions to protect large

populations. These missions are assigned only to those emergency workers who volunteer to receive

doses in excess of 25 rem TEDE. Real life-saving missions are likely to arise without warning. In such

cases, there will probably not be time to issue additional dosimetry, so use of both high-range and lowrange DRDs is recommended.

Those individuals with assignments outside the 10-mile EPZ who might come into contact with

radioactive materials are required to have PRDs. Because there is little chance of inhalation exposure by

these individuals, a factor to convert R as read by the DRDs to rem TEDE is not needed. Group dosimetry

for these emergency workers is permitted. Group dosimetry is accomplished by issuing a PRD to each

individual, then using one or more area DRDs to monitor exposure of the entire group. Group dosimetry

is also permitted for emergency workers assigned to a fixed facility inside the 10-mile EPZ; however, if

emergency workers are deployed outside the building, including moving to an alternate facility, they must

be issued a DRD.

c. Dose Control and Limits

The plans/procedures incorporate the following dose limits for emergency workers, as provided in EPA

400-R-92-001, or more restrictive limits:

 5 rem for any emergency activities;

 10 rem for activities to protect valuable property where a lower dose is not practical;

 25 rem for life-saving activities or protection of large populations where a lower dose is not practical;

and

 Greater than 25 rem for life-saving activities or protection of large populations where only emergency 

workers who volunteer for higher doses are allowed and only if they have been made fully aware of the

risks.

The plans/procedures also explain that the dose limits for emergency workers apply only during the

emergency phase. The emergency phase ends when (1) the utility determines that the release has

terminated, and (2) the responsible ORO has determined that public safety is ensured by appropriate

protective actions in accordance with applicable PAGs and that valuable property has been protected.

Doses incurred by emergency workers after these conditions are met are controlled according to dose

limits for occupational exposure, as identified in the state radiation control program‘s regulatory

requirements or 10 CFR Part 20, whichever is more restrictive.

The following three options for dose control are considered acceptable for implementing the EPA dose

limits for emergency workers. Other options may be submitted for consideration.

 Option 1. Until evacuation of the general public is complete, monitoring and control of emergency 

worker dose is based only on gamma radiation exposure as measured by a DRD without regard to

additional dose received from inhalation. Emergency workers entering the plume after evacuation of
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the general public has been completed will be assigned a predetermined administrative dose limit,

stated in terms of external radiation dose only, that is lower than the maximum TEDE dose

recommended by the EPA for the class of emergency response activity to be performed. The TEDE

calculation for emergency workers who have ingested KI does not include the contribution from

thyroid dose due to inhalation of radioiodine, as that contribution will be minimal if KI is administered

prior to exposure. The lower administrative dose limit may account for: (1) the radiation dose already

received by the emergency workers and (2) the calculated ratio of external dose to the TEDE. The basis

of this calculated ratio will be dose projections provided by the licensee or measurements of the

radionuclide mix in the plume. This calculated ratio is based on dose projections using utility-provided

source terms or measurements of the radionuclide mix in the plume.

 Option 2. An administrative limit on the dose to emergency workers entering the plume is determined

in advance and documented in emergency plans/procedures. The administrative limit is stated in terms

of the external dose measured by a DRD. To account for the inhalation dose, which cannot be

measured prior to or during a mission, the administrative limit is set lower than the limit for each class

of activity recommended by EPA. By selecting an appropriate value for the administrative limit on

measured external dose and restricting emergency workers to that limit, there can be reasonable

assurance that after including the dose from inhalation, the TEDE to an emergency worker is unlikely

to exceed the applicable limit. The TEDE calculation for emergency workers who have ingested KI

does not include the contribution from thyroid dose due to inhalation of radioiodine, because that

contribution will be minimal if KI is administered prior to exposure. For the less severe but more

probable reactor incident sequences, the TEDE to emergency workers who have taken KI is unlikely to

exceed 5 times their measured external dose as shown on DRDs. Therefore, if the external dose

measured by a DRD is limited to 1/5 of the applicable limit, the TEDE is unlikely to exceed the limit.

For example, if the external dose measured by a DRD is limited to 5 R, the TEDE is unlikely to exceed

25 rem.

 Option 3. Administrative dose limits for emergency workers are not predetermined, but are calculated

for the specific incidental release anticipated or in progress. The limits are based on dose calculations

similar to those used to determine the need for public protective actions. The limits, stated in terms of

external dose measured by a DRD, would be set low enough to keep the TEDE to emergency workers

below the maximum dose recommended for the various classes of activity.

The TEDE calculation for emergency workers who have taken KI does not include the contribution

from thyroid dose due to inhalation of radioiodine, because that contribution will be minimal if KI

is administered prior to exposure. The dose limits could remain the same throughout an emergency,

or they could be revised periodically on the basis of knowledge of the radionuclide constituents of

the plume.

The plans/procedures indicate the arrangements for calculating retrospective determinations of TEDE.

OROs do not need to undertake such retrospective analyses; instead they may rely on those conducted by

utilities and Federal agencies. PRDs could provide the external dose component; OROs should keep 

records on the time history of exposure.

d. Record Keeping

OROs keep a record listing the persons to whom both PRDs and DRDs are assigned. Emergency workers

keep their assigned PRDs throughout the emergency phase, unless their lead organization requests them

earlier to verify anomalous readings on a DRD or the radiological officer reissues all PRDs. OROs may 

assign a DRD to another emergency worker provided it has been re-zeroed and the initial reading

recorded for the other individual, along with its serial number or other means of identification. OROs

provide a specific contact, time, and location for return of all dosimeters.
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e. Quantities

The plans/procedures indicate the quantities of dosimetry available. Each emergency worker with 

assignments where he or she may be exposed to radiation requires a PRD. Emergency workers with 

assignments in the plume EPZ require DRDs. The State determines whether DRDs are required for 

emergency workers and/or teams with assignments outside of the plume EPZ. OROs may consider using 

group dosimetry for emergency workers who work in close proximity to each other (e.g., reception 

centers, hospital/medical facility emergency rooms, EOCs). If OROs use group dosimetry, the 

plans/procedures need to reflect that and include a description of the dosimetry storage location and its 

use. During response to HAB incidents, licensees and OROs coordinate use of group dosimetry for ORO 

emergency workers responding onsite.

f. Distribution

The plans/procedures describe how to distribute dosimetry to all emergency workers and, when permitted,

to members of the public needing access to the restricted area. If OROs store dosimetry somewhere other

than the distribution location, the plans/procedures specify the method for transporting dosimetry to the

distribution location. The plans/procedures address how the OROs will overcome possible shortages

during an emergency.

g. Considerations for HAB incidents

Under REP scenarios, the number of responders needing dosimetry and KI – and the levels of radiation to

which they may be exposed – has been fairly predictable. In an HAB incident, however, there will likely

be an increased number of emergency workers (e.g., local law enforcement agency personnel, firefighters,

and medical services personnel) potentially exposed to and requiring protection from radiation levels

above their normal exposure from their response on or near the NPP site to support incident mitigation

efforts. In particular, there may be an immediate need for certain responders to enter areas where they

require protection and where they may exceed dose limits (e.g., for life saving or law enforcement

actions). There also may be prolonged response and recovery operations (e.g., for forensic investigation,

plant security, victim recovery operations) that may result in greater cumulative worker exposure, which

will have further impacts on equipment and supply inventories.

As a result, plans/procedures for emergency worker protection during an HAB incident address the

following issues:

Resource availability. The increased number of responders will put a strain on the existing supply of

dosimetry and KI, and responders may need dosimetry and KI for a longer period of time than in

traditional REP scenarios, further increasing the amount needed. ORO plans/procedures address planning

for sufficient quantities of dosimetry and KI for augmented resources, including methods for estimating

the number of potential responders needing supplies and equipment and expected loss due to 

consumption, malfunction, and misplacement. OROs may need to maintain additional supplies for an 

HAB incident. Plans/procedures address how to obtain additional dosimetry and KI; who is responsible

for procurement, stockpiling, and storage; and the maintenance of sufficient quantities of appropriate

dosimetry – devices issued need to be able to detect and display the range of exposures for the particular

responder (e.g., for the time they are expected at the scene and the amount of radiation to which they may

be exposed).

Processes for dosimetry and KI distribution and training. Additional responders augmenting ORO

resources will need instruction on the location and use of supplies and equipment. OROs

coordinate/communicate plans/procedures with the licensee to identify responsibilities and processes for
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the issuance of dosimetry and KI to emergency workers responding onsite, specifically during an HAB

incident. ORO plans/procedures also describe where and how dosimetry and KI will be distributed, and

where and how emergency workers will be trained on its use, including just-in-time training.

Dose limits and authorizations to exceed limits. Some dose limits for certain specialized emergency

workers are not high enough to allow responders in an HAB incident to be able to continue working in the

area without seeking authorization to exceed these limits, which may be time consuming.

Plans/procedures address a methodology for quick authorizations to exceed administrative dose limits to

ensure a prompt, coordinated response to the NPP site to support critical life-saving, law enforcement,

and accident mitigation activities. OROs document all authorizations to exceed administrative dose limits.

Consistency in processes and authorizations. Because more responders from different organizations

(e.g., licensee, OROs, other jurisdictions, Federal government) will be carrying out similar functions in

the same location, organizations need to coordinate/communicate on consistency in worker exposure

limits and processes for equipment distribution and use.

References

 American National Standards Institute, Standard N13.11-1983, Personal Dosimetry Performance

Criteria for Testing.

 FEMA-REP-2, Revision 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 

– Airborne Release, June 1990.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 Nuclear Regulatory Commission (NRC), Regulatory Issue Summary (RIS) 2002-21, National Guard

and Other Emergency Responders Located in the Licensee’s Controlled Area, November 8, 2002.

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION K.3.b

Each organization shall ensure that dosimeters are read at appropriate frequencies

and provide for maintaining dose records for emergency workers involved in any

nuclear accident.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION K.3.b, ORO PLANS/PROCEDURES SHALL INDICATE:

 The method for obtaining dose information from emergency workers.

 The timeframes for reading dosimeters (e.g., every 15 or 30 minutes).

 The methods for recording doses (e.g., the form used).

 Appropriate reporting if administrative limits have been reached or exceeded (refer to Criterion K.4.).

EXPLANATION

The plans/procedures state that DRDs are read at regular intervals to determine whether emergency 

workers have been exposed to radiation. All emergency workers periodically read their dosimeters, record

each reading, and note any exposure indicated (including no exposure) on a record card or form provided

with the dosimeters. When a specific exposure has occurred, the emergency worker must inform the 
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radiological health officer or other supervisor, particularly if the dose limits for the mission have been

reached or exceeded. The details of these procedures may vary from one state to another. However, the

plans/procedures are consistent from location to location, and site to site, within a state. It also is

important that each plan/procedure has prescribed intervals for reading and recording exposure to

radiation. The plans/procedures specify the methods for recharging low-range DRDs if recharging is

necessary to support reporting of any administrative limits placed on dose. The plans/procedures describe

how emergency workers will be informed of the requirement to read, record, and report dosimeter values.

References

 FEMA-REP-2, Revision 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 

– Airborne Release, June 1990.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION K.4

Each State and local organization shall establish the decision chain for authorizing

emergency workers to incur exposures in excess of the EPA General Public

Protective Action Guides (i.e., EPA PAGs for emergency workers and lifesaving

activities).

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION K.4, ORO PLANS/PROCEDURES SHALL SPECIFY:

 Dose limits (TEDE) for missions, accounting for dose from inhalation.

 Actions taken when exposure limits have been reached.

 Any special conditions requiring additional limitations (e.g., pregnant emergency workers).

 Authorization to exceed pre-authorized exposure limits and management of emergency workers‘

exposure above the limits.

 Points of contact for authorization to remain in the hazard area and receive additional exposure (e.g.,

for special lifesaving missions) if the allowable upper limit has been reached.

 Information on risk and threshold doses for health effects to be provided to emergency workers

volunteering for higher dose exposure.

 Administrative limits.

EXPLANATION

During response to a radiological emergency, emergency workers may be at risk of incurring radiation

exposure beyond the EPA General Public PAG. To protect the health and safety of emergency workers,

ORO plans/procedures ensure that such excess exposures are undertaken only as authorized and

controlled by supervisory personnel.

As noted in Evaluation Criterion K.3.a., EPA-400-R-92-001 provides guidance on emergency worker

exposure control in terms of TEDE, which includes the deep-dose equivalent from external gamma
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radiation and committed effective dose equivalent from exposure to internal organs caused by inhalation

of airborne radioactive materials during an emergency. Plans/procedures include all applicable limits

(e.g., administrative, turn-back, general emergency assignments, protecting valuable property, life-saving

or protecting large populations, protecting pregnant women and unborn children). The dose limit is 5 rem

TEDE, unless circumstances warrant a higher limit. If 5 rem TEDE is not a practical limit, a limit up to 10

rem TEDE may be selected for protection of valuable property, and up to 25 rem TEDE for life-saving

activities or protection of large population groups. The plans/procedures address the assignment of these

limits for emergency work. Doses higher than 25 rem TEDE may be voluntarily accepted by emergency 

workers who are fully aware of the health risks, including the numerical estimates of dose at which acute

effects of radiation may be incurred and the risk of delayed effects from radiation dose.

The plans/procedures include or reference the Dose Limits for Emergency Workers table found in EPA

400-R-92-001. The plans/procedures also reference or include procedures that will be used for authorizing

emergency workers to volunteer for doses higher than the dose limits specified in the plans/procedures, as

well as procedures and the source of information for briefing volunteers on the radiation risks involved. In

addition, the plans/procedures clearly state that the dose to emergency workers is treated as a once-in-alifetime exposure and is not added to occupational radiation exposure accumulated under non-emergency

conditions.63 For individuals who volunteer to receive doses in excess of the stated limits, the

plans/procedures also include a description of the full reporting and decision chain process from the

emergency worker through the final authorizing person and back to the emergency worker.

As in the case of normal occupational exposure, doses received under emergency conditions are

minimized to the extent practicable (e.g., use of KI, where appropriate; limiting time spent working in

radiation areas; rotating available emergency workers). The organization indicates methods to ensure

protection of minors and the unborn during emergencies. Therefore, pregnant women or individuals under

age 18 do not perform emergency services in an area where radiation exposure is expected.

References

 FEMA-REP-2, Revision 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 

– Airborne Release, June 1990.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 NRC Regulatory Guide 8.7, Revision 1, The NRC Guidelines, Instructions for Recording and

Reporting Occupational Radiation Exposure Data, June 1992.

 NRC Regulatory Guide 8.35, Planned Special Exposures, June 1993.

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION K.5.a

Each organization as appropriate, shall specify action levels for determining the

need for decontamination.

Applicability and Cross Reference to Plans: Licensee X State X Local X

 

63 The NRC guidelines, Instructions for Recording and Reporting Occupational Radiation Exposure Data, NRC Regulatory Guide 8.7, Revision 

1 (June 1992) and NRC Regulatory Guide 8.35, Planned Special Exposures (June 1993), delineate additional requirements for documenting 

EW exposure.
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TO MEET THE INTENT OF CRITERION K.5.a, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Facilities for monitoring and decontaminating emergency workers, equipment, and vehicles, along with

operating and implementing procedures.

 Locations of monitoring and decontamination facilities (preferably located outside the plume EPZ).

 Methods for controlling the spread of contamination at the emergency worker monitoring facilities.

 Radioactive contamination levels that will trigger decontamination of emergency workers, equipment,

and vehicles, expressed in applicable units (e.g., cpm, mR/hr).

 Survey instruments (i.e., specific appropriate equipment and sensitivity, including radiation type) used

to monitor emergency workers, equipment, and vehicles.

 Procedures for monitoring individuals and equipment.

EXPLANATION

Because emergency workers may be working in areas where they could become contaminated with

radioactive materials, plans/procedures describe the capability to activate and operate facilities for

monitoring and decontaminating emergency workers, equipment, and vehicles. The plans/procedures

describe the facilities for monitoring and decontamination, including methods, supplies, and equipment to

minimize contamination (e.g., protective coverings or instructional signs). The plans/procedures also

describe trained staff available to perform monitoring and decontamination. Monitoring instruments

provide reasonable assurance that the risk of skin cancer and other significant radiation effects to the skin

of people exposed to radioactive contamination does not exceed the guidelines for risk of health effects

established by EPA.

Monitoring equipment checks: Monitoring procedures include the types of monitoring equipment to be

used, how operational checks will be conducted, and how people and equipment will be monitored. OROs 

conduct operational checks according to the procedures and guidance in the explanation under Criterion

H.10. For a hand-held monitor with a probe, these may include checking the batteries and measuring its

response to radiation from an accompanying radioactive check source. For a portal monitor, the procedure

involves turning the instrument on, checking for power indication, operating and observing any check

circuits, and counting the check source according to procedures for source location and counting time.

The plans/procedures indicate that the portal monitors will meet requirements contained in FEMA-REP21.

Monitoring procedures: The plans/procedures also describe the procedures for monitoring people using

either portal monitors or portable instruments. Portable survey instruments have earphones or speakers

and a covered detector/probe (e.g., covered with plastic wrap that is thin, transparent, fits tightly, and can

be easily replaced if it becomes contaminated). Experience has shown that one or two layers of plastic

wrap will not significantly shield the beta radiation from the detector. If the detector/probe is not covered,

extra detectors need to be available to replace those that become contaminated.

For portable instruments, the beta shield on the detector remains open and facing the contaminated

surface and is moved over the entire body of the individual, close to the surface, and at a relatively slow

speed. These factors vary, depending on the type of instrument and detector used, and are clearly

described in the appropriate procedures.64

 

64 For further guidance, see Contamination Monitoring Guidance for Portable Instruments Used for Radiological Emergency Response to 

Nuclear Power Plant Accidents, FEMA-REP-22, October 2002.
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Portal monitors are used for individuals standing inside or passing through the monitoring framework for

a specified period of time, while the instrument integrates the amount of radiation detected. The duration

of the integration depends on the type of portal monitor, background radiation in the area, and the

minimum detection level setting.

Vehicles and equipment: Plans/procedures also address monitoring emergency worker equipment and

vehicles. It generally is not necessary to monitor the entire surface of vehicles. At a minimum, areas such

as the front bumper, radiator grill, wheel wells, and door handles are monitored. If elevated readings are

observed in the hood area, it is possible that the air filter, which is located in the engine compartment, is

contaminated. In such cases, the plans/procedures provide for trigger/action levels. Because emergency 

workers may be working in areas where they (and their equipment and vehicles) could become

contaminated, interior surfaces including the driver‘s seat, steering wheel, and gas and brake pedals are

monitored. The passenger side floor and seat is monitored if persons who rode in the vehicle were found

to be contaminated or if otherwise deemed appropriate. Any area where emergency equipment was

placed, such as a trunk or deck area, and all equipment taken into the plume EPZ, including paper forms

and other spare supplies, is monitored.

Trigger/action levels: Organizations include in their plans/procedures the decision criteria that indicate a

need to decontaminate emergency workers, equipment, and vehicles. The instruments ordinarily used for

determining contamination levels are count rate meters employing G-M detectors. Therefore, the decision

criterion is usually given in counts per minute (cpm). The plans/procedures specify trigger/action levels,

although they may change depending on the detection instruments used.

References

 FEMA-REP-2, Revision 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 

– Airborne Release, June 1990.

 FEMA-REP-21, Contamination Monitoring Standard for a Portal Monitor Used for Radiological 

Emergency Response, March 1995.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 FEMA-REP-22, Contamination Monitoring Guidance for Portable Instruments Used for 

Radiological Emergency Response to Nuclear Power Plant Accidents, October 2002.

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION K.5.b

Each organization, as appropriate, shall establish the means for radiological

decontamination of emergency personnel wounds, supplies, instruments and

equipment, and for waste disposal.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION K.5.b, ORO PLANS/PROCEDURES SHALL ADDRESS:

 Supplies and equipment for decontamination.

 Decontaminating people, equipment, and vehicles.

 Re-monitoring people, equipment, and vehicles and recording the results.
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 Criteria for sending individuals with fixed contamination for medical attention.

 Controlling the spread of contamination.

 Number of people needed to perform decontamination in the event of an emergency.

 Contaminated waste collection, handling, and storage.

EXPLANATION

Facilities for decontaminating emergency workers and their equipment may be either co-located with or

located separately from decontamination facilities for the general public. The plans/procedures include

information on the following items:

a. Facility Locations

The plans/procedures indicate the location of emergency worker decontamination facilities. These are

located outside the plume EPZ, if possible. Facilities consist of a structure containing the necessary

equipment and supplies and an open area for monitoring and decontamination of vehicles and equipment.

The facilities include separate showers for men and women. The facility has sufficient parking space to

separate contaminated and uncontaminated vehicles and equipment. The plans/procedures include the

facility street address and physical layout, including diagrams showing the flow of individuals and

vehicles through the facility. Plans/procedures describe provisions for storage of contaminated clothing 

and other personal items, including: (1) procedures to avoid raising the background gamma exposure rate 

significantly in the monitoring area, (2) the location for initial waste storage, and (3) demarcation and 

security for storage areas.

b. Procedures for Detected Contamination

Plans/procedures describe the process for recording contamination and exposure of emergency workers as

well as procedures for isolating contaminated vehicles and equipment, if necessary. The plans/procedures

also describe the individual, by title/position, responsible for disposing of or storing contaminated wastes,

both initial and intermediate storage; the security measures to protect the waste from being mishandled;

and the means for disposal and/or storage.

c. Decontamination

The plans/procedures describe decontamination procedures for emergency workers, equipment, and

vehicles. Generally decontamination supplies available at the emergency worker decontamination center

include, at a minimum, sinks and showers with soap and water, wash cloths, towels, and changes of

clothing.

Decontamination of equipment and vehicles may include: (1) use of vacuum cleaners, preferably with

high-efficiency particulate filters; (2) scrubbing contaminated areas with soap and water; (3) copiously

applying low-pressure water and soap solutions to affected areas; and (4) applying organic solvents on

greasy or waxed surfaces.

The plans/procedures provide for the re-monitoring of individuals, vehicles, and equipment after

decontamination. The plans/procedures specify the number of decontamination attempts to be made

before an individual is sent to a medical facility for more intensive decontamination, and identify the

medical facilities that will receive individuals who are still contaminated. Procedures for dealing with

equipment and vehicles that cannot be adequately decontaminated are also described.
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The plans/procedures provide for collecting, handling, and storing contaminated wastes. Waste handling

procedures address all types of anticipated contaminated wastes, including clothing, equipment,

decontamination supplies, etc. OROs do not need to collect waste water from decontamination operations.

d. Contamination Control

The plans/procedures describe contamination control procedures (e.g., floor coverings, personal 

protective equipment worn by emergency workers) for each facility, including the means for separating

contaminated individuals from those who have not been monitored or those found to be uncontaminated.

References

 FEMA Policy Statement, Policy Statement on Disposal of Waste Water and Contaminated Products 

from Decontamination Activities, January 1989.

 FEMA-REP-2, Revision 2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 

– Airborne Release, June 1990.

 FEMA-REP-21, Contamination Monitoring Standard for a Portal Monitor Used for Radiological 

Emergency Response, March 1995.

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 FEMA-REP-22, Contamination Monitoring Guidance for Portable Instruments Used for 

Radiological Emergency Response to Nuclear Power Plant Accidents, October 2002.

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION K.6

Each licensee shall provide onsite contamination control measures including:

a. area access control;

b. drinking water and food supplies;

c. criteria for permitting return of areas and items to normal use, see EPA400-R-92-001.

65

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION K.7

Each licensee shall provide the capability for decontaminating relocated onsite

personnel, including provisions for extra clothing and decontaminants suitable for

the type of contamination expected, with particular attention given to radioiodine

contamination of the skin.

Applicability and Cross Reference to Plans: Licensee X State Local 

 

65 Original reference to Draft ANSI 13.12 replaced with EPA-400-R-92-001 per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 

2002.
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12. PLANNING STANDARD L – MEDICAL AND PUBLIC HEALTH SUPPORT

Arrangements are made for medical services for contaminated injured individuals.66

NUREG CRITERION L.1

Each organization shall arrange for local and backup hospital and medical services

having the capability for evaluation of radiation exposure and uptake, including

assurance that persons providing these services are adequately prepared to handle

contaminated individuals.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION L.1, ORO PLANS/PROCEDURES SHALL:

 Reference written agreements or LOAs with hospitals/medical facilities.

 Reference written agreements or LOAs for technical staff that are not employed by the

hospital/medical facility.

 Include individual facility capabilities, including the number of radiologically trained medical

personnel and support staff.

 Describe hospital/medical facility and support service operations for treating contaminated, injured, or

exposed individuals.

 Describe dosimetry procedures, including record keeping and final receipt for processing.

EXPLANATION

This criterion refers to arranging medical care for the general public. Medical care for members of the

licensee‘s utility staff is addressed in Criterion B.9. One primary local hospital/medical facility and one

backup facility for each site are designated for the evaluation and emergency treatment of contaminated

injured members of the general public. The primary and backup hospitals/medical facilities for the public

may be the same as those for the utility employees and emergency workers.

Provider location: FEMA prefers that both the primary and backup facilities and attendant emergency

medical transportation services be located at least 5 miles and preferably 10 miles beyond the boundaries

of the plume exposure pathway EPZ. FEMA recognizes that OROs may not be able to locate both the

primary and backup hospital/medical facility at those distances. Therefore, at least one of the medical

facilities and one attendant emergency medical transportation services provider are located at least 5 miles

outside the plume exposure pathway EPZ.

Letters of agreement: OROs obtain written agreements from the hospitals/medical facilities, medical

transportation providers, and technical staff (i.e., not employed or contracted by the hospital/medical

facility including health physicists, radiological control technicians, etc.) and include the agreements in

the plans/procedures. Criterion L.4 discusses more details regarding LOAs for medical transportation

providers. The written agreements contain assurances that the providers have adequate technical

information (e.g., treatment protocols) and treatment capabilities for handling contaminated, injured, or

exposed individuals. If OROs do not obtain written agreements, the licensee obtains the agreements with

 

66 The availability of an integrated emergency medical services system and a public health emergency plan serving the area in which the NPP is 

located and, as a minimum, equivalent to the Public Health Service Guide for Developing Health Disaster Plans (1974) and to the requirements 

of an emergency medical services system as outlined in the Emergency Medical Services System Act of 1973 (PL 93-154 and amendments in 

the 1979 PL 96-142) should be a part of and consistent with overall ORO disaster control plans/procedures and should be compatible with the 

specific overall emergency response for the NPP.
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the listed hospitals/medical facilities, medical transportation providers, and technical staff. If good faith

efforts are not successful in a particular case, the licensee provides or arranges for adequate compensatory

measures (e.g., obtain written agreements with other providers or provide temporary field medical care).

LOAs state the hospital/medical facility name; location of facility; type of capabilities; and approximate

number of contaminated, injured, or exposed patients who can be treated.

Staff specifications: Primary and backup facility capabilities are addressed in separate hospital/medical

facility plans/procedures. The plans/procedures identify those individuals, by title/position, who are in

charge of coordinating this program, as well as the number of radiologically trained medical personnel

available. Hospitals/medical facilities have at least one physician and one nurse capable of supervising the

evaluation and treatment of contaminated, injured, or exposed patients. The plans/procedures specify that

a physician will be present or readily available at all times during operation of the Radiation Emergency

Area.

67 Hospital/medical facility plans/procedures include or reference listings of such staff. Although not

required, a health physics technician or medical physicist should be available to assist the medical staff.

Plans/procedures identify, by title/position, the person who will monitor individuals to determine the

nature and extent of radiological contamination. Licensee personnel, health physics technicians, trained

hospital personnel, or members of the transport crew (see Criterion L.4) may perform monitoring. If

licensee personnel will perform radiological monitoring and contamination control for contaminated,

injured, or exposed individuals, plans/procedures document these arrangements and reference supporting 

written agreements.

Facility procedures: Hospital/medical facility plans/procedures describe the following:

 Maximum number of contaminated, injured, or exposed patients who could be treated at one time.

 Contingencies in place if the number of patients needing treatment exceeds capacity.

 Approximate response time needed to establish controlled areas and assemble and fully prepare the

necessary medical/radiological staff.

 Details of notification, including information that the hospital/medical facility would receive regarding

the incident and patients.

 Staff who would be mobilized and their responsibilities.

 Communication methods, particularly for emergency vehicles en route.

 Routes for incoming emergency vehicles.

 List of equipment available, including personal protective equipment (e.g., gloves, booties).

 Preparation of the decontamination area, including floor coverings, filtered ventilation systems, and

appropriate radiation warning signs.

 Diagram of the treatment and decontamination area, including a buffer zone separating the Radioactive 

Emergency Area from the rest of the facility.

 Monitoring and decontaminating patients, including controlling contamination, disposing of

contaminated waste, and re-monitoring after decontamination.

 An example of the system used to record patient data.

 

67 A Radiation Emergency Area is an area in a medical facility for monitoring, decontamination, and treatment of contaminated injured 

individuals, and for contamination control.
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Staff dosimetry: In addition, hospital/medical facility plans/procedures contain the following information

regarding staff dosimetry:

 How to obtain assigned dosimetry.

 The organization responsible for issuing dosimetry. This typically could be either the state/local

emergency management agency or the utility if the hospital/medical facility provides care to both

utility and government staff. In some cases, both parties issue dosimetry.

 The person, by title/position, or organization responsible for radiological monitoring and exposure

recordkeeping and processing.

 The mechanism for obtaining exposure records in special cases where dosimetry is not issued by the

organization responsible for final record keeping.

References

 Emergency Medical Services (EMS) System Act of 1973 (PL 93-154 and amendments in the 1979 PL

96-142).

 Public Health Service Guide for Developing Health Disaster Plans, 1974.

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION L.2

L.2. Each licensee shall provide for onsite first aid capability.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION L.3

Each State shall develop lists indicating the location of public, private and military

hospitals and other emergency medical services facilities within the State or

contiguous States considered capable of providing medical support for any

contaminated injured individual. The listing shall include the name, location, type of

facility and capacity, and any special radiological capabilities. These emergency

medical services should be able to radiologically monitor contamination personnel,

and have facilities and trained personnel able to care for contaminated injured

persons.

Applicability and Cross Reference to Plans: Licensee State X Local 

TO MEET THE INTENT OF CRITERION L.3, ORO PLANS/PROCEDURES SHALL INCLUDE:

 Lists of additional hospitals/medical facilities capable of providing medical support for contaminated,

injured, or exposed individuals.

EXPLANATION

The explanation for Evaluation Criterion L.1 addresses the need for establishing designated primary and

backup hospital/medical facilities for treatment of contaminated injured individuals. Evaluation Criterion

L.3 describes information for additional hospitals/medical facilities in the area that would be available to
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assist with overflow from the designated primary and backup facilities. This list will enable ORO officials

to direct the public to those institutions capable of handling contaminated, injured, or exposed patients.

This list includes the following for each facility:

 Name.

 Location.

 Type (i.e., public, private, or military hospital, or other type of medical facility).

 Capacity for ambulatory and non-ambulatory patients. Ambulatory capacity means the

hospital/medical facility‘s capacity to treat individuals as outpatients – or the number of individuals

that the facility can handle per day for treatment of radiological contamination or exposure without

regard to hospitalization. Non-ambulatory capacity refers to the facility‘s inpatient capacity, or the total

number of available beds without regard to treatment of radiological contamination or exposure.

 Any special radiological capabilities (e.g., specific radiologically trained staff such as health or medical

physicist), the types of monitoring equipment available, and the facility‘s capabilities for analyzing

samples for internal and external contamination.

Plans/procedures provide this information in the form of a matrix or list and include it in an appendix 

listing resources.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION L.4

Each organization shall arrange for transporting victims of radiological accidents to

medical support facilities.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION L.4, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 The method for determining an appropriate hospital/medical facility and the person, by title/position,

responsible for the determination.

 Means of transporting individuals, including how to request additional emergency medical services.

 Communications between the transport crew and hospital/medical facility staff.

 Specifics of radiological monitoring.

 Contamination control measures during transport.

 Decontamination techniques, including trigger/action levels.

 Dosimetry for the transport crew.

 LOAs with transportation providers (see Criterion A.3).

EXPLANATION

Transporting radiologically contaminated, injured, or exposed individuals involves more than moving an

individual from the incident scene to a hospital/medical facility. Plans/procedures include procedures and
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LOAs from transportation providers. LOAs include the name of the organization, type of services

provided, and maximum number of vehicles that can be provided.

Plans/procedures address the vehicles, equipment, procedures, and personnel needed for medical

transportation support. For patients with urgent medical conditions, the plans/procedures establish

priorities between addressing radioactive contamination and the need for prompt transportation to a

medical facility. The following topics are included in this discussion:

a. Appropriate Medical Facility

Plans/procedures identify the person responsible, by title/position, for arranging transportation to the

appropriate hospital/medical facility for contaminated, injured, or exposed individuals. Plans/procedures

include the process for selecting a facility based on the extent of contamination and nature of the injuries.

Individuals with urgent medical conditions (e.g., heart attack, serious injury) are transported directly to

the nearest facility regardless of the radioactive plume conditions.

b. Transport of Individuals

Two factors are considered in determining the appropriate type of vehicle to transport contaminated,

injured, or exposed individuals to a hospital/medical facility: (1) the type and severity of the medical

problems encountered and (2) the need for trained emergency medical services personnel. The early

symptoms of exposure to high levels of radiation may be limited to nausea and vomiting. In these cases,

non-specialized vehicles (e.g., auto, van, bus) may be used. When more severe symptoms or injuries are

present, emergency workers use specialized vehicles (e.g., ambulance, med vac, or critical care unit). Use

of these resources is supported by written agreements. Plans/procedures for transportation providers

include the process for making this decision and requesting additional emergency medical services.

c. Maintaining Communications

Plans/procedures describe the process for communicating with transport crews when transporting an

individual to a hospital/medical facility. These procedures ensure that vehicle crews maintain

communication with the hospital/medical facility to allow for advance preparations for treatment.

Procedures identify the person responsible, by title/position, for receiving notification from the transport

crew and notifying Radioactive Emergency Area staff to begin setup. Procedures include a list of

information that is provided to the receiving hospital/medical facility (e.g., data on the individual‘s

physical condition, vital signs, type of radiological contamination, and estimated time of arrival).

d. Monitoring of Individuals

Plans/procedures identify the person responsible, by title/position, for monitoring an individual to

determine the nature and extent of external radiological contamination. Licensee personnel, health physics

technicians, trained hospital personnel, or members of the transport crew may perform monitoring. If

plans/procedures state that licensee personnel will perform radiological monitoring and contamination

control functions during transportation of contaminated, injured, or exposed individuals, LOAs support 

these arrangements.

Plans/procedures also describe monitoring processes, whether performed in the field prior to transport or

immediately upon arrival at the hospital/medical facility. If individual monitoring is deferred to the

facility, plans/procedures state that transport crews assume the individual is contaminated and employ

appropriate contamination control measures. Plans/procedures also describe use of monitoring equipment

(e.g., type of instrumentation, required labeling, calibration, responsiveness to an identified check source,
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use of earphones or a speaker to allow the individual using the monitor to focus on correctly positioning

the survey instrument probe rather than reading the monitor).

e. Contamination Control Measures

Plans/procedures describe contamination control measures during transport of contaminated, injured, or

exposed individuals. Examples of contamination control measures include using gloves to prevent the

spread of contamination, lining the patient area of the vehicle with a protective covering or wrapping the

patient in a sheet or blanket, and covering the survey instrument probe with thin plastic to minimize

contamination. Because these actions are only for controlling the spread of contamination and will not

protect the patient or attendants from radiation, contamination control efforts do not hinder or delay

medical care for the patient.

f. Decontamination Measures

Plans/procedures describe decontamination processes and provide trigger/action levels for the vehicle and

crew if they are found to be contaminated upon arrival at the hospital/medical facility. Trigger/action

levels correspond to the radiological monitoring equipment being used. The plans/procedures state where

decontamination would take place.

g. Dosimetry

Plans/procedures identify the organization (e.g., state/local emergency management agency) responsible

for issuing dosimetry and describe how the transport crew would obtain their dosimetry.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
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13. PLANNING STANDARD M – RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS

General plans for recovery and reentry are developed.

NUREG CRITERION M.1

Each organization, as appropriate, shall develop general plans and procedures for

reentry and recovery and describe the means by which decisions to relax protective

measures (e.g., allow reentry into an evacuated area) are reached. This process

should consider both existing and potential conditions.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION M.1, ORO PLANS/PROCEDURES SHALL DESCRIBE

ACTIONS DURING INTERMEDIATE AND LATE PHASES OF AN INCIDENT, INCLUDING:

 Continuing environmental radiation measurements and dose assessments.

 Establishing restricted and buffer zones.

 Relocation.

 Controlled reentry into restricted areas.

 Return of the public to previously evacuated areas.

 Recovery, including a list of actions that may be needed and organizations responsible for carrying

them out.

EXPLANATION

At the time NUREG-0654/FEMA-REP-1 was published, ―recovery and reentry‖ was used as a general

term referring to activities that occur after the initial phase of an emergency. Since then, revised EPA

PAGs68 have described three phases of an incident:

 Early phase – initial response and protective actions. This phase is also called the plume or emergency

phase.

 Intermediate phase – continuing response and protective actions to protect the public from deposited

radioactivity. This phase includes ingestion and relocation activities.

 Late phase – return and recovery.

This criterion addresses the post-plume activities of the intermediate and late phases. Under updated

guidelines, post-plume actions address the following topics:

a. Relocation

Some people or households may need to be removed from contaminated areas, perhaps permanently, to

avoid chronic radiation exposure. Plans/procedures describe how to relocate individuals after an incident

and outline the organization‘s responsibilities, including decision making, notification, and provision of

physical and/or economic assistance.

 

68 See Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA 400-R-92-001 (May 1992).
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b. Reentry

Reentry can occur during the plume or post-plume phase. This criterion addresses post-plume reentry.

Certain individuals who have been evacuated or relocated from a restricted zone may be allowed to

reenter under controlled conditions to perform additional emergency response activities or carry out

specific types of personal business. For example, farmers may be permitted to reenter to provide essential

care for livestock. Plans/procedures include information on the types of reentry permitted and under what

conditions they would be permitted. Some conditions include: (1) use of access control points to issue

dosimetry and train reentering individuals on its use; (2) use of stay times (as used here, the amount of

time a person can safely stay in a restricted zone without exceeding their exposure limit), depending on

the location of the reentry destination; (3) use of a health physicist escort or other personnel escort trained

in the use of dosimetry; and (4) provision of monitoring and decontamination for exiting individuals.

c. Return

Previously evacuated persons are permitted to return to areas cleared for unrestricted residence.

Evacuated areas must be below radiation protection criteria for relocation before the evacuated or

relocated persons are allowed to return to their homes and businesses. The plans/procedures describe the

processes for determining which areas are cleared and include the organizations responsible for testing

and certifying that an area is safe for return.

d. Recovery

The term ―recovery‖ refers to the process of reducing radiation exposure rates and concentrations of

radioactive material in the environment to levels safe enough for the public to return to an area for

unconditional occupancy or use after the initial phase of the radiological emergency. In areas where

deposition occurred, procedures to reduce or remove the radioactive materials may need to be developed.

The plans/procedures include information on the organizations responsible for determining the need for

and carrying out such cleanup operations.

Assessment of an incident will continue during the intermediate and late phases. Activities will include:

(1) air and soil sampling and analysis; (2) dose assessment and projection; and (3) establishing restricted

zone(s) and buffer zone(s). It will be necessary to develop procedures to protect persons who live in or

use areas contaminated at levels below the dose for relocation. It will also be necessary to establish

controls for reentry, as described above under Reentry. All procedures to support relocation and return

decisions will be based on a comparison of EPA PAGs to the potential long-term dose to the public from

materials deposited after an incident.

References

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-115 October 2011

NUREG CRITERION M.2

Each licensee plan shall contain the position/title, authority, and responsibilities of

individuals who will fill key positions in the facility recovery organization. This

organization shall include technical personnel with responsibilities to develop,

evaluate, and direct recovery and reentry operations. The recovery organization

recommended by Functional Criteria for Emergency Response Facilities, NUREG0696 (February 1981) and Clarification of TMI Action Plan Requirements,

Requirements for Emergency Response Capability, NUREG-0737, Supplement 1

(January 1983),

69 is an acceptable framework.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION M.3

Each licensee and State plan shall specify means for informing members of the

response organizations that a recovery operation is to be initiated, and of any

changes in the organizational structure that may occur.

Applicability and Cross Reference to Plans: Licensee X State X Local 70

TO MEET THE INTENT OF CRITERION M.3, ORO PLANS/PROCEDURES SHALL INDICATE:

 Means used to keep all involved response organizations (e.g., OROs with affected populations and/or

areas) informed of recovery phase plans/procedures being developed, such as remedial measures, how

long they will take, and what final outcome is expected.

 Changes that might take place in the organizational structure (e.g., the Governor being in charge under

a ―state of emergency‖ that may then revert to a new or other authority).

EXPLANATION

Plans/procedures include information on the means for keeping all response organizations informed

of procedures developed and actions to be taken during the intermediate and late phases of an

incident.

References

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 National Incident Management System, December 2008.

 National Response Framework, January 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 

69 Original reference to The Atomic Industrial Forum’s Nuclear Power Plant Emergency Response Plan (October 11, 1979) has been superseded 

by the above two documents per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, dated March 2002.

70 FEMA recognizes that, in some instances, this criterion applies to local response organizations. 
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REP Program Manual Page II-116 October 2011

NUREG CRITERION M.4

Each plan shall establish a method for periodically estimating total population

exposure.

Applicability and Cross Reference to Plans: Licensee X State X Local 

TO MEET THE INTENT OF CRITERION M.4, ORO PLANS/PROCEDURES SHALL: 

 Identify agencies responsible for and involved in long-term dose assessment activities after an incident.

EXPLANATION

The purpose of this criterion is to provide a basis for an after-the-fact estimate of the health effects from

the radiological incident. The plans/procedures include information about how the state will estimate total

population exposure caused by the incident from all pathways. One or more Federal agencies usually 

performs the dose assessment process in coordination with state agencies.

References

 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

 National Incident Management System, December 2008.

 National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
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REP Program Manual Page II-117 October 2011

14. PLANNING STANDARD N – EXERCISES AND DRILLS

Periodic exercises are (will be) conducted to evaluate major portions of emergency

response capabilities, periodic drills are (will be) conducted to develop and maintain key

skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

NUREG CRITERION N.1.a

An exercise is an event that tests the integrated capability and a major portion of the

basic elements existing within emergency preparedness plans and organizations.

Exercises shall be conducted as set forth in NRC and FEMA rules and policy.71

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION N.1.a, ORO PLANS/PROCEDURES SHALL INDICATE THAT:

 REP exercises will be conducted in accordance with NRC and FEMA rules and policy.

EXPLANATION

Once plans/procedures have been developed and staff trained in response functions, exercises are

conducted to demonstrate that response capabilities described in the plans/procedures can actually be

implemented. Part III of this manual provides detailed information on exercise development, conduct, and

documentation.

Through PPD-8, the President directed the establishment of the National Exercise Program to integrate

national-level exercise activities. Key features of the HSEEP methodology include:

 Scheduling through the use of an annual Training and Exercise Plan Workshop (T&EPW) and Multiyear Training and Exercise Plan;

 Planning and implementation in accordance with the guidelines set forth in HSEEP methodology;

 A properly formatted After-Action Report/Improvement Plan (AAR/IP); and

 Tracking and implementation of corrective actions identified in the AAR/IP.

In concert with the National Exercise Program, REP exercises will use the HSEEP methodology and

guidance to align and standardize exercise program management, design, development, conduct,

evaluation, and improvement planning. However, as discussed in more detail in Part III, HSEEP does not

supersede existing NUREG-0654/FEMA-REP-1 requirements for the REP Program.

References

 HSEEP Volume I: HSEEP Overview and Exercise Program Management, February 2007.

 HSEEP Volume II: Exercise Planning and Conduct, February 2007.

 HSEEP Volume III: Exercise Evaluation and Improvement Planning, February 2007

 HSEEP Volume V: Prevention Exercises, March 28, 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 PPD-8 National Preparedness

 FEMA Directive 123-15, January 16, 2009.

 

71 This criterion amended per NUREG-0654/FEMA-REP-1, Supplement 4, (2011).
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REP Program Manual Page II-118 October 2011

NUREG CRITERION N.1.b

An exercise shall demonstrate the key skills of response organizations to adequately

respond to an incident scenario. The scenarios shall vary such that the major

elements of emergency plans are exercised within an eight-year exercise cycle. Each

scenario variation shall be demonstrated at least once during the eight-year exercise

cycle and shall include, but not be limited to, the following:

a. Hostile action directed at the plant site involving the integration of offsite

resources with onsite response;

b. An initial classification of or rapid escalation to a Site Area Emergency or

General Emergency;

c. No radiological release or an unplanned minimal radiological release that

requires the site to declare a Site Area Emergency, but does not require

declaration of a General Emergency. For this scenario variation the

following conditions shall apply:

i. The licensee is required to demonstrate the ability to respond to a

no/minimal radiological release scenario at least once within the

eight-year exercise cycle. State, Tribal and local response

organizations have the option, and are encouraged, to participate

jointly in this demonstration. 

ii. When planning for a joint no/minimal radiological release exercise,

affected State, Tribal and local jurisdictions, the licensee, and FEMA

will identify offsite capabilities that may still need to be evaluated and

agree upon appropriate alternative evaluation methods to satisfy

FEMA’s biennial criteria requirements. Alternative evaluation

methods that could be considered during the extent of play

negotiations include expansion of the exercise scenario, out of

sequence activities, plan reviews, staff assistance visits or other

means as described in FEMA guidance.

iii. If the offsite organizations elect not to participate in the licensee’s

required minimal or no-release exercise, they will still be obligated to

meet the exercise requirements as specified in 44 CFR § 350.9.72

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION N.1.b, ORO PLANS/PROCEDURES SHALL INDICATE THAT:

 All major elements of the plans/procedures will be tested at minimum at the frequency specified by the

REP Program Manual, Exhibit III-2.

 Scenarios for exercises will be varied from exercise to exercise and include all required scenario

variations during the exercise cycle.

 

72 This criterion amended per NUREG-0654/FEMA-REP-1, Supplement 4, (2011).
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-119 October 2011

EXPLANATION

This criterion addresses the use of exercises to demonstrate the capability of OROs to respond to an

emergency involving a commercial NPP. Criterion N.1.b addresses frequency and scenario requirements

for plume-phase exercises. Criterion N.1.d describes exercise requirements specific to ingestion-phase

activities.

a. Exercise Frequency

State and local OROs must conduct joint full-participation

exercises with the licensee biennially (i.e., every 2 years) in

order to comply with the regulations in 44 CFR § 350.9(c).

This applies to OROs that have an NPP within their

boundaries or that lie wholly or partially within the 10-mile

plume exposure EPZ of such a site. The current exercise

cycle is 8 years and spans 4 biennial exercises.

The exercise cycle is based on the date of the first joint

(licensee and ORO) exercise conducted at the site after

November 3, 1980 (the effective date of the NRC Final

Regulations on Emergency Planning, 10 CFR Part 50

[Appendix E]) (45 FR 55410, August 19, 1980), and

issuance of NUREG-0654/FEMA-REP-1, Revision 1,

November 1980.

One joint exercise in each 8-year cycle should be a full-scale

exercise that tests real-time response with all ORO entities

participating and includes the integrated demonstration of all

activities that would occur if the exercise scenario were to

occur in real life. In the other exercises within the cycle,

with the approval of the RAC Chair, OROs may utilize

different types of exercises, including functional and

tabletop exercises and drills, to demonstrate response

capabilities.

Partial participation: The regulatory provisions give OROs with responsibilities to multiple NPPs

flexibility to partially participate in some biennial exercises. States with multiple sites may rotate their full

participation among the sites (i.e., when not fully participating at a site, the state partially participates to

support OROs). If a local ORO lies within the EPZ of more than one NPP and full participation poses an

undue hardship, it may request permission to partially participate. OROs submit requests for exemption

from full participation to the FEMA Regional Office, which will forward the request to FEMA

Headquarters.

b. Scenario Variations

Exercises are a critical component of FEMA‘s reasonable assurance determinations that ORO REP

plans/procedures are adequate to protect public health and safety in the vicinity of operating or proposed

commercial NPPs. REP exercise scenarios need to be enhanced to help avoid anticipatory responses by

exercise participants due to preconditioning and to emphasize the expected interfaces and coordination

between key decision-makers based on realistic postulated events. Traditionally, REP exercise scenarios

have been designed to reliably deliver the expected demonstrations in a manner that facilitates

performance and evaluation. This situation has resulted in a pattern of predictable biennial exercises that

Full-participation Versus Full-scale

Full participation is a REP-specific term 

found in 44 CFR § 350.2(j) that refers to an 

exercise in which: (1) state and local 

government emergency personnel are 

engaged in sufficient numbers to verify the 

capability to respond to the actions required 

by the accident scenario; (2) the integrated 

capability to adequately assess and respond 

to an accident at a commercial nuclear 

power plant is tested; and (3) the 

implementation of the observable portions of 

state and/or local plans is tested.

A true full-scale exercise involves all 

organizations participating in real-time 

hands-on engagement that covers the full 

range of response activities and, for REP 

exercises, evaluation of all Demonstration 

Criteria. 

Most REP biennial full-participation joint 

exercises are functional exercises – they 

meet the criteria for full participation, but 

some response capabilities are simulated or 

demonstrated out of sequence from the 

scenario. In addition, not every ORO is 

required to participate in every fullparticipation exercise.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-120 October 2011

may precondition responders toward certain expectations about how the exercise scenario will unfold.

Some of the predictable features of biennial exercise scenarios included:

 A large radiological release, often resulting in the need for public dose-based protective actions beyond

5 miles;

 The initial plant conditions for the exercise often suggested the scenario outcome;

 The licensee was not allowed to mitigate the accident before a release occurs;

 The release occurred after a General Emergency is declared;

 Initial PARs were developed based on plant conditions rather than on an assessment of radiological

conditions;

 The release was directed toward the major population centers without regard for existing

meteorological conditions and terminated before the exercise ends;

 The exercise escalated in a sequential manner through the emergency classes; and

 There was enough time between emergency classes to facilitate the evaluation of required

demonstrations.

Further, typical scenarios in biennial exercises use simulated accidents such as loss of coolant and steam

generator tube rupture accidents, which do not address HAB incidents or site-specific ―all-hazards‖

incidents. Therefore, FEMA and the NRC have added new scenario variables, including varied release

conditions, non-sequential escalation of emergency classification levels, and incorporating HAB

incidents.

FEMA and the NRC currently allow exercise planners to vary the cause and magnitude of the radioactive

release as long as they meet two key criteria:

 Plume-phase scenarios must result in actual or potential conditions that trigger PADs for the public at

varying distances in the EPZ (e.g., evacuation, shelter-in-place, and use of KI). If the scenario calls for

no or minimal release, OROs use alternative methods (e.g., controller injects, out-of-sequence

activities, or other venues) to demonstrate the capability to make and implement PADs.

 At least one exercise every 8 years73 must include a post-plume phase ingestion pathway and

relocation/reentry/return exercise.

Periodic exercises demonstrate response to a wide spectrum of incidents including, but not limited to,

those with and without core damage, with and without a radiological release, that involve hostile action

against the site, and that allow realistic simulated actions to mitigate consequences of the incident.

The introduction of the scenario variations below is intended to enhance the variability of exercise events

and minimize any negative training practices. The initiating event of an exercise scenario is varied to go

beyond the traditional equipment malfunctions and operation actions and bring more of an all-hazards

perspective.

Required scenario variations:

(1) Hostile action directed at the plant site involving the integration of offsite resources with

onsite response. Hostile actions against an NPP are initiating events that present unique

 

73 44 CFR § 350.9(c)(4) requires that states within the 50 mile EPZ of a site exercise the ingestion exposure pathway at least once every 5 years. 

This was modified to 6 years in 10 CFR Part 50, Appendix E, Section IV.F.2.d and GM PR-1, ―Policy on NUREG-0654/FEMA-REP-1 and 44 

CFR 350 Requirements‖ (October 4, 1985). The cycle was modified to 8 years by Supplement 4.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-121 October 2011

challenges to the licensee and OROs. An HAB incident may overwhelm local and state

response agencies, and may also involve response from agencies not normally involved in a

REP exercise. This scenario is used in at least one exercise in the 8-year cycle. The HAB

scenario variable can coincide with either a release or ―no release‖ scenario variable, but the

scenarios must not include a ―no release option‖ for consecutive HAB exercises at a particular

site.

(2) An initial classification of or rapid escalation to a Site

Area Emergency or General Emergency. Skipping or

rapidly escalating ECLs can make scenarios more

realistic and challenging. One scenario variable option is

to have an initial classification of or rapid escalation to a

Site Area Emergency or General Emergency. This

scenario is used in at least one exercise in the 8-year 

cycle and will vary depending on the jurisdictions‘

plans/procedures.

(3) No radiological release or an unplanned minimal

radiological release that requires the site to declare a

Site Area Emergency, but does not require the

declaration of a General Emergency. Not having every

exercise result in a radiological release will help avoid

anticipatory responses. Licensees are required to use this

variable at least once per 8-year exercise cycle. OROs are encouraged, but not required, to

participate in this exercise with the licensee. If OROs elect to participate in a joint exercise with

no or minimal release, part of the planning for the exercise will include identifying

Demonstration Criteria that will not be evaluated during the exercise and determining

appropriate alternative demonstration and evaluation venues so that the OROs can meet their

biennial evaluation requirements. See Part III of this manual for discussion of exercise planning

using this scenario variable.

Optional Scenario Variations:

(4) Varied radiological release effects and meteorological conditions. Varying release effects

and meteorological conditions from scenario to scenario is one option for enhancing realism in

exercise play. The variations should be consistent with plant design, site location, and

geography.

(5) A broader spectrum of initiating/concurrent events. All-hazard incidents may be considered

as possible scenario initiating or concurrent events, based on applicability to the site, provided

that they do not become the primary focus of the exercise or detract from the demonstration of

REP capabilities. All-hazard incidents may include:

 Natural disaster historically applicable to the area (e.g., hurricane, tornado, earthquake,

flooding);

 Site-specific all-hazards incidents (e.g., accident involving near-site facility, train

derailment on or adjacent to site owner controlled area); and

 Seasonal factors impacting the PARs and decision process (e.g., transient populations,

weather conditions, agricultural seasons).

The Planning and 

Preparedness Assessment 

Strategy Complements the 

Joint Biennial Exercise

The expansion of venues for 

demonstrating preparedness outside 

of the biennial exercise increases 

flexibility in the REP exercise 

program. For example, if the biennial 

exercise scenario is using the 

no/minimal release variable, OROs 

can use other types of exercises or 

out-of-sequence activities to meet 

evaluation requirements for the 

Demonstration Criteria that were not 

met through the biennial exercise.
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-122 October 2011

References

 National Incident Management System, December 2008.

 HSEEP Volume I: HSEEP Overview and Exercise Program Management, February 2007.

 HSEEP Volume II: Exercise Planning and Conduct, February 2007.

 HSEEP Volume III: Exercise Evaluation and Improvement Planning, February 2007.

 HSEEP Volume V: Prevention Exercises, March 28, 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION N.1.c

Provisions must be made to start a drill or exercise between 6:00 p.m. and 4:00 a.m.

at least once in every eight-year exercise cycle. Some drills or exercises should be

unannounced.74

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION N.1.d

An exercise shall include mobilization and implementation of State and local (as

appropriate) personnel and resources adequate to verify the capability and response

to a large radiological release requiring ingestion pathway protective actions beyond

the 10 mile EPZ at least once every 8 years. Organizations shall specify who is

responsible for the decision-making process. OROs shall reference or include the

organization’s procedures for making PADs and implementing protective actions

based upon PAGs that are consistent with EPA recommendations, and the process

for ensuring coordination of PADs with all applicable jurisdictions.75

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF CRITERION N.1.d, ORO PLANS/PROCEDURES SHALL INDICATE THAT:

 The state and other OROs (as appropriate) will participate in an ingestion pathway exercise at least

once every 8 years.

 States that do not have an NPP located within their borders, but are located within the 50-mile EPZ of a

bordering state‘s NPP, must fully participate in at least one exercise at least once every 8 years at the

bordering state‘s site(s).

 OROs within the 50-mile EPZ that are not part of the full-participation ingestion exercise with the state

participate in an ingestion tabletop exercise or other ingestion pathway training activity at least once

during the exercise cycle.

 The number and types of personnel participating in ingestion aspects of an exercise will be sufficient

for carrying out those ingestion measures required by the incident scenario.

 

74 This criterion added per NUREG-0654/FEMA-REP-1, Supplement 4, (2011).

75 This criterion added per NUREG-0654/FEMA-REP-1, Supplement 4, (2011).
PART II: REP PROGRAM PLANNING GUIDANCE

REP Program Manual Page II-123 October 2011

EXPLANATION:

States within the 50-mile ingestion exposure pathway EPZ of an NPP must participate in the ingestion

pathway portion of exercises at least once every 8 years at that site.76 The level of participation may vary

as follows:

States that have multiple sites rotate this participation from site to site; no partial participation is required.

During the year in which the full-participation ingestion pathway exercise is held at one of the sites, the

responsible OROs review their ingestion pathway plans/procedures for the other sites within the state to 

verify their accuracy and completeness. This review validates the identification of farms, food processors,

and distributors. OROs report this review and any resultant plan revisions in the ALC as part of the

annual review and plans/procedures update.

If a state is within the 50-mile ingestion exposure pathway zone of a site located in a bordering state, and

also has a site located within its own borders, the state partially participates in all ingestion pathwayrelated exercises for those bordering state sites. States that do not have an NPP located within their

borders, but are located within the 50-mile EPZ of a bordering state‘s NPP, must fully participate in at

least one exercise at least once every 8 years at the bordering state‘s site(s).

Since local governments are not usually required to develop and test ingestion pathway plans/procedures

and preparedness, state officials would be the emergency personnel primarily involved in the ingestion

pathway portion of exercises. However, in some states, local governments have responsibilities that

require their participation in such exercises. The number and function of personnel needed is sufficient for

carrying out those protective action measures that are necessitated by a particular accident scenario. Also,

organizations with field sampling responsibilities that are fully participating in the ingestion pathway

portion of an exercise deploy field monitoring teams to secure and analyze media samples as required by

the accident scenario.

OROs within the 50-mile EPZ that are not part of the full-participation ingestion exercise with the state

participate in an ingestion tabletop exercise or other ingestion pathway training activity at least once

during the exercise cycle. OROs report this ingestion pathway training in the ALC.

These ingestion exposure pathway phase activities may be performed either in connection with or

separate from a plume exercise. Separating ingestion from plume activities would provide OROs with

additional time for performing these activities more comprehensively. If separated, the plume phase

technical data may be extended into ingestion exposure pathway activities. However, the bases for

performing the ingestion exposure pathway phase activities may be derived from technical data other than

that which was used in the previous plume exercise.

References

 44 CFR § 350.9.c

 

76 44 CFR § 350.9(c)(4) requires that states within the 50 mile EPZ of a site exercise the ingestion exposure pathway at least once every 5 years. 

This was modified to 6 years in GM PR-1, ―Policy on NUREG-0654/FEMA-REP-1and 44 CFR 350 Requirements‖ (October 4, 1985) and 

subsequently to 8 years in NUREG-0654/FEMA-REP-1, Supplement 4.
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NUREG CRITERION N.2

A drill is a supervised instruction period aimed at testing, developing and

maintaining skills in a particular operation. A drill is often a component of an

exercise. A drill shall be supervised and evaluated by a qualified drill instructor.

Each organization shall conduct drills, in addition to the biennial77 exercise at the

frequencies indicated below:

NUREG CRITERION N.2.a

Communications Drills. Communications with State and local governments within

the plume exposure pathway Emergency Planning Zone shall be tested monthly.

Communications with Federal emergency response organizations and States within

the ingestion pathway shall be tested quarterly. Communications between the

nuclear facility, State and local emergency operations centers, and field assessment

teams shall be tested annually. Communication drills shall also include the aspect of

understanding the content of messages.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION N.2.a, ORO PLANS/PROCEDURES SHALL INDICATE THAT:

 ORO communications systems are tested monthly.

 Communications with the Federal response organizations and states within the ingestion pathway are

tested quarterly.

 Communications with the NPP, ORO EOCs, and field assessment teams are tested annually.

 All communications drills include a message content check.

EXPLANATION

OROs test communications with organizations that have roles in the emergency response at the minimum

intervals specified in the Evaluation Criterion. These tests include more than just assurance that the

communications hardware is functioning properly. The plans/procedures need to ensure that the messages

likely to be transmitted in an emergency will be understood by the receiving organizations. OROs could 

accomplish this goal by structuring drills to include a ―content check‖ using the actual messages or

notifications that would be sent to the receiving organization in an emergency.

References

 National Incident Management System, December 2008.

 HSEEP Volume I: HSEEP Overview and Exercise Program Management, February 2007.

 HSEEP Volume II: Exercise Planning and Conduct, February 2007.

 HSEEP Volume III: Exercise Evaluation and Improvement Planning, February 2007.

 HSEEP Volume IV: Sample Exercise Documents and Formats, February 2006.

 HSEEP Volume V: Prevention Exercises, March 28, 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

 

77 Annual exercises changed to biennial exercises per FEMA GM PR-1, Policy on NUREG-0654/FEMA-REP-1 and 44 CFR Periodic 

Requirements, October 1, 1985.
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NUREG CRITERION N.2.b

Fire Drills. Fire drills shall be conducted in accordance with the plant (nuclear

facility) technical specifications.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION N.2.c

Medical Emergency Drills. A medical emergency drill involving a simulated

contaminated individual which contains provisions for participation by the local

support services agencies (i.e., ambulance and offsite medical treatment facility)

shall be conducted annually. The offsite portions of the medical drill may be

performed as part of the required biennial78 exercise.

Applicability and Cross Reference to Plans: Licensee X State Local X

TO MEET THE INTENT OF CRITERION N.2.c, ORO PLANS/PROCEDURES SHALL INDICATE THAT:

 Medical emergency drills are conducted annually.

EXPLANATION

OROs conduct medical emergency drills, commonly referred to as medical services drills, annually to

demonstrate that procedures for transporting contaminated, injured, or exposed individuals to the

appropriate medical facility can be implemented. Drills also enable medical facility staff to demonstrate

proper care of contaminated, injured, or exposed persons at appropriately equipped facilities. The focus of

these drills is contamination control measures, not medical protocols per se. The exception pertains to

modification of contamination control procedures and decisions on transportation to a medical facility

when the individual has an urgent medical condition. FEMA evaluates medical services drills biennially;

drills may be held in conjunction with the biennial evaluated exercise.

Drills provide opportunity for responders to determine the nature and extent of an individual‘s external

radiological contamination. This demonstration may be performed in the field prior to transport to the

medical facility or immediately upon arrival. If monitoring is deferred until arrival at the medical facility,

the transport crew assumes that the individual is contaminated and follows appropriate contamination

control measures. Medical priorities are established so that if the individual has an urgent medical

condition, radiological monitoring and contamination control measures would not hinder medical care.

Medical emergency drills include the following elements:

 Provisions are made for conducting appropriate drills for contaminated, injured, or exposed 

individuals. 

 Drills provide opportunity for responders to determine the nature and extent of an individual‘s external 

radiological contamination.

 Personnel responsible for transporting individuals from the incident site follow appropriate 

contamination control measures. 

 

78 Annual exercises changed to biennial exercises per FEMA GM PR-1, Policy on NUREG-0654/FEMA-REP-1 and 44 CFR Periodic 

Requirements, October 1, 1985.
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 An appropriate official determines which medical facility the individual will be taken to, and that the 

individual is transported without undue delay. 

 Communications are maintained with the receiving medical facility. 

 The vehicle and occupants are monitored to detect the nature and extent of radiological contamination 

and, if necessary, are decontaminated. 

 At the medical facility, appropriate staff members are present or available on short notice. 

 The medical facility prepares for arrival of a contaminated, injured, or exposed individual and sets up 

appropriate contamination control measures. 

 Medical personnel demonstrate the capability to determine whether individuals are contaminated, as

appropriate, and demonstrate the procedures and equipment to remove contamination. 

 Medical personnel maintain contamination control measures, including contaminated waste disposal 

during and after treatment.

 Dosimetry procedures are established and implemented. 

References

 National Incident Management System, December 2008.

 HSEEP Volume I: HSEEP Overview and Exercise Program Management, February 2007.

 HSEEP Volume II: Exercise Planning and Conduct, February 2007.

 HSEEP Volume III: Exercise Evaluation and Improvement Planning, February 2007.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION N.2.d

Radiological Monitoring Drills. Plant environs and radiological monitoring drills

(onsite and offsite) shall be conducted annually. These drills shall include collection

and analysis of all sample media (e.g., water, vegetation, soil and air), and provisions

for communications and record keeping. The State drills need not be at each site.

Where appropriate, local organizations shall participate.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION N.2.d, ORO PLANS/PROCEDURES SHALL INDICATE THAT:

 Radiological monitoring drills are conducted annually.

EXPLANATION

The organization‘s plans/procedures state that radiological monitoring drills will be conducted annually.

The radiological monitoring drill may be held in conjunction with an evaluated exercise. Demonstration 

Criteria 1.a.1, 1.d.1, 1.e.1, 4.a.2, 4.a.3, and 4.b.1 may be used as a guide to what topics drills cover.

References

 National Incident Management System, December 2008.

 HSEEP Volume I: HSEEP Overview and Exercise Program Management, February 2007.

 HSEEP Volume II: Exercise Planning and Conduct, February 2007.

 HSEEP Volume III: Exercise Evaluation and Improvement Planning, February 2007.
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 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION N.2.e(1)

Health Physics Drills (1). Health physics drills shall be conducted semi-annually

which involve response to, and analysis of, simulated elevated airborne and liquid

samples and direct radiation measurements in the environment. The State drills

need not be at each site.

Applicability and Cross Reference to Plans: Licensee X State X Local 

TO MEET THE INTENT OF CRITERION N.2.e, ORO PLANS/PROCEDURES SHALL INDICATE THAT:

 Health physics drills are conducted semi-annually.

EXPLANATION

Demonstration Criteria 1.a.1, 1.d.1, 1.e.1, 4.a.2, 4.a.3, and 4.b.1 may be used as a guide to what topics

drills cover.

References

 National Incident Management System, December 2008.

 HSEEP Volume I: HSEEP Overview and Exercise Program Management, February 2007.

 HSEEP Volume II: Exercise Planning and Conduct, February 2007.

 HSEEP Volume III: Exercise Evaluation and Improvement Planning, February 2007.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION N.2.e(2)

Health Physics Drills (2). Analysis of inplant liquid samples with actual elevated

radiation levels shall be included in Health Physics drills by licensees annually.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION N.3

Each organization shall describe how exercises and drills are to be carried out to

allow free play for decisionmaking and to meet the following objectives. Pending the

development of exercise scenarios and exercise evaluation guidance by the NRC

and FEMA the scenarios for use in exercises and drills shall include, but not be

limited to, the following:

a. The basic objective(s) of each drill and exercise and appropriate

evaluation criteria;

b. The date(s), time period, place(s), and participating organizations;

c. The simulated events;
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d. A time schedule of real and simulated initiating events;

e. A narrative summary describing the conduct of the exercises or drills to

include such things as simulated casualties, offsite fire department

assistance, rescue of personnel, use of protective clothing, deployment of

radiological monitoring teams, and public information activities; and

f. A description of the arrangements for and advance materials to be

provided to official observers.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION N.3, ORO PLANS/PROCEDURES SHALL INDICATE THAT:

 Each of the items a through f above will be addressed in the scenario developed for the exercise.

EXPLANATION

Plans/procedures discuss the ORO‘s approach to exercises that allows free play for decision making and

the maximum realism possible. This discussion includes the process of scenario development. Part III.B

of this manual provides guidance on exercise scenario development.

References

 National Incident Management System, December 2008.

 HSEEP Volume I: HSEEP Overview and Exercise Program Management, February 2007.

 HSEEP Volume II: Exercise Planning and Conduct, February 2007.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION N.4

Biennial exercises shall be evaluated and critiqued as required. FEMA evaluators

shall evaluate offsite emergency response organization performance in the biennial

exercise in accordance with FEMA REP exercise methodology.

79

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION N.4., ORO PLANS/PROCEDURES SHALL STATE THAT:

 ORO exercise performance is evaluated according to FEMA REP exercise methodology.

EXPLANATION

Part III of the REP Program Manual includes six Assessment Areas that are derived from the 16 Planning

Standards of 44 CFR Part 350 and NUREG-0654/FEMA-REP-1 and their associated Evaluation Criteria.

Each Assessment Area contains Sub-elements and Demonstration Criteria designed to exercise the

implementation of ORO plans/procedures. Part III also contains detailed guidance on the development,

conduct, evaluation, and documentation of REP exercises.

Part III.B, REP Program Exercise Guidance: REP Exercise Process, provides guidance on conducting

exercise evaluation and post-exercise critiques.

 

79 This criterion amended per NUREG-0654/FEMA-REP-1, Supplement 4, (2011).
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References

 FEMA GM-8, Revision 1, RAC Coordination With Utilities, October 3, 1983.

 National Incident Management System, December 2008.

 HSEEP Volume I: HSEEP Overview and Exercise Program Management, February 2007.

 HSEEP Volume III: Exercise Evaluation and Improvement Planning, February 2007.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION N.5

Each organization shall establish means for evaluating observer and participant

comments on areas needing improvement, including emergency plan procedural

changes, and for assigning responsibility for implementing corrective actions. Each

organization shall establish management control used to ensure that corrective

actions are implemented.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION N.5, ORO PLANS/PROCEDURES SHALL DESCRIBE:

 Processes for correcting issues identified during exercises.

EXPLANATION

The organization‘s plans/procedures include processes for correcting issues identified during exercises.

This process includes a description of the issue, the organization and individual, by title/position,

responsible for implementing the chosen corrective action, and the timeframe for completing the

corrective action. The state‘s ALC and annual update include the results of exercises and verification that

any changes to plans/procedures and needed training have been completed, with the exception of

Deficiencies, which are addressed in a separate AAR.

References

 FEMA GM-8, Revision 1, RAC Coordination With Utilities, October 3, 1983.

 National Incident Management System, December 2008.

 HSEEP Volume I: HSEEP Overview and Exercise Program Management, February 2007.

 HSEEP Volume III: Exercise Evaluation and Improvement Planning, February 2007.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
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15. PLANNING STANDARD O – RADIOLOGICAL EMERGENCY RESPONSE TRAINING

Radiological emergency response training is provided to those who may be called on to

assist in an emergency.

NUREG CRITERION O.1

Each organization shall assure the training of appropriate individuals.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION O.1, ORO PLANS/PROCEDURES SHALL:

 Identify organizations responsible for coordinating radiological training.

 Identify organizations that will ensure radiological emergency response training will be included as

part of fire, police, and ambulance/rescue training, if appropriate.

 Describe provisions to ensure availability of just-in-time training on basic radiation protection for all

emergency workers, as needed.

 Describe provisions to ensure appropriate personnel participate in training courses designed for

individuals who will assist in radiological emergency response (e.g., transportation providers).

EXPLANATION

The plans/procedures identify organizations responsible for coordinating radiological-specific and other

relevant emergency response training. The plans/procedures also state that the organizations will ensure

that personnel who will be called on in radiological emergency response operations (e.g., transportation

providers, radiological monitors) participate in appropriate Federal- and state-sponsored training courses.

Training includes procedures for initial notification, basic radiation protection, including dosimetry and

KI use, Incident Command System, and review of evacuation routes. Plans/procedures also include

provisions for just-in-time training on basic radiation protection for emergency workers, as needed. The

plans/procedures identify which organizations will ensure that radiological emergency response training

will be part of fire, police, and ambulance/rescue training, if appropriate for those organizations. Training

for hospital/medical facility personnel, ambulance/rescue teams, and police and fire departments includes

procedures for notification, basic radiation protection, and expected roles.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION O.1.a

Each facility to which the plan applies shall provide site-specific emergency

response training for those offsite emergency organizations who may be called

upon to provide assistance in the event of an emergency.

Applicability and Cross Reference to Plans: Licensee X State Local 
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NUREG CRITERION O.1.b

Each offsite response organization shall participate in and receive training. Where

mutual aid agreements exist between local agencies such as fire, police, and

ambulance/rescue, the training shall also be offered to the other departments that

are members of the mutual aid district.

Applicability and Cross Reference to Plans: Licensee State X Local X

TO MEET THE INTENT OF O.1.b, THE ORO PLANS/PROCEDURES SHALL STATE THAT:

 Training is offered to the mutual aid district, if mutual aid plans/procedures have been established

between local agencies,

EXPLANATION

Plans/procedures identify mutual aid organizations and specify the arrangements for offering training to

or receiving training from those organizations, as appropriate.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION O.2

The training program for members of the onsite emergency organization shall,

besides classroom training, include practical drills in which each individual

demonstrates ability to perform his assigned emergency function. During the

practical drills, on-the-spot correction of erroneous performance shall be made and

a demonstration of the proper performance offered by the instructor.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION O.3

Training for individuals assigned to licensee first aid teams shall include courses

equivalent to Red Cross Multi-Media.

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION O.4

Each organization shall establish a training program for instructing and qualifying

personnel who will implement radiological emergency response plans. The

specialized initial training and periodic retraining programs (including the scope,

nature, and frequency) shall be provided in the following categories:
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NUREG CRITERION O.4.a

Directors or coordinators of the response organizations;

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION O.4.a, ORO PLANS/PROCEDURES SHALL DISCUSS:

 Training programs specific to directors/coordinators.

 Scope of the training programs.

 Time intervals at which these training programs will be offered.

 Organizations (e.g., licensee, FEMA) that will provide training assistance, if applicable.

EXPLANATION

If OROs do not have adequate capability and resources to accomplish training for directors or

coordinators, plans/procedures identify which organization (e.g., licensee, FEMA) they would call on for

training assistance.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION O.4.b

Personnel responsible for accident assessment;

Applicability and Cross Reference to Plans: Licensee X State X Local *

*NRC and FEMA encourage OROs that have these capabilities to continue to include them in their

training programs.

TO MEET THE INTENT OF CRITERION O.4.b, ORO PLANS/PROCEDURES SHALL DISCUSS:

 Training programs specific to accident assessment personnel.

 Scope of the training programs.

 Time intervals at which these training programs will be offered.

 Organizations (e.g., licensee, FEMA) that will provide training assistance, if applicable.

EXPLANATION

The plans/procedures discuss training programs specific to accident assessment personnel.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
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NUREG CRITERION O.4.c

Radiological monitoring teams and radiological analysis personnel;

Applicability and Cross Reference to Plans: Licensee X State X Local *

*NRC and FEMA encourage state and local governments that have these capabilities to continue to

include them in their training programs.

TO MEET THE INTENT OF CRITERION O.4.c, ORO PLANS/PROCEDURES SHALL DISCUSS:

 Training programs specific to radiological monitoring teams and radiological analysis personnel.

 Scope of the training programs.

 Time intervals at which these training programs will be offered.

 Organizations (e.g., licensee, FEMA) that will provide training assistance, if applicable.

EXPLANATION

The plans/procedures discuss training programs specific to radiological monitoring teams and radiological

analysis personnel.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION O.4.d

Police, security, and fire-fighting personnel;

Applicability and Cross Reference to Plans: Licensee X State * Local X

*NRC and FEMA encourage state and local governments that have these capabilities to continue to

include them in their training programs.

TO MEET THE INTENT OF CRITERION O.4.d, ORO PLANS/PROCEDURES SHALL DISCUSS:

 Training programs specific to police, security, and firefighting personnel.

 Scope of the training programs.

 Time intervals at which these training programs will be offered.

 Organizations (e.g., licensee, FEMA) that will provide training assistance, if applicable.

EXPLANATION

The plans/procedures discuss training programs specific to police, security, and firefighting personnel

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
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REP Program Manual Page II-134 October 2011

NUREG CRITERION O.4.e

Repair and damage control/correctional action teams (onsite);

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION O.4.f

First aid and rescue personnel;

Applicability and Cross Reference to Plans: Licensee X State * Local X

*NRC and FEMA encourage state and local governments that have these capabilities to continue to

include them in their training programs.

TO MEET THE INTENT OF CRITERION O.4.f, ORO PLANS/PROCEDURES SHALL DISCUSS:

 Training programs specific to first aid and rescue personnel.

 Scope of the training programs.

 Time intervals at which these training programs will be offered.

 Organizations (e.g., licensee, FEMA) that will provide training assistance, if applicable.

EXPLANATION

The plans/procedures discuss training programs specific to first aid and rescue personnel.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION O.4.g

Local support services personnel including Civil Defense/Emergency Service

personnel;80

Applicability and Cross Reference to Plans: Licensee X State Local X

TO MEET THE INTENT OF CRITERION O.4.g, ORO PLANS/PROCEDURES SHALL DISCUSS:

 Training programs specific to support services personnel.

 Scope of the training programs.

 Time intervals at which these training programs will be offered.

 Organizations (e.g., licensee, FEMA) that will provide training assistance, if applicable.

 

80 Civil defense/emergency service personnel are also referred to as emergency management personnel.
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EXPLANATION

The plans/procedures discuss training programs specific to support services personnel.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION O.4.h

Medical support personnel;

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION O.4.h, ORO PLANS/PROCEDURES SHALL DISCUSS:

 Training programs specific to medical support personnel, including specific training for

hospital/medical facility staff and transportation providers.

 Scope of the training programs.

 Time intervals at which these training programs will be offered.

 Organizations (e.g., licensee, FEMA) that will provide training assistance, if applicable.

EXPLANATION

The plans/procedures discuss training programs specific to medical support personnel.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION O.4.i

Licensee’s headquarters support personnel;

Applicability and Cross Reference to Plans: Licensee X State Local 

NUREG CRITERION O.4.j

Personnel responsible for transmission of emergency information and instructions.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION O.4.j, ORO PLANS/PROCEDURES SHALL DISCUSS:

 Training programs specific to personnel responsible for transmission of emergency information and

instructions.

 Scope of the training programs.
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REP Program Manual Page II-136 October 2011

 Time intervals at which these training programs will be offered.

 Organizations (e.g., licensee, FEMA) that will provide training assistance, if applicable.

EXPLANATION

The plans/procedures discuss training programs specific to personnel responsible for transmission of

emergency information and instructions.

References

 FEMA GM-21, Revision 1, Acceptance Criteria for Evacuation Plans, February 29, 1984.

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION O.5

Each organization shall provide for the initial and annual retraining of personnel with

emergency response responsibilities.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION O.5, THE PLANS/PROCEDURES SHALL:

 State which organizations will provide initial training as well as retraining.

FEMA HIGHLY RECOMMENDS THAT PLANS/PROCEDURES INCLUDE:

 A training matrix that lists all available courses and provides general descriptions of those courses.

 Names of the organizations requiring training and the type of training they require.

EXPLANATION

The plans/procedures state that organizations will provide personnel with initial training as well as annual

retraining. A description of the types and sources of training courses available to emergency personnel are

listed in the plans/procedures.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
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16. PLANNING STANDARD P – RESPONSIBILITY FOR THE PLANNING EFFORT:

DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS

Responsibilities for plan development and review and for distribution of emergency plans

are established, and planners are properly trained.

NUREG CRITERION P.1

Each organization shall provide for the training of individuals responsible for the

planning effort.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION P.1, ORO PLANS/PROCEDURES SHALL:

 Identify, by title/position, individuals responsible for oversight of plan/procedure development and

maintenance, including the positions referred to in Criteria P.2 and P.3, and any other positions with

planning responsibilities.

 Specify the training regimen for the identified individuals.

EXPLANATION

Plans/procedures identify emergency planners by title/position and describe provisions to ensure their

training.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION P.2

Each organization shall identify by title the individual with the overall authority and

responsibility for radiological emergency response planning.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION P.2, ORO PLANS/PROCEDURES SHALL:

 Identify, by title/position, the individual responsible for radiological emergency response planning.

EXPLANATION

Plans/procedures identify the position with the overall responsibility and authority for emergency

response planning. This position is the legally designated authority responsible for radiological

emergency preparedness and response (e.g., the senior elected official), but may or may not be the same

position with operational responsibility.

References

 National Incident Management System, December 2008.
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 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION P.3

Each organization shall designate an Emergency Planning Coordinator with

responsibility for the development and updating of emergency plans and

coordination of these plans with other response organizations.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION P.3, ORO PLANS/PROCEDURES SHALL:

 Identify, by title/position, the individual responsible for developing and updating emergency

plans/procedures as well as coordinating plans/procedures with other response organizations.

EXPLANATION

The plans/procedures identify the Emergency Planning Coordinator. This may be the same position

identified under Criterion P.2, or it may be a separate emergency planning coordinator position with

operational responsibility for planning and coordination (e.g., the County Emergency Management

Director).

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION P.4

Each organization shall update its plan and agreements as needed, review and

certify it to be current on an annual basis. The update shall take into account

changes identified by drills and exercises.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION P.4, ORO PLANS/PROCEDURES SHALL INCLUDE:

 Evidence that plans/procedures and agreements have been reviewed for accuracy and completeness of

information and appropriate changes made within the last year (e.g., a signature page, etc.).

 A process for correcting plan issues identified in drills and exercises.

 A process for periodic update of maps.

 A process for periodic updating of ingestion pathway information (e.g., a list of food processing

facilities, etc.)(See also Criterion J.11)
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EXPLANATION

States are required to submit an ALC81 to the appropriate FEMA Regional Administrator by January 31st

of each year, certifying, among other things, that the ORO plans/procedures and agreements have been

updated as needed and are current.

The plans/procedures are updated periodically to correct plan issues identified in drills and exercises. The

latest AAR contains a list of Deficiencies, Areas Requiring Corrective Action (ARCAs), and Plan Issues.

The correction of these items may necessitate plan/procedure changes.

References

 Memorandum from Kay Goss to Directors, Regions I, II, III, IV, V, VI, VII, IX, and X dated July 5, 

2000 on Annual Letter of Certification Reporting Requirements Under 44 CFR Part 350 and 

NUREG-0654/FEMA-REP-1, Revision 1.

 National Incident Management System, December 2008.

 HSEEP Volume III: Exercise Evaluation and Improvement Planning, February 2007.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION P.5

The emergency response plans and approved changes to the plans shall be

forwarded to all organizations and appropriate individuals with responsibility for

implementation of the plans. Revised pages shall be dated and marked to show

where changes have been made.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION P.5, ORO PLANS/PROCEDURES SHALL:

 List the organizations and individuals who are given the updated plans/procedures.

 Identify individual(s), by title/position, responsible for distributing plan/procedure updates and what

the update cycle is.

 Include revision bar markings or equivalent visual indications on revised pages to reflect where

changes were made and on what date, or a summary list of changes in cases where changes are so

numerous or extensive that revision bars are impractical.

EXPLANATION

The plans/procedures contain lists of organizations and individuals who are given the plan updates. The

plans/procedures also indicate individuals, by title/position, responsible for distributing the updates and

what the update cycle is (e.g., updates are distributed by June 1 of each year). The update mechanism

covers all procedures (e.g., in some cases, a sub-organization, such as a school district, may be

responsible for updating its own procedures). OROs date and (preferably) mark revised pages with

revision bars or some other indication of where changes were made. Where changes are so numerous or

extensive that revision bars are impractical, OROs supply a list or summary of changes.

References

 National Incident Management System, December 2008.

 

81 See Part IV, Annual Letter of Certification.
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 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION P.6

Each plan shall contain a detailed listing of supporting plans and their source.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION P.6, ORO PLANS/PROCEDURES SHALL CONTAIN:

 A list of supporting radiological emergency plans/procedures.

EXPLANATION

Plans/procedures include a list of other organizations‘ emergency response plans that are referenced or

otherwise support implementation (e.g., municipalities, school districts, hospital/medical facilities, etc.), if

applicable.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION P.7

Each plan shall contain an appendix listing, by title, procedures required to

implement the plan. The listing shall include the section(s) of the plan to be

implemented by each procedure.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION P.7, ORO PLANS/PROCEDURES SHALL:

 Include a list of all implementing procedures associated with the body of the plan. The list indicates

which section(s) of the plan are implemented by each procedure.

EXPLANATION

Plans identify the procedural documents not included in the body of the plan, as well as which section of

the plan the procedure supports. For example, plans identify an EOC activation checklist and crossreference it to the section of the plan covering EOC operations.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
PART II: PLANNING GUIDANCE

REP Program Manual Page II-141 October 2011

NUREG CRITERION P.8

Each plan shall contain a specific table of contents. Plans submitted for review

should be cross-referenced to these criteria.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION P.8., ORO PLANS/PROCEDURES SHALL CONTAIN:

 A specific table of contents.

 A cross-reference between the plans/procedures and the NUREG-0654/FEMA-REP-1 Evaluation

Criteria.

EXPLANATION

The plans/procedures contain a table of contents and a table cross-referencing the plans/procedures to the

NUREG-0654/FEMA-REP-1 Evaluation Criteria. The NUREG-0654/FEMA-REP-1 cross-reference table

is specific; it addresses each Evaluation Criterion element and provides references to specific subparts of

the plans/procedures. The cross-reference does not merely indicate, for example, a chapter containing

dozens of pages; it references sections specific enough to allow reviewers to quickly locate the relevant

information. A detailed cross-reference ensures all NUREG-0654/FEMA-REP-1 criteria are addressed,

facilitates review and updating of the plans/procedures, and helps avoid the common situation of a piece

of information being updated in one section of the plans/procedures, but not in another.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.

NUREG CRITERION P.9

Each licensee shall arrange for and conduct independent reviews of the emergency

preparedness program at least every 12 months. (An independent review is one

conducted by any competent organization either internal or external to the licensee’s

organization, but who are not immediately responsible for the emergency

preparedness program). The review shall include the emergency plan, its

implementing procedures and practices, training, readiness testing, equipment, and

interfaces with State and local governments. Management controls shall be

implemented for evaluation and correction of review findings. The result of the

review, along with recommendations for improvements, shall be documented,

reported to appropriate licensee corporate and plant management, and involved

Federal, State, and local organizations, and retained for a period of five years.

Applicability and Cross Reference to Plans: Licensee X State Local 
PART II: PLANNING GUIDANCE

REP Program Manual Page II-142 October 2011

NUREG CRITERION P.10

Each organization shall provide for updating telephone numbers in emergency

procedures at least quarterly.

Applicability and Cross Reference to Plans: Licensee X State X Local X

TO MEET THE INTENT OF CRITERION P.10, ORO PLANS/PROCEDURES SHALL INDICATE:

 Who, by title/position, is responsible for quarterly updates of each procedure that contains telephone

numbers.

EXPLANATION

This criterion refers to emergency procedures; the plans/procedures identify individuals, by title/position,

or organizations responsible for quarterly updates of each procedure that contains telephone numbers. The

update function may be centralized or different sub-organizations may be responsible for updating their

own procedures. Quarterly updates do not need to involve physical replacement of procedure pages if

there are no changes; the objective is to ensure that someone checks quarterly to see whether any of the

numbers have changed.

References

 National Incident Management System, December 2008.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and 

Local Government Emergency Plans, Version 2, November 2010.
REP Program Manual Page III-1 October 2011

Part III: REPPROGRAM DEMONSTRATION

GUIDANCE

A. INTRODUCTION

This section of the REP Manual supplements the 

HSEEP process and provides specific guidance 

unique to the design, development, conduct, 

evaluation, and improvement planning of REP 

exercises. FEMA provides this guidance for 

REP controllers, evaluators, contractors, and any 

OROs responsible for planning, preparing, and 

executing REP exercises, as well as other 

Federal staff who assist the FEMA as members 

of the RACs. This section provides licensee 

partners with guidelines regarding coordination 

of REP exercise activities by the Federal 

government.

1. CONTENTS AND ORGANIZATION

This manual presents Part III in three major 

subparts: 

Subpart B, REP Exercise Process, provides an 

overview of REP Program-specific exercise 

scheduling, design and development, evaluation, 

and improvement planning considerations. 

Subpart C, Assessment Areas, explains the 

REP Assessment Areas. FEMA derived the 

Assessment Areas from the Planning Standards 

and associated Evaluation Criteria of NUREG0654/FEMA-REP-1 that OROs must 

demonstrate in exercises. The Assessment Areas 

functionally restate the Planning Standards and 

Evaluation Criteria. The following headings 

describe the Sub-elements of each Assessment 

Area:

 Intent – describes the origin and purpose of 

the Assessment Area Sub-element.

 Demonstration Criterion – identifies the 

applicable NUREG-0654/FEMA-REP-1 

Planning Standard(s) and interprets the 

essentials of emergency actions associated 

with that Sub-element.

 Assessment/Extent of Play – provides a 

baseline for the extent of demonstration, or 

―play,‖ required for a given Demonstration 

Criterion during an exercise or assessment 

in a different venue (drill, training, etc.).

Subpart D, Evaluation of Medical Services 

Drills, briefly describes the procedures and

Demonstration Criteria associated with 

evaluation of medical services drills.

2. BACKGROUND

FEMA bases its reasonable assurance

determination that OROs can protect the health

and safety of the public in the event of an

incident at an NPP on both adequate

plans/procedures and the demonstrated ability to

implement them. OROs use exercises, drills,

seminars, training, SAVs, and actual events to

practice and fine-tune plan implementation.

FEMA observes or uses records of ORO 

activities, as well as plan reviews, SAVs, and the

ALC, to fulfill its responsibility to assess the

adequacy of offsite response. Part III focuses

primarily on exercises, but touches on the other

venues as well. More detailed guidance on plan

reviews, the ALC, and SAVs is located in Part

IV.

HSEEP: Using HSEEP methodology for 

exercises facilitates program efficiency. Such 

integration does not establish additional exercise 

requirements for the REP Program or replace 

existing REP Demonstration Criteria with new 

capabilities.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-2 October 2011

Target capabilities: The DHS TCL identifies 

37 specific capabilities for preventing, 

protecting from, responding to, and recovering 

from a wide range of incidents. The DHS 

National Exercise Program uses HSEEP 

exercises to practice and test the capabilities 

developed through planning, training, and 

equipment acquisition. Like National Exercise 

Program exercises, REP exercises verify the 

ability of OROs to implement various aspects of 

their response plans. However, in the REP 

Program, the regulations in 44 CFR Part 350

dictate certain capabilities the ORO must 

demonstrate. Under these regulations, REP 

exercises must demonstrate reasonable 

assurance that OROs can meet the Planning 

Standards of NUREG-0654/FEMA-REP-1. 

Demonstration Criteria: REP exercises use the 

REP Assessment Areas, Sub-elements, and 

Demonstration Criteria to observe and evaluate

the ability to meet the appropriate Planning 

Standards. Each Sub-element identifies a major 

facet of its Assessment Area. Each 

Demonstration Criterion sets the standard for an 

ORO‘s ability to perform a specific emergency 

function under the Sub-element (e.g.,

communicating among response organizations;

making dose assessments; alerting and notifying 

the public). Thus, The REP Assessment Areas, 

Sub-elements, and Demonstration Criteria work 

like HSEEP capabilities, activities, and tasks. 

FEMA identified the set of Target Capabilities 

correlating to the REP Demonstration Criteria so 

that REP exercise evaluations using HSEEP 

exercise documents may occur (see Appendix G 

for additional information).

B. REP EXERCISE PROCESS

As stated previously, REP exercises use the

HSEEP methodology and guidance. Key

features of HSEEP methodology include:

 Scheduling through the use of an annual

T&EPW and Multi-year Training and

Exercise Plan;

 Exercise planning and implementation in

accordance with the guidelines set forth in

HSEEP methodology;

 A properly formatted AAR/IP; and

 Tracking and implementation of corrective

actions identified in the AAR/IP.

This section identifies the unique regulatory 

requirements of the REP Program that affect 

REP exercise scheduling, design and 

development, evaluation, and improvement 

planning within the HSEEP framework. FEMA 

created a crosswalk (see Appendix G) relating 

the REP Demonstration Criteria to the Target 

Capabilities to assist OROs with the integration 

process. The process of applying HSEEP

methodology to REP exercises involves the

following steps:

 Scheduling REP Activities

 Conducting Pre-Planning Activities

 Holding Exercise Planning Meetings

 Developing REP Exercise Documents

 Conducting REP Exercises

 REP Exercise Documentation

This section also explains the process for 

requesting and receiving REP exercise credit for 

participating in actual incidents (see subsection 

7). 

Exhibit III-1, Milestones for REP Exercise 

Process, provides a time frame for completing 

exercise development, conduct, evaluation, and 

reporting activities. FEMA highly recommends 

many of these milestones that fall short of being 

a requirement. However, the milestones 

surrounded by asterisks are relatively inflexible, 

representing deadlines imposed by regulations or 

that could significantly impact the exercise if 

missed.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-3 October 2011

Exhibit III-1: Milestones for the REP Exercise Process

* # * Indicates milestones significantly impacting the exercise process

Calendar Days

Before/After

Exercise

Milestone

Lead/

Responsible

Organization

*730* Request additional Federal support (e.g., Federal 

Radiological Monitoring and Assessment Center 

(FRMAC), Advisory Team for Environment, Food, and 

Health, etc.), if desired for the exercise

State,

FEMA

365 Establish or confirm exercise date82 State, FEMA

200 Identify Exercise Planning Team (EPT) members State, Utility,

FEMA

*180* Conduct Initial Planning Conference (IPC) to include

Concepts and Objectives (C&O) Meeting as necessary

State, FEMA

*120* FEMA prepares work order for contract support FEMA

120 If exercise includes FRMAC participation, submit

required scenario and source information (for ingestion

phase activities only) to FRMAC83

State, Utility

90 Conduct Mid-term Planning Conference (MPC). MPC 

members review the following draft documents: Master 

Scenario Events List (MSEL), Exercise Plan (ExPlan),

Controller/Evaluator (C/E) Handbook, Exercise 

Evaluation Guides (EEGs), and the Extent-of-Play 

Agreement.

State, FEMA

*90* Submit approved ORO plans/procedures to FEMA

Region

OROs

75 FEMA completes a review of draft ExPlan and EEGs and 

approves

FEMA

*60* Submit draft exercise scenario for FEMA technical 

review

State, Utility

60 Confirm and assign controllers and evaluators State, FEMA

45 Complete draft ExPlan State, FEMA

45 Complete draft C/E Handbook State, Utility,

FEMA

30 FEMA completes Scenario Review and approves FEMA

30 Finalize MSEL State

30 Conduct Final Planning Conference (FPC) State, FEMA

*30* Prepare and distribute C/E packets State, FEMA

1 Conduct C/E briefing State, FEMA

Exercise Day

(ED)

Conduct Exercise OROs

ED Begin documenting organizational exercise performance FEMA

ED Conduct player hot wash OROs

ED +1 RAC Chair initiates consultation process for Deficiencies FEMA

ED +2 Notification of potential Deficiencies to FEMA

Headquarters

FEMA

 

82 For changes to an exercise date due to extenuating circumstances, notice is given to the FEMA Region as soon as possible.

83 120 days is FEMA‘s guidance. FRMAC‘s requirement is at least 90 days for submittal of the scenario and source information. FRMAC will 

not participate in the exercise if the scenario and source information are received later than 90 days before the exercise.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-4 October 2011

Calendar Days

Before/After

Exercise

Milestone

Lead/

Responsible

Organization

ED +2 Complete exercise evaluation documentation FEMA

ED +2 Conduct evaluator debrief FEMA

ED +3 Evaluators conduct post-exercise participant interviews FEMA

ED +3 Conduct participants meeting FEMA

ED +3 Conduct post-exercise meeting that includes the public FEMA, NRC

ED +7 Conduct controller debrief and initiate consultation

process

State

*ED +10* Notification of Deficiencies to state FEMA

*ED +20* State acknowledges receipt of Deficiency letter and

proposes schedule for remedial actions

State

*ED +30* Draft AAR/IP sent to states for review FEMA

ED +60 Draft AAR/IP comments sent from state(s) to FEMA 

Region

State

ED +75 Conduct After Action Conference (AAC) State, FEMA

*ED +90* Final AAR/IP issued by FEMA Region FEMA

ED +90 Share lessons learned, areas for improvement, best

practices, and strengths identified in final AAR/IP

State, FEMA

*ED +120* Deficiencies corrected; evaluate and report on remedial

exercises

FEMA

Ongoing Track evaluation of Demonstration Criteria State, FEMA

1. SCHEDULING REP ACTIVITIES

HSEEP methodology promotes synchronization 

across exercises, which increases efficiency and 

alleviates exercise fatigue. By coordinating REP 

scheduling with other HSEEP activities, OROs 

may identify opportunities to demonstrate other 

National Exercise Program exercise activities at 

a REP exercise.

The steps in scheduling REP activities include:

 Determining appropriate activity types

 Determining exercise cycle requirements

 Establishing a Training and Exercise Plan

a. Activity Types

FEMA‘s planning and preparedness assessment 

strategy uses a combination of exercises, drills, 

training, SAVs, and reporting to ensure that 

offsite planning and preparedness remain 

adequate to protect the health and safety of the 

public. The HSEEP scheduling process permits 

coordination of many of these activities. The 

activity types described here include the variety 

of venues available for demonstration and 

evaluation of REP planning and preparedness.

(1) Exercises

Exercises conducted jointly with the licensee 

offer an excellent opportunity to exercise 

Direction and Control and Protective Action 

Decision-making when considering plant 

conditions. With the exception of the site‘s 

qualifying exercise and subsequent full-scale 

exercises, these Demonstration Criteria can also 

be adequately assessed during functional and 

tabletop exercises. Always use outcome-based 

exercise evaluation to allow for greater 

efficiency in the process.

The minimum capabilities assessed in a joint 

exercise are Sub-Element c of Assessment Area

1 and Assessment Area 2. These represent the 

critical decision-making capabilities requiring at 

least biennial demonstration in a coordinated 
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-5 October 2011

manner in one of the following types of

exercises:

 Full-Scale Exercises engage all ORO 

entities in real-time hands-on response 

activities including all of those specified in 

the Demonstration Criteria extent-of-play 

sections. The site uses a full-scale exercise 

for its qualifying exercise, which validates 

the adequacy of the offsite plans and 

procedures for formal FEMA plan approval. 

Subsequently, FEMA/NRC requires a fullscale exercise at least once every eight years 

and includes demonstration of ingestion 

pathway procedures by the appropriate state

and local OROs.

 Functional Exercises sufficiently engage 

organizations to test their abilities to 

respond to the scenario, but participation is 

less than full-scale. Most REP biennial joint 

exercises are functional exercises because 

they simulate some response capabilities or 

demonstrate them out of sequence from the 

scenario, and the exercise may not require

participation of all offsite entities that would

respond in a real radiological emergency.

Processes that require multiple elements in

play for protective action decision making

and implementation may be demonstrated

in a functional exercise that includes full

participation to the extent necessary to

achieve the exercise goals. OROs may use 

functional exercises concurrently with a

licensee‘s annual exercise to test

utility/offsite interaction and

communications.

 Tabletop Exercises are discussion-based 

and may test single or multiple scenarios 

and outcomes. OROs may use tabletop 

exercises to assess key elements in 

decision-making and implementation. 

Offsite planners may opt to use a tabletop

exercise in conjunction with a licensee‘s

annual exercise, or as a separate training or

planning event. The suitability of a tabletop

exercise might vary depending on the

number of jurisdictions that need to

participate to meet exercise objectives.

Note: Full participation is a REP-specific term 

found in 44 CFR § 350.2(j) that refers to the 

level of participation required to meet regulatory 

requirements. A full-participation exercise is one 

in which: (1) state and local government 

emergency personnel are engaged in sufficient 

numbers to verify the capability to respond to 

the actions required by the accident scenario; (2) 

the integrated capability to adequately assess 

and respond to an accident at a commercial 

nuclear power plant is tested; and (3) the 

implementation of the observable portions of 

state and/or local plans is tested.

(2) Drills

Under NUREG-0654/FEMA-REP-1 Evaluation

Criterion N.2, OROs conduct drills to test,

develop, and maintain skills in a particular

operation. Evaluation Criteria N.2.a through 

N.2.e establish the specific types of evaluated

drills required and their frequency.

OROs may conduct other types of drills to

evaluate certain Demonstration Criteria.

Wherever practicable, drills provide a superior

means of assessing technical proficiency,

particularly in critical areas such as Emergency

Worker Exposure Control and Field Monitoring.

Similarly, activation drills may serve as an

assessment tool for infrequently activated 

facilities.

(3) Seminars and Training

A major element of the ORO‘s annual activities

includes review of training objectives, ongoing

maintenance of personnel proficiency, and skill

development. FEMA should observe training

and seminars wherever possible and practical

demonstrations used to assess proficiency.

Occasionally, it may be appropriate for an

organization to request feedback or technical

advice during its training. FEMA can furnish

appropriate resources in those instances and be

part of the assessment.

Both full-scale and functional exercises 

can be full-participation exercises.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-6 October 2011

(4) Plan Reviews

OROs and FEMA Regions review offsite plans

annually for consistency and revise them where

necessary. OROs and the Region jointly decide

on the need to test new procedures before

adoption, which they then incorporate in the

annual training and exercise plan.

(5) Staff Assistance Visits

FEMA Headquarters and Regional staff provide

support to OROs through SAVs. Such assistance

can include: technical assistance with plan

development, review, or implementation;

attending meetings with OROs and the licensee;

participating in or observing non-evaluated

exercises and drills; evaluating exercises and

drills to fulfill biennial requirements; and

verifying ALC and plan information (e.g., KI

inventories, equipment maintenance, training

courses offered).

(6) Actual Events

Where a significant commonality in plans and

personnel exists, an actual event could serve to

validate elements for a facility‘s annual

assessment. If time permits, the Site Specialist

may deploy to the location during the event.

Otherwise, the ORO can submit a request for

REP exercise credit to the FEMA Region

according to the process described in Section 7

of Part III.B.

b. Exercise Cycle Requirements

NUREG Criteria N.1.b and N.1.d establish

considerations for both the Demonstration

Criteria and the scenario variables selected for

REP exercises. Exercise planners need to

consider the following when scheduling REP

activities: 

 FEMA evaluates all elements of the

NUREG-0654/FEMA-REP-1 Planning

Standards, as expressed functionally

through the Evaluation Areas, Subelements, and Demonstration Criteria, in a

full-scale integrated exercise at least once in

an 8-year exercise cycle. FEMA must 

evaluate certain core elements of the 

Assessment Areas at least biennially. 

FEMA may evaluate elements involving 

activities that are not central to the decisionmaking process less frequently as indicated 

in Exhibit III-2, Federal Evaluation Process

Matrix.

 States and applicable local jurisdictions

must fully participate in an ingestion

pathway exercise at least once every 8

years.

 Scenario Variations: NUREG Criterion

N.1.b also establishes requirements for

certain scenario variations within the 8-year

cycle. An exercise may combine required

variations.

 At least one exercise every 8-year

cycle must involve an HAB scenario.

 At least one exercise scenario every

8-year exercise cycle must involve an

initial classification of or rapid

escalation to a Site Area Emergency

or General Emergency.

 At least one exercise every 8-year

cycle must include a scenario

involving no radiological release or

an unplanned minimal radiological

release that requires the site to declare

a Site Area Emergency, but does not

require declaration of a General

Emergency.

Exhibit III-2 provides a crosswalk between the

Demonstration Criteria and NUREG0654/FEMA-REP-1 requirements and identifies

the minimum frequency for evaluation of each

Demonstration Criterion. It also provides

guidance on which Demonstration Criteria

FEMA can evaluate during an out-of-sequence

exercise activity or SAV. In addition, Exhibit

III-2 identifies the Demonstration Criteria for

which OROs may receive credit if applicable

activities occur during an actual incident. As

noted in Exhibit III-2, only certain

Demonstration Criteria are eligible for actual

incident credit.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-7 October 2011

Exhibit III-2: Federal Evaluation Process Matrix84

Assessment Area and Sub-elements

NUREG0654/

FEMA-REP1 Criteria

Minimum

Evaluation

Frequency85

Out-ofSequence

Evaluation

Actual

Incident

Credit

Staff

Ass’t

Visit

1. EMERGENCY OPERATIONS MANAGEMENT 

a. Mobilization

1.a.1: OROs use effective procedures to alert, notify,

and mobilize emergency personnel and activate

facilities in a timely manner.

A.1.a, e;

A.3, 4;

C.1, 4, 6;

D.4; E.1, 2;

H.3, 4

At least

biennially YES YES NO

b. Facilities

1.b.1: Facilities are sufficient to support the

emergency response.

H.3; G.3.a;

J.10.h, J.12;

K.5.b

No less than

once every 8

years86

YES YES YES

c. Direction and Control

1.c.1: Key personnel with leadership roles for the

ORO provide direction and control to that part of the

overall response effort for which they are responsible.

A.1.d;

A.2.a,b; A.3;

C.4, 6

At least

biennially NO NO NO

d. Communications Equipment

1.d.1: At least two communication systems are

available, at least one operates properly, and

communication links are established and maintained

with appropriate locations. Communications

capabilities are managed in support of emergency

operations.

F.1,2 At least

biennially YES87 NO NO

e. Equipment and Supplies to Support

Operations

1.e.1: Equipment, maps, displays, dosimetry, KI, and

other supplies are sufficient to support emergency

operations.

H.7, 10;

I.7, 8, 9;

J.10.a, b, e;

J.11, 12;

K.3.a; K.5.b

At least

biennially YES NO YES

2. PROTECTIVE ACTION DECISION-MAKING

a. Emergency Worker Exposure Control

2.a.1: OROs use a decision-making process,

considering relevant factors and appropriate

coordination, to ensure that an exposure control

system, including use of KI, is in place for emergency

workers, including provisions to authorize radiation

exposure in excess of administrative limits or PAGs.

C.6;

J.10.e, f;

K.4

At least

biennially NO NO NO

 

84 See Demonstration Criteria for specific requirements.

85 See NUREG-0654/FEMA-REP-1 Criteria N.1.b and N.1.d for additional details.

86 Facilities evaluated once when they are new and once every 8 years thereafter. Facilities are re-evaluated for this criterion if, in the interim 

since the last evaluation, they have substantial changes in structure, equipment, or mission that affect key capabilities, as outlined in 

emergency plans/procedures.

87 Communications equipment can be demonstrated in an out-of-sequence scenario during medical services and reception/relocation center drills 

as negotiated in the extent of play. 
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-8 October 2011

Assessment Area and Sub-elements

NUREG0654/

FEMA-REP1 Criteria

Minimum

Evaluation

Frequency85

Out-ofSequence

Evaluation

Actual

Incident

Credit

Staff

Ass’t

Visit

b. Dose Assessment & PARs & PADs for the

Emergency Event

2.b.1: Appropriate PARs are based on available

information on plant condition, field monitoring data,

and licensee and ORO dose projections, as well as

knowledge of onsite and offsite environmental

conditions.

I.10;

Supp. 3

At least

biennially NO NO NO

2.b.2: A decision-making process involving

consideration of appropriate factors and necessary

coordination is used to make PADs for the general

public (including the recommendation for use of KI, if

ORO policy).

A.3; C.4, 6;

D.4; J.9;

J.10.f, m

At least

biennially NO NO NO

c. PADs for the Protection of persons with 

disabilities and access/functional needs

2.c.1: PADs are made, as appropriate, for groups of 

people with disabilities and those with

access/functional needs.

D.4; J.9;

J.10.d,e

At least

biennially NO NO NO

d. Radiological Assessment and Decisionmaking for the Ingestion Exposure Pathway88

2.d.1: Radiological consequences for the ingestion

pathway are assessed and appropriate PADs are

made based on the ORO planning criteria.

A.3; C.1, 4;

D.4; J.9, 11

Every

ingestion

exercise

NO NO NO

e. Radiological Assessment & Decision-making

Concerning Post-Plume Phase Relocation,

Reentry, and Return

2.e.1: Timely post-plume phase relocation, reentry,

and return decisions are made and coordinated as

appropriate, based on assessments of radiological

conditions and criteria in the ORO’s plan and/or

procedures.

I.10; J.9;

K.3.a; M.1

No less than

once every 8

years

NO NO NO

3. PROTECTIVE ACTION IMPLEMENTATION

a. Implementation of Emergency Worker

Exposure Control

3.a.1: The OROs issue appropriate dosimetry, KI, and

procedures, and manage radiological exposure to

emergency workers in accordance with the

plans/procedures. Emergency workers periodically

and at the end of each mission read their dosimeters

and record the readings on the appropriate exposure

record or chart. Appropriate record-keeping of the

administration of KI for emergency workers is

maintained.

J.10.e,

K.3.a, b,

K.4

At least

biennially YES NO NO

b. Implementation of KI Decision for

Institutionalized Individuals and the Public

3.b.1: KI and appropriate instructions are made

available in case a decision to recommend use of KI

is made. Appropriate record keeping of the

administration of KI for institutionalized individuals

and the general public is maintained.

J.10.e, f

At least

biennially89 YES NO NO

 

88 The post-plume phase (ingestion, relocation, reentry, and return) may be demonstrated separately from the plume phase.

89 Demonstrated in every biennial exercise. Participation may be rotated among facilities, but each individual distribution facility must be 

evaluated no less than once every 8 years.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-9 October 2011

Assessment Area and Sub-elements

NUREG0654/

FEMA-REP1 Criteria

Minimum

Evaluation

Frequency85

Out-ofSequence

Evaluation

Actual

Incident

Credit

Staff

Ass’t

Visit

c. Implementation of Protective Actions for

persons with disabilities and access/functional 

needs

3.c.1: PADs are implemented for people with 

disabilities and those with access/functional needs

other than schools within areas subject to protective

actions.

J.10.c, d, e,

g

No less than

once every 8

years

YES YES YES

3.c.2: OROs/school officials implement protective

actions for schools.

J.10.c, d, e,

g

No less than

once every 8

years 90

YES YES YES

d. Implementation of Traffic and Access Control91

3.d.1: Appropriate traffic and access control is

established. Accurate instructions are provided to

traffic and access control personnel.

A.3;

C.1, 4;

J.10.g, j

At least

biennially YES YES YES

3.d.2: Impediments to evacuation are identified and

resolved. J.10.k At leastbiennially YES YES YES

e. Implementation of Ingestion Pathway

Decisions

3.e.1: The ORO demonstrates the availability and

appropriate use of adequate information regarding

water, food supplies, milk, and agricultural production

within the ingestion exposure pathway emergency

planning zone for implementation of protective

actions.

A.3; C.1, 4;

J.11

Every

ingestion

exercise

YES NO NO

3.e.2: Appropriate measures, strategies, and preprinted instructional material are developed for

implementing PADs for contaminated water, food

products, milk, and agricultural production.

G.1, J.9, 11

Every

ingestion

exercise

YES NO NO

f. Implementation of Post-Plume Phase

Relocation, Reentry, and Return Decisions

3.f.1: Decisions regarding controlled reentry of

emergency workers and relocation and return of the

public during the post-emergency phase are

coordinated with appropriate organizations and

implemented.

E.7;

J.10.j; J.12;

K.5.b;

M.1,3

No less than

once every 8

years

YES NO NO

4. FIELD MEASUREMENT AND ANALYSIS

a. Plume Phase Field Measurement and Analyses

4.a.1: [RESERVED]

4.a.2: Field teams (two or more) are managed to

obtain sufficient information to help characterize the

release and to control radiation exposure.

C.1;

H.12;

I.7, 8, 11;

J.10.a

Every full

participation

exercise92

YES NO NO

 

90 Participation may be rotated among school districts, but each school system/district in the EPZ and at least one of its schools must be evaluated

no less than once every 8 years. It is not required that every school within the school system/district be evaluated.

91 Physical deployment of resources is not necessary except in a full-scale exercise.

92 Each state within the 10-mile EPZ of a commercial nuclear power site shall fully participate in an exercise jointly with the licensee and 

appropriate OROs at least every 2 years (44 CFR Part 350.9(c)(1)). Each state with multiple sites within its boundaries shall fully participate in 

a joint exercise at some site on a rotational basis at least every 2 years (44 CFR Part 350.9(c)(2)). When not fully participating in an exercise at 

a site, the state shall partially participate at that site to support full participation of the OROs. See NUREG-0654/FEMA-REP-1 Criterion N.1.b 

for clarification of full participation. 
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-10 October 2011

Assessment Area and Sub-elements

NUREG0654/

FEMA-REP1 Criteria

Minimum

Evaluation

Frequency85

Out-ofSequence

Evaluation

Actual

Incident

Credit

Staff

Ass’t

Visit

4.a.3: Ambient radiation measurements are made

and recorded at appropriate locations, and

radioiodine and particulate samples are collected.

Teams will move to an appropriate low-background

location to determine whether any significant (as

specified in the plan and/or procedures) amount of

radioactivity has been collected on the sampling

media.

C.1;

I.8, 9;

H.12;J.10.a

Every full

participation

exercise

YES NO NO

b. Post Plume Phase Field Measurements and

Sampling

4.b.1: The field teams (two or more) demonstrate the

capability to make appropriate measurements and

collect samples (e.g., food crops, milk, water,

vegetation, and soil) to support adequate

assessments and protective action decision-making.

C.1;

I.8;

J.11

Every

ingestion

exercise

YES NO NO

c. Laboratory Operations

4.c.1: The laboratory is capable of performing

required radiological analyses to support PADs.

C.1; 3;

J.11

No less than

once every 8

years

YES YES NO

5. EMERGENCY NOTIFICATION AND PUBLIC INFORMATION

a. Activation of the Prompt Alert and Notification

System

5.a.1: Activities associated with primary alerting and

notification of the public are completed in a timely

manner following the initial decision by authorized

offsite emergency officials to notify the public of an

emergency situation. The initial instructional message

to the public must include as a minimum the elements

required by current REP guidance.

E.5, 6, 7

At least

biennially YES NO NO

5.a.2: [RESERVED]

5.a.3: Backup alert and notification of the public is

completed within a reasonable time following

detection by the ORO of a failure of the primary alert

and notification system.

E.6;

Appendix

3.B.2.c

No less than

once every 8

years

YES NO NO

5.a.4: Activities associated with FEMA approved

exception areas (where applicable) are completed

within 45 minutes of the initial decision by authorized

offsite emergency officials to notify the public of an

emergency situation.

E.6;

Appendix

3.B.2.c

At least

biennially YES NO NO

b. Emergency Information and Instructions for

the Public and the Media

5.b.1: OROs provide accurate emergency information

and instructions to the public and news media in a

timely manner.

E.5, 7;

G.3.a;

G.4.a, c

At least

biennially YES NO NO

6. Support Operation/Facilities

a. Monitoring, Decontamination, and Registration

of Evacuees

6.a.1: The reception center facility has appropriate

space, adequate resources, and trained personnel to

provide monitoring, decontamination, and registration

of evacuees.

A.3; C.4;

J.10.h; J.12

No less than

once every 8

years93

YES YES NO

 

93 Participation may be rotated among facilities, but each facility must be evaluated no less than once every 8 years. 
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-11 October 2011

Assessment Area and Sub-elements

NUREG0654/

FEMA-REP1 Criteria

Minimum

Evaluation

Frequency85

Out-ofSequence

Evaluation

Actual

Incident

Credit

Staff

Ass’t

Visit

b. Monitoring and Decontamination of

Emergency Workers and their Equipment and

Vehicles

6.b.1: The facility/ORO has adequate procedures and

resources to accomplish monitoring and

decontamination of emergency workers and their

equipment and vehicles.

K.5.a, b

No less than

once every 8

years

YES YES NO

c. Temporary Care of Evacuees

6.c.1: Managers of congregate care facilities

demonstrate that the centers have resources to

provide services and accommodations consistent with

planning guidelines. Managers demonstrate the

procedures to assure that evacuees have been

monitored for contamination and have been

decontaminated as appropriate before entering

congregate care facilities.

J.10.h;

J.12

No less than

once every 8

years94

YES YES YES

d. Transportation and Treatment of

Contaminated Injured Individuals

6.d.1: The facility/ORO has the appropriate space,

adequate resources, and trained personnel to provide

transport, monitoring, decontamination, and medical

services to contaminated injured individuals.

F.2; H.10;

K.5.a,b;

L.1, 4

At least

biennially95 YES YES NO

 

94 Facilities managed by the American Red Cross under the American Red Cross/FEMA MOU will be evaluated once when designated or when 

substantial changes occur; all other facilities not managed by the American Red Cross must be evaluated no less than once every 8 years.

95 At least one facility must be evaluated biennially. All designated primary and backup facilities and transportation providers must be evaluated 

no less than once every 8 years.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-12 October 2011

c. The Training and Exercise Plan and

Workshop

The basis for effective management of HSEEP

training and exercises is the development of the

Multi-year Training and Exercise Plan. The

Training and Exercise Plan identifies what

training and exercises a jurisdiction plans to

execute in order to address homeland security

priorities and capabilities.

OROs typically develop and review the Training 

and Exercise Plan each year at an annual

T&EPW. REP schedules can align with other 

HSEEP activities through participation in 

T&EPWs at the state and Regional level, as 

appropriate. At these meetings, OROs review 

the REP training and exercise schedules in the 

Training and Exercise Plan to identify 

opportunities to combine activities and potential 

schedule conflicts. In addition, coordinated 

scheduling of REP exercises involving multiple 

states or FEMA Regions can occur at the 

Regional T&EPW.

Before attending the T&EPW, OROs and the

FEMA Region determine (1) what type(s) of

exercise they will schedule, and (2) what time

period the scheduling will cover.

State and local jurisdictions conduct the first 

level of T&EPW. The resulting state Training 

and Exercise Plans are then coordinated by

multiple states at a Regional T&EPW. The

T&EPW at different levels may have different

representatives for the REP exercise. The state

T&EPW may include REP representatives from

the OROs, the state, and the FEMA Region,

resulting in a state-level Training and Exercise 

Plan that includes REP exercises.

FEMA Regions participate in the Regional

T&EPW to incorporate REP training and

exercises into the Regional Training and 

Exercise Plan. FEMA coordinates the resulting

Regional Training and Exercise Plan with the

National Exercise Program 5-year plan, which

includes the National Level Exercises, as well as

other exercises.

Activities considered at the T&EPW include all

REP planning, training and exercise events and

incorporate a schedule for SAVs. The schedule 

also includes plan reviews as necessary, as well 

as events not normally within the scope of REP 

activities. The purpose is to review all training, 

exercises and plans to incorporate these 

activities in the upcoming year‘s schedule. If 

another scheduled activity or exercise provides 

an opportunity to meet requirements, OROs can 

take full advantage of that activity and reduce or

eliminate redundant exercises.

The RAC Chairs ensure the entry of REP

exercises into the National Exercise Schedule, a

compilation of all National-level, Federal, state,

local, tribal, and territorial exercises. Per

Homeland Security Grant Program guidance,

state Administrative Agencies must schedule all

exercises through the National Exercise 

Schedule System, so that it can accurately reflect

all the exercises (e.g., REP, the Chemical 

Stockpile Emergency Preparedness Program,

public health, transit, port security, etc.)

occurring throughout the nation.

2. CONDUCTING PRE-PLANNING

ACTIVITIES

a. Establish an Exercise Planning Team

The REP exercise design and development

process will include establishing an EPT led by

the state(s) (or designee), with representatives 

from the licensee, OROs, and FEMA REP staff.

This EPT will hold one or more planning

conferences as needed to determine exercise

scope, design, scenario, and logistics.

Because EPT members have access to scenariorelated information, ORO representatives on the 

EPT serve as confidential representatives/trusted 

agents (CR/TAs). They may participate 

substantially in the exercise design but must 

Maximizing the T&EPW

Knowing more details about the timing and 

necessity of REP training and exercises

maximizes the opportunities to combine other 

efforts and/or avoid scheduling conflicts.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-13 October 2011

agree not to divulge exercise confidences to 

potential players or others involved in the 

exercise. For exercises, confidential 

representatives/trusted agents may only serve on 

the response team in limited instances. The 

following conditions must exist: 

 The ORO must have a shortage of available 

personnel;

 The CR/TA must fill a role that would not 

employ the confidential information. For 

example, he or she could serve as 

traffic/access controller, reception center 

monitor, dispatcher, or dose assessment 

team member, but could not serve as a 

primary decision maker. 

b. Identify the Responsible OROs for

Demonstration Criteria

Generally, ORO plans/procedures assign

responsibilities for multiple emergency response

functions to individual response organizations.

Exercise planners analyze all Demonstration

Criteria, as well as those Demonstration Criteria

evaluated for each ORO in the previous three

exercises, and the set of emergency functions in

order to assign Demonstration Criteria to the

appropriate OROs.

The RAC Chair and site specialist will

coordinate with the state REP Program manager,

state Exercise Officer, state Site Specialist (if

assigned), and local OROs to determine

Demonstration Criteria assignments for a given

location at a particular site. Assignments will

vary from site to site and exercise to exercise,

depending upon the plans/procedures and extent

of play. Assignments should also include all 

locations with responsibilities for portions of a 

process. For example, at site X, the state EOC

prepares the press releases, which the JIC then 

releases. Therefore, both the state EOC and the

JIC have Demonstration Criterion 5.b.1, which

addresses whether OROs provide accurate

information and instructions to the public and

news media in a timely manner.

c. Determine Scenario Type and

Variables

REP Program exercise scenarios create

opportunities for OROs to demonstrate their

ability to take appropriate actions to protect the

public and emergency workers.

All scenarios should be realistic, plausible, and

challenging, but not so complicated that they

overwhelm players. Scenario development needs

to take into account the following factors: 

 Realism (including threats/hazards and

weather variables)

 Specific site location and geography

 Variations (e.g., varied release conditions,

non-sequential ECLs, and incorporation of

HAB incidents) to reduce exercise

predictability and associated negative

training practices

Prior to initiating development of a scenario, the

EPT agrees on the exercise objectives and 

Demonstration Criteria and determines which 

criteria the various OROs will demonstrate and 

the extent of play. The licensee and state then 

develop the scenario and submit it to the 

appropriate FEMA Regional REP personnel for 

review at least 60 days before the exercise. The 

FEMA RAC Chair completes a review of the 

scenario at least 45 days before the exercise to 

confirm that it is sufficient to drive the exercise 

play to demonstrate the agreed-upon exercise 

Demonstration Criteria and extent of play. To 

ensure the integrity of the exercise, participants 

must not learn scenario details.

(1) Scenario Types

Plume Exposure Pathway exercise play.

Plume exposure pathway exercise play requires

developing a scenario that will drive the

demonstration of capabilities to protect public

health and safety within the 10-mile EPZ. In

general, the source term and resultant dose

projections reach a sufficient magnitude and

distance from the plant to drive the performance

of the agreed-upon Demonstration Criteria and

extent of play.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-14 October 2011

Ingestion Exposure Pathway exercise play.

For ingestion exposure pathway scenario

development, the scenario drives exercise play 

for all participating jurisdictions within the 50-

mile EPZ. An Initial Planning Conference (IPC) 

comprised of participating agencies determines 

the criteria that they will demonstrate. The 

scenario will need to ensure that the radioactive 

plume and consequent ground deposition affect 

the appropriate areas within these jurisdictions.

Relocation, reentry, and return exercise play.

The scenario incorporates simulated offsite

radiological deposition that exceeds the

relocation PAGs as set forth in the affected

jurisdiction‘s plans/procedures. For relocation

activities, the projected dose is calculated for the

first year, any subsequent year, and 50 years.

The deposition should contain both short-lived

and long-lived radionuclides, such as iodine and

cesium, to prevent decision-makers from waiting

out radionuclide decay to avoid relocation

decisions. FEMA recommends demonstrating

ingestion exposure pathway, relocation, reentry,

and return activities within the same exercise

when possible because of the similar scenario

requirements of exercise play.

(2) Scenario Variables

As discussed in the explanation for NUREG0654/FEMA-REP-1 Evaluation Criterion N.1.b,

FEMA and the NRC added new scenario

variables to enhance scenario realism and avoid

preconditioning. Exercise designers must 

account for these scenario variables to meet the

scheduling parameters. These variables include:

(a) Hostile Actions against an NPP

 A scenario variation with this initiating

event is required at least once in every 8-

year cycle. HAB incidents present unique

challenges to the licensee and OROs. An

HAB incident may overwhelm local and

state response agencies, and may also

involve response from agencies not

normally involved in a REP exercise. The

HAB scenario variable can coincide with

either a release or no/minimal release

scenario variable, but the scenarios must not

include a no/minimal release option for

consecutive HAB exercises at a particular

site. Considerations for use of the HAB

scenario variable may include: 

 Varying the method of attack (e.g., insider

threat; ground, waterborne, or airborne

attacks; or a combination);

 Simultaneous attacks or threats to other

facilities at the regional or local level that

would impact ORO resource availability in

responding to an incident at the NPP site;

 Equipment/component failures (e.g., failure

of an emergency diesel generator or

emergency core cooling system pump to

start, failure of containment to isolate) to

facilitate escalation in ECL or radiological

release potential; and/or

 Federal players. Federal play will not 

impact ORO evaluation.

(b) An initial classification of or rapid

escalation to a Site Area Emergency

or General Emergency

Scenarios employ this variable at least once per

8-year exercise cycle. When using this variable,

the EPT needs to ensure that all appropriate

criteria can still be demonstrated. Reaching the

GE may or may not be necessary depending on

the OROs‘ plans/ procedures and the actions that

are triggered with regard to the changing ECLs.

(c) No radiological release or an

unplanned minimal radiological

release that requires the site to

declare a Site Area Emergency, but

does not require the declaration of a

General Emergency

Licensees must use this variable at least once per

8-year exercise cycle. FEMA encourages, but

does not require, OROs to participate in this

exercise with the licensee. If OROs elect to

participate in a joint exercise with no or minimal

release, part of the planning for the exercise will

include identifying Demonstration Criteria that

cannot be evaluated during the exercise and

determining appropriate alternative

demonstration and evaluation venues so that the

OROs can meet their biennial evaluation

requirements.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-15 October 2011

Alternative venues could include controller

injects during the exercise to drive

demonstration of specific response elements;

out-of-sequence activities connected to the

exercise; or additional activities during the

assessment cycle. For example, controller injects

could drive demonstration of dose projection;

decisions to decontaminate people and

equipment; emergency worker understanding

and use of established turn back values; and

field monitoring. In addition, creative scenario

elements could be used to drive demonstration

of protective action decision-making (e.g.,

evacuation, sheltering in place).

If OROs have a Deficiency related to protective 

action decision-making from the last exercise, 

regardless of whether the Deficiency has been 

corrected, the offsite portion of the scenario 

must be expanded as appropriate to drive ORO 

demonstration of protective action decisionmaking. 

Due to the impact on ORO resources, the

licensee and appropriate OROs must agree on

the use of the ―no/minimal release‖ option as

part of the overall scenario development process.

Planners must not use a ―no/minimal release‖

scenario in consecutive exercises.

(d) Varied radiological release effects and

meteorological conditions

Varied release effects and meteorological 

conditions can be used to reduce the possibility 

of pre-conditioned responses. However, no 

specific requirements for use of this variable 

currently exist. Variations in release may include 

puff versus continuous release and ground-level 

versus elevated release; variations in conditions 

may include shifting wind direction and speed, 

precipitation, temperature, and other conditions 

as applicable.

(e) A broader spectrum of

initiating/concurrent events

There are no specific requirements for use of

this variable, but a broader spectrum of

initiating/concurrent events should be used to

create more realistic and challenging exercises.

In addition to the traditional equipment

malfunctions and operator actions, all-hazard

incidents may be considered as possible scenario

initiating events, based on applicability to site,

provided that they do not become the primary

focus of the exercise or detract from the

demonstration of REP capabilities. These

incidents are not limited to the impact on NPP

structures or components and consider the

impact on ORO resources and command and

control. Such incidents may include:

 Natural disasters historically applicable to

the area (e.g., hurricane, tornado,

earthquake, flooding);

 Site-specific all-hazard incidents (e.g.,

accident involving near-site facility, train

derailment on or adjacent to site owner

controlled area).

 Seasonal factors impacting the PARs and

decision process (e.g., transient populations,

weather conditions, agricultural seasons).

d. Select Demonstration Criteria for

Evaluation

Before the planning process begins, the FEMA 

Region compiles a list of Demonstration Criteria 

that must be evaluated at the OROs to provide 

reasonable assurance. Some Demonstration 

Criteria are core functions and activities that 

FEMA must evaluate for each participating 

ORO at least biennially, as identified in Exhibit 

III-2, Federal Evaluation Process Matrix. Other 

Demonstration Criteria focus on specific 

radiological emergency response capabilities for 

which only certain organizations are responsible. 

Scenario events, exercise play, and the criterion 

demonstration schedule determine the particular

organizations that will participate. 

The type of exercise will determine which 

Demonstration Criteria FEMA will evaluate. For 

the qualifying exercise, FEMA must evaluate all 

Demonstration Criteria at the appropriate ORO 

in accordance with the plans/procedures.

96 For 

biennial exercises, planners review the 

 

96 See Standard Operating Procedure and Guidelines For the New 

Reactor Combined License Application, available on www. 

fema.gov/about/divisions/thd_repp.shtm
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-16 October 2011

Demonstration Criteria evaluated during the 

previous three exercises to determine those that 

need to be evaluated for the current exercise 

cycle. The FEMA Region will come to the IPC 

with the recommended list of Demonstration 

Criteria for evaluation. This list provides a 

starting point for discussions to define the extent 

of play and scope of the exercise during the 

subsequent planning meetings. 

The FEMA Region also considers 

Demonstration Criteria that may be performed 

out of sequence. The RAC Chair will make the 

final decision on all aspects of acceptable out-ofsequence evaluations. The biennial after-action 

report (AAR) includes out-of-sequence 

evaluations that are scheduled no more than 60 

days prior to or 30 days after the biennial 

exercise. A separate AAR documents out-ofsequence evaluations scheduled outside the 

specified timeframe.

In addition, the FEMA Region considers any 

credit given to OROs for activities performed 

during real-world incidents. The process for 

requesting and documenting REP exercise credit 

is provided in subsection 7 of Part III.B.

3. DEVELOPING REP EXERCISE 

DOCUMENTS

This section describes the following REP 

exercise documents:

 ExPlan 

 C/E Handbook

 EEGs

 MSEL

Although document development occurs as part 

of the Planning Meetings described in the next 

section, they are explained first here for clarity. 

a. Exercise Plan

The ExPlan includes general exercise 

information, but does not contain scenario 

details. It is the ―game plan‖ for the exercise. 

The EPT typically distributes the ExPlan to 

Players and Observers, but should also give it to

Controllers and Evaluators. The EPT brings all 

information needed to complete the ExPlan to 

the IPC. The EPT develops the draft ExPlan 

prior to the MPC, and creates the Final ExPlan 

prior to or at the FPC.

b. Controller/Evaluator Handbook

The C/E Handbook is largely considered to be a 

supplement to the ExPlan. The C/E Handbook

contains most of the same information but 

provides more detail about exercise 

administration and the scenario. The EPT only 

distributes the C/E Handbook to the Controllers 

and Evaluators. Other exercise participants must 

not receive the C/E Handbook.

For REP Program exercises, the EPT only 

creates C/E Handbooks when it determines a 

need for them. The EPT should consider 

creating a C/E Handbook in the following 

situations:

 Large number of Controllers and/or 

Evaluators: the C/E Handbook will help 

provide more specific information and 

targeted instruction to the larger groups.

 Complex scenario and/or MSEL: The C/E 

Handbook can include the scenario details, 

injects, and/or MSEL itself to ensure that 

Controllers and Evaluators have all 

pertinent information.

For exercises without a C/E Handbook, the EPT 

can easily include additional information within 

the ExPlan itself (e.g., Controller and Evaluator 

roles and responsibilities) or its appendices for 

information with limited distribution (e.g., 

scenario information).

c. Exercise Evaluation Guides

FEMA recommends that REP exercise planners 

develop tailored capability-based EEGs. The 

capability-based Master EEGs maintain the 

integrity of the REP exercise criteria while 

providing useful input to the jurisdictions that 

helps them test and build their capabilities.

FEMA Region decides the degree of EPT and 

ORO involvement in tailoring the Master EEGs 
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-17 October 2011

into exercise-specific EEGs. A successful 

evaluation does not require direct ORO 

involvement in the EEG development process.

However, the benefits of involving the OROs in 

the process include:

 Clarifying how the REP exercise and OROs 

Target Capabilities fit together.

 Creating site-specific EEGs that lead to a 

more detailed evaluation. 

 Improved ORO understanding and 

acceptance of the REP/HSEEP approach. 

FEMA recommends providing all information 

needed to complete the EEGs at the IPC. The 

EPT develops the Draft EEGs prior to the MPC, 

with the Final EEGs being created prior to or at

the FPC.

d. Master Scenario Events List 

Exercise planners may use scenario injects to 

increase participation by OROs during lulls in 

the primary radiological response activities. For 

example, a scenario inject for a simulated 

HAZMAT incident could require an immediate 

response by OROs. While scenario injects may 

enhance exercise play for OROs, they should not 

detract from the primary goals, technical 

analysis, and timeline of the primary scenario. 

Most REP/HSEEP exercises may not need an 

MSEL Conference because player reactions to a 

limited number of scenario events (i.e., ECL 

changes and PADs) primarily control exercise 

play. However, exercises with HAB or non-REP 

scenario elements (e.g., a joint REP and allhazards exercise) may warrant an MSEL 

Conference. 

MSEL conferences, when used, should include a 

representative from the licensee to ensure that 

changes in off-site event timing do not conflict 

with the on-site scenario that drives licensee 

actions. Exercise planners must ensure that 

MSEL injects are either timed to be consistent 

with the on-site scenario events or the EPT must 

conduct a MSEL Conference as early as possible 

to give the licensee time to modify the scenario 

and reactor simulator model.

4. HOLDING EXERCISE PLANNING

MEETINGS

Following meetings occur after the pre-planning

activities.

a. Concepts & Objectives Meeting

Under HSEEP, a C&O Meeting is held to

identify the type, scope, and purpose of the

exercise, as well as the specific Demonstration 

Criteria that will be evaluated. The EPT can 

combine the C&O Meeting with the IPC for

REP exercises. However, the initial REP

exercise held using the HSEEP methodology in

a FEMA Region, state, or at a particular site may

warrant a separate meeting to orient the

planners.

b. Initial Planning Conference

The IPC lays the foundation for exercise

development, and occurs at least six months

before the exercise to address:

 REP Demonstration Criteria to be

evaluated, including location and by whom

 Target capabilities

 Scenario type and variables

 Out-of-sequence demonstrations and

potential schedule

 Roles and responsibilities for exercise

document preparation

 Schedule for upcoming planning meetings

 Responsibility for exercise document

development

During the IPC, the FEMA Region, state, and

OROs review and finalize the appropriate

Demonstration Criteria. The FEMA Region

identifies any criteria that need to be evaluated

based on Exhibit III-2 and any outstanding

uncorrected ARCAs and comes to the IPC with 

a criteria list. The FEMA Region orders these

criteria according to location (e.g., County EOC)

and/or function (e.g., field monitoring team).

Following the IPC, and leading up to the MPC,

the EPT develops the following:
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-18 October 2011

 Final list of Demonstration Criteria/Target 

Capabilities to be evaluated

 Initial draft Extent-of-Play Agreement

 Draft ExPlan

 Draft EEGs

 Initial draft of off-site scenario and MSEL

c. Mid-term Planning Conference

REP/HSEEP MPCs generally occur three

months before the exercise. Items to address and

accomplish include:

 Negotiate and finalize the ORO Extent-ofPlay Agreement

 Review the Draft ExPlan and incorporate

the finalized extent of play

 Review general scenario concepts (FEMA

reviews the scenario before the exercise and

does not wait for the FPC)

 Review draft MSEL, if needed

 Review draft EEGs

 Prepare the out-of-sequence events

schedule

 Prepare the exercise events schedule

 Determine the need for a C/E Handbook

 Discuss and resolve planning and logistical

issues

Some EPTs may decide to hold more than one 

meeting to prepare all the items typically 

covered in the MPC, especially if there is a large 

volume of information to review. In any event, 

the EPT completes the actions below before the 

FPC: 

 C/E Handbook, if needed

 ExPlan

 EEGs

 Scenario (limited to Trusted Agents only)

 MSEL, if needed (limited to Trusted Agents

only)

d. Final Planning Conference

The purpose of an FPC is to undertake a 

comprehensive review of all exercise documents 

and identify and resolve any outstanding items. 

The EPT finalizes the exercise documents after 

the FPC. The EPT should schedule the FPC 

early enough that any outstanding items can be 

resolved prior to the exercise. While current 

HSEEP guidance recommends holding the FPC 

30 days before an exercise, the FPC for a 

REP/HSEEP Integrated Exercise should occur

no later than 45 days before the exercise. This 

timeframe provides the FEMA Region with

adequate time to assemble Evaluator Packets 

and distribute them 30 days before the exercise. 

During the FPC, the EPT:

 Reviews all exercise processes and

procedures

 Approves and finalizes all exercise

documents

 Finalizes exercise logistics

 Finalizes controller and evaluator

assignments

 Resolves outstanding items or schedules

their resolution

 Determines information to present at the

exercise briefings

Following the FPC, the EPT: 

 Prepares final versions of the ExPlan, C/E

Handbook, EEGs, Scenario, and MSEL

 Compiles Controller Packets (state/OROs)

 Compiles Evaluator Packets (FEMA)

 Finalizes exercise briefings

5. CONDUCTING REP EXERCISES

This section provides guidance for activities

conducted immediately before and after the

exercises including:

 Assigning and Confirming Evaluators

 Pre-Exercise Meetings/Briefings

 Post Exercise Briefings
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-19 October 2011

a. Assigning and Confirming Evaluators

REP exercises use evaluators specifically trained 

to identify and evaluate the REP Demonstration 

Criteria. The FEMA Region bases its 

determination regarding the number of REP 

evaluators assigned to each jurisdiction upon the 

number of Demonstration Criteria requiring 

evaluation and the Extent-of-Play Agreement. 

The RAC Chair (or designee) ensures that all 

evaluators have completed the required REPapproved training courses offered by FEMA‘s 

Emergency Management Institute as well as onthe-job training with a FEMA-accepted 

evaluator.

b. Pre-Exercise Meetings/Briefings

Prior to the exercise, the EPT provides the 

exercise participants with a briefing to educate 

them on their roles and responsibilities during 

the exercise. The briefings provide a schedule of 

meetings and exercise events, logistical 

information, and instructions and procedures for 

conducting the exercise and evaluation 

activities. 

Evaluator briefings include information and 

instructions regarding the REP/HSEEP 

evaluation approach used by the Region. The 

briefings address the applicable Demonstration 

Criteria/Target Capabilities to be evaluated, the 

exercise scenario overview, the timeline of 

significant events, and how evaluators will 

document the results. 

c. Post-Exercise Meetings

Although all HSEEP exercises include hot 

washes, 44 CFR § 350.9 requires post-exercise 

participant briefings and public meetings for 

REP exercises. The RAC Chair conducts two 

meetings – one with participants only to discuss 

preliminary results, and one including the public

to discuss the evaluation of the exercise.

Hot wash: Unlike HSEEP, which is designed

for ―no-fault‖ exercises, exercise evaluation

under the REP program is driven by regulation

and the results are graded. Therefore, the

HSEEP concept of a Hot Wash, with Evaluators

and Players sharing observations and identifying

exercise issues together, may not be practical for

an evaluated REP/HSEEP exercise. State and 

OROs can incorporate their separate 

controller/player hot wash results into the Draft 

AAR/Improvement Plan (IP) after the FEMA 

regulatory findings are completed. FEMA highly 

encourages HSEEP hot washes at non-evaluated

REP activities.

Participant briefing: FEMA uses the 

participant briefing conducted after the REP 

exercise as an opportunity to present OROs with 

initial exercise results. These results include 

identified strengths, areas for improvement, and 

potential issues. The briefing provides OROs 

with the opportunity to discuss the preliminary 

results of the exercise so they have a clear 

understanding of the issues and can provide their 

perspective. The RAC Chair conducts the 

participant briefing. 

The recommended participant briefing agenda is 

as follows:

 Review by RAC Chair of offsite activities, 

including the option of the RAC Chair 

asking evaluation team leaders or specific 

evaluators to make presentations regarding 

their observations;

 Presentation of OROs views;

 Review of Federal response, if applicable, 

by RAC Chair; and

 Question-and-answer period.

The presentations provide a brief integrated 

overview of the highlights of the exercise. They 

include commendations for good performance 

and a preliminary assessment of strengths and 

weaknesses of the demonstration. At this stage, 

the RAC Chair may discuss potential exercise 

issues not yet classified as Deficiencies or 

ARCAs. This meeting provides OROs with a 

forum to discuss the preliminary exercise results 

so that they clearly understand the issues and 

can provide their perspective on the situation.

Public meeting: The RAC Chair conducts the 

public meeting in accordance with 44 CFR § 

350.9(e). The RAC Chair may combine the 
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-20 October 2011

participant briefing with the public meeting at 

his or her discretion. The State or licensee 

publishes notice of the public meeting 7 days 

prior to the exercise date in the local newspaper 

with the largest circulation in the area (or other 

comparable media, at the discretion of the 

FEMA Regional Administrator [or designee]). 

The RAC Chair will invite representatives of 

participating OROs, the NRC, and other Federal 

agencies. Members of the public and media may 

attend as observers.

The recommended public meeting agenda is as

follows:

 Review of onsite actions (presented by the 

NRC);

 Presentation of licensee views;

 Review by RAC Chair of offsite activities,

including the option of the RAC Chair

asking evaluation team leaders or specific

evaluators to make presentations regarding

their observations;

 Presentation of OROs views;

 Review of Federal response, if applicable,

by RAC Chair; and

 Question-and-answer period.

During the public meeting, the FEMA Regional 

Administrator (or designee) provides an 

overview of the exercise, along with his or her 

observations. The FEMA Regional 

Administrator (or designee) may solicit 

comments from RAC members and other 

evaluators at his or her discretion. When 

discussing organizational performance problems 

during the meeting, FEMA regional officials do 

not classify these problems as Deficiencies or 

ARCAs.

The FEMA Regional Administrator (or 

designee) may accept written comments from 

the public and media during or after the meeting 

at his or her discretion. The FEMA Regional 

Office retains copies of each written submission, 

along with a written response. The Regional 

Administrator (or designee) takes results of the 

meeting and any written comments received into 

consideration in his or her evaluation of the 

exercise. 

For remedial exercises, the FEMA Regional 

Administrator (or designee), at his or her 

discretion, may conduct a public meeting. This 

meeting acquaints the public and media with any 

significant plans/procedures amendments and 

discusses the results of the remedial exercise. 

When the Regional Administrator holds this 

meeting, it proceeds in the same manner as

meetings held in conjunction with biennial

exercises that take place after the initial 44 CFR

Part 350 qualifying exercise.

6. DOCUMENTING REP EXERCISES

a. Identifying Exercise Outcomes and 

Issues 

During exercises or other evaluated 

demonstrations, evaluators make extensive notes 

on the activities that occur. Evaluators also note 

any variations from expected activities and 

outcomes. After the exercise, evaluators compile 

their observations into narratives that describe 

the capabilities demonstrated and any 

weaknesses in the organization‘s ability to carry 

out expected actions.

The Assessment Areas and Demonstration 

Criteria are designed to assist FEMA in 

assessing how successfully OROs carry out their 

REP plans/procedures to meet planning and 

preparedness requirements outlined in 44 CFR 

Part 350. 

The AAR/IP captures observations from the 

exercise and includes recommendations for postexercise improvements.

REP Terminology: Issue

An issue is any problem in organizational 

performance that is linked through the Assessment 

Areas, Sub-elements, and Demonstration Criteria 

to specific NUREG-0654/FEMA-REP-1 Planning 

Standards and applicable Evaluation Criteria.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-21 October 2011

(1) Identifying Issues

The REP program uses specific terminology to

characterize problems identified during an 

exercise. FEMA has established the following

categories of issues:

 Deficiency: An observed or identified

inadequacy of organizational performance

in an exercise that could cause a finding that

offsite emergency preparedness is not

adequate to provide reasonable assurance

that appropriate protective measures can be

taken in the event of a radiological

emergency to protect the health and safety

of the public living in the vicinity of an

NPP.

 ARCA: An observed or identified

inadequacy of organizational performance

in an exercise that is not considered, by

itself, to adversely impact public health and

safety.

 Plan Issue: An observed or identified

inadequacy in the ORO‘s emergency

plan/procedures, rather than in the ORO‘s

performance.

FEMA includes these issues in the exercise 

AAR/IP. FEMA can include non-REP issue 

recommendations for improvement (i.e., not 

linked to NUREG-0654/FEMA-REP-1 

requirements) in the AAR/IP or address them

independently in accordance with the HSEEP

AAR/IP process.

(2) Correcting Issues during the

Exercise

In some circumstances, an ORO may correct an 

issue immediately during the play of the 

exercise. FEMA and the OROs negotiate the 

immediate re-demonstration of issues before the 

exercise. Each Region‘s RAC Chair determines 

the Demonstration Criteria eligible for redemonstration. During the extent-of-play 

negotiations (part of the exercise planning 

process), each ORO requests the criteria for redemonstration during the exercise. 

During the exercise, an evaluator who notes that 

an ORO did not correctly demonstrate activities 

for a particular criterion advises the appropriate 

controller of the issue. Participants may redemonstrate an activity that the ORO or FEMA 

determined was not performed satisfactorily 

only when the correction would not interrupt the 

flow of the exercise. The controller or other 

ORO personnel will re-train the staff that 

performed the criterion activity incorrectly. 

Upon completion of the training, those staff will 

re-demonstrate the criterion activity. If the ORO 

demonstrates that activity adequately, the AAR 

will record the issue, but a follow-on statement 

will describe the corrective action demonstrated.

(3) Classifying Issues

The RAC Chair, in consultation with the other

RAC members present at the exercise, will

determine the severity of each issue. If the RAC 

Chair determines that an issue will be an ARCA,

the evaluator will complete a specific issue

narrative. However, if the RAC chair classifies

the issue as a potential Deficiency, he or she

must immediately notify FEMA Headquarters of

the issue. The RAC Chair must then, within two 

days, write a description of the issue and the 

reasons he or she believes it may receive 

Deficiency classification. FEMA Headquarters 

staff will, in turn, notify NRC headquarters. 

The RAC Chair should use definitions, facts, 

and overall exercise performance to determine 

classification. The RAC Chair also considers the 

potential impact of the identified issues on 

public health and safety, including the

following: 

 If the identified issue could, by itself, have

an adverse impact on public health and

Areas for Potential Deficiencies

Over the history of REP Program exercises, FEMA 

has identified Deficiencies in all six Assessment 

Areas. The Assessment Areas provide a means to 

evaluate OROs’ ability to meet the criteria outlined 

in Planning Standards A, C, D, E, F, G, H, I, J, K, 

L, and M. The Assessment Areas do not address 

Planning Standard B, which applies only to 

licensees, or Planning Standards N, O, and P, 

which address administrative topics.
PART III: DEMONSTRATION GUIDANCE

REP Program Manual Page III-22 October 2011

safety, the RAC Chair classifies the issue as

a Deficiency.

 A RAC Chair may assess a Deficiency

when the collective impact of two or more

ARCAs on an organization‘s emergency

functioning precludes adequate protection

of public health and safety. Multiple

exercise issues may indicate a more severe

problem. If the combined effect of the

exercise issues leads to a determination that

offsite emergency preparedness is not

adequate to provide reasonable assurance

that appropriate protective measures can be

taken in the event of a radiological

emergency to protect the health and safety

of the public living in the vicinity of a

nuclear power plant, then the RAC Chair 

should assess a single Deficiency, rather

than multiple ARCAs.

 If the identified issue could NOT, by itself,

have an adverse impact on public health

and safety, but simply reflects that the

Demonstration Criteria were not met, the

RAC Chair classifies the issue as an ARCA.

 If the identified issue describes any

inadequacy in an ORO‘s performance, the

RAC Chair classifies the issue as a

Deficiency or ARCA, even if it resulted

from following inadequate

plans/procedures.

(4) Standardized Exercise Issue

Numbering

FEMA employs a standardized system for

numbering issues. This system provides

consistency in numbering exercise issues among

FEMA Regions and site-specific AARs within

each Region. It also expedites tracking of issues

on a nationwide basis.

Elements of the Standard Exercise Issue

Number

The identifying number for Deficiencies,

ARCAs, and Plan Issues includes the following

elements, with each element separated by a

hyphen (-).

 Plant Site Identifier – A two-digit number,

corresponding to the Utility Billable Plant

Site Codes (see Part IV.V for a list of these 

codes).

 Exercise Year – Last two digits of the year

the exercise was conducted.

 Demonstration Criterion – The letters and

numbers corresponding to the

Demonstration Criterion in Part III.C of this

FEMA REP Program Manual.

 Issue Classification Identifier – D =

Deficiency, A = ARCA, P = Plan

 Exercise Issue Identification Number – A

separate two (or three) digit indexing

number assigned to each issue identified in

the exercise.

Exhibit III-3: Illustration of the Standard Exercise Issue Number

EXAMPLE:

Issue Number: 76-94-1.b.1-A-01

76 94 1.b.1 A 01

Plant Site 

Identifier

Exercise Year Demonstration 

Criterion

Classification: 

Deficiency (D)

ARCA (A)

Plan (P)

Issue Number
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-23 October 2011

(5) Assigning Exercise Issue Numbers

The RAC Chair assigns exercise issue

identification numbers to issues included in the

AAR. After all issues have been identified and

classified, they are assigned an individual

exercise issue identification number in the

sequence in which they appear in Section III of

the AAR. However, Deficiencies, ARCAs, and

Plan Issues are numbered separately, with issue

numbers beginning with ―01‖ in each category.

FEMA assigns each exercise issue a unique 

identification number. While FEMA may need 

to add or delete issues during the post-exercise 

review process, only the last two digits of the 

identification numbers will change when the

report is finalized.

b. Determining Demonstration Criterion

Status

Once all exercise issues are classified, the RAC

Chair is responsible for describing the status of

each Demonstration Criterion demonstrated by

individual jurisdictions and/or functional entities

during the exercise or activity. In Section III of

the AAR, Exercise Evaluation and Results, the 

RAC Chair may use any of the five terms that

describe the status of the scheduled

Demonstration Criteria at each jurisdiction

and/or functional entity after the current

exercise.

 MET (M) – The jurisdiction or functional

entity performed all activities under the

Demonstration Criterion to the level

required in the Extent-of-Play Agreement,

with no Deficiencies or ARCAs assessed

under that criterion in the current exercise

and no unresolved prior ARCAs.

 DEFICIENCY (D) – The jurisdiction or

functional entity performed activities under

the Demonstration Criterion, but had one or

more Deficiencies assessed under the

criterion.

 ARCA (A) – The jurisdiction or functional

entity performed activities under the

Demonstration Criterion, but had one or

more ARCAs assessed under the criterion

in the current exercise and/or one or more

ARCAs assessed during a previous exercise

which it did not resolve in the current

exercise.

 NOT DEMONSTRATED (N) – For a

justifiable reason, the jurisdiction or

functional entity did not perform activities

under the Demonstration Criterion as

specified in the Extent-of-Play Agreement

or at the frequency required in Exhibit III-2

(see Not Demonstrated in the glossary).

 NOT APPLICABLE (N/A) – The

criterion does not apply to the jurisdiction.

FEMA may grant an ORO an exemption from

scheduled evaluation of one or more

Demonstration Criteria at an exercise if the ORO

cannot participate due to response to an actual

incident. If this situation is known in advance of

the exercise, the state must request an

exemption, which FEMA‘s Regional Office and 

Headquarters must approve.

When FEMA grants an advance exemption for 

one or more REP Demonstration Criteria at an 

exercise, the AAR lists those criteria as MET

and documents the exemption rationale in the 

Extent-of-Play Agreement.

If the ORO does not receive an advance

exemption and does not perform the activities

under a scheduled Demonstration Criterion

during the exercise, the RAC Chair carefully

reviews and considers the facts surrounding the

failure. If the RAC Chair determines that the

reason for not performing the activities was

valid, the Demonstration Criterion status is

defined as NOT DEMONSTRATED. In

general, a jurisdiction or functional entity may

justify not demonstrating a criterion because:

 Exercise participation had to be suspended

so the ORO, or members of its staff, could

respond to an actual emergency during the

time the exercise was being conducted; or

 A significant extenuating circumstance,

such as a fire or flood at the facility,

prevented its use during the exercise.

Note that in all cases where a criterion is defined

as NOT DEMONSTRATED, evaluation must 
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-24 October 2011

occur no later than the site‘s next biennial

exercise.

If the RAC Chair determines that a failure to

perform the activities under the Demonstration

Criterion was not justified, the criterion status is

defined as a DEFICIENCY.

c. Notifying the State of Deficiencies

Within two days of the exercise, the RAC Chair 

initiates consultation with FEMA Headquarters, 

RAC members, and the state in order to identify 

potential Deficiencies. As a result of this 

consultation process, the RAC Chair prepares a 

letter to the state that the Regional Administrator 

(or designee) will sign. The letter includes: (a) 

jurisdictions affected; (b) description of 

Deficiencies identified; (c) remedial actions 

recommended to correct the Deficiencies; and 

(d) timeframe for completion of remedial 

actions. The Regional Administrator (or 

designee) forwards the letter within 10 days of 

the exercise to the state informing it of identified 

Deficiencies and the actions needed to correct 

the problem(s). Within 20 days of the exercise, 

the state acknowledges receipt of this letter and 

may either propose a schedule for remedial 

actions or appeal the issue classification of 

Deficiencies. 

The FEMA Region provides copies of the letter 

to FEMA Headquarters and the appropriate 

NRC Regional Office. FEMA Headquarters then

provides a copy of the letter to NRC 

Headquarters. For more on this process refer to

Appendix A to 44 CFR Part 353 (FEMA/NRC 

MOU). 

The FEMA Regional Administrator (or 

designee) determines the extent of ORO 

participation in a remedial exercise or drill. 

OROs demonstrate only those activities 

necessary for correction of the Deficiencies. To 

the extent possible, FEMA limits participation in 

remedial exercises to the OROs having the 

Deficiencies. If an ORO cannot demonstrate the 

corrective action without the involvement of 

other OROs, then their participation is at a level 

necessary to confirm the correction of the 

Deficiencies. The host NRC Regional 

Administrator arranges Licensee participation, if 

needed.

The primary reason for providing states with 

formal documentation of identified Deficiencies 

is to facilitate prompt correction of these 

identified problems. While it is FEMA‘s intent 

to provide this formal documentation to states 

within 10 days, there may be circumstances 

where this timeframe is not met. However, 

through the consultation process initiated 

immediately following each exercise, all 

involved exercise participants will be made 

aware of significant issues and problems that 

necessitate prompt correction. Subsequent 

formal notification of Deficiencies more than 10 

days after the exercise date does not, therefore, 

preclude prompt correction of Deficiencies 

within 120 days. Similarly, if the state

experiences administrative delays due to 

extenuating real-world incidents/circumstances 

which would impact the state‘s ability to 

respond to these timelines, FEMA will take this 

into consideration. 

d. Developing the After Action Report

The AAR/IP captures observations from the

exercise and includes recommendations for postexercise improvements. AARs are designed to

meet varying levels of sensitivity – portions not

intended for public disclosure can be separated

and protected.

Consistent with the capability-based EEGs, the

AAR/IP is capability-based (i.e., includes an

analysis of capabilities exercised and activities

performed as well as recommendations for

addressing identified areas of improvement).

Because regulations require successful

demonstration of the Planning Standards, the

AAR also includes discussions of ARCAs,

Deficiencies, and Plan Issues. FEMA retains 

exercise documentation in the Regional files as a

permanent record of exercise play.

The FEMA Region sends the draft AAR to the

state(s) and RAC members for review and

comment within 30 calendar days of the

exercise. All review and comment focuses on

the accuracy of data and information contained
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-25 October 2011

in the draft report; identification and proper

classification of exercise issues; and overall

report quality. Those reviewing the draft AAR

contact the RAC Chair or report preparation

staff for clarification of any items in question.

The FEMA Region receives all comments on the

draft AAR report no later than 60 calendar days

after the exercise. The RAC Chair receives all 

comments in writing to facilitate the

consideration and incorporation of comments,

the Schedule of Corrective Actions received, and

the retention of comments in the Regional files.

The RAC Chair will contact individual

reviewers as necessary to adjudicate any

comments in question. The report preparation

staff incorporates approved comments into the

final report.

The RAC Chair must prepare a letter of

reasonable assurance for the NRC to accompany

the AAR, stating that OROs can take appropriate

protective measures in the event of a

radiological emergency to protect the health and

safety of the public living in the vicinity of an

NPP. The FEMA Regional Administrator (or

designee) transmits the final AAR to the NRC

Regional Administrator no more than 90 days 

after the exercise.

Biennial exercise AARs may include the 

evaluations of drills or out-of-sequence activities 

(e.g., medical services or reception center drills) 

conducted within 60 days prior to or 30 days 

after the exercise date. FEMA issues separate 

drill AARs for evaluations occurring outside the 

specified timeframe. The FEMA Regional 

Administrator (or designee) transmits drill

AARs to the NRC Regional Administrator

within 45 days of the drill date.

The RAC Chair distributes copies of the final

AAR as follows:

 Signed hard copy – mailed directly to:

NRC Headquarters

Document Control Desk

US Nuclear Regulatory Commission

Washington, DC 20555-0001

 Electronic copy to applicable NRC Region

 NRC Region I

RI_FEMADistribution@nrc.gov

 NRC Region II

RII_FEMADistribution@nrc.gov

 NRC Region III

RIII_FEMADistribution@nrc.gov

 NRC Region IV

RIV_FEMADistribution@nrc.gov

 Hard or electronic copy

 State(s) Agency/Organization with

primary responsibility for REP program

activity

 Appropriate RAC members

 REP Headquarters Branch Chief

 REP Headquarters Regional Project

Officer

e. Developing the Improvement Plan

The IP is an outcome of the AAR. The IP

contains information on how OROs will correct 

or improve ARCAs, Deficiencies, Plan Issues,

and Areas for Improvement, who is responsible,

and an anticipated timeline for correction/

improvement. As FEMA documents each

ARCA, Deficiency, Plan Issue, and/or Area for

Improvement within the AAR, OROs make a

corresponding entry in the IP. The content of the

IP will be negotiated during the AAC, so it is

not necessary for all information to be filled in

when the Draft AAR/IP goes out for comment.

f. Conducting the After Action

Conference

The FEMA RAC Chair (or designee) holds an 

AAC to present, discuss, and refine the draft 

AAR and to develop an IP. The FEMA RAC 

Chair (or designee) should hold the AAC as 

soon as practical after the exercise so that 

participants can easily recall the events. The 

AAC may take place in person or via 

videoconferencing. The Regions provide the 

draft AAR/IP to the state within 30 days of the 

exercise. Generally, the AAC occurs two weeks 
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-26 October 2011

after the Region provides the draft AAR/IP, 

which gives the OROs time to review it.

g. Issue Correction

The guidelines for correcting Deficiencies,

ARCAs, and Plan Issues are listed below.

(1) Correction of Deficiencies

Because of the potential impact of Deficiencies

on public health and safety, Appendix 1 to 44

CFR 350 requires corrections within 120 days of

the exercise. An ORO demonstrates correction

of Deficiencies identified in an exercise through

remedial actions, including exercises, drills, or 

other actions, including plan/procedure 

revisions. For actions conducted to correct a

Deficiency, the RAC Chair will prepare a

separate AAR of the remedial exercise, drill, or

other action within 30 days of the remedial

action. If the ORO successfully completes the 

remedial action within 75 days of the biennial

exercise, FEMA includes the results and

findings of the remedial exercise in the final

AAR for the biennial exercise.

If a remedial exercise or other remedial actions

occur, but the ORO does not correct the 

Deficiency, FEMA initiates the following

process immediately:

(a) Consult and coordinate with all pertinent

parties, including the state(s), the NRC,

and RAC member agencies, to discuss

resolution of the Deficiency and reach

agreement on the specific corrective

actions that need to occur and the

timetable for completing those

corrective actions.

(b) Delineate the specific corrective actions 

(e.g., further remedial exercises, 

plan/procedure revisions, training) that 

need to occur and the timetable for 

accomplishing those actions.

(c) Provide the agreed-upon schedule of

corrective actions and timeline to the 

NRC, state(s), and licensee.

(d) Enter and track corrective actions using

the DHS Corrective Action Program

System.

This entire process is completed within 10

calendar days of the remedial exercise in which

the ORO did not resolve Deficiency.

If a Deficiency remains unresolved at the end of

the 120-day period following the biennial

exercise, FEMA will issue an AAR that clearly:

(a) describes the effort expended and specific

actions taken to resolve the Deficiency during

the initial 120-day period; (b) delineates the

specific corrective actions that need to occur to

resolve the Deficiency and timeline for

completing those actions; and (c) establishes and

implements a system for monitoring and

documenting, on a bi-weekly basis, OROs‘

continuing efforts and progress in resolving the

Deficiency.

If these efforts fail to achieve the satisfactory

resolution of the Deficiency, and all possible

paths toward its resolution have been exhausted,

the FEMA Region will issue an AAR, along

with a finding that FEMA cannot provide

reasonable assurance that public health and

safety can be protected. Specifically, this report

will clearly: (a) describe the effort expended and

specific actions taken to resolve the Deficiency;

and (b) identify the factors or obstacles that have

led to the conclusion that all possible paths for

resolving the Deficiency have been exhausted.

Prior to issuance of any such report, the FEMA 

Regions must coordinate with the REP Branch

Chief and Technical Hazards Division Director,

NPD, at FEMA Headquarters. If FEMA has

approved offsite planning and preparedness for

the subject site under 44 CFR Part 350, FEMA

will initiate steps to withdraw the 350 approval

under 44 CFR § 350.1.

(2) Correction of ARCAs

The ORO completes correction of ARCAs as

soon as practicable and FEMA verifies the 

correction before or during the next biennial

exercise at that site. For states with multiple sites

within their boundaries, the state may, at the

discretion of the RAC Chair, demonstrate the 

correction of non-site-specific ARCAs during an

exercise at another site within the state or where

the 10-mile EPZ impacts the state.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-27 October 2011

(3) Correction of Plan Issues

If, during the exercise, FEMA identified some

section of the plans/procedures as inadequate, it 

will report a Plan Issue to the state for

correction, regardless of the adequacy of the 

ORO‘s performance.

FEMA includes Plan Issues in the AAR/IP and

may also provide them to the state(s) for

correction via letter from the RAC Chair no later

than 90 days after the exercise. The ORO 

corrects Plan Issues through revision of the

appropriate plans/procedures within one year or

during the next annual plan review and update. 

The state submits corrections for FEMA review,

and reports them in the ALC.

7. REP PROGRAM CREDIT FOR

PARTICIPATION IN ACTUAL

INCIDENTS

As part of the HSEEP process, FEMA supports

OROs seeking to combine multiple requirements

into fewer total exercises. FEMA will consider

granting REP Program exercise credit to OROs

for their participation in a response to a realworld incident. The Credit column in Exhibit

III-2: Federal Evaluation Process Matrix

indicates which functions and activities FEMA 

may consider for exercise credit.

When requesting exercise credit for a response

to an actual incident, OROs need to ensure that

the actual response included, at a minimum, the

following four elements:

 A prompt and timely mobilization of key

ORO staff and providers responsible for

REP emergency functions;

 An actual reporting of the key REP staff

who, in accordance with the

plans/procedures, would report to the

facility in a REP incident;

 Activation of the facility(ies) of the

responding jurisdiction(s); and

 Establishment of communication links

among responding organizations

At a minimum, the ORO then provides the

following documentation to FEMA:

 Type and nature of the incident;

 Timeline, including time of response and

time the ORO REP staff arrived at the

facility;

 Any applicable incident documentation

including sign in/sign out sheets with

name(s), function(s), date(s), and time(s);

 List of applicable REP personnel and

organizations as well as their connection to

a REP response;

 Communications log(s) showing the

establishment of communication links with

other organizations;

 List of participating jurisdictions;

 Incident decisions made and implemented;

 Resources (facilities, equipment, etc.) used; 

and

 List of corrective actions and/or 

improvement planning items identified in 

the AAR.

Additional documentation includes sufficient

information to support the performance of

specific Demonstration Criteria. For example, an

ORO seeking credit for field monitoring

activities includes field logs, calibration records,

air sampling results, etc.

An ORO submits a request for credit to the

appropriate state. If approved, the state forwards

the request to the appropriate FEMA RAC

Chair. The request specifies the basis for the

credit and the REP Demonstration Criterion for

which credit is requested. The request also

contains the appropriate documentation, as

specified above. The state provides this 

information to the appropriate FEMA RAC 

Chair within 90 days following the conclusion of 

the incident.

FEMA may consider granting credit for REP 

exercises when an ORO responds to an actual 

incident that compels demonstration of REPspecific criteria or capabilities.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-28 October 2011

The RAC Chair adjudicates the ORO‘s request

for credit and transmits it with his or her review

and recommendations to the REP Branch Chief,

FEMA Headquarters. The REP Branch Chief

makes the final determination on the request

within 30 days of receipt. If credit is granted, the

RAC Chair will then issue the ORO an

exemption from FEMA evaluation of the

Demonstration Criterion for the next REP

exercise.

FEMA will grant exemption from evaluation of

a specific Demonstration Criterion only once

during the exercise cycle for the applicable REP

exercise. Even when FEMA grants credit, the

ORO may still have to perform the function at

the biennial exercise in order to avoid

compromising the integrity of the exercise. This

performance is at the discretion and

consideration of the RAC Chair and will be

determined in the Extent-of-Play Agreement

negotiations.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-29 October 2011

C. EXERCISE DEMONSTRATION

Planning Standard N of NUREG-0654/FEMAREP-1 states that ―Periodic exercises are (will

be) conducted to evaluate major portions of

emergency response capabilities...and

deficiencies identified as a result of exercises...

are (will be) corrected.‖ Evaluation Criterion

N.1.a defines an exercise as ―an event that tests

the integrated capability and a major portion of

the basic elements existing within emergency

preparedness plans and organizations.‖ The

Planning Standard N Evaluation Criteria

presume that exercises will be conducted as set

forth in NRC and FEMA rules and exercise

evaluation guidance.

FEMA’s preparedness assessment philosophy 

focuses more on accomplishing the mission 

than on the steps taken to achieve a result. 

FEMA‘s Assessment Area methodology, along 

with the incorporation of HSEEP methodology, 

minimizes exercise issue inconsistencies among 

its Regions and makes the evaluations less 

dependent upon prescriptive criteria. FEMA‘s 

focus during REP exercises and drills is to test 

the capability of OROs to protect public health 

and safety. 

Each of the Assessment Areas contains specific 

Sub-elements and Demonstration Criteria. 

Together, the FEMA Regions use these to 

develop Exercise Evaluation Guides that assist 

the evaluator in focusing on observing and 

recording exercise and drill events as they occur. 

FEMA will continue to review the Assessment 

Areas to allow for changes to the methodology 

dictated by changing times, methods, and

environments.

The FEMA Regional Office is responsible for

assigning the various Demonstration Criteria to

each facility and/or functional entity that it will

evaluate. Each FEMA Region must also track 

when evaluations of these facilities and/or 

functions occur, which Demonstration Criteria 

FEMA evaluated, and the status of that 

demonstration. Exhibit III-2 establishes the 

minimum frequency with which FEMA must 

evaluate each of the Demonstration Criteria. 

FEMA encourages OROs to voluntarily exercise 

certain criteria more frequently than the 

minimum frequencies for evaluation shown in 

the matrix.

The Assessment Areas with each Sub-element

and associated Demonstration Criteria are as 

follows:

1. Emergency Operations Management

 Sub-element 1.a – Mobilization

 Criterion 1.a.1

 Sub-element 1.b – Facilities

 Criterion 1.b.1

 Sub-element 1.c – Direction and Control

 Criterion 1.c.1

 Sub-element 1.d – Communications

Equipment

 Criterion 1.d.1

 Sub-element 1.e – Equipment and Supplies

to Support Operations

 Criterion 1.e.1

2. Protective Action Decision-Making

 Sub-element 2.a – Emergency Worker

Exposure Control

 Criterion 2.a.1

Demonstrating Reasonable Assurance

The Assessment Areas, derived from the 

NUREG-0654/FEMA-REP-1 Planning Standards 

and Evaluation Criteria, reflect current FEMA

policy and guidance on the activities that OROs 

are expected to be able to perform to maintain 

reasonable assurance that the health and safety 

of the public can be protected in the event of an 

incident at an NPP.

REP/HSEEP Evaluation

The Assessment Areas, Sub-elements, and 

Demonstration Criteria can be aligned to HSEEP 

Target Capabilities, Activities, and Critical Tasks. 
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-30 October 2011

 Sub-element 2.b – Dose Assessment, PARs

and PADs for the Emergency Event

 Criterion 2.b.1

 Criterion 2.b.2

 Sub-element 2.c – PADs Consideration for

the Protection of Persons with Disabilities 

and Access/Functional Needs

 Criterion 2.c.1

 Sub-element 2.d – Radiological Assessment

and Decision-Making for the Ingestion

Exposure Pathway

 Criterion 2.d.1

 Sub-element 2.e – Radiological Assessment

and Decision-Making Concerning PostPlume Phase Relocation, Reentry, and

Return

 Criterion 2.e.1

3. Protective Action Implementation

 Sub-element 3.a – Implementation of

emergency worker Exposure Control

 Criterion 3.a.1

 Sub-element 3.b –Implementation of KI

Decision for Institutionalized Individuals

and the Public

 Criterion 3.b.1

 Sub-element 3.c – Implementation of

Protective Actions for Persons with 

Disabilities and Access/Functional Needs

 Criterion 3.c.1

 Criterion 3.c.2

 Sub-element 3.d – Implementation of Traffic

and Access Control

 Criterion 3.d.1

 Criterion 3.d.2

 Sub-element 3.e – Implementation of

Ingestion Pathway Decisions

 Criterion 3.e.1

 Criterion 3.e.2

 Sub-element 3.f – Implementation of PostPlume Phase Relocation, Reentry,

and Return Decisions

 Criterion 3.f.1

4. Field Measurements and Analyses

 Sub-element 4.a – Plume Phase Field

Measurements and Analyses

 Criterion 4.a.1

 Criterion 4.a.2

 Criterion 4.a.3

 Sub-element 4.b – Post-Plume Phase Field

Measurements and Sampling

 Criterion 4.b.1

 Sub-element 4.c – Laboratory Operations

 Criterion 4.c.1

5. Emergency Notification and Public

Information

 Sub-element 5.a – Activation of the Prompt

Alert and Notification System

 Criterion 5.a.1

 Criterion 5.a.2

 Criterion 5.a.3

 Criterion 5.a.4

 Sub-element 5.b – Emergency Information

and Instructions for the Public and Media

 Criterion 5.b.1

6. Support Operations/Facilities

 Sub-element 6.a – Monitoring,

Decontamination, and Registration of

Evacuees

 Criterion 6.a.1

 Sub-element 6.b – Monitoring and

Decontamination of Emergency Workers

and their Equipment and Vehicles

 Criterion 6.b.1

 Sub-element 6.c – Temporary Care of

Evacuees

 Criterion 6.c.1

 Sub-element 6.d – Transportation and

Treatment of Contaminated Injured

Individuals

 Criterion 6.d.1
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-31 October 2011

ASSESSMENT AREA 1: EMERGENCY OPERATIONS MANAGEMENT

Sub-element 1.a – Mobilization

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to alert, notify, and mobilize emergency personnel, and activate and staff emergency facilities.

Criterion 1.a.1: OROs use effective procedures to alert, notify, and mobilize emergency

personnel and activate facilities in a timely manner. (NUREG-0654/

FEMA-REP-1, A.1.a, e; A.3, 4; C.1,4, 6; D.4; E.1, 2; H.3, 4)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, an actual event, or by means of drills conducted at any time. 

Responsible OROs must demonstrate the capability to receive notification of an incident from the

licensee; verify the notification; and contact, alert, and mobilize key emergency personnel in a timely

manner and demonstrate the ability to maintain and staff 24-hour operations. Twenty-four-hour

operations can be demonstrated during the exercise via rosters or shift changes or otherwise in an actual

activation. Local responders must demonstrate the ability to receive and/or initiate notification to the

licensees or other respective emergency management organizations of an incident in a timely manner,

when they receive information from the licensee or alternate sources. Responsible OROs must

demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival.

Activation of facilities and staff, including those associated with the Incident Command System, must be

completed in accordance with ORO plans/procedures. The location and contact information for facilities

included in the incident command must be available to all appropriate responding agencies and the NPP

after these facilities have been activated.

The REP program does not evaluate Incident Command System tactical operations, only coordination

among the incident command, the utility, and all appropriate OROs, pursuant to plans/procedures.

Pre-positioning of emergency personnel is appropriate, in accordance with the Extent-of-Play Agreement,

at those facilities located beyond a normal commuting distance from the individual‘s duty location or

residence. This includes the staggered release of resources from an assembly area. Additionally, prepositioning of staff for out-of-sequence demonstrations may be used in accordance with the Extent-ofPlay Agreement.

Initial law enforcement, fire service, HAZMAT, and emergency medical response to the NPP site may

impact the ability to staff REP functions. The ability to identify and request additional resources or

identify compensatory measures must be demonstrated. Exercises must also address the role of mutual aid

in the incident, as appropriate. An integral part of the response to an HAB scenario at an NPP may also be

within the auspices of the Federal Government (e.g., FBI, NRC, or DHS). Protocols for requesting

Federal, state, local, and tribal law enforcement support must be demonstrated, as appropriate. Any

resources identified through LOA/MOUs must be on the ORO‘s mobilization list so they can be contacted

during an incident, if needed.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-32 October 2011

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 1.b – Facilities

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have facilities

to support the emergency response.

Criterion 1.b.1: Facilities are sufficient to support the emergency response.

(NUREG-0654/FEMA-REP-1, H.3; G.3.a; J.10.h; J.12; K.5.b)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, an actual event, or by out-of-sequence evaluations.

Responsible OROs must demonstrate, at least once in a baseline evaluation, the availability of fixed

facilities that support accomplishment of emergency operations. Baseline evaluations are performed for

EOCs and JICs, as well as other fixed facilities such as reception/relocation centers. Some of the areas

evaluated within the facilities are adequate space, furnishings, lighting, restrooms, ventilation, backup

power, and/or alternate facility, if required to support operations.

After a baseline evaluation has been established, facilities will only be evaluated for this criterion if they

are new or have substantial changes in structure, equipment, or mission that affect key capabilities, as

outlined in respective emergency plans/procedures. A substantial change is one that has a direct effect or

impact on emergency response operations performed in those facilities. Examples of substantial changes

include: modifying the size or configuration of an emergency operations center, adding more function to a

center, or changing the equipment available for use in a center.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 1.c – Direction and Control

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to control their overall response to an emergency.

Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control

to that part of the overall response effort for which they are responsible. (NUREG-0654/FEMAREP-1, A.1.d; A.2.a, b; A.3; C.4, 6)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished in a full scale, functional, or tabletop 

exercise. 

Leadership personnel must demonstrate the ability to carry out the essential management functions of the

response effort (e.g., keeping staff informed through periodic briefings and/or other means, coordinating

with other OROs, and ensuring completion of requirements and requests.) Leadership must demonstrate
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-33 October 2011

the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other

agreements) when faced with competing demands for finite resources. Any resources identified through

LOA/MOUs must be on the ORO‘s mobilization list so they may be contacted during an incident, if

needed.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 1.d – Communications Equipment

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs establish and

operate reliable primary and backup communication systems to ensure communications with key

emergency personnel at locations such as contiguous governments within the EPZ, Federal emergency

response organizations, the licensee and its facilities, EOCs, Incident Command Posts, and FMTs.

Criterion 1.d.1: At least two communication systems are available, at least one operates

properly, and communication links are established and maintained with appropriate

locations. Communications capabilities are managed in support of emergency operations.

(NUREG-0654/FEMA-REP-1, F.1, 2)

Assessment/Extent of Play

Assessment of this Demonstration Criterion is accomplished initially in a baseline evaluation and 

subsequently in periodic testing and drills. System familiarity and use must be demonstrated as applicable 

in full scale, functional and tabletop exercises, or if their use would be required, during an actual event. 

OROs must demonstrate that a primary system, and at least one backup system for fixed facilities, is fully

functional at all times. Communications systems are maintained and tested on a recurring basis

throughout the assessment period and system status is available to all operators. Periodic test results and

corrective actions are maintained on a real time basis. If a communications system or systems are not

functional, but exercise performance is not affected, no exercise issue will be assessed.

Communications equipment and procedures for facilities and field units are used as needed for

transmission and receipt of exercise messages. All facilities, FMTs, and incident command must have the

capability to access at least one communication system that is independent of the commercial telephone

system. Responsible OROs must demonstrate the capability to manage the communication systems and

ensure that all message traffic is handled without delays that might disrupt emergency operations. OROs

must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

Exercise scenarios may require the failure of a communication system and use of an alternate system, as

negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 1.e – Equipment and Supplies to Support Operations

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have

emergency equipment and supplies adequate to support the emergency response.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-34 October 2011

Criterion 1.e.1: Equipment, maps, displays, monitoring instruments, dosimetry, potassium

iodide (KI) and other supplies are sufficient to support emergency operations (NUREG0654/FEMA-REP-1, H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b)

Assessment/Extent of Play

Assessment of this Demonstration Criterion is accomplished primarily through a baseline evaluation and 

subsequent periodic inspections. 

A particular facility‘s equipment and supplies must be sufficient and consistent with that facility‘s

assigned role in the ORO‘s emergency operations plans. Use of maps and other displays is encouraged.

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the

assigned operational role. At locations where traffic and access control personnel are deployed,

appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available, or their

availability described.

Specific equipment and supplies that must be demonstrated under this criterion include KI inventories,

dosimetry, and monitoring equipment, as follows:

KI: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use

by: (1) emergency workers; (2) institutionalized individuals, as indicated in capacity lists for facilities;

and (3) where stipulated by the plans/procedures, members of the general public (including transients)

within the plume pathway EPZ. In addition, OROs must demonstrate provisions to make KI available to

specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search

and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures). The

plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI,

as well as a mechanism for identifying emergency workers that have declined KI in advance. Consider

carefully the placement of emergency workers that have declined KI in advance.

ORO quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical

inspection at the storage location(s) or through documentation of current inventory submitted during the

exercise, provided in the ALC submission, and/or verified during an SAV. Available supplies of KI must

be within the expiration date indicated on KI bottles or blister packs. As an alternative, the ORO may

produce a letter from a certified private or state laboratory indicating that the KI supply remains potent, in

accordance with U.S. Pharmacopoeia standards.97

Dosimetry: Sufficient quantities of appropriate direct-reading and permanent record dosimetry and

dosimeter chargers must be available for issuance to all emergency workers who will be dispatched to

perform an ORO mission. In addition, OROs must demonstrate provisions to make dosimetry available to

specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search

and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures).

Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting

limits and maximum exposure limits contained in the ORO‘s plans/procedures.

Direct-reading dosimeters must be zeroed or operationally checked prior to issuance. The dosimeters must

be inspected for electrical leakage at least annually and replaced when necessary. Civil Defense Victoreen

Model 138s (CD V-138s) (0-200 mR), due to their documented history of electrical leakage problems,

must be inspected for electrical leakage at least quarterly and replaced when necessary. This leakage

testing will be verified during the exercise, through documentation submitted in the ALC and/or through

an SAV.

 

97 See part IV, REP Program Administration: Potassium Iodide (KI) for the Public – Requirements.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-35 October 2011

Operational checks and testing of electronic dosimeters must be in accordance with the manufacturer‘s

instructions and be verified during the exercise, through documentation submitted in the ALC and/or

through an SAV.

Monitoring Instruments: All instruments must be inspected, inventoried, and operationally checked

before each use. Instruments must be calibrated in accordance with the manufacturer‘s recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturer‘s

recommendation must be calibrated annually. Modified CDV-700 instruments must be calibrated in

accordance with the recommendation of the modification manufacturer. A label indicating such

calibration must be on each instrument or calibrated frequency can be verified by other means. In

addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating

the effective range of the readings. The range of readings documentation specifies the acceptable range of

readings that the meter should indicate when it is response-checked using a standard test source.

For FMTs, the instruments must be capable of measuring gamma exposure rates and detecting beta

radiation. These instruments must be capable of measuring a range of activity and exposure, including

radiological protection/exposure control of team members and detection of activity on air sample

collection media, consistent with the intended use of the instrument and the ORO‘s plans/procedures. An

appropriate radioactive check source must be used to verify proper operational response for each lowrange radiation measurement instrument (less than 1R/hr) and for high-range instruments when available.

If a source is not available for a high-range instrument, a procedure must exist to operationally test the

instrument before entering an area where only a high-range instrument can make useful readings.

In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s).

The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a

Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the

manufacturer‘s recommendations.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-36 October 2011

ASSESSMENT AREA 2: PROTECTIVE ACTION DECISION-MAKING

Sub-element 2.a – Emergency Worker Exposure Control

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to assess and control the radiation exposure received by emergency workers and have a

decision chain in place, as specified in the ORO‘s plans/procedures, to authorize emergency worker

exposure limits to be exceeded for specific missions.

Radiation exposure limits for emergency workers are the recommended accumulated dose limits or

exposure rates that emergency workers may be permitted to incur during an emergency. These limits

include any pre-established administrative reporting limits (that take into consideration TEDE or organspecific limits) identified in the ORO‘s plans/procedures.

Criterion 2.a.1: OROs use a decision-making process, considering relevant factors and

appropriate coordination, to ensure that an exposure control system, including the use of KI,

is in place for emergency workers, including provisions to authorize radiation exposure in

excess of administrative limits or protective action guides. (NUREG-0654/FEMA-REP-1, C.6;

J.10. e, f; K.4)

Assessment/Extent of Play

Assessment of this Demonstration Criterion must be assessed concurrently with a licensee exercise and 

may be demonstrated in a full scale, functional or tabletop exercise.

OROs authorized to send emergency workers into the plume exposure pathway EPZ must demonstrate a

capability to comply with emergency worker exposure limits based on their emergency plans/procedures.

Participating OROs must also demonstrate the capability to make decisions concerning authorization of

exposure levels in excess of pre-authorized levels and the number of emergency workers receiving

radiation doses above pre-authorized levels. This would include providing KI and dosimetry in a timely

manner to emergency workers dispatched onsite to support plant incident assessment and mitigating

actions, in accordance with respective plans/procedures.

As appropriate, OROs must demonstrate the capability to make decisions on the distribution and

administration of KI as a protective measure for emergency workers, based on their plans/procedures or

projected thyroid dose compared with the established PAGs for KI administration.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 2.b. – Radiological Assessment and Protective Action Recommendations

and Decisions for the Plume Phase of the Emergency

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to independently project integrated dose from projected or actual dose rates and compare these

estimates to the PAGs.
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REP Program Manual Page III-37 October 2011

OROs must have the capability to choose, among a range of protective actions, those most appropriate in

a given emergency. OROs base these choices on PAGs from their plans/procedures or EPA‘s Manual of 

Protective Action Guides and Protective Actions for Nuclear Incidents and other criteria, such as plant

conditions, licensee PARs, coordination of PADs with other political jurisdictions (e.g., other affected

OROs and incident command), availability of in-place shelter, weather conditions, and situations, to

include HAB incidents, the threat posed by the specific hostile action, the affiliated response, and the

effect of an evacuation on the threat response effort, that create higher than normal risk from general

population evacuation.

Criterion 2.b.1: Appropriate protective action recommendations (PARs) are based on

available information on plant conditions, field monitoring data, and licensee and ORO dose

projections, as well as knowledge of onsite and offsite environmental conditions.

(NUREG-0654/FEMA-REP-1, I.10 and Supplement 3)

Assessment/Extent of Play

Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise 

and may be demonstrated in a full-scale, functional or tabletop exercise.

During the initial stage of the emergency response, following notification of plant conditions that may

warrant offsite protective actions, the ORO must demonstrate the capability to use appropriate means,

described in the plans/procedures, to develop PARs for decision-makers based on available information

and recommendations provided by the licensee as well as field monitoring data, if available. The ORO

must also consider any release and meteorological data provided by the licensee.

The ORO must demonstrate a reliable capability to independently validate dose projections. The types of

calculations to be demonstrated depend on the data available and the need for assessments to support the

PARs must be appropriate to the scenario. In all cases, calculation of projected dose must be

demonstrated. Projected doses must be related to quantities and units of the PAG to which they will be

compared. PARs must be promptly transmitted to decision-makers in a pre-arranged format.

When the licensee and ORO projected doses differ by more than a factor of 10, the ORO and licensee

must determine the source of the difference by discussing input data and assumptions, using different

models, or exploring possible reasons. Resolution of these differences must be incorporated into the

PARs if timely and appropriate. The ORO must demonstrate the capability to use any additional data to

refine projected doses and exposure rates and revise the associated PARs.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and

necessary coordination is used to make protective action decisions (PADs) for the general

public (including the recommendation for the use of KI, if ORO policy). (NUREG-0654/FEMAREP-1,A.3; C.4, 6; D.4; J.9; J.10.f, m)

Assessment/Extent of Play

Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise 

and may be demonstrated in a full-scale, functional or tabletop exercise.

OROs must have the capability to make both initial and subsequent PADs. OROs must demonstrate the

capability to make initial PADs in a timely manner appropriate to the incident, based on information from

the licensee, assessment of plant status and potential or actual releases, other available information related
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to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the

utility and ORO staff. In addition, a subsequent or alternate PAD may be appropriate if various conditions

(e.g., an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation, or if

evacuation may disrupt the efforts to respond to a hostile action.

OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to

implement a PAD if local law enforcement, fire service, HAZMAT, and emergency medical resources are

utilized to augment response to the NPP site or other key infrastructure.

Dose assessment personnel may provide additional PARs based on the subsequent dose projections, field

monitoring data, or information on plant conditions. In addition, incident command must provide input

regarding considerations for subsequent PARs based on the magnitude of the ongoing threat, the

response, and/or site conditions. The decision-makers must demonstrate the capability to change

protective actions based on the combination of all these factors.

If the ORO has determined that KI will be used as a protective measure for the general public under

offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and

administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO‘s

plans/procedures or projected thyroid dose compared with the established PAG for KI administration. The

KI decision-making process must involve close coordination with appropriate assessment and decisionmaking staff.

If more than one ORO is involved in decision making, all appropriate OROs must communicate and

coordinate PADs with each other. In addition, decisions must be coordinated/communicated with incident

command. OROs must demonstrate the capability to communicate the results of decisions to all the

affected locations.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 2.c – PAD Consideration for the Protection of Persons with Disabilities and 

Access/Functional Needs

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to determine PADs, including evacuation, sheltering, and use of KI, if applicable, for groups of 

persons with disabilities and access/functional needs (e.g., hospitals, nursing homes, correctional

facilities, schools, licensed daycare centers, mobility-impaired individuals, and transportation-dependent

individuals). The focus is on those groups of persons with disabilities and access/functional needs that

are, or potentially will be, affected by a radiological release from an NPP.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for groups of persons 

with disabilities and access/functional needs. (NUREG-0654/FEMA-REP-1,D.4; J.9; J.10.d, e)

Assessment/Extent of Play

Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise 

and may be demonstrated in a full-scale, functional or tabletop exercise that would include the use of 

plant conditions transmitted from the licensee. 
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Usually it is appropriate to implement evacuation in areas where doses are projected to exceed the lower

end of the range of PAGs, except for incidents where there is a high-risk environmental condition or

where high-risk groups (e.g., the immobile or infirm) are involved. In these cases, factors that must be

considered include weather conditions, shelter availability, availability of transportation assets, risk of

evacuation versus risk from the avoided dose, and precautionary school evacuations. In addition,

decisions must be coordinated/communicated with the incident command. In situations where an

institutionalized population cannot be evacuated, the ORO must consider use of KI.

Applicable OROs must demonstrate the capability to alert and notify all public school systems/districts of

emergency conditions that are expected to or may necessitate protective actions for students.

Demonstration requires that the OROs actually contact public school systems/districts during the exercise.

In accordance with plans/procedures, OROs and/or officials of public school systems/districts must

demonstrate the capability to make prompt decisions on protective actions for students. The decisionmaking process, including any preplanned strategies for protective actions for that ECL, must consider the

location of students at the time (e.g., whether the students are still at home, en route to school, or at

school).

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 2.d. – Radiological Assessment and Decision Making for the Ingestion

Exposure Pathway

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

means to assess the radiological consequences for the ingestion exposure pathway, relate them to the

appropriate PAGs, and make timely, appropriate PADs to mitigate exposure from the pathway.

During an incident at an NPP, a release of radioactive material may contaminate water supplies and

agricultural products in the surrounding areas. Any such contamination would likely occur during the

plume phase of the incident and, depending on the nature of the release, could impact the ingestion

pathway for weeks or years.

Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and

appropriate protective action decisions are made based on the ORO’s planning criteria.

(NUREG-0654/FEMA-REP-1, A.3; C.1, 4; D.4; J.9,11)

Assessment/Extent of Play

Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise 

and may be demonstrated in a full-scale, functional or tabletop exercise that would include the use of 

plant conditions transmitted from the licensee. 

OROs are expected to take precautionary actions to protect food and water supplies, or to minimize

exposure to potentially contaminated water and food, in accordance with their respective

plans/procedures. Often OROs initiate such actions based on criteria related to the facility‘s ECLs. Such

actions may include recommendations to place milk animals on stored feed and use protected water

supplies.
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The ORO must use its procedures to assess the radiological consequences of a release on the food and

water supplies, such as the development of a sampling plan. The ORO‘s assessment must include

evaluation of the radiological analyses of representative samples of water, food, and other ingestible

substances of local interest from potentially impacted areas; characterization of the releases from the

facility; and the extent of areas potentially impacted by the release. During this assessment, OROs must

consider use of agricultural and watershed data within the 50-mile EPZ. The radiological impacts on the

food and water must then be compared to the appropriate ingestion PAGs contained in the ORO‘s

plans/procedures. The plans/procedures contain PAGs based on specific dose commitment criteria or on

criteria as recommended by current Food and Drug Administration (FDA) guidance. Timely and

appropriate recommendations must be provided to the ORO decision-makers group for implementation

decisions. OROs may also include a comparison of taking or not taking a given action on the resultant

ingestion pathway dose commitments.

The ORO must demonstrate timely decisions to minimize radiological impacts from the ingestion

pathway, based on the given assessments and other information. Any such decisions must be

communicated and, to the extent practical, coordinated with neighboring OROs.

OROs must use Federal resources, as identified in the Nuclear/Radiological Incident Annex of the NRF

and other resources (e.g., compacts or nuclear insurers). Evaluation of this criterion will take into

consideration the level of Federal and other participating resources.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 2.e. – Radiological Assessment and Decision Making Concerning PostPlume Phase Relocation, Reentry, and Return

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to make decisions on post-plume phase relocation, reentry, and return of the general public.

These decisions are essential for protection of the public from direct long-term exposure to deposited

radioactive materials from a severe incident at an NPP.

Criterion 2.e.1: Timely post-plume phase relocation, reentry, and return decisions are made

and coordinated as appropriate, based on assessments of the radiological conditions and

criteria in the ORO’s plan and/or procedures. (NUREG-0654/FEMA-REP-1, I.10; J.9; K.3.a; M.1)

Assessment/Extent of Play

Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise 

and may be demonstrated in a full-scale, functional or tabletop exercise that would include the use of 

plant conditions transmitted from the licensee.

Relocation: OROs must demonstrate the capability to estimate integrated dose in contaminated areas and

compare these estimates with PAGs; apply decision criteria for relocation of those individuals in the

general public who have not been evacuated, but where actual or projected doses are in excess of

relocation PAGs; and control access to evacuated and restricted areas. OROs will make decisions for

relocating members of the evacuated public who lived in areas that now have residual radiation levels in

excess of the PAGs. Determination of areas to be restricted must be based on factors such as the mix of

radionuclides in deposited materials, calculated exposure rates versus the PAGs, and analyses of

vegetation and soil field samples.
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Reentry: Decisions must be made on location of control points and policies regarding access and

exposure control for emergency workers and members of the general public who need to temporarily

enter the evacuated area to perform specific tasks or missions.

Examples of control procedures are the assignment of, or checking for, direct-reading and permanent

record dosimetry for emergency workers; questions regarding an individual‘s objectives, locations

expected to be visited, and associated timeframes; availability of maps and plots of radiation exposure

rates; and advice on areas to avoid. Control procedures also include monitoring of individuals, vehicles,

and equipment; the implementation of decision criteria regarding decontamination; and proper disposition

of emergency worker dosimetry and maintenance of emergency worker radiation exposure records.

Responsible OROs must demonstrate the capability to develop a strategy for authorized reentry of

individuals into the restricted zone(s), based on established decision criteria. OROs must demonstrate the

capability to modify those policies for security purposes (e.g., police patrols), maintenance of essential

services (e.g., fire protection and utilities), and other critical functions. They must demonstrate the

capability to use decision-making criteria in allowing access to the restricted zone by the public for

various reasons, such as to maintain property (e.g., to care for farm animals or secure machinery for

storage) or retrieve important possessions. Coordinated policies for access and exposure control must be

developed among all agencies with roles to perform in the restricted zone(s). OROs must demonstrate the

capability to establish policies for provision of dosimetry to all individuals allowed to reenter the

restricted zone(s). The extent to which OROs need to develop policies on reentry will be determined by

scenario events.

Return: OROs must demonstrate the capability to implement policies concerning return of members of

the public to areas that were evacuated during the plume phase (i.e., permitting populations that were

previously evacuated to reoccupy their homes and businesses on an unrestricted basis). OROs must base

decisions on environmental data and political boundaries or physical/ geological features, which allow

identification of the boundaries of areas to which members of the general public may return. Return is

permitted to the boundary of the restricted area(s) that is based on the relocation PAG.

Other factors that the ORO must consider in decision-making include conditions that permit cancellation

of the ECL and relaxation of associated restrictive measures. OROs must base return recommendations on

measurements of radiation from ground deposition. OROs must have the capability to identify services

and facilities that require restoration within a few days and to identify the procedures and resources for

their restoration. Examples of these services and facilities are medical and social services, utilities, roads,

schools, and intermediate-term housing for relocated persons.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
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ASSESSMENT AREA 3: PROTECTIVE ACTION IMPLEMENTATION

Sub-element 3.a – Implementation of Emergency Worker Exposure Control

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to provide for the following: distribution, use, collection, and processing of direct-reading

dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at

appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing a

decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of

the PAGs, and the capability to provide KI for emergency workers, always applying the ―as low as is

reasonably achievable‖ principle as appropriate.

Criterion 3.a.1: The OROs issue appropriate dosimetry,KI, and procedures, and manage

radiological exposure to emergency workers in accordance with the plans/procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and

record the readings on the appropriate exposure record or chart. OROs maintain appropriate

record-keeping of the administration of KI to emergency workers. (NUREG-0654/FEMA-REP-1,

J.10.e; K.3.a, b; K.4)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional or 

tabletop exercise. Other means may include drills, seminars or training activities that would fully 

demonstrate technical proficiency.

OROs must demonstrate the capability to provide emergency workers (including supplemental resources)

with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI, and

instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is

defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are preestablished at a level low enough to consider subsequent calculation of TEDE and maximum exposure

limits, for those emergency workers involved in lifesaving activities, contained in the ORO‘s

plans/procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the

ORO‘s plans/procedures. If supplemental resources are used, they must be provided with just-in-time

training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate

procedures to monitor and record dosimeter readings and manage radiological exposure control.

During a plume phase exercise, emergency workers must demonstrate the procedures to be followed

when administrative exposure limits and turn-back values are reached. The emergency worker must report

accumulated exposures during the exercise as indicated in the plans/procedures. OROs must demonstrate

the actions described in the plans/procedures by determining whether to replace the worker, authorize the

worker to incur additional exposures, or take other actions. If exercise play does not require emergency 

workers to seek authorizations for additional exposure, evaluators must interview at least two workers to

determine their knowledge of whom to contact in case authorization is needed, and at what exposure

levels. Workers may use any available resources (e.g., written procedures and/or coworkers) in providing

responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be

situations where team members will be in close proximity to each other during the entire mission. In such
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cases, adequate control of exposure can be achieved for all team members using one direct-reading

dosimeter worn by the team leader. Emergency workers assigned to low-exposure rate fixed facilities

(e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) may

have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., directreading dosimeters strategically placed in the work area). Each team member must still have his or her

own permanent record dosimetry. Individuals authorized by the ORO to reenter an evacuated area during

the plume (emergency) phase, must be limited to the lowest radiological exposure commensurate with

completing their missions.

OROs may have administrative limits lower than EPA-400-R-92-001 dose limits for emergency workers

performing various services (e.g., life saving, protection of valuable property, all activities). OROs must

ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the

capability to respond to an incident where life saving and/or protection of valuable property may require

an urgent response.

OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent

with decisions made. OROs must have the capability to develop and maintain lists of emergency workers

who have ingested KI, including documentation of the date(s) and time(s) they did so. Ingestion of KI

recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual

ingestion of KI shall not be performed. OROs must demonstrate the capability to formulate and

disseminate instructions on using KI for those advised to take it. Emergency workers must demonstrate

basic knowledge of procedures for using KI whether or not the scenario drives the implementation of KI

use. This can be accomplished by an interview with the evaluator.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 3.b – Implementation of KI Decision for Institutionalized Individuals and the

General Public

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to provide KI for institutionalized individuals, and, if in the plans/procedures, to the general

public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed. While

it is necessary for OROs to have the capability to provide KI to institutionalized individuals, providing KI

to the general public is an ORO option and must be reflected as such in ORO plans/procedures.

Provisions must include the availability of adequate quantities, storage, and means of distributing KI.

Criterion 3.b.1: KI and appropriate instructions are available if a decision to recommend use

of KI is made. Appropriate record-keeping of the administration of KI for institutionalized

individuals and the general public is maintained. (NUREG-0654/FEMA-REP-1, J.10.e, f)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional or 

tabletop exercise. Other means may include drills, seminars or training activities that would fully 

demonstrate technical proficiency.

OROs must demonstrate the capability to make KI available to institutionalized individuals, and, where

provided for in their plans/procedures, to members of the general public. OROs must demonstrate the

capability to accomplish distribution of KI consistent with decisions made. OROs must have the
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capability to develop and maintain lists of institutionalized individuals who have ingested KI, including

documentation of the date(s) and time(s) they were instructed to ingest KI. Ingestion of KI recommended

by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI

shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions

on using KI for those advised to take it.

If a recommendation is made for the general public to take KI, appropriate information must be provided

to the public by the means of notification specified in the ORO‘s plans/procedures.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 3.c – Implementation of Protective Actions for Persons with Disabilities and 

Access/Functional Needs

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to implement PADs, including evacuation and/or sheltering, for all persons with disabilities and 

access/functional needs. The focus is on those persons with disabilities and access/functional needs that

are (or potentially will be) affected by a radiological release from an NPP.

Criterion 3.c.1: Protective action decisions are implemented for persons with disabilities and 

access/functional needs other than schools within areas subject to protective actions.

(NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, an actual event, or by means of drills conducted at any time.

Applicable OROs must demonstrate the capability to alert and notify (i.e., provide PARs and emergency

information and instructions to) persons with disabilities and access/functional needs, including

hospitals/medical facilities, nursing homes, correctional facilities, and mobility-impaired and

transportation-dependent individuals. OROs must demonstrate the capability to provide for persons with 

disabilities and access/functional needs in accordance with plans/procedures.

Contact with persons with disabilities and access/functional needs and reception facilities may be actual

or simulated, as agreed to in the extent of play. Some contacts with transportation providers must be

actual, as negotiated in the extent of play. All actual and simulated contacts must be logged.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Criterion 3.c.2: OROs/School officials implement protective actions for schools.

(NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or 

tabletop exercise, an actual event, or by means of drills conducted at any time.
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Public school systems/districts must demonstrate the ability to implement PADs for students. The

demonstration must be made as follows: Each school system/district within the 10 mile EPZ must

demonstrate implementation of protective actions. At least one school per affected system/district must

participate in the demonstration. Canceling the school day, dismissing early, or sheltering in place must

be simulated by describing to evaluators the procedures that would be followed. If evacuation is the

implemented protective action, all activities to coordinate and complete the evacuation of students to

reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished

through an interview process.

If accomplished through an interview, appropriate school personnel including decision-making officials

(e.g., schools‘ superintendent/principals and transportation director/bus dispatchers), and at least one bus

driver (and the bus driver‘s escort, if applicable) must be available to demonstrate knowledge of their

role(s) in the evacuation of school children. Communications capabilities between school officials and the

buses, if required by the plans/procedures, must be verified.

Officials of the school system(s) must demonstrate the capability to develop and provide timely

information to OROs for use in messages to parents, the general public, and the media on the status of

protective actions for schools.

The provisions of this criterion also apply to any private schools, private kindergartens, and licensed

daycare centers that participate in REP exercises pursuant to the ORO‘s plans/procedures as negotiated in

the Extent-of-Play Agreement.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 3.d. – Implementation of Traffic and Access Control

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to implement protective action plans/procedures, including relocation and restriction of access

to evacuated/sheltered areas. This Sub-element focuses on selecting, establishing, and staffing of traffic

and access control points, and removal of impediments to the flow of evacuation traffic.

Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions

are provided to traffic and access control personnel. (NUREG-0654/FEMA-REP-1, A.3; C.1,4;

J.10.g, j)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, an actual event, or by means of drills conducted at any time.

OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control

points consistent with current conditions and PADs (e.g., evacuating, sheltering, and relocation) in a

timely manner. OROs must demonstrate the capability to provide instructions to traffic and access control

staff on actions to take when modifications in protective action strategies necessitate changes in

evacuation patterns or in the area(s) where access is controlled.
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Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities,

including verifying emergency worker identification and access authorization to the affected areas, as per

the Extent-of-Play Agreement. These capabilities may be demonstrated by actual deployment or by

interview, in accordance with the Extent-of-Play Agreement.

In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail,

water, and air traffic), they must demonstrate the capability to contact the state or Federal agencies that

have the needed authority, as agreed upon in the Extent-of-Play Agreement.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654/FEMAREP-1, J.10.k)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, an actual event, or by means of drills conducted at any time.

OROs must demonstrate the capability, as required by the scenario, to identify and take appropriate

actions concerning impediments to evacuation. Actual dispatch of resources to deal with impediments,

such as wreckers, need not be demonstrated; however, all contacts, actual or simulated, must be logged.

The impediment must occur during the evacuation and be on an evacuation route such that re-routing of

traffic is required, triggering decision-making and coordination with the JIC to communicate the alternate

route to evacuees leaving the area.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 3.e – Implementation of Ingestion Pathway Decisions

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to implement protective actions, based on criteria recommended by current FDA guidance, for

the ingestion exposure pathway EPZ (i.e., the area within an approximate 50-mile radius of the NPP).

This Sub-element focuses on those actions required for implementation of protective actions.

Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate

information regarding water, food supplies, milk, and agricultural production within the

ingestion exposure pathway emergency planning zone for implementation of protective

actions. NUREG-0654/FEMA-REP-1, A.3; C.1, 4; J.11)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, an actual event, or by means of drills conducted at any time.

Applicable OROs must demonstrate the capability to secure and use current information on the locations

of dairy farms, meat and poultry producers, fisheries, fruit growers, vegetable growers, grain producers,

food processing plants, and water supply intake points to implement protective actions within the EPZ.

OROs use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex, and other
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resources (e.g., compacts, nuclear insurers), if available. Evaluation of this criterion will take into

consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Criterion 3.e.2: Appropriate measures, strategies, and pre-printed instructional material are

developed for implementing protective action decisions for contaminated water, food

products, milk, and agricultural production. (NUREG-0654/FEMA-REP-1, G.1, J.9, 11)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, an actual event, or by means of drills conducted at any time.

OROs must demonstrate the development of measures and strategies for implementation of ingestion

exposure pathway EPZ protective actions by formulating protective action information for the general

public and food producers and processors. Demonstration of this criterion includes either pre-distributed

public information material in the ingestion exposure pathway EPZ or the capability for rapid

reproduction and distribution of appropriate reproduction-ready information and instructions to predetermined individuals and businesses.

OROs must also demonstrate the capability to control, restrict, or prevent distribution of contaminated

food by commercial sectors. Exercise play must include demonstration of communications and

coordination among organizations to implement protective actions. Field play of implementation activities

may be simulated. For example, communications and coordination with agencies responsible for

enforcing food controls within the ingestion exposure pathway EPZ must be demonstrated, but actual

communications with food producers and processors may be simulated.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 3.f – Implementation of Post-Plume Phase Relocation, Reentry, and Return

Decisions

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to implement plans, procedures, and decisions for post-plume phase relocation, reentry, and

return. Implementation of these decisions is essential for protecting the public from direct long-term

exposure to deposited radioactive materials from a severe incident at a commercial NPP.

Criterion 3.f.1: Decisions regarding controlled reentry of emergency workers and relocation

and return of the public during the post-plume phase are coordinated with appropriate

organizations and implemented. (NUREG-0654/FEMA-REP-1, E.7; J.10.j; J.12; K.5.b; M.1, 3)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or 

tabletop exercise, an actual event, or by means of drills conducted at any time.
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Relocation: OROs must demonstrate the capability to coordinate and implement decisions concerning

relocation of individuals located in radiologically contaminated areas who were not previously evacuated.

Such individuals must be relocated to an area(s) where radiological contamination will not expose the

general public to doses that exceed the relocation PAGs. OROs must also demonstrate the capability to

provide for short- or long-term relocation of evacuees who lived in an area(s) that has residual radiation

levels above the (first-, second-, and 50-year) PAGs.

Areas of consideration must include the capability of OROs to communicate with other OROs regarding

timing of actions, notification of the population of procedures for relocation, and notification of, and

advice for, evacuated individuals who will be converted to relocation status in situations where they will

not be able to return to their homes due to high levels of contamination. OROs must also demonstrate the

capability to communicate instructions to the public regarding relocation decisions and intermediate-term

housing for relocated persons.

Reentry: OROs must demonstrate the capability to control reentry and exit of individuals who are

authorized by the ORO to temporarily reenter the restricted area during the post-plume (i.e., intermediate

or late) phase to protect them from unnecessary radiation exposure. OROs must also demonstrate the

capability to control exit of vehicles and other equipment to control the spread of contamination outside

the restricted area(s). Individuals without specific radiological response missions, such as farmers for

animal care, essential utility service personnel, or other members of the public who must reenter an

evacuated area during the post-emergency phase must be limited to the lowest radiological exposure

commensurate with completing their missions. Monitoring and decontamination facilities will be

established as appropriate.

Examples of control procedures are: (1) assignment of, or checking for, direct-reading and permanent

record dosimetry for emergency workers; (2) questions regarding the individuals‘ objective(s), location(s)

expected to be visited, and associated timeframes; (3) maps and plots of radiation exposure rates; (4)

advice on areas to avoid; (5) procedures for exit, including monitoring of individuals, vehicles, and

equipment; (6) decision criteria regarding contamination; (7) proper disposition of emergency worker

dosimetry, and (8) maintenance of emergency worker radiation exposure records.

Return: OROs must demonstrate the capability to implement policies concerning return of members of

the public to areas that were evacuated during the plume phase. OROs must demonstrate the capability to

identify and prioritize services and facilities that require restoration within a few days, and to identify

procedures and resources for their restoration. Examples of these services and facilities are medical and

social services, utilities, roads, and schools.

Communication among OROs for relocation, reentry, and return may be simulated. All simulated or

actual contacts must be documented. These discussions may be accomplished in a group setting.

OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex, and

other resources (e.g., compacts or nuclear insurers), if available. Evaluation of this criterion will take into

consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
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ASSESSMENT AREA 4: FIELD MEASUREMENTS AND ANALYSIS

Sub-element 4.a – Plume Phase Field Measurements and Analyses

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to deploy FMTs with the equipment, methods, and expertise necessary to determine the

location of airborne radiation and particulate deposition on the ground from an airborne plume. In

addition, NUREG-0654/FEMA-REP-1 indicates that OROs must have the capability to use FMTs within

the plume exposure pathway EPZ to detect airborne radioiodine in the presence of noble gases and

radioactive particulate material in the airborne plume. In an incident at an NPP, the possible release of

radioactive material may pose a risk to the nearby population and environment. Although incident

assessment methods are available to project the extent and magnitude of a release, these methods are

subject to large uncertainties. During an incident, it is important to collect field radiological data to help

characterize any radiological release. Adequate equipment and procedures are essential to such field

measurement efforts.

Criterion 4.a.1: [RESERVED]

Criterion 4.a.2: Field teams (2 or more) are managed to obtain sufficient information to help

characterize the release and to control radiation exposure. (NUREG-0654/FEMA-REP-1, C.1;

H.12; I.7, 8, 11; J.10.a)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or 

tabletop exercise. Other means may include drills, seminars or training activities that would fully 

demonstrate technical proficiency. 

Responsible OROs must demonstrate the capability to brief FMTs on predicted plume location and

direction, plume travel speed, and exposure control procedures before deployment. During an HAB

incident, the Field Team management must keep the incident command informed of field monitoring

teams‘ activities and location. Coordination with FMTs and field monitoring may be demonstrated as outof-sequence demonstrations, as negotiated in the Extent-of-Play Agreement.

Field measurements are needed to help characterize the release and support the adequacy of implemented

protective actions, or to be a factor in modifying protective actions. Teams must be directed to take

measurements at such locations and times as necessary to provide sufficient information to characterize

the plume and its impacts.

If the responsibility for obtaining peak measurements in the plume has been accepted by licensee field

monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be

repeated by ORO monitoring teams. If the licensee FMTs do not obtain peak measurements in the plume,

it is the ORO‘s decision as to whether peak measurements are necessary to sufficiently characterize the

plume. The sharing and coordination of plume measurement information among all FMTs (licensee,

Federal, and ORO) is essential. Coordination concerning transfer of samples, including a chain-ofcustody form(s), to a radiological laboratory(ies) must be demonstrated.

OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and

other resources (e.g., compacts or the licensee). Evaluation of this criterion will take into consideration

the level of Federal and other resources participating in the exercise.
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All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate

locations, and radioiodine and particulate samples are collected. Teams will move to an

appropriate low background location to determine whether any significant (as specified in the

plan and/or procedures) amount of radioactivity has been collected on the sampling media.

(NUREG-0654/FEMA-REP-1, C.1; H.12: I.8, 9; J.10.a)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or 

tabletop exercise. Other means may include drills, seminars or training activities that would fully 

demonstrate technical proficiency. 

Two or more FMTs must demonstrate the capability to make and report measurements of ambient

radiation to the field team coordinator, dose assessment team, or other appropriate authority. FMTs must

also demonstrate the capability to obtain an air sample for measurement of airborne radioiodine and

particulates, and to provide the appropriate authority with field data pertaining to measurement. If

samples have radioactivity significantly above background, the authority must consider the need for

expedited laboratory analyses of these samples.

OROs must share data in a timely manner with all other appropriate OROs. All methodology, including

contamination control, instrumentation, preparation of samples, and a chain-of-custody form(s) for

transfer to a laboratory(ies), will be in accordance with the ORO‘s plans/procedures.

OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and

other resources (e.g., compacts or the licensee). Evaluation of this criterion will take into consideration

the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 4.b – Post-Plume Phase Field Measurements and Sampling

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to assess the actual or potential magnitude and locations of radiological hazards to determine

the ingestion exposure pathway EPZ and to support relocation, reentry, and return decisions. This Subelement focuses on collecting environmental samples for laboratory analyses that are essential for

decisions on protecting the public from contaminated food and water and direct radiation from deposited

materials.
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Criterion 4.b.1: The field teams (2 or more) demonstrate the capability to make appropriate

measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation,

and soil) to support adequate assessments and protective action decision making.

(NUREG-0654/FEMA-REP-1, C.1; I.8; J.11)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or 

tabletop exercise. Other means may include drills, seminars or training activities that would fully 

demonstrate technical proficiency. 

The ORO‘s FMTs must demonstrate the capability to take measurements and samples, at such times and

locations as directed, to enable an adequate assessment of the ingestion pathway and to support reentry,

relocation, and return decisions. When resources are available, use of aerial surveys and in-situ gamma

measurement is appropriate. All methodology, including contamination control, instrumentation,

preparation of samples, and chain-of-custody form(s) for transfer to a laboratory(ies), will be in

accordance with the ORO‘s plans/procedures.

The FMTs and/or other sampling personnel must secure ingestion pathway samples from agricultural

products and water. Samples in support of relocation and return must be secured from soil, vegetation,

and other surfaces in areas that received radioactive ground deposition.

OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and

other resources (e.g., compacts, the licensee, or nuclear insurers). Evaluation of this criterion will take

into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 4.c – Laboratory Operations

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples to

support protective action decision making.

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to

support protective action decisions. (NUREG-0654/FEMA-REP-1, C.1, 3; J.11)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or 

tabletop exercise. Other means may include drills, seminars or training activities that would fully 

demonstrate technical proficiency. 

The laboratory staff must demonstrate the capability to follow appropriate procedures for receiving

samples, including logging information, preventing contamination of the laboratory(ies), preventing

buildup of background radiation due to stored samples, preventing cross contamination of samples,

preserving samples that may spoil (e.g., milk), and keeping track of sample identity. In addition, the

laboratory staff must demonstrate the capability to prepare samples for conducting measurements.
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The laboratory(ies) must be appropriately equipped to provide, upon request, timely analyses of media of

sufficient quality and sensitivity to support assessments and decisions anticipated in the ORO‘s

plans/procedures. The laboratory instrument calibrations must be traceable to standards provided by the

National Institute of Standards and Technology. Laboratory methods used to analyze typical

radionuclides released in a reactor incident must be as described in the plans/procedures. New or revised

methods may be used to analyze atypical radionuclide releases (e.g., transuranics or as a result of a

terrorist incident) or if warranted by incident circumstances. Analysis may require resources beyond those

of the ORO.

The laboratory staff must be qualified in radioanalytical techniques and contamination control procedures.

OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and

other resources (e.g., compacts, the licensee, or nuclear insurers). Evaluation of this criterion will take

into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
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ASSESSMENT AREA 5: EMERGENCY NOTIFICATION AND PUBLIC INFORMATION

Sub-element 5.a – Activation of the Prompt Alert and Notification System

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to provide prompt instructions to the public within the plume exposure pathway EPZ. Specific

provisions addressed in this Sub-element are derived from the Guide for the Evaluation of Alert and 

Notification Systems for Nuclear Power Plants, FEMA-REP-10 (November 1985).

Exhibit III-4: Evaluation Standards for Alert and Notification Systems

Demonstration Criterion: In a Timely 

Manner

Within 45 

minutes

Within a 

Reasonable 

Time

Primary Alert and Notification for non-rapidly escalating incidents

5.a.1: ...covering essentially 100% of the 10-mile EPZ X

5.a.4: ...for FEMA-approved exception areas X

Primary Alert and Notification for initial classification of or rapid escalation to a Site Area Emergency or

General Emergency

5.a.4: ...for FEMA-approved exception areas X

Backup Alert and Notification for All Incidents

5.a.3: ...covering the 10-mile EPZ X

Criterion 5.a.1: Activities associated with primary alerting and notification of the public are

completed in a timely manner following the initial decision by authorized offsite emergency

officials to notify the public of an emergency situation. The initial instructional message to

the public must include as a minimum the elements required by current REP guidance.

(NUREG-0654/FEMA-REP-1, E.5, 6, 7)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, drills, or operational testing of equipment that would fully demonstrate capability. 

Responsible OROs must demonstrate the capability to sequentially provide an alert signal followed by an

initial instructional message to populated areas (permanent resident and transient) throughout the 10-mile

plume EPZ. Following the decision to activate the alert and notification system, OROs must complete

system activation for primary alert/notification and disseminate the information/instructions in a timely

manner. For exercise purposes, timely is defined as ―with a sense of urgency and without undue delay.‖ If

message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s)

will document a specific delay or cause as to why a message was not considered timely.

Procedures to broadcast the message must be fully demonstrated as they would in an actual emergency up

to the point of transmission. Broadcast of the message(s) or test message(s) is not required. The

procedures must be demonstrated up to the point of actual activation. The alert signal activation should be

simulated, not performed. Evaluations of EAS broadcast stations may also be accomplished through

SAVs.
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The capability of the primary notification system to broadcast an instructional message on a 24-hour basis

must be verified during an interview with appropriate personnel from the primary notification system,

including verification of provisions for backup power or an alternate station.

The initial message must include at a minimum the following elements:

 Identification of the ORO responsible and the official with authority for providing the alert signal and

instructional message;

 Identification of the commercial NPP and a statement that an emergency exists there;

 Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in

telephone books) for use by the general public during an emergency; and

 A closing statement asking that the affected and potentially affected population stay tuned for

additional information, or that the population tune to another station for additional information.

If route alerting is demonstrated as a primary method of alert and notification, it must be done in

accordance with the ORO‘s plans/procedures and the Extent-of-Play Agreement. OROs must demonstrate

the capability to accomplish the primary route alerting in a timely manner (not subject to specific time

requirements). At least one route needs to be demonstrated and evaluated. The selected route(s) must vary

from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once

every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the

message that would actually be used is read for the evaluator, but not actually broadcast) as negotiated in

the extent of play. Actual testing of the mobile public address system will be conducted at an agreed-upon

location.

OROs may demonstrate any means of primary alert and notification included in their plans/procedures as

negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Criterion 5.a.2: [RESERVED]

Criterion 5.a.3: Backup alert and notification of the public is completed within a reasonable

time following the detection by the ORO of a failure of the primary alert and notification

system. (NUREG-0654/FEMA-REP-1, E.6, Appendix 3.B.2.c)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, drills, or operational testing of equipment that would fully demonstrate capability.

If the exercise scenario calls for failure of any portion of the primary system(s) or if any portion of the

primary system(s) actually fails to function during the exercise, OROs must demonstrate backup means of

alert and notification. Backup means of alert and notification will differ from facility to facility. 

Backup alert and notification procedures that would be implemented in multiple stages must be structured

such that the population closest to the plant (e.g., within 2 miles) is alerted and notified first. The

populations farther away and downwind of any potential radiological release would be covered

sequentially (e.g., 2 to 5 miles, followed by downwind 5 to 10 miles, and finally the remaining population

as directed by authorities). Topography, population density, existing ORO resources, and timing will be

considered in judging the acceptability of backup means of alert and notification.
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Although circumstances may not allow this for all situations, FEMA and the NRC recommend that OROs

and operators attempt to establish backup means that will reach those in the plume exposure EPZ within a

reasonable time of failure of the primary alert and notification system, with a recommended goal of 45

minutes. The backup alert message must, at a minimum, include (1) a statement that an emergency exists

at the plant and (2) instructions regarding where to obtain additional information.

If backup route alerting is demonstrated, only one route needs to be selected and demonstrated. All alert

and notification activities along the route(s) must be simulated (that is, the message that would actually be

used is read for the evaluator, but not actually broadcast), as negotiated in the extent of play. Actual

testing of the mobile public address system will be conducted at an agreed-upon location.

OROs may demonstrate any means of backup alert and notification included in their plans/procedures as

negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Criterion 5.a.4: Activities associated with FEMA-approved exception areas (where applicable)

are completed in a timely manner following the initial decision by authorized offsite

emergency officials to notify the public of an emergency situation. (NUREG-0654/FEMA-REP1, E.6; Appendix 3.B.2.c)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, drills, or operational testing of equipment that would fully demonstrate capability.

OROs with FEMA-approved exception areas (identified in the approved Alert and Notification System

Design Report), 5 to 10 miles from the NPP, must demonstrate the capability to accomplish primary

alerting and notification of the exception area(s). FEMA and the NRC recommend that OROs and

operators establish means that will reach those in approved exception areas in a timely manner, with a

recommended goal of 45 minutes, once the initial decision is made by authorized offsite emergency

officials to notify the public of an incident. The exception area alert message must, at a minimum, include

(1) a statement that an emergency exists at the plant and (2) instructions regarding where to obtain

additional information.

For exception area alerting, at least one route must be demonstrated and evaluated. The selected route(s)

must vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less

than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is,

the message that would actually be used is read for the evaluator, but not actually broadcasted) as

negotiated in the extent of play. Actual testing of the mobile public address system will be conducted at

an agreed-upon location. For exception areas alerted by aircraft, actual flights will be negotiated in the

extent of play, but must be demonstrated no less than once every 8 years.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
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Sub-element 5.b – Subsequent Emergency Information and Instructions for the Public

and the Media

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to disseminate appropriate emergency information and instructions, including any

recommended protective actions, to the public. In addition, NUREG-0654/FEMA-REP-1 requires OROs

to ensure that the capability exists for providing information to the media. This includes the availability of

a physical location for use by the media during an emergency. NUREG-0654/FEMA-REP-1 also provides

that a system must be available for dealing with rumors. This system will hereafter be known as the

―public inquiry hotline.‖

Criterion 5.b.1: OROs provide accurate subsequent emergency information and instructions

to the public and the news media in a timely manner. (NUREG-0654/FEMA-REP-1, E.5, 7;

G.3.a, G.4.a, c)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, or drills.

The responsible ORO personnel/representatives must demonstrate actions to provide emergency

information and instructions to the public and media in a timely manner following the initial alert and

notification (not subject to specific time requirements). For exercise purposes, timely is defined as ―with a

sense of urgency and without undue delay.‖ If message dissemination is identified as not having been

accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a

message was not considered timely.

Message elements: The ORO must ensure that emergency information and instructions are consistent

with PADs made by appropriate officials. The emergency information must contain all necessary and

applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what

to take when evacuating, shelter-in-place instructions, information concerning protective actions for

schools and persons with disabilities and access/functional needs, and public inquiry hotline telephone

number) to assist the public in carrying out the PADs provided. The ORO must also be prepared to

disclose and explain the ECL of the incident. At a minimum, this information must be included in media

briefings and/or media releases. OROs must demonstrate the capability to use language that is clear and

understandable to the public within both the plume and ingestion exposure pathway EPZs. This includes

demonstration of the capability to use familiar landmarks and boundaries to describe protective action

areas.

The emergency information must be all-inclusive by including the four items specified under exercise

Demonstration Criterion 5.a.1 and previously identified protective action areas that are still valid, as well

as new areas. The OROs must demonstrate the capability to ensure that emergency information that is no

longer valid is rescinded and not repeated by broadcast media. In addition, the OROs must demonstrate

the capability to ensure that current emergency information is repeated at pre-established intervals in

accordance with the plans/procedures. OROs must demonstrate the capability to develop emergency

information in a non-English language when required by the plans/procedures.

If ingestion pathway measures are exercised, OROs must demonstrate that a system exists for rapid

dissemination of ingestion pathway information to pre-determined individuals and businesses in

accordance with the ORO‘s plans/procedures.
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Media information: OROs must demonstrate the capability to provide timely, accurate, concise, and

coordinated information to the news media for subsequent dissemination to the public. This would

include demonstration of the capability to conduct timely and pertinent media briefings and distribute

media releases as the incident warrants. The OROs must demonstrate the capability to respond

appropriately to inquiries from the news media. All information presented in media briefings and releases

must be consistent with PADs and other emergency information provided to the public. Copies of

pertinent emergency information (e.g., EAS messages and media releases) and media information kits

must be available for dissemination to the media.

Public inquiry: OROs must demonstrate that an effective system is in place for dealing with calls

received via the public inquiry hotline. Hotline staff must demonstrate the capability to provide or obtain

accurate information for callers or refer them to an appropriate information source. Information from the

hotline staff, including information that corrects false or inaccurate information when trends are noted,

must be included, as appropriate, in emergency information provided to the public, media briefings,

and/or media releases.

HAB considerations: The dissemination of information dealing with specific aspects of NPP security

capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law enforcement

response must be coordinated/communicated with appropriate security authorities, e.g., law enforcement

and NPP security agencies, in accordance with ORO plans/procedures.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
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ASSESSMENT AREA 6: SUPPORT OPERATIONS/FACILITIES

Sub-element 6.a – Monitoring, Decontamination, and Registration of Evacuees

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to implement radiological monitoring and decontamination of evacuees, while minimizing

contamination of the facility. OROs must also have the capability to identify and register evacuees at

reception centers.

Criterion 6.a.1: The reception center facility has appropriate space, adequate resources, and

trained personnel to provide monitoring, decontamination, and registration of evacuees.

(NUREG-0654/FEMA-REP-1, A.3; C.4; J.10.h; J.12)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, drills, or SAV.

Radiological monitoring, decontamination, and registration facilities for evacuees must be set up and

demonstrated as they would be in an actual emergency or as indicated in the Extent-of-Play Agreement. 

OROs conducting this demonstration must have one-third of the resources (e.g., monitoring

teams/instrumentation/portal monitors) available at the facility(ies) as necessary to monitor 20 percent of

the population within a 12-hour period. This would include adequate space for evacuees‘ vehicles.

Availability of resources can be demonstrated with valid documentation (e.g., MOU/LOA, etc.) reflecting

how necessary equipment would be procured for the location. Plans/procedures must indicate provisions

for service animals.

Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the

instrument(s) for proper operation. Staff responsible for the radiological monitoring of evacuees must

demonstrate the capability to attain and sustain, within about 12 hours, a monitoring productivity rate per

hour needed to monitor the 20 percent EPZ population planning base. The monitoring productivity rate

per hour is the number of evacuees that can be monitored, per hour, by the total complement of monitors

using an appropriate procedure. For demonstration of monitoring, decontamination, and registration

capabilities, a minimum of six evacuees must be monitored per station using equipment and procedures

specified in the plans/procedures. The monitoring sequences for the first six simulated evacuees per

monitoring team will be timed by the evaluators to determine whether the 12-hour requirement can be

met.

OROs must demonstrate the capability to register evacuees upon completion of the monitoring and

decontamination activities. The activities for recording radiological monitoring and, if necessary,

decontamination must include establishing a registration record consisting of the evacuee‘s name,

address, results of monitoring, and time of decontamination (if any), or as otherwise designated in the

plan and/or procedures. Audio recorders, camcorders, or written records are all acceptable means for

registration.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger/action

levels for determining the need for decontamination. They must also explain the procedures for referring

any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with

the ORO‘s plans/procedures. Contamination of the evacuee(s) will be determined by controller inject and

not simulated with any low-level radiation source. All activities must be based on the ORO‘s
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plans/procedures and completed as they would be in an actual emergency, unless noted above or

otherwise specified in the Extent-of-Play Agreement.

Decontamination of evacuees may be simulated and conducted by interview. Provisions for separate

showering and same-sex monitoring must be demonstrated or explained. The staff must demonstrate

provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and

appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially

contaminated areas. Provisions must also exist to separate contaminated and uncontaminated evacuees,

provide changes of clothing for those with contaminated clothing; and store contaminated clothing and

personal belongings to prevent further contamination of evacuees or facilities. In addition, for any

evacuee found to be contaminated, procedures must be discussed concerning handling of potential

contamination of vehicles and personal belongings. Waste water from decontamination operations does

not need to be collected.

Individuals who have completed monitoring (and decontamination, if needed) must have means (e.g.,

hand stamp, sticker, bracelet, form, etc) indicating that they, and their service animals and vehicles, where

applicable, have been monitored, cleared, and found to have no contamination or contamination below the

trigger/action level.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have

their vehicle monitored. These individuals do not require confirmation that their vehicle is free from

contamination prior to entering the congregate care areas.

However, those individuals who are found to be contaminated and are then decontaminated will have

their vehicles monitored and decontaminated (if applicable) and do require confirmation that their vehicle

is free from contamination prior to entering the congregate care areas.

Sub-element 6.b – Monitoring and Decontamination of Emergency Workers and their

Equipment and Vehicles

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to implement radiological monitoring and decontamination of emergency workers and their

equipment, inclusive of vehicles.

Criterion 6.b.1: The facility/ORO has adequate procedures and resources to accomplish

monitoring and decontamination of emergency workers and their equipment and vehicles.

(NUREG-0654/FEMA-REP-1, K.5.a, b)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, drills, or SAV.

The monitoring staff must demonstrate the capability to monitor emergency worker personnel and their

equipment and vehicles for contamination in accordance with the ORO‘s plans/procedures.

Specific attention must be given to equipment, including any vehicles that were in contact with

contamination. The monitoring staff must demonstrate the capability to make decisions on the need for

decontamination of personnel, equipment, and vehicles based on trigger/action levels and procedures

stated in the ORO plans/procedures. Monitoring of emergency workers does not have to meet the 12-hour

requirement. However, appropriate monitoring procedures must be demonstrated for a minimum of two
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-60 October 2011

emergency workers and their equipment and vehicles. Before using monitoring instrument(s), the

monitor(s) must demonstrate the process of checking the instrument(s) for proper operation.

The area to be used for monitoring and decontamination must be set up as it would be in an actual

emergency, with all route markings, instrumentation, record keeping, and contamination control measures

in place. Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not

necessary to monitor the entire surface of vehicles. However, the capability to monitor areas such as

radiator grills, bumpers, wheel wells, tires, and door handles must be demonstrated. Interior surfaces of

vehicles that were in contact with contaminated individuals must also be checked.

Decontamination of emergency workers may be simulated and conducted via interview. Provisions for

separate showering and same-sex monitoring must be demonstrated or explained. The staff must

demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings,

signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from

potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated

individuals where applicable; provide changes of clothing for those with contaminated clothing; and store

contaminated clothing and personal belongings to prevent further contamination of emergency workers or

facilities.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger/action

levels for determining the need for decontamination. They must also explain the procedures for referring

any emergency workers who cannot be adequately decontaminated for assessment and follow-up in

accordance with the ORO‘s plans/procedures. Contamination of the individual(s) will be determined by

controller inject and not simulated with any low-level radiation source.

Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully

decontaminated may be simulated and conducted by interview. Waste water from decontamination

operations does not need to be collected.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 6.c – Temporary Care of Evacuees

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires OROs to have the

capability to establish relocation centers in host/support jurisdictions. The American Red Cross normally

provides congregate care in support of OROs under existing letters of agreement.

Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have

resources to provide services and accommodations consistent with American Red Cross

planning guidelines. Managers demonstrate the procedures to assure that evacuees have

been monitored for contamination and have been decontaminated as appropriate prior to

entering congregate care facilities. (NUREG-0654/FEMA-REP-1, J.10.h, J.12)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, drills, or SAV.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-61 October 2011

The evaluator must conduct a walk-through of the center to determine, through observation and inquiries,

that the services and accommodations are consistent with applicable guidance.

For planning purposes, OROs must plan for a sufficient number of congregate care centers in host/support 

jurisdictions to accommodate a minimum of 20 percent of the EPZ population. In this simulation, it is not

necessary to set up operations as they would be in an actual emergency. Alternatively, capabilities may be

demonstrated by setting up stations for various services and providing those services to simulated

evacuees. Given the substantial differences between demonstration and simulation of this criterion,

exercise demonstration expectations must be clearly specified in Extent-of-Play Agreements.

Congregate care staff must also demonstrate the capability to ensure that evacuees, service animals, and

vehicles have been monitored for contamination, decontaminated as appropriate, and registered before

entering the facility.

Individuals arriving at congregate care facilities must have means (e.g., hand stamp, sticker, bracelet,

form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been

monitored, cleared, and found to have no contamination or contamination below the trigger/action level.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have

their vehicle monitored. These individuals do not need confirmation that their vehicle is free from

contamination prior to entering the congregate care areas.

However, those individuals who are found to be contaminated and are then decontaminated will have

their vehicles monitored and decontaminated (if applicable) and do need confirmation that their vehicle is

free from contamination prior to entering the congregate care areas. This capability may be determined

through an interview process.

If operations at the center are demonstrated, material that would be difficult or expensive to transport

(e.g., cots, blankets, sundries, and large-scale food supplies) need not be physically available at the

facility(ies). However, availability of such items must be verified by providing the evaluator a list of

sources with locations and estimates of quantities.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Sub-element 6.d – Transportation and Treatment of Contaminated Injured Individuals

Intent

This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the

capability to transport contaminated injured individuals to medical facilities with the capability to provide

medical services.98

Criterion 6.d.1: The facility/ORO has the appropriate space, adequate resources, and trained

personnel to provide transport, monitoring, decontamination, and medical services to

contaminated injured individuals. (NUREG-0654/FEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4)

Assessment/Extent of Play

Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 

exercise, or drills.

 

98 See also Part III.D, REP Program Exercise Guidance: Evaluation of Emergency Medical Services Drills.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-62 October 2011

Monitoring, decontamination, and contamination control efforts must not delay urgent medical care for

the victim.

OROs must demonstrate the capability to transport contaminated injured individuals to medical facilities.

An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of

service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to

the medical facility. Normal communications between the ambulance/dispatcher and the receiving

medical facility must be demonstrated. If a substitute vehicle is used for transport to the medical facility,

this communication must occur before releasing the ambulance from the drill. This communication would

include reporting radiation monitoring results, if available. In addition, the ambulance crew must

demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and

decontaminated, if required, or whom to contact for such information.

Monitoring of the victim may be performed before transport or en route, or may be deferred to the

medical facility. Before using monitoring instruments, the monitor(s) must demonstrate the process of

checking the instrument(s) for proper operation. All monitoring activities must be completed as they

would be in an actual emergency. Appropriate contamination control measures must be demonstrated

before and during transport and at the receiving medical facility.

The medical facility must demonstrate the capability to activate and set up a radiological emergency area

for treatment. Equipment and supplies must be available for treatment of contaminated injured

individuals.

The medical facility must demonstrate the capability to make decisions on the need for decontamination

of the individual, follow appropriate decontamination procedures, and maintain records of all survey

measurements and samples taken. All procedures for collection and analysis of samples and

decontamination of the individual must be demonstrated or described to the evaluator. Waste water from

decontamination operations must be handled according to facility plans/procedures.

All activities must be based on the ORO‘s plans/procedures and completed as they would be in an actual

emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-63 October 2011

D. EVALUATION OF MEDICAL SERVICES DRILLS

During the Atomic Safety and Licensing Board

hearing involving offsite emergency response

planning and preparedness for the San Onofre

Nuclear Generating Station, and in subsequent

litigation in the United States Court of Appeals,

the court ruled that the existing interpretation of

the required pre-accident medical arrangements

for contaminated injured individuals was not

sufficient. As a result of this litigation, FEMA,

in consultation with the NRC, developed GM

MS-1, Medical Services (November 13, 1986)

concerning the planning guidance for offsite

emergency medical facilities, transportation and

personnel. The guidance in this manual

supersedes GM MS-1.

NUREG-0654/FEMA-REP-1 requires that

OROs demonstrate their capabilities regarding

medical services for contaminated and injured

individuals of the general public in annual drills.

As a result of the court decision, NRC requested

that FEMA evaluate each annual medical

services drill until OROs demonstrate that their

capabilities have been substantially enhanced.

When FEMA determined that these capabilities

were substantially enhanced and were

consistently adequate to protect public health

and safety in a radiological emergency at a

commercial NPP, the evaluation frequency

could be reduced to biennially.

Using applicable FEMA REP Program guidance

and Assessment Area methodology, FEMA has

determined that these capabilities have been

enhanced and consistently demonstrated as

adequate; therefore, offsite medical services

drills need to be evaluated only biennially.

FEMA will, at the request of the involved ORO,

continue to evaluate the drills on an annual

basis. If more than two medical facilities and

transportation providers are designated as

primary or backup, they are also evaluated

biennially.

A medical services drill demonstrates the ability

of the transportation services as well as medical

facilities to handle an injured contaminated

individual without spreading contamination.

During a medical services drill, both the

transporting service and medical facility will be

evaluated. Medical facilities are expected to

have at least one trained physician and one

trained nurse to perform and supervise treatment

of contaminated injured members of the general

public. Contaminated injured individuals

transported to medical facilities are monitored as

soon as possible to assure that everyone

(ambulance and medical facility) is aware of the

medical and radiological status of the

individual(s). However, if an ambulance defers

monitoring to the medical facility, then the

ambulance crew presumes that the patient(s) is

contaminated and demonstrate appropriate

contamination controls until the patient(s) is

monitored. It is allowable for an ambulance to

demonstrate up to the point of departure for the

medical facility and then have a non-specialized

vehicle transport the ―victim(s)‖ to the medical

facility. This option is used in areas where

removing an ambulance from service to drive a

great distance (over an hour) for a drill would

not be in the best interests of the community.

For further details on the exercise

Demonstration Criteria for medical services

drills, see exercise Demonstration Criterion

6.d.1, in Part III.C, REP Program Exercise

Guidance: Assessment Areas, Assessment Area

6: Support Operations/ Facilities.
PART III: REP PROGRAM DEMONSTRATION GUIDANCE

REP Program Manual Page III-64 October 2011

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REP Program Manual Page IV-1 October 2011

Part IV: FEMA REPPROGRAM

ADMINISTRATION

A. INTRODUCTION

The intent of this part of the REP Program Manual is to provide general guidance on the FEMA REP

Program administrative policies and procedures. Examples provided in this Part are meant to show how a

particular task may be accomplished, but are not intended to mandate a specific way of accomplishing

tasks.

Following this introduction, the contents of this Part are:

B. Regulatory Summary

C. Non-participating State, Tribal, and Local Governments (NUREG-0654/FEMA-REP-1, Supplement 

1)

D. Early Site Permit Applications (NUREG-0654/FEMA-REP-1, Supplement 2)

E. Protective Action Strategies (NUREG-0654/FEMA-REP-1, Supplement 3)

F. Exercise Methodology, More Challenging Drills and Exercises, and Backup Alert and Notification 

Requirements (NUREG-0654/FEMA-REP-1, Supplement 4)

G. Target Capabilities List

H. Integration of REP Demonstration Criteria and HSEEP Capabilities

I. Emergency Planning Zone Boundary Changes

J. Credentialing Framework

K. Use of State, Local, and Tribal Personnel as REP Exercise Evaluators

L. Tribal Policies and Procedures

M. Staff Assistance Visits

N. Evacuation Time Estimates

O. Potassium Iodide for the Public

P. Conducting Plan Reviews

Q. Conducting Scenario Reviews

R. Annual Letter of Certification

S. Public Information Guide and Process

T. Conducting a Disaster Initiated Review

U. List of Commercial Nuclear Power Plants
PART IV – REP PROGRAM ADMINISTRATION

REP Program Manual Page IV-2 October 2011

B. REGULATORY SUMMARY

This section summarizes the FEMA regulations

pertinent to the REP Program (44 CFR Parts

350-354). This section is intended for

background only. FEMA staff and other persons

interested in emergency preparedness for NPPs

are urged to consult the regulations themselves

for the authoritative answer to any questions

concerning FEMA REP policy and procedure. In

all cases the regulations shall take precedence

over any statements or representations made in

this section.

1. 44 CFR PART 350 – REVIEW AND

APPROVAL OF STATE AND LOCAL

RADIOLOGICAL EMERGENCY

PLANS AND PREPAREDNESS

44 CFR Part 350 sets forth the basis for FEMA‘s

REP Program. This part covers:

 The procedural process by which state and

tribal governments submit plans/procedures

to protect the health and safety of the public

to FEMA for formal approval;

 Substantive requirements for emergency

planning and exercises;

 FEMA‘s process for evaluating and

approving emergency preparedness; and

 Requirements and procedures for involving

the public.

This discussion is divided into four sections:

Initial Approval, Continuation of Approval,

Withdrawal of Approval, and Appeals.

a. Initial Approval of Plans/Procedures

and Preparedness

The approval of plans/procedures under 44 CFR

Part 350 is site-specific. Each state and/or tribal

Nation, together with the affected local

jurisdictions within the site‘s EPZ, applies for

approval under 44 CFR § 350.7(c).

(1) Overview of Requirements and

Procedure

The following requirements must be fulfilled for

FEMA to formally approve ORO radiological

emergency preparedness for a commercial NPP:

 Acceptable ORO emergency response

plans/procedures must be in place for the

plume and ingestion pathway EPZs.

Planning for protective measures within the

ingestion pathway is a state responsibility,

as stated in NUREG-0654/FEMA-REP-1.

 At least one joint, Federally-evaluated

exercise must be held by the affected

OROs.

 A public meeting must be held near the

power plant to receive comments on the

adequacy of the plans/procedures and

whether the OROs are capable of

implementing them.

After the state and/or tribal Nation has applied to

FEMA for approval under 44 CFR Part 350 the

responsible FEMA Regional Office, assisted by

members of the RAC, makes the initial

determination as to whether the requirements

have been fulfilled. The FEMA Regional Office

then furnishes the application, together with

supporting materials and an evaluation of

preparedness, to FEMA Headquarters. FEMA

Headquarters staff, with assistance from the

FRPCC, reviews the application and materials.

(The composition and role of the FRPCC and

RAC are described further in 44 CFR § 351.)

The Director of FEMA‘s Technological Hazards

Division (hereafter, THD Director) within the

FEMA NPD,

99 issues a decision on the

application and forwards it to the Deputy

Administrator for National Preparedness and the

FEMA Administrator.The Administrator

notifies the Governor(s) of the state(s) making

application, the NRC, and the appropriate

 

99 The term Associate Director as used in the regulation originally 

referred to the Associate Director, State and Local Programs and 

Support [44 CFR Part 350.2(c)].
PART IV – REP PROGRAM ADMINISTRATION

REP Program Manual Page IV-3 October 2011

FEMA Regional Administrator.The

Administrator also publishes a notice on the

final decision in the Federal Register.

(2) Application Procedure

The application procedure is described in 44

CFR § 350.7. The application is submitted by

the Governor (or Governor‘s designee) to the

appropriate FEMA Regional Administrator. The

application must include a copy of the state

plans/procedures (including coverage of

response in the ingestion exposure pathway

EPZ) and local radiological emergency

plans/procedures for the site‘s plume exposure

pathway EPZ [350 CFR § 350.7(a)]. The state

must also certify that the plans/procedures are

―adequate to protect the public health and safety

of its citizens living within the emergency

planning zones...by providing reasonable

assurance that state and local governments can

and intend to effect appropriate protective

measures offsite in a radiological emergency‖

[44 CFR § 350.7(d)].

(3) FEMA Regional Review

Receipt of Application and Review of Plans

Upon receipt of the application from a state, the

FEMA Regional Administrator:

 Acknowledges receipt of the application, in

writing, within 10 days [44 CFR §

350.8(a)].

 Publishes a notice in the Federal Register

within 30 days. The notice must state that

the application has been received and that

copies of the application are available to the

public at the FEMA Regional Office for

review in accordance with 44 CFR 5.26 [44

CFR § 350.8(b)]. (44 CFR 5.26, entitled

―Rules for public inspection and copying,‖

specifies that documents will be available

for public inspection during normal

business hours and that copies will be

furnished according to a standard fee

schedule.)

 Furnishes copies of the plans/procedures to

the RAC for evaluation and comment [44

CFR § 350.8(c)]. See Exhibit IV-1 for RAC

agency plan review responsibilities by

NUREG-0654/FEMA-REP-1 Evaluation

Criterion.

 Conducts a detailed review of the

plans/procedures and evaluates the ability

of the OROs to implement them, using

comments from the RAC members as part

of the evaluation process [44 CFR §

350.8(d)]. (See Part IV, Conducting Plan

Reviews.)

Exhibit IV-1: Plan Review Responsibilities for RAC Agencies

NUREG0654/FEMAREP-1

FEMA NRC DOE EPA FDA HHS DOT USDA DOI DOC

A.1.a X X X

A.1.b X X X

A.1.c X X X

A.1.d X X X X

A.1.e X X X

A.2.a X X X X X X X X X

A.2.b X X

A.3 X X X X X X

A.4 X X

B (All) Onsite
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-4 October 2011

NUREG0654/FEMAREP-1

FEMA NRC DOE EPA FDA HHS DOT USDA DOI DOC

C.1.a X X

C.1.b X

C.1.c X X

C.2.a X X X

C.3 X X X X

C.4 X X X X X X X X

D.3 X X

D.4 X

E.1 X X X X X X

E.2 X X X X X

E.5 X X X X

E.6 X X X X X X

E.7 X X X X

F.1.a X X

F.1.b X X

F.1.c X X X

F.1.d X X X

F.1.e X X X

F.2 X X X

F.3 X X X X X X

G.1 X X X X X X

G.2 X

G.3.a X X X X

G.4.a X X X

G.4.b X

G.4.c X X

G.5 X X

H.3 X X X

H.4 X X X

H.7 X X X

H.10 X X X

H.11 X X X

H.12 X X X

I.7 X X X

I.8 X X X X

I.9 X X X X

I.10 X X X X

I.11 X

J.2 X X

J.9 X X

J.10.a X X

J.10.b X X

J.10.c X X X

J.10.d X

J.10.e X

J.10.f X

J.10.g X X

J.10.h X X X

J.10.i X X

J.10.j X X X

J.10.k X X

J.10.l X X

J.10.m X X X X X

J.11 X X X X

J.12 X X X X
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-5 October 2011

NUREG0654/FEMAREP-1

FEMA NRC DOE EPA FDA HHS DOT USDA DOI DOC

K.3.a X X X X X

K.3.b X X X X

K.4 X X X X

K.5.a X X X X X

K.5.b X X X X X

L.1 X X X

L.3 X X X X

L.4 X X X

M.1 X X X X

M.3 X

M.4 X X X

N.1.a X X X X X

N.1.b X X X X

N.2.a X X

N.2.c X X

N.2.d X X X X

N.2.e X X X X X

N.3.a X X X X

N.3.b X X X X

N.3.c X X X X

N.3.d X X

N.3.e X X X

N.3.f X X X X

N.4 X X X X X X X X X X

N.5 X X X X X X X

O.1 X X X X

O.1.b X X X

O.4.a X X X X

O.4.c X X X X

O.4.d X X

O.4.f X X X

O.4.g X

O.4.h X X

O.4.j X

O.5 X X

P.1 X X

P.2 X X

P.3 X X

P.4 X X X

P.5 X X X X

P.6 X X

P.7 X X

P.8 X

P.10 X

The Regional Administrator ―may make

suggestions to [the state] concerning perceived

gaps or deficiencies in the plans, and the state

may amend the plan at any time prior to

forwarding to the [FEMA Administrator]...‖

[44 CFR § 350.8(e)].

Qualifying Exercise

As part of the approval process, the state,

appropriate local jurisdictions, and licensee must

conduct a joint exercise. As stated in 44 CFR §

350.9(a), ―Before a Regional [Administrator]

can forward a state plan to the [FEMA

Administrator] for approval, the state, together

with all appropriate local governments, must

conduct a joint exercise of that state plan,
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-6 October 2011

involving full participation of appropriate local

government entities, the state and the

appropriate licensee of the NRC.‖ Full

participation is defined in the regulation as

follows:

 ORO emergency personnel are engaged in

sufficient numbers to verify the capability

to respond to the actions required by the

accident scenario;

 Integrated capability to adequately assess

and respond to an accident at a commercial

NPP is tested; and

 Implementation of the observable portions

of ORO plans/procedures are tested [44

CFR § 350.2(j)].

FEMA evaluates the exercise with assistance

from the RAC. Within 48 hours of completion of

the exercise, the Regional Administrator reports

preliminary findings to exercise participants and

Federal evaluators in a briefing. If the evaluation

reveals any deficiencies, either in the

plans/procedures themselves or in the ability of

the relevant governments to implement them,

FEMA must ―make them known promptly in

writing to appropriate state officials‖ [44 CFR §

350.9(a)]. FEMA then works with the state to

resolve the deficiencies through

plans/procedures revisions, a remedial exercise,

or both.

The FEMA Regional Administrator, in

forwarding the application for approval to

FEMA Headquarters, must certify that an

exercise as described above has been conducted

and any deficiencies have been corrected [44

CFR § 350.9(b)].

Public Meeting

Following the qualifying exercise, but prior to

approval, the FEMA Regional Administrator

will ensure that at least one public meeting is

held in the vicinity of the NPP. The purpose of

the meeting is to provide information about the

plans/procedures and exercise, answer questions,

take comments and suggestions from the public

on ways to improve preparedness, and explain

how the plans/procedures are expected to

function in a real emergency. The meeting is

held after the joint exercise and include

representatives from FEMA, the NRC, the

licensee, and OROs [44 CFR § 350.10]. The

public must be notified in advance of the

meeting as follows [44 CFR § 350.10(b)]:

 Notice is given in the local newspaper with

the largest circulation in the area, or other

such media as the Regional Administrator

may select, on at least two occasions. One

occasion must be at least 2 weeks before the

meeting and the other must be a few days

before it.

 The Regional PIO prepares the

announcement and provides it to the RAC

Chair for approval. Then, the PIO can

release it and notify all media outlets.

 Local radio and television stations are

notified at least 1 week in advance.

If the public meeting reveals deficiencies in the

plans/procedures or exercise, the Regional

Administrator must inform the state and provide

recommendations for improvement. No approval

of plans/procedures and preparedness shall be

made until the meeting described above has been

held.

Regional Administrator’s Evaluation

The FEMA Regional Administrator evaluates

the plans/procedures (and accompanying

documentation) in accordance with the criteria

in 44 CFR § 350.5, and reports on each Planning

Standard. The accompanying documentation

(―relevant record material‖) includes:

 The state and relevant ORO

plans/procedures;

“deficiencies” and “Deficiencies”

The term “deficiencies” as used in 44 CFR 

Part 350 (with a lower-case “d”) refers 

collectively to all planning and preparedness 

issues. The definition of “Deficiency” (as the 

term is used now with a capital “D”) was not 

established until 1993 in the NRC/FEMA 

Memorandum of Understanding (44 CFR Part 

350, Appendix A). 
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-7 October 2011

 Results of the exercise (deficiencies noted

and corrections made);

 Summary of deficiencies identified during

the public meeting; and

 Recommendations made to the state and

actions or commitments by the state to

improve plans/procedures and

preparedness.

The Regional Administrator then forwards his or

her evaluation along, with appropriate

documentation, to the FEMA Administrator.

(4) Criteria for Review

The joint FEMA/NRC guidance document

(NUREG-0654/FEMA-REP-1, Revision 1)

established 16 Planning Standards and

Evaluation Criteria for assessing radiological

emergency preparedness at NPP sites. FEMA

regulations specify that FEMA review of ORO

plans/procedures and preparedness will be

conducted according to the Planning Standards

in NUREG-0654/FEMA-REP-1 and 44 CFR §

350.5. While the FEMA‘s regulations in 44 CFR

§ 350.5 specifically delineate only the Planning

Standards from NUREG-0654/FEMA-REP-1,

the associated Evaluation Criteria are adopted by

reference in the regulation language.

(5) Assistance in Development of ORO

Plans

Upon request, the FEMA Regional Office staff

and RAC members provide OROs with technical

assistance in developing their plans/procedures.

Technical assistance includes review and

comment on plans/procedures, but does not

include the actual writing of plans/procedures

(44 CFR § 350.6). The regulations list the

agencies in the RAC as NRC, DOE, EPA, FDA,

HHS, DOT, USDA, and DOC, and specify that

the FEMA Region official will be the RAC

Chair.

(6) FEMA Headquarters Review and

Approval

Upon receipt of the Regional Administrator‘s

evaluation and associated documentation, the

FEMA Administrator will review these materials

―as he or she shall deem necessary‖ and provide

copies to other offices of FEMA and members

of the FRPCC [44 CFR § 350.12(a)]. The final

approval decision rests with the FEMA

Administrator. Approval may be withheld

pending review of other jurisdictions within that

site‘s EPZs [44 CFR § 350.12(d)]. For example,

where the EPZ for a site falls within two states,

approval of one state‘s plans/procedures for the

site might be withheld pending approval of the

other state‘s plans/procedures for the site.

As set forth in 44 CFR § 350.12(b), offsite

plans/procedures and preparedness will be

approved only if they are:

 Adequate to protect the health and safety of

the public living in the vicinity of the

nuclear power facility, by providing

reasonable assurance that appropriate

protective measures can be taken offsite in a

radiological emergency; and

 Capable of being implemented (e.g.,

adequacy and maintenance of procedures,

training, resources, staffing levels,

qualification, and equipment adequacy).

The FEMA Administrator‘s decision is

concurrently communicated to the Governor, the

NRC, and the Regional Administrator, and

published in the Federal Register. If the

application is not approved, the Deputy

Administrator, NPD must indicate in writing the

reasons for the decision and request

improvements [44 CFR § 350.12(d)].

b. Continued Approval

After obtaining initial approval of

plans/procedures and preparedness under 44

CFR Part 350, the state and/or tribal Nation and

local governments must:

 Conduct Federally evaluated biennial

exercises for the site, and

 Report on the periodic requirements set

forth in NUREG-0654/FEMA-REP-1,

Revision 1.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-8 October 2011

(1) Exercises Required for Continuing

Approval

The regulations spell out a required schedule of

exercises to demonstrate continuing capability to

protect the public [44 CFR § 350.9(c)].

 Each local jurisdiction within a site‘s plume

pathway EPZ must fully participate in an

exercise every 2 years. If a local jurisdiction

is in the EPZ for more than one site, the

FEMA Regional Administrator may seek

approval from the Deputy Administrator,

NPD for an exemption from this

requirement for every site.

 Each state within the plume pathway EPZ

for a power plant must fully participate in

an exercise every 2 years. Full participation

primarily refers to each organization

demonstrating all the emergency phase

capabilities outlined in its plans/procedures,

including both facility and field-based

functions. States with multiple sites may

rotate the site at which they fully

participate, and partially participate at the

other sites. Partial participation is defined as

―engagement of state and local government

emergency personnel in an exercise

sufficient to adequately test direction and

control functions for protective action

decision-making related to Emergency

Action Levels (EALs) and communication

capabilities among affected state and local

governments and the licensee.‖

 Ingestion pathway exercises are conducted

at least once every 8

100 years. For states with

multiple sites, the ingestion pathway play is

rotated among the sites. States impacted by

the pathway from sites outside their borders

must partially participate in the exercises

held at those sites.

 The FEMA Regional Administrator may

require jurisdictions to conduct remedial

exercises to correct deficiencies found

during regularly scheduled exercises.

 

100 This requirement was changed from 6 years to 8 years by 

NUREG-0654/FEMA-REP-1, Supplement 4.

Failure to exercise in accordance with this

schedule ―shall be grounds for withdrawing

FEMA approval‖ [44 CFR § 350.9(f)].

(2) Periodic Requirements

FEMA determined that the periodic reporting

requirements contained in NUREG0654/FEMA-REP-1, Revision 1, could be

accomplished through an ALC.

c. Withdrawal of Approval

Once approval has been granted under the

process described above, it continues

indefinitely. In other words, approval does not

automatically expire after a set period of time.

FEMA continues to provide determinations of

reasonable assurance to the NRC on a biennial

basis with transmittal of the exercise report to

the NRC and the review of the ALC. However,

the regulations define a process for withdrawing

approval any time FEMA determines that

planning and preparedness are no longer

adequate to protect public health and safety.

Approval of planning and preparedness may be

withdrawn through the process described in 44

CFR § 350.13. Under these regulations, the

FEMA Administrator may initiate proceedings

to withdraw approval any time that he or she

―determines, on his or her own initiative...or on

the basis of information another person supplied,

that the state or local plan is no longer adequate

to protect public health and safety by providing

reasonable assurance that appropriate protective

measures can be taken, or is no longer capable

of being implemented...‖ [44 CFR § 350.13(a)].

Such a determination must be based on the same

criteria applied to the approval process, namely,

the Planning Standards and Evaluation Criteria

in NUREG-0654/FEMA-REP-1.

To begin the procedure, the FEMA

Administrator notifies the Governor of the

affected state (through the FEMA Regional

Administrator) and the NRC in writing. The

notification cites the reasons for the

determination of inadequacy, citing deficiencies

in the plans/procedures or preparedness. The

state then has 4 months to either correct the
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-9 October 2011

deficiencies or submit an acceptable plan for

correcting them [44 CFR § 350.13(a)]. This

period has been referred to in the program as a

―120-day clock.‖

The state can submit a plan for correcting the

Deficiencies and negotiate a timetable with the

FEMA Administrator. If the Deficiencies are

successfully corrected within the timetable, the

FEMA Administrator ends the withdrawal action

and notifies the Regional Administrator, the

Governor, and the NRC. Notices are also

published in the Federal Register and the

newspaper of widest circulation in the affected

state [44 CFR § 350.13(b)]. If the Deficiencies

are not corrected within the allotted time, the

FEMA Administrator withdraws approval.

Notice of such withdrawal is given to the FEMA

Regional Administrator, the Governor, and the

NRC, and published as described above.

d. Appeals

Any time FEMA approval of planning and

preparedness is granted or withdrawn by the

FEMA Administrator, the decision may be

appealed. The appeal may be made by ―any

interested person‖ [44 CFR § 350.15(a)]. Appeal 

of approval must be based on the grounds that 

the decision was unsupported by substantial 

evidence [44 CFR § 350.12(e)]. Appeal of 

withdrawal must be based on the grounds that 

the Deputy Administrator, NPD‘s decision was 

unsupported by substantial evidence based on 

the available record [44 CFR § 350.13(c)].

Written notice of the appeal must be submitted

within 30 days of the date the approval decision

is published in the Federal Register. The appeal

letter must state specific reasons for the appeal

and include an offer to provide supporting

documentation.

The FEMA Administrator (or designee) then

reviews the file as submitted by the FEMA

Regional Administrator, plus the appeal letter

and its supporting documentation, to determine

whether the decision was ―supported by

substantial evidence in the file and...consistent

with FEMA policy‖ [44 CFR § 350.15(b)].

The decision by the FEMA Administrator (or

designee) is published in the Federal Register

and copies are provided to the appellant, the

Governor, the NRC, and the licensee. The

decision is considered final and not subject to

review within FEMA ―except upon a showing

that it was procured by fraud or

misrepresentation‖ [44 CFR § 350.15(c)].

e. Resources

FEMA REP resources can be obtained from the

FEMA website, http://www.fema.gov/about/

divisions/thd_repp.shtm. The full set of FEMA

REP regulations, along with NRC regulations

and other Federal regulations and documents,

can be obtained in print from the National

Archives and Records Administration website,

http://www.gpoaccess.gov/cfr/index.html.

2. 44 CFR PART 351 – RADIOLOGICAL

EMERGENCY PLANNING AND

PREPAREDNESS

This part of the regulation establishes Federal

agency roles and assigns tasks regarding Federal

assistance to OROs in their radiological

emergency planning and preparedness activities.

This part is applicable to both fixed nuclear

facilities and transportation accidents involving

radiological material. This part does not cover

Federal response, which is discussed in the NRF

Nuclear/Radiological Incident Annex, June

2008.

44 CFR Part 351 also establishes two types of

committees: FRPCC and the RACs.

Membership of FRPCC includes FEMA, which

chairs the committee, HHS, DOC, DOD, DOE,

DOT, EPA, NRC, and USDA. Other agencies

may be added as the incident warrants. The

RACs have similar membership and are located

in each of the FEMA Regions that have NPPs

within their regional borders.

The FRPCC assists FEMA in providing policy

direction for OROs‘ radiological emergency

planning and preparedness activities.

Subcommittees of the FRPCC are dedicated to

research, training, emergency instrumentation,

transportation, information, education, and
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-10 October 2011

Federal response. The FRPCC also assists

FEMA with approval of state plans/procedures

under 44 CFR Part 350 and assures that research

efforts of its member agencies are coordinated

with the Interagency Radiation Research

Committee.

The RACs assist ORO officials in developing

their radiological emergency plans/procedures,

and review these plans/procedures and observe

exercises to evaluate adequacy of the

plans/procedures and preparedness.

3. 44 CFR PART 352 – COMMERCIAL

NPP: EMERGENCY PREPAREDNESS

PLANNING

This part of the regulation deals with the

situation where ―state or local governments,

either individually or together, decline or fail to

prepare commercial nuclear power plant offsite

radiological emergency preparedness

plans/procedures that are sufficient to satisfy

NRC licensing requirements or to participate

adequately in the preparation, demonstration,

testing, exercise, or use of such plans.‖

This part establishes the framework for review

and evaluation of the adequacy of licensee

offsite radiological emergency planning and

preparedness, and for providing Federal

assistance to licensees.

NUREG-0654/FEMA-REP-1, Supplement 1 

provides additional guidance on the application 

of this regulation.

4. 44 CFR PART 353 – FEE FOR

SERVICES IN SUPPORT, REVIEW,

AND APPROVAL OF STATE AND

LOCAL GOVERNMENT OR LICENSEE

RADIOLOGICAL EMERGENCY

PLANS AND PREPAREDNESS

This part of the regulations establishes fees

charged for site-specific radiological emergency

planning and preparedness services rendered by

FEMA, as authorized by 31 U.S.C. 9701.

44 CFR Part 353 also includes the FEMA/NRC

Memorandum of Understanding (MOU) as

Appendix A. The MOU establishes the

framework for cooperation between FEMA and

the NRC. The major areas of cooperation

include NRC licensing review, FEMA review of

offsite plans/procedures and preparedness,

preparation for and evaluation of joint exercises,

emergency planning and preparedness guidance,

support for document management system,

public information and education programs, and

recovery from disasters affecting offsite

emergency preparedness. The MOU also

establishes an NRC/FEMA steering committee.

The MOU also contains the first official

definition of ―Deficiency.‖

5. 44 CFR PART 354 – FEE FOR

SERVICES TO SUPPORT FEMA’S

OFFSITE REP PROGRAM

44 CFR Part 354 establishes the methodology

for FEMA to assess and collect user fees. The

fees are to recover at least 100 percent of the

amounts for the REP Program. There are both

site-specific and flat fees. The site-specific

component is related to plume pathway

exercises and covers the costs of:

 Scheduling plume pathway biennial

exercises;

 Reviewing plume pathway EPZ biennial

exercise objectives and scenarios;

 Providing pre-plume pathway EPZ biennial

exercise logistics;

 Conducting plume pathway EPZ biennial

exercise, evaluations, and post-exercise

briefing;

 Preparing, reviewing, and finalizing plume

pathway EPZ biennial exercise reports;

 Giving notice and conducting public

meetings; and

 Activities related to medical services and

other drills in support of a biennial plume

pathway exercise.
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REP Program Manual Page IV-11 October 2011

C. NON-PARTICIPATING STATE, TRIBAL, AND LOCAL

GOVERNMENTS (NUREG-0654/FEMA-REP-1,

SUPPLEMENT 1)

Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in 

Support of Nuclear Power Plants – Criteria for Preparation and Evaluation of Radiological Emergency

Response Plans and Preparedness in Support of Nuclear Power Plants, November 1980 (NUREG0654/FEMA-REP-1, Supplement 1)

Supplement 1 expands on 44 CFR Part 352,

which governs the offsite planning process in an

instance where a state, local, and/or tribal

government(s) declines or fails to participate in

preparing offsite emergency plans/procedures, or

has significant planning or preparedness

inadequacies and has not demonstrated the

commitment or capabilities to correct those

inadequacies. In such situations, the licensee

will submit offsite plans/procedures, which will

be reviewed following the process specified in

44 CFR § 350. This part of the regulation also

provides the procedures for providing Federal

resources to assist the licensee when the licensee

has made a request under this part. Specific

actions to take are delineated in 44 CFR Part

352.

D. EARLY SITE PERMIT APPLICATIONS (NUREG0654/FEMA-REP-1, SUPPLEMENT 2)

Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in 

Support of Nuclear Power Plants – Criteria for Emergency Planning in an Early Site Permit Application,

Draft Report for Comment, March 1996 (NUREG-0654/ FEMA-REP-1, Supplement 2)

Supplement 2 provides additional detailed

guidance on the requirements and procedures

applicable to issuance of an Early Site Permit

found in Subpart A of 10 CFR Part 52. An ESP

is an optional step whereby an applicant obtains

NRC approval of a reactor site prior to submittal

of a Combined License application as described

in Subpart C of 10 CFR § 52. NUREG0654/FEMA-REP-1, Supplement 2 provides

guidance for ESP applicants and NRC and

FEMA reviewers in the preparation and

evaluation of the emergency planning aspects of

ESP applications. This supplement includes

application and review guidance regarding (1)

identification of physical characteristics that

could pose a significant impediment to

development of emergency plans/procedures; (2)

contacts and arrangements with local, state, and

Federal agencies with emergency planning

responsibilities; and (3) submittal of either major

features of emergency plans/procedures or

complete and integrated emergency

plans/procedures. Emergency plans/procedures

submitted under the major features of

emergency plans/procedures provision of

Supplement 2 are evaluated against selected and

modified emergency Planning Standards and

Evaluation Criteria from Section II of NUREG0654/FEMA-REP-1, Revision 1.

NOTE: Although there is no NUREG0654/FEMA-REP-1 supplement addressing

combined licensing, the process has been fully

outlined in the New Reactor Licensing Standard

Operating Procedure. This document is available

at www.fema.gov/about/divisions/

thd_repp.shtm.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-12 October 2011

E. PROTECTIVE ACTION STRATEGIES (NUREG-0654/FEMAREP-1, SUPPLEMENT 3)

Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in 

Support of Nuclear Power Plants – Guidance for Protective Action Strategies, October 2011 (NUREG0654/FEMA-REP-1, Revision 1, Supplement 3)

The 2011 publication of Supplement 3

supersedes the previous version of Supplement 

3, ―Criteria for Protective Action 

Recommendations for Severe Accidents‖ 

published in 1996 as a draft report for interim 

use and comment.

Supplement 3 provides guidance for use in 

developing site specific protective action 

strategies for implementation during a General 

Emergency at an NPP. The revised supplement 

provides background information and a 

protective action logic development tool that 

should be used by licensees to develop site 

specific protective action recommendation 

procedures and is recommended for use by 

OROs to develop protective action strategy 

guidance for decision makers. In addition, 

Supplement 3, Revision 1, contains guidance for 

enhancing public information materials and 

emergency messaging, including further 

considerations for individuals and populations 

with disabilities and access/functional needs.

In late 2004, the NRC initiated a project to 

analyze the relative efficacy of alternative 

protective action strategies in reducing 

consequences to the public from a spectrum of 

NPP core melt accidents. The study is 

documented in NUREG/CR-6953, ―Review of 

NUREG-0654, Supplement 3,  ̳Criteria for 

Protective Action Recommendations for Severe 

Accidents,‘‖ Volumes 1 (2007), 2 (2008) and 3 

(2010). The study provides a technical basis for 

enhancing protective action guidance and 

contributed to the revision of Supplement 3. 

Input from State and local government 

emergency response professionals, stakeholders, 

and industry was also incorporated. 

The guidance of Supplement 3, Rev. 1, provides 

an acceptable method to comply with 10 CFR § 

50.47(b)(10) in development of a range of 

protective actions for the plume EPZ. However, 

alternative methods may also be acceptable and 

may be submitted for consideration.

F. EXERCISE METHODOLOGY, MORE CHALLENGING DRILLS

AND EXERCISES, AND BACKUP ALERT AND NOTIFICATION

REQUIREMENTS (NUREG-0654/FEMA-REP-1,

SUPPLEMENT 4)

Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in 

Support of Nuclear Power Plants – Criteria for National Preparedness Initiative Integration, Exercise 

Enhancement, and Backup Alert and Notification Systems, October 2011 (NUREG-0654/FEMA-REP-1, 

Supplement 4)

Supplement 4 provides additional guidance for

the development, review, and evaluation of

offsite radiological emergency response

planning and preparedness surrounding the

Nation‘s commercial NPPs on four emerging

issues: 
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-13 October 2011

1. Integration of National Preparedness 

Initiatives into ORO Plans and 

Activities: integration of NIMS/

Incident Command System and National

Exercise Program/HSEEP concepts into

offsite emergency response plans and

activities.

2. Coordination between OROs and 

Licensees during a Hostile ActionBased Incident: unique challenges

posed during HAB incidents regarding

the capability of OROs to respond to the

NPP site while maintaining offsite

response capabilities.

3. Challenging Drills and Exercises:

developing exercise scenarios that

incorporate a broader spectrum of

options regarding releases and initiating

events to increase realism and to

minimize participant preconditioning.

 Predictability of Emergency

Classification Levels (ECLs)

 Varying Radiological Release

Options

 Varying Radiological Release

Conditions

 Broader Spectrum of Initiating

Events

4. Backup Means for Alert and

Notification Systems: requirements for

backup capabilities for both alert and

notification functions.

New requirements set forth in this Supplement

include:

 Three new Evaluation Criteria

o C.6 – addresses coordination of

onsite and offsite response in an

HAB incident

o N.1.c – requires off-hours and

unannounced exercises for the

licensee only

o N.1.d – identifies specific ORO

requirements for demonstration of

ingestion pathway response.

 Exercise scenario variations, including

no/minimal release, HAB incidents, and

rapidly escalating incidents.

 Change in the exercise cycle length

from 6 years to 8 years.

 A full backup to the Alert and

Notification System.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-14 October 2011

G. TARGET CAPABILITIES LIST

The National Preparedness Goal, issued under 

PPD-8, established a risk-based, all-hazards 

approach to preparedness to allow the Federal 

government to determine how to invest 

homeland security resources in order to achieve 

the greatest return on investment for our 

Nation‘s homeland security. To aid in 

accomplishing this goal, DHS developed the 

Target Capabilities List that defines capabilities 

necessary to prevent, protect against, respond to, 

and recover from large and complex incidents of 

any type. TCL 2.0, released September 2007, 

identified 37 capabilities under the four 

Homeland Security mission areas (Prevent, 

Protect, Respond, and Recover) and common 

capabilities. 

Common Capabilities

 Planning

 Interoperable Communications

 Risk Management

 Citizen Preparedness and Participation

 Intelligence and Information Sharing and 

Dissemination

Prevent Mission Area

 Information Gathering and Recognition of 

Indicators and Warnings

 Intelligence Analysis and Production

 Counter-Terrorism Investigation and Law 

Enforcement

 Chemical, Biological, Radiological, 

Nuclear, and Enhanced Conventional 

Weapons 

 Detection

Protect Mission Area

 Critical Infrastructure Protection

 Food and Agriculture Safety and Defense

 Epidemiological Surveillance and 

Investigation

 Laboratory Testing

Respond Mission Area

 On-Site Incident Management

 Emergency Operations Center Management

 Critical Resource Logistics and Distribution

 Volunteer Management and Donations 

 Worker Health and Safety

 Emergency Public Safety and Security 

Response

 Firefighting Operations/Support 

 Weapons of Mass Destruction and 

Hazardous Materials Response and 

Decontamination

 Explosive Device Response Operations

 Animal Disease Emergency Support

 Environmental Health

 Citizen Evacuation and Shelter in Place 

 Isolation and Quarantine

 Search and Rescue (Land-Based)

 Emergency Public Information and 

Warning

 Emergency Triage and Pre-Hospital 

Treatment

 Medical Surge 

 Medical Supplies Management and 

Distribution

 Mass Prophylaxis

 Mass Care 

 Fatality Management

Recover Mission Area

 Structural Damage Assessment and 

Mitigation

 Restoration of Lifelines

 Economic and Community Recovery
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-15 October 2011

H. INTEGRATION OF REP DEMONSTRATION CRITERIA AND 

HSEEP CAPABILITIES

The REP program is adopting the HSEEP 

exercise documentation format to be consistent 

with national preparedness and exercise 

initiatives. Although the goals of the REP and 

HSEEP exercise evaluation methodologies are 

the same – the assessment of response and 

recovery capabilities and identification of items 

that need to be improved – the REP program has 

traditionally expressed exercise outcomes in 

terms of Demonstration Criteria and reasonable 

assurance, whereas HSEEP uses Target 

Capabilities. Integrating the two exercise 

methodologies so that they are ―speaking the 

same language‖ has several major benefits for 

response organizations: 

 OROs that have already adopted the 

HSEEP methodology will now be able to 

use the same processes and report formats 

for their REP and HSEEP exercise 

activities.

 OROs can use REP After Action Reports 

(AARs) to document progress toward their 

overall preparedness and Target Capability 

goals; and

 OROs that are required to use the HSEEP 

methodology because they receive Federal 

preparedness grant funds can use REP 

AARs to satisfy grant spending 

documentation requirements.

To facilitate the integration process, FEMA has 

developed two tools: the criterion-capability 

crosswalk and REP-specific Exercise Evaluation 

Guides (EEGs).

The information in this subpart includes the 

following three sections:

 Criteria-Capability Crosswalk

 Exercise Evaluation Guides

 Customizing EEGs for an Exercise

1. CRITERIA-CAPABILITY CROSSWALK

The crosswalk was developed as a starting point 

for translating the REP Demonstration Criteria 

into applicable HSEEP Target Capabilities from 

the Target Capabilities List (TCL). FEMA 

reviewed the extent of play associated with each 

REP Demonstration Criterion and compared it 

with the Target Capabilities and associated 

activities to identify any similarities. The 

analysis considered the diverse range of 

government systems and ORO radiological 

emergency response frameworks that may be 

encountered and evaluated by a FEMA Region. 

The resulting crosswalk provides a ―menu‖ of 

potential correlations between each REP 

Demonstration Criterion and the Target 

Capabilities, rather than a ―one-size-fits-all‖ 

prescriptive list. The crosswalk is found in 

Exhibit IV-2.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-16 October 2011

Exhibit IV-2: Criteria-Capability Crosswalk

REP Assessment Areas and Demonstration Criteria

Emergency 

Operations 

Management

Protective Action 

Decision-Making

Protective Action 

Implementation

Field 

Measurement and 

Analysis

Emergency 

Notification 

and Public 

Information

Support 

Operations/

Facilities

Target Capabilities 

by Mission Area

1.a.11.b.1

1.c.1

1.d.11.e.12.a.12.b.12.b.2

2.c.1

2.d.12.e.13.a.13.b.1

3.c.13.c.2

3.d.13.d.23.e.13.e.2

3.f.1

4.a.24.a.34.b.1

4.c.1

5.a.15.a.25.a.35.a.45.b.16.a.16.b.1

6.c.1

6.d.1

Common

Communications X

Protect

Food and Agriculture Safety and 

Defense X X X X X X X X

Laboratory Testing X X X X X

Respond

Citizen Evacuation and Shelter-inPlace X X X X X X X X X X X X X X

Critical Resource Logistics and 

Distribution X X X X X X X

Emergency Operations Center 

Management X X X X X X X X X X X X X X X X X X X X X X X X X X

Emergency Public Information and 

Warning X X X X X X X X X X X

Emergency Public Safety and Security 

Response X X X X X X X X X X X X

Emergency Triage and Pre-Hospital 

Treatment X X X X X X
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-17 October 2011

 

101 Medical Services Drill

102 On-scene, can include mobile command vehicles

REP Assessment Areas and Demonstration Criteria

Emergency 

Operations 

Management

Protective Action 

Decision-Making

Protective Action 

Implementation

Field 

Measurement and 

Analysis

Emergency 

Notification 

and Public 

Information

Support 

Operations/

Facilities

Target Capabilities 

by Mission Area

1.a.11.b.1

1.c.1

1.d.11.e.12.a.12.b.12.b.2

2.c.1

2.d.12.e.13.a.13.b.1

3.c.13.c.2

3.d.13.d.23.e.13.e.2

3.f.1

4.a.24.a.34.b.1

4.c.1

5.a.15.a.25.a.35.a.45.b.16.a.16.b.1

6.c.1

6.d.1

Respond

Environmental Health X X X X X X

Mass Care (Sheltering, Feeding, & 

Related Services) X

Mass Prophylaxis X X X X

Medical Surge101 X X X X X X

On-Site 

Incident Management102 X X X X X X

Responder Safety and Health X X X X X

WMD & Hazardous Materials 

Response and Decontamination X X X X X X X X X X

Recover

Economic & Community Recovery X X

Restoration of Lifelines X X
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REP Program Manual Page IV-18 October 2011

2. EXERCISE EVALUATION GUIDES

FEMA used the crosswalk and the REP Exercise 

Preparation Guide to develop a master set of 

REP-specific capability-based EEGs for the 

potential locations and functional entities (i.e., 

EOC, field monitoring team, etc.) that may be 

evaluated during REP exercises. Each REP 

capability-based EEG is pre-populated with the 

following: 

 TCL Capability – This field denotes which 

Target Capability is being evaluated, and

subsequently, described in the AAR. The 

Target Capabilities represented in the EEGs 

come from the TCL and should be 

associated with one of the objectives set for 

the exercise.

 Activity – This field denotes which 

activities are being evaluated. The activities 

represent a functional process that can be 

observed, much like the observable 

functional processes of the REP 

Demonstration Criteria, making the 

Demonstration Criteria roughly equivalent 

to the level of an ―activity‖ under HSEEP. 

 Task – Under each Activity, tasks drawn 

from the TCL and Extent-of-Play 

Agreement provide links between the REP 

functions being carried out and specific 

Target Capabilities. The tasks originating in 

the TCL/Universal Task List (UTL), have 

corresponding TCL task numbers (i.e., 

Res.B1c 5.2.4). The tasks without TCL task 

numbers are REP-specific items that do not 

have an equivalent task within the 

TCL/UTL. 

 Observation Keys – This field provides 

additional observation detail for the 

Evaluator. These Keys identify specific 

things evaluators should look for or provide 

additional detail on what they might 

observe. This field should only be used to 

provide further information for the 

Evaluators. The Observation Keys included 

in the EEGs were taken from the REP 

Exercise Preparation Guide. 

This EEG structure enables users to meet the 

traditional reasonable assurance standards of the 

REP Program as well as address and document 

the selected Target Capabilities. 

The REP EEGs were created, tested, and 

validated during a series of REP/HSEEP 

Integration Exercises held in 2009 and 2010. A 

sample Master Capability-based REP EEG is 

found in Exhibit IV-3 on the following pages. 

Note that the Master Capability-based EEGs 

continue to evolve as they are used in different 

exercises and new lessons learned are 

discovered. The most current versions of the 

master REP EEGs are available on the 

REP/HSEEP Pilot EEGs channel on LLIS.gov. 

Access to this channel can be requested through 

FEMA Headquarters.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-19 October 2011

Exhibit IV-3: Sample Exercise Evaluation Guide

Location: Emergency Operations Center (EOC)

TCL Capability: Emergency Operations Center Management

Activity: Mobilize (1.a.1)

Definition: Offsite response organization’s (ORO’s) use effective procedures to alert, 

notify, and mobilize emergency personnel and activate facilities in a timely manner. 

(NUREG-0654, A.4, D.3, 4, E.1, 2, H.4)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B1c 4 Activate the EOC/MACC/IOF

[Name, 

Pg/Sec#]

Res.B1c

4.3

Activate, alert, and request response from EOC/MACC/IOF personnel

 Ensure positions identified in the ORO‘s plan/procedures are identified and that 

24-hour positions are staffed. 

 Note any pre-positioned staff at your location not in accordance with the EOP.

 Ensure facility staff is provided with current incident conditions. 

[Name, 

Pg/Sec#]

Res.B1c

5.2.4

Ensure appropriate notifications are made

 Establish and maintain communication with responding units in accordance with 

plans and/or procedures. 

 Document verification of ECL changes, if applicable. 

 Note times (e.g., 24-hour clock) of all key events applicable at your location, 

including when: 

o Notifications are received from the Utility/State, and at what ECL level

o Response staff are notified

o Response staff arrive

o The facility is declared operational

[Name, 

Pg/Sec#]

ComC 3.5 Initiate documentation process of required forms and follow-up notations

[Name, 

Pg/Sec#]

ComC 

4.2.1

Communicate incident response information per agency protocols

 Document verification of ECL changes, if applicable. 

 Establish and maintain communication with responding units in accordance with 

plans and/or procedures.

 Ensure staff is provided with current incident conditions. 

[Name, 

Pg/Sec#]

ComC 

4.2.3

Report and document the incident by completing and submitting required 

forms, reports, documentation, and follow-up notations on immediate response 

communications

 Ensure positions identified in the ORO‘s plan/procedures are identified and that 

24-hour positions are staffed. 

 Note any pre-positioned staff at your location not in accordance with the EOP.

 Note times (e.g., 24-hour clock) of all key events applicable at your location, 

including when: 

o Notifications are received from the Utility/State, and at what ECL level

o Response staff are notified

o Response staff arrive

o The facility is declared operational

Capability 

Task 

Location where 

criteria will be 

demonstrated OR

who is 

demonstrating 

criteria

1

st Activity 

Observation Keys 

for evaluators

Location of 

relevant material in 

ORO REP plan/ 

procedure
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-20 October 2011

Activity: Provide Sufficient Facilities (1.b.1)

Definition: Facilities are sufficient to support the emergency response. (NUREG-0654, 

H.3)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B1c

1.2.1

Create one central and one backup EOC/Multi-Agency Coordination Center 

(MACC)/Initial Operating Facility (IOF)

[Name, 

Pg/Sec#]

Res.B1c

3.1 Establish organization/operation of EOC/MACC/IOF

[Name, 

Pg/Sec#]

n/a Ensure the emergency operations center (EOC) set-up is sufficient to support 

emergency response operations

 Check that the facility is set up (as shown in the floor plan) and operated 

according to the offsite response organization‘s (ORO‘s) plan/procedures, unless 

otherwise indicated in the EOP agreement. If not, did it cause any adverse 

consequences? Are changes to the plan or procedures recommended as a result?

Activity: Provide Direction and Control (1.c.1)

Definition: Key personnel with leadership roles for the offsite response organization 

(ORO) provide direction and control to that part of the overall response effort for which 

they are responsible. (NUREG-0654, A.1.d; A.2.a, b)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B1c

3.3.1 Coordinate jurisdictional emergency management operations

[Name, 

Pg/Sec#]

Res.B1c

3.3.3 Direct all support organizations participating in EOC/MACC/IOF

[Name, 

Pg/Sec#]

n/a Ensure that all decisions are made in a timely manner and in consideration of 

all appropriate data from all appropriate sources

 Note if the key personnel in leadership roles make timely decisions. Also, observe 

whether the decision-makers obtained input from their support staff.

[Name, 

Pg/Sec#]

Res.B1c

4.4 Brief incoming personnel

[Name, 

Pg/Sec#]

n/a Maintain situational awareness by conducting briefings at regular intervals

[Name, 

Pg/Sec#]

Res.B1c

5.1.2 Monitor communications and information systems

[Name, 

Pg/Sec#]

Res.B1c

5.2.2

Coordinate emergency management efforts among local, County, Regional, 

State, and Federal EOC/MACC/IOF

[Name, 

Pg/Sec#]

Res.B1c

5.2.3

Coordinate with nongovernment agencies and/or private sector to collect/share 

data on incident situation

[Name, 

Pg/Sec#]

Res.B1c

5.2.4 Ensure appropriate notifications are made

[Name, 

Pg/Sec#]

Res.B1c

6.1.4

Identify issues

 Document how key personnel in leadership roles resolve conflicts, if they arise.

[Name, 

Pg/Sec#]

Res.B1c

6.1.5

Identify and elevate needs/issues up the chain of command as needed, while 

tracking status

[Name, 

Pg/Sec#]

Res.B1c

6.3 Track issues until they are resolved

2

nd Activity 

Activity 
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-21 October 2011

Activity: Utilize Communications Equipment (1.d.1)

Definition: At least two communication systems are available, at least one operates 

properly, and communication links are established and maintained with appropriate 

locations. Communications capabilities are managed in support of emergency 

operations. (NUREG-0654/FEMA REP-1, F.1, 2)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B1c

1.3

Establish operational and redundant communication systems for EOC 

operation

 Ensure that the primary and at least one backup communication system are fully 

functional at the commencement of the exercise.

 Identify the communication system(s) available independent of commercial 

telephone.

 Note any communications equipment failures. If there were failures, document 

them in your narrative. Did any communications failures affect exercise 

performance? If so, describe the issue in your write-up.

[Name, 

Pg/Sec#]

Res.B2c

5.1.1

Verify that all participating public safety-related Communication Centers, 

serving the EOC/MACC/IOF directly or indirectly, have established 

communication links with the EOC/MACC/IOF

 Observe whether a communications check with other jurisdictions, field teams, 

and/or other support organizations was performed.

Activity: Provide Equipment and Supplies to Support Operations (1.e.1)

Definition: Equipment, maps, displays, monitoring instruments, dosimetry, potassium 

iodide (KI) and other supplies are sufficient to support emergency operations. (NUREG0654/FEMA REP-1, H.7, 10; J.10. a, b, e; J.11; K.3.a)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

n/a Determine what resources are required for response operations

 Note any displays used by the offsite response organization (ORO).

 If instructed, verify that appropriate equipment, e.g., barriers, cones, etc. is 

available for traffic and access control activities.

[Name, 

Pg/Sec#]

n/a Provide dosimetry and potassium iodide resources sufficient to support 

emergency operations

 If instructed, verify the quantities of DRDs and Thermoluminescent dosimeters 

(TLDs), and the testing/calibration dates of DRDs and survey instruments.

 If instructed, verify that field instruments have been calibrated in accordance with 

manufacturers‘ specifications or at least annually.

 If instructed, verify annual leakage checks for mR DRDs and quarterly leakage 

checks for Civil Defense Victoreen (CDV) Model 138s (CDV-138s). 

 If instructed, verify that there are sufficient quantities of KI within the expiration 

date for those who may need to take it. (If KI is beyond the expiration date, does 

the ORO have a letter from a certified private or State laboratory indicating that 

the supply is still potent)?

[Name, 

Pg/Sec#]

Res.C2a

3.3.1

Coordinate with the Medical Supply and Distribution Capability to ensure that 

medical stockpile warehouses can re-supply Points of Dispensing (PODs) as 

needed

[Name, 

Pg/Sec#]

Res.C2a

8.3.1

Ensure adequate supply of pharmaceuticals, ancillary medical supplies and 

drug information sheets

 If instructed, verify that there are sufficient quantities of KI within the expiration 

date for those who may need to take it. (If KI is beyond the expiration date, does 

the offsite response organization (ORO) have a letter from a certified private or 

State laboratory indicating that the supply is still potent)?

[Name, 

Pg/Sec#]

Res.B1b

6.3 Ensure the provision of appropriate safety and health equipment
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-22 October 2011

Activity: Provide Emergency Worker Exposure Control System (2.a.1)

Definition: Offsite response organization’s (ORO’s) use a decision-making process, 

considering relevant factors and appropriate coordination, to ensure that an exposure 

control system, including the use of Potassium Iodide (KI), is in place for emergency 

workers (EWs) including provisions to authorize radiation exposure in excess of 

administrative limits or protective action guides. (NUREG-0654/FEMA REP-1, K.4, J.10. 

e, f)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B1b

4.3 Ensure ongoing safety and health assessments of response operations

[Name, 

Pg/Sec#]

Res.B1b

5.1 Perform an incident safety analysis

[Name, 

Pg/Sec#]

Res.B1b

5.1.1

Identify and prioritize the operations, hazards, and exposures of greatest risk to 

site personnel and coordinate with the IC to develop specific actions to address 

them and protect site personnel

 Observe whether decision-makers considered projected doses and likely exposure 

rate patterns before dispatching workers into the emergency planning zone (EPZ). 

 Note whether the decision-makers considered:

o Alternate entry and exit routes 

o Potential changes in meteorological conditions

o Areas or roads to be avoided

o What to do in the event of equipment and vehicle failure

o Previous exposure(s) of personnel

[Name, 

Pg/Sec#]

Res.B1b

5.2

Assist the IC in developing an incident safety and control plan to respond 

within the capabilities of available response personnel, taking into account 

available resources such as PPE, monitoring equipment, and control equipment

 Note whether the decision to use KI was based on projected thyroid dose 

compared with the established Protective Action Guides (PAGs) for KI 

administration.

 Note if the KI decision-making process involved close coordination among 

assessment and decision-making staff.

 Document that the correct dosimeter correction factor was used.

[Name, 

Pg/Sec#]

Res.B1b

5.4.2

Provide command structure with observation-based recommendations for the 

safety of on-site personnel

[Name, 

Pg/Sec#]

Res.B1b

7.5.5

Make recommendation to alter, suspend, or terminate any activity judged to be 

an imminent danger or immediately dangerous to life and health

[Name, 

Pg/Sec#]

n/a Ensure that the process for authorizing exposure levels to Emergency Workers 

(EWs) in excess of pre-authorized levels is clear and understood by all EWs

Activity: Make Appropriate Protective Action Decisions (PADs) (2.b.2)

Definition: A decision-making process involving consideration of appropriate factors 

and necessary coordination is used to make protective action decisions (PADs) for the 

general public (including the recommendation for the use of Potassium Iodide (KI), if 

offsite response organization (ORO) policy). (NUREG-0654/FEMA REP-1, J.9, 10.f, m)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B1c

6.1.5

Identify and elevate needs/issues up the chain of command as needed, while 

tracking status

[Name, 

Pg/Sec#]

Res.B1c

7.3.1

Facilitate resolution to legal, policy, political, social, and economic sensitivities 

of the affected jurisdiction(s) as they impact response and recovery operations
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-23 October 2011

Name, 

Pg/Sec#]

n/a Ensure that all appropriate information sources and data points are factored 

into the formation of protective action decisions (PADs)

 Note whether initial PADs are made based on:

o Notification from the licensee,

o Assessment of plant conditions and/or radiological releases, or

o PARs from the utility and ORO staff (dose assessment group).

[Name, 

Pg/Sec#]

Res.B1c

7.3.2

Facilitate formulation of PADs, as needed

 Follow the KI decision-making process. Did the decision require coordination 

with assessment and decision-making staff and was it based on projected thyroid 

dose compared with the established Protective Action Guide (PAG).

 Note how KI information was provided to those who needed to take it. Evaluate 

message content for timeliness and clarity on KI instructions.

Name, 

Pg/Sec#]

n/a Ensure subsequent protective action decisions (PADs) follow similar 

formulation processes

 Note whether the subsequent PADs are made based on:

o Subsequent dose projections,

o Field monitoring data, or

o Information on plant conditions.

 Evaluate the decision-maker(s) capability to change protective actions as 

appropriate based on new information.

[Name, 

Pg/Sec#]

Res.B3a

3.1.2

Identify populations, institutions (e.g., hospitals, nursing homes, correctional 

facilities) and locations to be evacuated or SIP

[Name, 

Pg/Sec#]

Res.B3a

3.1.3

Coordinate with law enforcement to identify risk (e.g., from a potential 

terrorist attack) to transportation infrastructure that may be used for evacuation

[Name, 

Pg/Sec#]

Res.B3a

3.2

Determine appropriate course of action to address the incident

 Note whether initial PADs are made based on:

o Notification from the licensee,

o Assessment of plant conditions and/or radiological releases, or

o PARs from the utility and ORO staff (dose assessment group).

[Name, 

Pg/Sec#]

Res.B3a

3.2.1

Identify appropriate decision making authority responsible for deciding a 

course of action to address the incident

 Note whether the subsequent PADs are made based on:

o Subsequent dose projections,

o Field monitoring data, or

o Information on plant conditions.

 Evaluate the decision-maker(s) capability to change protective actions as 

appropriate based on new information.

[Name, 

Pg/Sec#]

n/a As needed, coordinate issuance of shelter-in-place protective action decision 

(PAD) with appropriate entities

[Name, 

Pg/Sec#]

n/a As needed, coordinate issuance of evacuation protective action decision (PAD) 

with appropriate entities

Name, 

Pg/Sec#]

n/a Coordinate formulation of protective action decisions (PADs) with all 

appropriate entities

 Follow the KI decision-making process. Did the decision require coordination 

with assessment and decision-making staff and was it based on projected thyroid 

dose compared with the established PAG.

 Note how KI information was provided to those who needed to take it. Evaluate 

message content for timeliness and clarity on KI instructions.

Activity: Make PADs for the Protection of Special Populations (2.c.1)

Definition: Protective action decisions are made, as appropriate, for special population 

groups. (NUREG-0654/FEMA REP-1, J.9, J.10.d, e)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B1c

6.1.5

Identify and elevate needs/issues up the chain of command as needed, while 

tracking status
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-24 October 2011

[Name, 

Pg/Sec#]

Res.B1c

7.3.1

Facilitate resolution to legal, policy, political, social, and economic sensitivities 

of the affected jurisdiction(s) as they impact response and recovery operations

Name, 

Pg/Sec#]

n/a Ensure that all appropriate information sources and data points are factored 

into the formation of protective action decisions (PADs) for special 

populations

 Note whether decisions for school children were based on:

o ORO recommendation,

o ECL at time of notification,

o School plans,

o Location of students, and/or

o Time of day.

 Note the basis of the PADs for other special populations, e.g.:

o Emergency Classification Level (ECL)

o Weather conditions,

o Shelter availability,

o Availability of transportation assets

o Availability of alternate locations for special populations,

o Risk of evacuation vs. risk from avoided dose.

[Name, 

Pg/Sec#]

n/a Facilitate formulation of PADs for special populations, as needed

 Note what PADs are made for special populations, including schools, e.g.:

o Evacuation,

o Shelter-in-Place,

o Administration of KI.

o Precautionary Evacuations.

 Note the time of the protective action decision (or precautionary protective action 

decision), its implementation, and who made it.

 If there was a delay in making the decision, document what the delay was.

 Note the organization/title of the individual who makes the PADs for special 

populations.

[Name, 

Pg/Sec#]

Res.B3a

3.1.2

Identify populations, institutions (e.g., hospitals, nursing homes, correctional 

facilities) and locations to be evacuated or sheltered-in-place

[Name, 

Pg/Sec#]

Res.B3a

3.1.3

Coordinate with law enforcement to identify risk (e.g., from a potential 

terrorist attack) to transportation infrastructure that may be used for evacuation

[Name, 

Pg/Sec#]

n/a In taking the needs of special populations into account, determine appropriate 

course of action to address the incident

 Note whether decisions for school children were based on:

o ORO recommendation,

o ECL at time of notification,

o School plans,

o Location of students, and/or

o Time of day.

 Note the basis of the PADs for other special populations, e.g.:

o Emergency Classification Level (ECL)

o Weather conditions,

o Shelter availability,

o Availability of transportation assets

o Availability of alternate locations for special populations,

o Risk of evacuation vs. risk from avoided dose.

[Name, 

Pg/Sec#]

Res.B3a

3.2.1

Identify appropriate decision making authority responsible for deciding a 

course of action to address the incident

 Note what PADs are made for special populations, including schools, e.g.:

o Evacuation,

o Shelter-in-Place,

o Administration of KI.

o Precautionary Evacuations.

 Note the time of the protective action decision (or precautionary protective action 

decision), its implementation, and who made it.

 If there was a delay in making the decision, document what the delay was.

 Note the organization/title of the individual who makes the PADs for special 

populations.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-25 October 2011

[Name, 

Pg/Sec#]

n/a As needed, coordinate issuance of shelter-in-place protective action decision 

(PAD) for special populations with appropriate entities

[Name, 

Pg/Sec#]

n/a As needed, coordinate issuance of evacuation protective action decision (PAD) 

for special populations with appropriate entities

[Name, 

Pg/Sec#]

Res.B3a

4.4.1

Determine locations of populations who may need assistance with evacuation 

from affected area (e.g., using pre-established registry of populations in 

facilities)

Activity: Provide Dosimetry and Manage Emergency Worker Radiological Exposure 

(3.a.1)

Definition: The OROs issue appropriate dosimetry and procedures, and manage 

radiological exposure to emergency workers in accordance with the plans and/or 

procedures. Emergency workers periodically and at the end of each mission read their 

dosimeters and record the readings on the appropriate exposure record or chart. 

(NUREG-0654/FEMA REP-1, K.3.a, b)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B1b

6.1

Ensure the availability of incident/site-specific training

 Observe the Radiological Officer (or designated staff member) brief the 

emergency workers on exposure control equipment and methodology.

 Note whether emergency workers undertaking life-saving missions or protecting 

valuable property or large populations were briefed on the increased risk from 

radiation.

 Determine whether emergency workers know what the administrative reporting 

exposure limits are and what to do when the limits are reached. 

 Determine whether emergency workers know what the maximum exposure limits 

are, what activities would warrant receiving that kind of dose, and who would 

authorize such activities.

[Name, 

Pg/Sec#]

Res.B1b

6.3

Ensure the provision of appropriate safety and health equipment

 If instructed, verify that the dosimetry kits being distributed to emergency 

workers are those specified in the plan.

 Note whether all emergency workers have been issued TLDs.

 Interview at least two emergency workers.

[Name, 

Pg/Sec#]

Res.B1b

7.5.2

Assist the IC and ICS staff in implementing exposure monitoring and enforcing 

safety considerations

[Name, 

Pg/Sec#]

Res.B1b

7.5.5

Make recommendation to alter, suspend, or terminate any activity judged to be 

an imminent danger or immediately dangerous to life and health

[Name, 

Pg/Sec#]

n/a Ensure that emergency workers (EWs) read their dosimetry on a regular basis 

and note results on their exposure record cards, according to plans

 Note whether emergency workers read their dosimetry on a regular basis as 

specified in the plan, and note the result on their exposure record cards, including 

those being monitored by a group dosimeter or dosimeters.

[Name, 

Pg/Sec#]

n/a Coordinate with safety officer to monitor responders for exposure to 

radiological hazmat
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-26 October 2011

Activity: Implement KI Decision (3.b.1)

Definition: KI and appropriate instructions are available should a decision to 

recommend use of KI be made. Appropriate record-keeping of the administration of KI 

for emergency workers and institutionalized individuals is maintained.

(NUREG-0654/FEMA REP-1, J.10.e)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.C2a

3.2

Coordinate dispensing/administration of mass prophylaxis

 Note how KI is distributed to those who may need to take it. Note whether 

instructions on the use of KI were included with the KI.

 Note how the decision to take KI was disseminated to emergency workers, 

institutionalized individuals, and, if applicable, to the general public.

 Determine if emergency workers have a basic knowledge of procedures for 

ingestion and recording the use of KI, even if the scenario does not drive the use 

of KI. (This can be accomplished by interview.)

[Name, 

Pg/Sec#]

Res.C2a

4.4

Implement local, regional, and state plans for distributing and dispensing 

prophylaxis, this should include procedures for requesting federal SNS assets 

when state and local caches and other available resources have been depleted.

[Name, 

Pg/Sec#]

Res.C2a

4.6

Implement the plan to provide mass prophylaxis to functional and medical 

support sheltering locations for populations with disabilities, etc.

[Name, 

Pg/Sec#]

n/a Ensure proper documentation is created for each emergency worker (EW) 

receiving prophylaxis

 Note whether the ORO has a method of tracking who, other than the general 

public, ingested KI and when.

[Name, 

Pg/Sec#]

Res.C2a

8.2.6

Dispense the appropriate medication and dosage to the population, including 

children, infants and persons with disabilities and access/functional needs

[Name, 

Pg/Sec#]

Res.C2a

8.3.3 Ensure availability of and distribute pre-printed drug information sheets

Activity: Implement Protective Actions for Special Populations (3.c.1)

Definition: Protective action decisions are implemented for special populations other 

than schools within areas subject to protective actions. (NUREG-0654/FEMA REP-1, 

J.10.c, d, g)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B3a

3.1.2

Identify populations, institutions (e.g., hospitals, nursing homes, correctional 

facilities) and locations to be evacuated or sheltered-in-place

 Record the PAD and the time the PAD was reached or received for special 

populations. 

 Identify the groups that were notified. Check for up-to-date lists of special 

populations.

 Check to see if the administrator of each special population‘s facility has a current 

plan?

[Name, 

Pg/Sec#]

Res.B3a

3.4.1

Coordinate with transportation agencies to implement evacuation plans

 Document the names of the transportation provider companies including special 

resources for disabled persons (some calls to transportation providers should be 

actual calls, as indicated in the extent of play). All calls, real and simulated, 

should be logged (obtain a copy of the log maintained of both actual and 

simulated calls to special populations and transportation resources).

 Note any gaps identified between the transportation resources needed and the 

resources available and whether alternate resource providers were identified and 

resources provided.

[Name, 

Pg/Sec#]

Res.B3a

3.5.3

Coordinate medical assistance for evacuees with disabilities and 

access/functional needs in transit
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-27 October 2011

[Name, 

Pg/Sec#]

Res.B3a

3.5.4

Notify appropriate agencies of anticipated medical assistance required upon 

arrival at temporary locations (staging area, shelters, etc.)

[Name, 

Pg/Sec#]

Res.B3a

4.2.4

Coordinate with agencies providing emergency public information and 

warning to ensure effective communication of evacuation/shelter-in-place 

order and procedures

 Note the method(s) used to make notifications and who made the notifications.

[Name, 

Pg/Sec#]

Res.B3a

4.4.1

Determine locations of populations who may need assistance with evacuation 

from affected area (e.g., using pre-established registry of populations in 

facilities)

[Name, 

Pg/Sec#]

Res.B3a

4.5 Implement systems for tracking evacuees and those who shelter in place

[Name, 

Pg/Sec#]

Res.B3a

6.1.1

Coordinate with supporting agencies and pre-arranged providers to obtain 

appropriate means of transportation for those requiring transportation 

assistance (e.g., buses, ambulances, handicap-assisted vans)

[Name, 

Pg/Sec#]

Res.B3a

6.1.2

Implement plans for providing alternative means of transport for immobilized 

individuals or those needing other special assistance in transit

[Name, 

Pg/Sec#]

Res.B3a

6.3.1

Collect individuals at pre-established collection points and transfer to 

staging/reception area

Activity: Implement Protective Actions for Schools (3.c.2)

Definition: OROs/School officials implement protective actions for schools103. 

(NUREG-0654/FEMA REP-1, J.10.c, d, g)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

n/a Implement protective action decision (PAD), ensuring coordination with all 

appropriate agencies

 Record the ECL, time, who notified school official(s), and how the notification 

was received. All school district(s) must be contacted.

 Note what protective action was used:

o Cancellation of School,

o Early dismissal,

o Shelter-in-Place, or

o Evacuate.

 Observe whether there is a current copy of the plan available at the school.

 Determine what actions the school would take.

 Document the communication systems used to notify schools and parents. 

 Determine what responsibilities the school has after the children arrive at the 

reception center.

[Name, 

Pg/Sec#]

Res.B3a

3.4.1 Coordinate with transportation agencies to implement evacuation plans

[Name, 

Pg/Sec#]

Res.B3a

3.5.3

Coordinate medical assistance for evacuees with disabilities and 

access/functional needs in transit

[Name, 

Pg/Sec#]

Res.B3a

3.5.4

Notify appropriate agencies of anticipated medical assistance required upon 

arrival at temporary locations (staging area, shelters, etc.)

[Name, 

Pg/Sec#]

Res.B3a

4.2.4

Coordinate with agencies providing emergency public information and 

warning to ensure effective communication of evacuation/shelter-in-place 

order and procedures

 Note what method was used to notify parents.

 Note who notifies the parents of actions taken to protect the students, and when.

 Observe whether there was coordination with the ORO‘s Public Information 

Officer to determine the correct information on the status of protective actions for

schools.

[Name, 

Pg/Sec#]

Res.B3a

4.5 Implement systems for tracking evacuees and those who shelter in place

 

103 Schools include all public schools, licensed day care centers, and participating private schools.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-28 October 2011

[Name, 

Pg/Sec#]

Res.B3a

6.1.1

Coordinate with supporting agencies and pre-arranged providers to obtain 

appropriate means of transportation for those requiring transportation 

assistance (e.g., buses, ambulances, handicap-assisted vans) 

 Determine whether the bus driver is aware of where to take the students or has a 

current map to the location.

 If required by the plan, note if the bus driver is knowledgeable about emergency 

worker exposure control (dosimetry).

[Name, 

Pg/Sec#]

Res.B3a

6.1.2

Implement plans for providing alternative means of transport for immobilized 

individuals or those needing other special assistance in transit

[Name, 

Pg/Sec#]

Res.B3a

6.3.1

Collect individuals at pre-established collection points and transfer to 

staging/reception area

[Name, 

Pg/Sec#]

Res.B3a

9.3.1 Ensure access to emergency communications while sheltered-in-place

Activity: Implement Traffic and Access Control (3.d.1)

Definition: Appropriate traffic and access control is established. Accurate instructions 

are provided to traffic and access control personnel. (NUREG-0654/FEMA REP-1, J.10.g, 

j)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B3d

3.1.1 Identify personnel needed to maintain security support and response

[Name, 

Pg/Sec#]

Res.B3d

3.1.2

Deploy appropriate personnel for public safety and security

 Check that TCP/ACPs were established (identified, staffed, and established) in 

timely manner for the affected areas. 

[Name, 

Pg/Sec#]

Res.B3d

3.1.3

Establish staging areas for law enforcement to conduct deputization, personnel 

assignment, and briefing prior to entering the impacted area

[Name, 

Pg/Sec#]

Res.B3d

3.2

Coordinate public safety and security operations with Incident 

Command/Unified Command

 Document time and ECL when rail, water, and air traffic access control were 

notified by the ORO.

 Note whether instructions were provided to traffic and access control staff on 

changes/modifications of protective action decisions.

 Note whether access control personnel were moved when protective action 

decisions expanded the affected area.

[Name, 

Pg/Sec#]

Res.B3d

3.4 Implement and maintain an on-scene personnel identity management system

[Name, 

Pg/Sec#]

Res.B3d

6.1 Identify and establish an incident perimeter and zones

[Name, 

Pg/Sec#]

Res.B3d

6.3

Control traffic and crowds

 Determine if traffic and access control personnel have accurate knowledge of 

their roles and responsibilities, including: 

o Location of traffic and/or access control point(s),

 The Exposure Control Items Are Evaluated Under Criterion 3.a.1 

or 3.b.1

 Radiological Exposure Control, including:

- Dosimetry,

- Knowledge of administrative and turn back limits,

- KI – knowledge of purpose, who authorizes, etc.

o Location of reception/registration centers,

o Location of emergency worker monitoring and decontamination center, 

and

o Equipment available to establish traffic and access control points.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-29 October 2011

Activity: Identify and Resolve Impediments to Evacuation (3.d.2)

Definition: Impediments to evacuation are identified and resolved.

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B3a

3.3.1

Re-assess evacuation traffic management plan and adjust as needed

 Identify impediments to evacuation.

 Note if actions (actual or simulated) to remove impediments are taken in a timely 

manner.

[Name, 

Pg/Sec#]

Res.B3a

3.3.1.1

Re-assess emergency evacuation routes and adjust as needed

[Name, 

Pg/Sec#]

Res.B3a

5.2.1

Coordinate with appropriate agencies regarding support for traffic control

 Obtain log of all contacts (actual or simulated) with resources.

 Note if resources were available when needed.

[Name, 

Pg/Sec#]

Res.B3a

5.3

Monitor evacuation traffic flow/demand and adjust evacuation traffic 

management plan and measures as appropriate

[Name, 

Pg/Sec#]

Res.B3a

5.4.1

Provide services (e.g., gas, food, water, tow trucks, etc.) along the evacuation 

route(s)

 Note whether organizations were identified to assist in removal of impediments.

Activity: Activate the Prompt Alert and Notification System (5.a.1)

Definition: Activities associated with primary alerting and notification of the public are 

completed in a timely manner following the initial decision by authorized offsite 

emergency officials to notify the public of an emergency situation. The initial 

instructional message to the public must include as a minimum the elements required by 

current FEMA REP guidance. (NUREG-0654/FEMA REP-1, E.5, 6, 7)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B1f 3.1 Coordinate public emergency information

[Name, 

Pg/Sec#]

Res.B1f

3.3.1 Plan and coordinate warnings, instructions, and information updates

[Name, 

Pg/Sec#]

Res.B1f 5.1 Activate plans, procedures, and policies for coordinating, managing, and 

disseminating public information and warning

[Name, 

Pg/Sec#]

n/a Ensure primary alerting and notification of the public is completed in a timely 

manner (i.e., with a sense of urgency and without undue delay)

 At ORO:

o Note time of Alert Signal (can be simulated).

 Method used: sirens, tone alert radios, etc.

o Note time of instructional message.

 Method used: EAS station, National Weather Service (NWS), etc. 

o Identify the ORO that authorized the alert and notification (A&N) 

sequence.

o Document any delays or reasons why message(s) were not timely.

[Name, 

Pg/Sec#]

n/a Provide initial instructional message to the public that is clear and accurate 

and, at a minimum, includes all element required by FEMA REP guidance

 Observe whether message contents were clear and accurate? Did they correctly 

reflect the protective action decisions (PADs)? (Obtain copies of the messages)

 Note if the message was pre-scripted. If so, did it contain all the required FEMA 

guidance?

 Observe whether the EAS station or other notification method was kept updated 

by the ORO about which messages to continue broadcasting, and at what time 

intervals.

 Note if the ORO issued follow-on news releases/special news broadcasts after 

activation of the EAS or other notification method. (Obtain copies of the 

messages)
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-30 October 2011

Activity: Conduct Alert and Notification of Exception Areas and Back-Up Alert and 

Notification (5.a.3)

Definition: Activities associated with FEMA approved exception areas (where 

applicable) are completed within 45 minutes following the initial decision by authorized 

offsite emergency officials to notify the public of an emergency situation. Backup alert 

and notification of the public is completed with 45 minutes following the detection by 

the ORO of a failure of the primary alert and notification system.

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

n/a Ensure alerting and notification of the public is completed in a timely manner 

(i.e., with a sense of urgency and without undue delay).

 Document any delays or cause why message not considered timely.

[Name, 

Pg/Sec#]

n/a Conduct backup alert and notification of the public when the primary alert and 

notification system fails.

 Document whether notification of the public is completed within 45 minutes 

following the detection by the ORO of a failure of the primary alert and 

notification system.

 Note if a route (or routes) was actually demonstrated (or simulated if inclement 

weather).

 Note the length of time it took to run the route, if it was actually demonstrated.

[Name, 

Pg/Sec#]

n/a Provide instructional messages to the public that are clear and accurate and, at 

a minimum, includes all element required by FEMA REP guidance.

 Check to see if the message contents included elements required by current 

FEMA REP guidance (obtain copy of message). Note that actual message should 

be read to evaluator – but not broadcasted.

[Name, 

Pg/Sec#]

ComC 1.6 Develop supplemental and backup communications and information 

technology plans, procedures, and systems.

[Name, 

Pg/Sec#]

n/a Ensure alerting and notification of the public is completed in a timely manner 

(i.e., with a sense of urgency and without undue delay)

 Document any delays or cause why message not considered timely.

[Name, 

Pg/Sec#]

n/a Conduct notification of exception areas

 Document whether notification of exception areas was completed within 45 

minutes following initial decision.

 Note if a route (or routes) was actually demonstrated (or simulated if inclement 

weather).

 Note the length of time it took to run the route, if it was actually demonstrated.

[Name, 

Pg/Sec#]

n/a Provide instructional messages to the public that are clear and accurate and, at 

a minimum, includes all element required by FEMA REP guidance

 Check to see if the message contents included elements required by current 

FEMA REP guidance (obtain copy of message). Note that actual message should 

be read to evaluator – but not broadcasted.

Activity: Provide Emergency Information and Instructions for the Public and the 

Media (5.b.1)

Definition: Offsite response organizations (OROs) provide accurate emergency 

information and instructions to the public and the news media in a timely manner. 

(NUREG-0654/FEMA REP-1, E.5, 7; G.3.a, G.4.c)

ORO 

Plan Ref

TCL 

Task # Task

[Name, 

Pg/Sec#]

Res.B1f 3.1 Coordinate public emergency information
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-31 October 2011

[Name, 

Pg/Sec#]

Res.B1f

3.2.2

Coordinate and integrate the resources and operations of external affairs 

organizations to provide accurate, consistent, and timely information through 

the Joint Information Center (JIC)

[Name, 

Pg/Sec#]

Res.B1f

3.3.1 Plan and coordinate warnings, instructions, and information updates

[Name, 

Pg/Sec#]

Res.B1f

3.3.3

Coordinate with emergency operations center (EOC)/responders for public 

safety concerns that need to be disseminated

[Name, 

Pg/Sec#]

Res.B1f

3.3.5

Monitor communications and information systems as needed to identify 

information to be disseminated to public

[Name, 

Pg/Sec#]

Res.B1f

3.3.6

Coordinate with law enforcement and provide media outlets to provide the 

public with accurate, consistent, and timely information

[Name, 

Pg/Sec#]

Res.B1f 5.1 Activate plans, procedures, and policies for coordinating, managing, and 

disseminating public information and warnings

[Name, 

Pg/Sec#]

Res.B1f 4.2 Ensure appropriate representation of all relevant public affairs entities, to 

include nongovernmental organizations and the private sector, in any JIC that 

is established by the government

[Name, 

Pg/Sec#]

Res.B1f

4.2.1 Assign Public Information Officer (PIO)

[Name, 

Pg/Sec#]

Res.B1f

4.2.2 Identify appropriate spokesperson(s)

[Name, 

Pg/Sec#]

Res.B1f

5.1.1

Coordinate the provision of timely and accurate emergency public information 

through the Joint Information System (JIS)

 Compare EAS or other notification method, Special News Broadcasts messages, 

press releases, media briefings, and media inquiries for consistency and accuracy.

[Name, 

Pg/Sec#]

Res.B1f

6.1.3

Provide a central contact for the media through the JIC, ensuring a ―one 

accurate message, many voices‖ approach to information dissemination

 Observe if the media spokesperson (i.e., the Public Information Officer (PIO)) 

handled media inquiries and telephone inquiries.

[Name, 

Pg/Sec#]

Res.B1f 6.2 Coordinate emergency public information through the JIS

 Note that incoming and outgoing messages and media releases were logged. 

(Obtain a copy of the log.)

[Name, 

Pg/Sec#]

Res.B1f

6.2.1 Implement routing and approval protocols for release of information

[Name, 

Pg/Sec#]

Res.B1f

6.2.3 Provide for external media support and operations

[Name, 

Pg/Sec#]

Res.B1f

7.2.6.1 Correct misinformation before next news cycle

[Name, 

Pg/Sec#]

Res.B1f

7.2.8 Provide for rumor control within information network

[Name, 

Pg/Sec#]

Res.B1f 7.5 Prepare post-incident information

[Name, 

Pg/Sec#]

Res.B1f 5.2 Provide emergency public information to persons with disabilities and 

access/functional needs and special populations

[Name, 

Pg/Sec#]

Res.B1f

5.2.1

Disseminate prompt, accurate information to the public in appropriate 

languages and formats that take into account demographics and persons with 

disabilities and access/functional needs

 Determine whether emergency information was disseminated in a non-English 

language, if required.

[Name, 

Pg/Sec#]

Res.B1f

5.2.4

Provide emergency public information to special, vulnerable, and at-risk 

populations that are economically disadvantaged, have limited language 

proficiency, have disabilities (physical, mental, sensory, or cognitive 

limitations), experience cultural or geographic isolation, or are vulnerable due 

to age

[Name, 

Pg/Sec#]

Res.B1f

5.2.5

Provide emergency information to the public that is verified, accurate, and as 

up-to-date as possible

 Note whether the ORO updated the media and the EAS station(s) or other 

notification method as information developed. 
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-32 October 2011

[Name, 

Pg/Sec#]

n/a Provide instructional messages to the public that are clear and accurate and, at 

a minimum, includes all element required by FEMA REP guidance

 Document whether emergency information and instructions:

o Were consistent with protective action decisions made by appropriate 

officials,

o Were current (invalid or outdated information deleted),

o Were complete, containing all necessary and applicable instructions for 

public,

o Contained evacuation instructions including evacuation routes,

o Indicated Reception Center locations,

o Included information on what to take when evacuating,

o Included information on pets,

o Described shelter-in-place information (if applicable),

o Contained information on schools and special populations,

o Listed a public information or inquiry telephone number

o Referenced Public Information Brochures and other printed sources of 

emergency information (such as telephone books),

o Described routes and locations using familiar landmarks and road names.

[Name, 

Pg/Sec#]

Res.B1f

5.5.2

Disseminate critical health and safety information designed to alert the public 

to clinical symptoms and reduce the risk of exposure to ongoing and potential 

hazards

[Name, 

Pg/Sec#]

Res.B1f

7.2.1

Provide periodic updates and conduct regularly scheduled media conferences

 Document media briefings: Number, times, content of briefings, and whether 

information disseminated was accurate.

 Document press releases: Number, times, copies of releases, and accuracy of 

information. Observe whether copies of news releases and EAS or other 

notification method messages were retained and provided to media? (Obtain 

copies and copy of media log and, if there is one, a copy of the media kit.)

 Note whether information is repeated at pre-established intervals. If so, how often 

was information repeated?

[Name, 

Pg/Sec#]

Res.B1f

7.2.4

Monitor media coverage of event to ensure that information is accurately 

relayed

 Note whether media broadcasts were monitored.

[Name, 

Pg/Sec#]

Res.B1f

7.2.6

Issue corrective messages when errors are recognized in previous public 

announcements

 Verify that trends and/or rumors are addressed in media releases.

[Name, 

Pg/Sec#]

Res.C2a

3.4

Coordinate public information releases regarding location of points of 

dispensing (PODs)

[Name, 

Pg/Sec#]

Res.B3a

4.2.4

Coordinate with agencies providing emergency public information and 

warning to ensure effective communication of evacuation/shelter-in-place 

order and procedures

[Name, 

Pg/Sec#]

Res.B3a

5.1.2 Provide information regarding evacuation staging area location

[Name, 

Pg/Sec#]

n/a Provide return information to the public on a timely and on-going basis

[Name, 

Pg/Sec#]

n/a Coordinate with appropriate agencies to provide instructions and information if 

return is not feasible

3. CUSTOMIZING EEGS FOR AN 

EXERCISE

During the exercise planning process, the FEMA 

Region customizes the master Capability-based 

EEGs for each location or functional entity to 

reflect the actual Demonstration Criteria 

scheduled for evaluation. The regions may 

involve the exercise planning team (EPT) in the 

customization process. In addition, the 

Capability-based EEGs are customized to reflect 

the response framework established in the 

applicable OROs‘ plans and procedures. This 

tailoring process results in a set of EEGs that 

have been modified to reflect each ORO‘s 

specific plans and procedures and the applicable 

REP Demonstration points of review found in 
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-33 October 2011

the Exercise Preparation Guide. Thus, for 

example, the Master Emergency Operations 

Center EEG in the previous exhibit may look 

entirely different when prepared for a county 

EOC versus a sub-county jurisdiction (e.g., 

township, borough) EOC. 

The Master Emergency Operations Center EEG

contains activities and tasks related to 

Demonstration Criteria 1.a.1, 1.b.1, 1.c.1, 1.d.1, 

1.e.1, 2.a.1, 2.b.2, 2.c.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 

3.d.1, 3.d.2, 5.a.1, 5.a.3, and 5.b.1. However, all 

of these Demonstration Criteria might not be 

scheduled for evaluation during a particular 

exercise, or at the applicable EOC. For example, 

a facility inspection (1.b.1) is not required unless 

the facility is new or substantially changed since 

the baseline inspection. In this case, items 

associated with the activity ―Provide Sufficient 

Facilities (1.b.1)‖ would be deleted from the 

EEG template.

The EEG template can be further tailored to 

reflect responsibilities applicable to each 

jurisdiction/functional entity. A sub-county 

jurisdiction might receive instructions from the 

county and have no direct responsibility for 

activities such as activating the prompt alert and 

notification system (5.a.1), providing emergency 

information and instructions for the public and 

media (5.a.3), or protective action decision 

making (2.b.2). Depending on the local authority 

structure, responsibility for activities such as 

implementation of protective actions for schools 

(3.c.2) could belong to any combination of the 

county, sub-county governmental jurisdiction, 

and the school district.

The tasks listed under each activity are then 

customized to reflect actual tasks expected to be 

performed at each location or by each functional 

entity according to their associated plans and 

procedures. For example, some OROs assign 

different entities with the tasks needed to 

implement the protective action decisions for 

schools (Activity ―Implement Protective Actions 

for Schools (3.c.2)‖. The County EOC may be 

responsible for notifying the schools and the 

public of the decision to relocate students, but 

the schools are responsible for arranging 

transportation and medical assistance. In this 

case, the EEG would be tailored for the County 

EOC by keeping the appropriate tasks and 

removing the others. 

Finally, the ORO Plan Reference column 

provides a plan/procedure reference showing the 

specific location of the material that addresses 

each task. As with the EEG customization, this 

information will be entered in at the discretion 

of the Region. Plan/procedure references can be 

inserted by the EPT, exercise support staff, or 

the evaluators as part of their pre-exercise 

preparation.

I. EMERGENCY PLANNING ZONE BOUNDARY CHANGES

In accordance with NUREG-0654/FEMA-REP1, Revision 1, an EPZ is defined as the area

surrounding an NPP for which planning is

needed to ensure that prompt and effective

actions can be taken to protect the public in an

accident or incident at the site. Generally, the

plume exposure pathway of the EPZ is an area

about 10 miles in radius, and the ingestion

pathway is about 50 miles in radius.

If an ORO wants to change the boundary of an

existing EPZ, the proposal must be submitted to

the FEMA Regional Administrator or his/her

designee, usually the RAC Chair. The proposal

shall include, but not be limited to:

 Action by appropriate ORO officials

desiring the change to the boundary (i.e.,

resolution by elected official, etc.);

 Description of the change to the boundary;

 Discussion of the population affected by the

change;

 Effect that the change has on evacuation

routes or evacuation time estimates; and
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-34 October 2011

 Maps showing the existing EPZ boundary

and proposed new boundary.

FEMA and the RAC will review the request on

its merits. After the regional review, the request

and RAC recommendation will be forwarded to

FEMA Headquarters for final action.

If the EPZ boundary change is approved, the

approval is contingent on the ORO submitting

for review the appropriate changes to their

plans/procedures, maps of the EPZ, public

information material, and impact that the

addition or subtraction of population from the

EPZ has on the evacuation time estimates. The

required information would include changes to

the geographical boundary descriptions and the

ANS, including additional sirens or other means

for public notification. Any modifications to an

ANS must be consistent with FEMA-REP-10.

J. CREDENTIALING FRAMEWORK

REP Program Credentialing Framework, December 2010

Credentialing is the administrative process for 

validating personnel qualifications and 

providing authorization to perform specific 

functions3. For purposes of the REP Program 

Credentialing Framework, it is a system that 

defines levels of proficiency for individuals 

participating in REP Program exercise 

evaluations and plan reviews. Credentialing 

ensures that individuals are qualified and 

experienced in performing their roles and 

responsibilities. It assesses whether an 

individual meets the training and experience 

required to perform tasks within a proficiency 

level. 

The Credentialing Framework enables the REP 

Program to consistently manage current and 

prospective REP Program evaluators and plan 

reviewers. The Framework ensures they meet 

specific requirements and possess the 

knowledge, skills, and abilities needed to 

successfully evaluate an exercise or review a 

plan. Credentialing does not provide a 

certification, license, or badge. However, it will 

provide: 

 A framework for individuals to become 

qualified in serving at various proficiency 

levels for evaluating exercises and 

reviewing plans. 

 A reference to accurately identify training 

gaps and needs of REP evaluators and plan 

reviewers. 

 A uniform system of processes and tools to 

assess the evaluator/plan reviewer‘s 

development. 

The three major components of the 

Credentialing Framework are training, 

practicum, which is a practical application of 

skills involving evaluator on-the-job training 

(OJT) and plan reviewer mentorship, and 

experience. The proficiency levels link these 

three components together. 

An individual will be designated one of four 

possible levels depending upon the 

qualifications met and the proficiency 

demonstrated: Trainee, Type III, Type II, and 

Type I (increasing, respectively, in proficiency). 

An individual will initially enter as a Trainee 

pursuing one or both of the functional areas, 

Emergency Operations and Technical 

Operations. Contingent upon successful 

completion of training, an individual will be 

assigned a higher proficiency level 

commensurate with experience and 

qualifications. In order to advance to a 

subsequent level, individuals must meet all 

requirements of their current proficiency level 

for evaluator or plan reviewer track.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-35 October 2011

K. USE OF STATE, LOCAL, AND TRIBAL PERSONNEL AS REP

EXERCISE EVALUATORS

1. ADMINISTRATIVE PROCESS

Training Requirement: State, local, and tribal

personnel must successfully complete the

training/experience required of all FEMA

evaluators.

Application Packet: Applicants complete and

submit their qualification packets to the RAC 

Chair, which must include the following

materials: 

 Resumé describing actual REP-related

experience and/or equivalent experience;

 Evidence of completion of FEMA

credentialing program

 Two reference letters addressing the

evaluator‘s ability to be impartial,

suitability, and qualifications (applicants

must be high school graduates, or

equivalent [college is recommended]); and

 Commitment signed by the applicant‘s

employer.

Application Review: The RAC Chair reviews

the application and determines whether to

approve it. Selected candidates are assigned to

their respective Home of Record FEMA Region

for incorporation into that Regions‘ roster. State,

local, and tribal personnel may not evaluate

within their state (Home of Record); county

personnel may not evaluate within their state

(Home of Record) or within the EPZ for their

site. The accepting RAC Chair is responsible for

communications with the assigned evaluator,

and will send to each applicant a selection/nonselection letter.

National Registry: FEMA Headquarters

maintains a national registry of available

qualified ORO evaluators.

2. HOST REGION RESPONSIBILITIES

The FEMA Host Region will:

 Request evaluator(s) for upcoming exercise;

 Match training/educational skills to the

assignment;

 Complete an informal proximity and travel

cost/benefit analysis;

 Budget and pay for invitational travel

expenses, including transportation and per

diem;

 Select, assign, and approve or disapprove

evaluator candidates; and

 Send invitational travel letter to prospective

evaluators.

3. EVALUATOR RESPONSIBILITIES

The evaluator will:

 Evaluate at least one exercise per year, to

remain active;

 Review all exercise material;

 Participate in all required exercise meetings;

 Prepare all written exercise evaluator

documentation; and

 Ensure time flexibility in participating as an

evaluator (may require weekend duty).

4. EVALUATOR EMPLOYER

COMMITMENT:

The evaluator‘s employer will facilitate

employee attendance at all required evaluator

training, meetings, etc., and agree, in writing, to

the conditions stated below.

5. CONDITIONS

ORO REP exercise evaluators are not eligible to

receive any compensation, workmen‘s or other;

health insurance; life insurance; annual or sick

leave; Federal monetary awards; or any other

benefits from FEMA. Evaluator performance

does not count toward career tenure or time in

service to the Federal government.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-36 October 2011

L. TRIBAL POLICIES AND PROCEDURES

1. FEDERALLY RECOGNIZED TRIBAL 

NATIONS AND THE REP PROGRAM

In support of the Presidential policy

memorandum issued April 29, 1994, Federallyrecognized Tribal Nations must be part of all

Federal programs. Pursuant to this Presidential

policy, FEMA developed and instituted the Final

Agency Policy on Government-to-Government

Relations with American Indians and Alaska

Native Tribal Governments (Federal Register,

January 12, 1999).

2. DEFINITIONS

Indian Tribe: Indian or Alaska Native Tribe,

band, nation, pueblo, village, or community that

the Secretary of the Interior acknowledges to

exist as an Indian Tribe under the Federally

Recognized Indian Tribe List Act of 1994, 25

U.S.C. 479a.

Tribal Government: Recognized governing body

of an Indian Tribe, band, nation, pueblo, village,

or community, including any Alaska Native

Village defined in or established pursuant to the

Alaska Native Claims Settlement Act (85 Stat.

688).

3. POLICY

FEMA recognizes that Tribes‘ right of selfgovernment flows from the inherent sovereignty

of Tribes as nations and that the Federallyrecognized Tribes have a unique and direct

relationship with the Federal Government.

Furthermore, FEMA recognizes that, as a

sovereign government, each tribal government

has the right to set its own priorities and goals.

FEMA acknowledges the trust relationship

between the Federal Government and American

Indian and Alaska Native tribal governments,

and will evaluate to the extent possible the

impact of policies, programs, and activities on

tribal trust resources and assure that they

consider the rights and concerns of tribal

governments. Every Federal employee has the

responsibility to protect the trust relationship

with Federally-recognized Tribal Nations.

One Tribal Nation, the Prairie Island Nation, is

located within the 10-mile EPZ of an NPP. In

addition, many Tribal Nations are located within

the 50-mile ingestion pathway EPZ of an NPP.

Each Region, except for Region III, has an

identified tribal Liaison. At this time, Region III

is the only FEMA Region without any

Federally-recognized tribes.

The Emergency Management Institute (EMI)

has developed an Internet course, Building

Partnerships with Tribal Governments, EMI

Independent Study Program. This course is

designed to raise awareness prior to working

with Tribal Nations. Everyone is strongly

encouraged to take the course. The course can be

located on the EMI website.

The main website page for FEMA

(www.fema.gov) contains a link to a website for

tribal information (www.fema.gov/government/

tribal/index.shtm). The tribal Liaison at FEMA

Headquarters maintains this page. Among the

items on the site is the complete FEMA policy

on Tribal Nations, as well as maps prepared by

Geographic Information System that indicate the

locations of tribal lands.

M. STAFF ASSISTANCE VISITS

The purpose of an SAV is to provide assistance

to OROs. The SAV may also be used to support

demonstration/evaluation of certain

Demonstration Criteria as shown in Exhibit III2, Federal Evaluation Process Matrix.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-37 October 2011

An SAV is coordinated with the affected OROs.

The visits may be initiated by the FEMA

Regional Office or requested by the OROs.

The purposes of the SAV may include, but are

not limited to:

 Providing technical assistance to OROs

regarding their plans/procedures or their

implementation.

 Supporting development or completion of

state requests for plan/procedure approval

under 44 CFR Part 350.

 Attending meetings with OROs and the

licensee. These meetings are initiated by

either the state or licensee, and FEMA is

invited to attend.

 Participating in ORO emergency training.

 Attending and participating in exercises and

drills to provide support and/or exchange

ideas and suggestions.

 Assisting emergency responders with the

development and submission of

applications for credit for responses to

actual emergencies.

 Verifying statements and documentation

provided in the ALC and ORO

plans/procedures, including:

 Equipment and supplies for

emergency workers;

 Supply and operability of

monitoring equipment;

 Dosimetry supplies, operation, and

maintenance performed according

to manufacturer recommendations;

 Assuring KI supply and its

currency for both emergency

workers and, if state policy, the

general public; and

 Reviewing training records related

to the REP Program.

 Meeting with tribal Nations located in either

the plume and/or ingestion exposure

pathway EPZs.

N. EVACUATION TIME ESTIMATES

Evacuation Time Estimates (ETEs) are required

within the plume exposure pathway EPZ by

NUREG-0654/FEMA-REP-1 under Planning

Standard J: Protective Response (Evaluation 

Criterion J.10.m) and Appendix 4: Evacuation

Time Estimates. Please note they are not

required for the ingestion EPZ.

NUREG-0654/FEMA-REP-1 requires the

licensee to prepare the ETEs and the state to

include the information in its plans/procedures,

but FEMA does not review or approve ETEs.

Instead, FEMA reviews ORO plans/procedures

to see whether they include the latest ETE

information from the licensee.

NRC provides guidance to licensees in the

document NUREG/CR7002, Criteria for 

Development of Evacuation Time Estimate 

Studies. This guidance requires that ETEs be

updated following each decennial census. In

addition, an ETE update must be performed if at

any time during the 10-year period the EPZ

permanent resident population estimate

increases such that it causes the longest ETE

value for the 2-mile zone or 5-mile zone,

including affected emergency response planning

areas, or for the entire 10-mile EPZ to change by

25 percent or 30 minutes, whichever is less,

from the licensee‘s currently approved ETE.
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REP Program Manual Page IV-38 October 2011

O. POTASSIUM IODIDE FOR THE PUBLIC

Federal Register, Volume 66, No. 13, pp. 5427-5440, Consideration of Potassium Iodide in Emergency 

Plans, Final Rule, Nuclear Regulatory Commission, January 19, 2001

Federal Register, Volume 67, No. 7, pp. 1335-1357, Federal Policy on Use of Potassium Iodide (KI), 

Federal Emergency Management Agency, January 10, 2002

Guidance for Federal Agencies and State and Local Governments Potassium Iodide Tablets Shelf Life 

Extension, Food and Drug Administration, March 2004

FEMA’s REP Program Guidance to State and Local Governments for Shelf-Life Extension of Potassium 

Iodide (KI), April 12, 2007

Planning Requirements: In 2001, the NRC 

revised emergency planning regulations in 10 

CFR § 50.47 to require that planners consider

including KI as a protective measure for the 

general public to supplement sheltering and

evacuation. The NRC also agreed to fund state, 

and, in some cases, local KI stockpiles. State and 

governments are responsible for all other 

funding connected with the incorporation of KI, 

such as preparing guidelines for its stockpiling, 

maintenance, distribution and use, and any other 

ancillary costs.

Federal Policy on the Use of KI: The FRPCC 

revised Federal policy regarding the use of KI as 

a thyroidal blocking agent by emergency 

workers, institutionalized persons and the 

general public in the vicinity of nuclear power 

plants. The Federal position is that KI should be 

stockpiled and distributed to emergency workers 

and institutionalized persons for radiological 

emergencies at a nuclear power plant and its use 

should be considered for the general public 

within the 10-mile EPZ of a nuclear power plant. 

However, the decision on whether to use KI for 

the general public is left to the discretion of 

States and, in some cases, local governments.

KI Shelf Life: FEMA issued a policy paper in 

2007 providing guidelines for OROs to use in

determining whether the expiration date of

stored KI may be extended. Procedures for

implementing and documenting the extension

are also included. The policy paper incorporates

the guidance contained in the Food and Drug

Administration‘s letter to the NRC, dated

February 15, 2007, which details how KI tablets‘

shelf life may be extended in 2-year increments

under certain conditions. It also incorporates the

guidance contained in the FDA Center for Drug

Evaluation and Research paper Guidance for

Federal Agencies and State and Local

Governments, Potassium Iodide Tablets, Shelf

Life Extension, dated March 2004, which details

the laboratory testing necessary to ensure

continued stability of the KI.

How to Obtain KI: States interested in 

obtaining a supply of KI for distribution to the 

public should send a request letter to Director, 

Division of Preparedness and Response, Office 

of Nuclear Security and Incident Response, US 

NRC, Washington, DC 20555.
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REP Program Manual Page IV-39 October 2011

P. CONDUCTING PLAN REVIEWS

1. RADIOLOGICAL EMERGENCY 

PREPAREDNESS 

PLANS/PROCEDURES

REP plans/procedures describe what a given 

jurisdiction will do in case of a radiological 

emergency. The plans/procedures are part of an 

organization‘s emergency operations plan for all 

types of hazards and may be documented as a 

hazard-specific appendix to the emergency 

operations plan as recommended in FEMA‘s 

Comprehensive Preparedness Guide 101. Most of 

the plan/procedure is devoted to describing the 

emergency response activities and functions that 

must be performed and designating the OROs 

that perform them. Most plans/procedures 

describe emergency functions at three levels of 

detail:

 A ―concept of operations‖ section gives an 

overview of the entire jurisdiction‘s 

response organization and briefly describes 

the main functions of each agency.

 Agency-specific chapters give more 

detailed descriptions of agency roles and 

responsibilities.

 Step-by-step procedures outline the tasks to 

be performed by particular response staff, 

and are incorporated into the plan or 

attached as separate volumes. For example, 

the Health Department may have a specific 

procedure for its EOC representative, 

outlining which Health Department 

resources to activate at particular ECLs. 

Health Department staff members assigned 

to radiological monitoring may have their 

own procedures that outline equipment 

checks, monitoring procedures, reporting 

protocols, etc.

A REP Plan also generally describes how the 

jurisdiction‘s response efforts relate to the 

efforts of other jurisdictions and organizations, 

such as the licensee, neighboring OROs, and the 

Federal Government. 

In addition to describing emergency roles, 

plans/procedures contain policies and 

procedures for routine administration of the 

preparedness program. For example, the REP 

plans/procedures are required to cite the 

statutory authority and responsibilities of public 

officials with respect to emergency 

management, describe the jurisdiction‘s 

preparedness training and exercise program, and 

assign responsibilities and procedures for 

maintaining equipment and updating the 

plans/procedures.

A REP plan is generally prepared by a state, 

county, local, or tribal jurisdiction. In some 

cases, a specific agency or institution, such as a 

school district, hospital, university, or 

correctional facility, will have its own 

plans/procedures. Preparation of these 

plans/procedures is coordinated with the 

plans/procedures of the jurisdiction in which the 

institution is located. Such plans/procedures 

usually cover only a subset of functions within 

an organization‘s all-hazards emergency 

operations plan. However, they are reviewed 

because they may be the primary documents that 

guide efforts to protect particular parts of the 

population. In addition, portions of a REP plan 

may also consist of separate documentation 

(e.g., detailed training plans, public 

information/affairs procedures) that supports the 

plan‘s core components (i.e., concept of 

operations, agency-specific chapters, and stepby-step procedures, as mentioned above). This 

supporting documentation is reviewed to verify 

the adequacy of planning to satisfy various 

criteria of the NUREG-0654/FEMA-REP-1 

Planning Standards and other REP guidance. 

The term ―plans/procedures‖ as used in this 

manual includes radiological emergency 

preparedness/response plans/procedures, 

associated implementing procedures such as 

Standard Operating Guides, and other 

supporting and referenced materials, all of which 

are subject to review. The generic term 

―plans/procedures‖ is used specifically to allow 
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-40 October 2011

flexibility. Procedures may be either 

incorporated in the main plans or into separate 

procedural documents at the discretion of the 

ORO.

2. DIVISION OF FUNCTIONS AND 

APPLICABILITY OF CRITERIA

NUREG-0654/FEMA-REP-1 contains the 

Planning Standards and Evaluation Criteria 

adopted by the NRC and FEMA for evaluating 

REP plans/procedures and preparedness. 

Licensees and OROs generally work together to 

ensure that all emergency response functions 

and capabilities described in NUREG0654/FEMA-REP-1 are available. However, the 

specific allocation of functions among 

jurisdictions may vary from site to site. Some 

functions described in NUREG-0654/FEMAREP-1 may be primarily (or solely) state

responsibilities; some may be local 

responsibilities; and others may be both. 

When evaluating a REP plan, the reviewer must 

be aware of the functions for which the 

jurisdiction is responsible. Generally, these 

functions are described in the concept of 

operations section of the plans/procedures. In 

some cases, it may be necessary for the reviewer 

to examine other related plans/procedures to 

determine how responsibilities are allocated 

among jurisdictions. For example, when 

reviewing ORO plans/procedures, it may be 

necessary to examine the corresponding state

plans/procedures to fully understand the 

breakdown of responsibilities between the state

and the local jurisdictions. Although the 

applicability of each Evaluation Criterion to 

tribal plans/procedures are not specified, 

generally most criteria applicable to local 

government plans/procedures (and perhaps some 

applicable to state plans/procedures) will also be 

applicable to tribal plans/procedures. Once 

again, the reviewer must be aware of the overall 

concept for offsite emergency response and the 

functions for which the jurisdiction is 

responsible. 

Plan reviews are conducted as shown in Exhibit 

IV-4.

Exhibit IV-4: Plan Review Responsibility

Plan Review Activity Responsible Agency

Application for formal FEMA 44 CFR Part 350 approval FEMA

Combined Operating License (COL) Applications FEMA

Early Site Permit (ESP) Applications FEMA

Prior to submittal of the ALC to FEMA. An ALC is required regardless of whether or not 

changes to plans/procedures have been made.

State

Changes resulting from annual or periodic reviews by OROs, exercises, and/or lessons 

learned from disasters

State

FEMA

A REP plan review is normally conducted by 

evaluating the plans/procedures against the 

entire set of NUREG-0654/FEMA-REP-1 

Evaluation Criteria. A cross-reference between 

the corresponding Evaluation Criterion/Criteria 

must be provided when plans/procedures are 

submitted for review to aid the reviewer in 

locating information. However, because 

allocation of functions varies among 

jurisdictions, given plans/procedures usually 

address most, but not all, functions described in 

NUREG-0654/FEMA-REP-1. If a particular 

function is not addressed in the REP plan, the 

plans/procedures reference the document in 

which it is addressed. For example, local 

plans/procedures may stipulate that the licensee 

and state conduct radiological monitoring and 

dose assessments. A reviewer must cross-check 

plans/procedures, if necessary, to make sure that 

each point is covered somewhere and the 

pertinent references have been clearly stated in 

both places. 
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REP Program Manual Page IV-41 October 2011

The result of the reviewer‘s evaluation is 

expressed as one of the following for each 

NUREG-0654/FEMA-REP-1 Evaluation 

Criterion:

 Adequate: Contents of the REP 

plans/procedures are consistent and in full 

compliance with the requirements 

delineated in the stated Evaluation 

Criterion.

 Adequate – Corrections Must Be Made:

Contents of the REP plans/procedures are 

adequate, but before a determination can be 

made as to whether they can be 

implemented, corrections must be made to 

the plans/procedures or supporting 

measures must be demonstrated (e.g., 

adequacy and maintenance of procedures, 

training, resources, staffing levels and 

qualifications, and equipment). 

 Inadequate: Contents of the REP 

plans/procedures do not satisfy the 

Evaluation Criterion.

 Not Applicable: Evaluation Criterion does 

not apply to the REP plans/procedures 

being reviewed. For example, some 

Evaluation Criteria may be applicable to 

state REP plans/procedures but may not 

apply to local plans/procedures.

3. FORMAT FOR PLAN REVIEWS

A partial sample of the general format used by 

FEMA to document REP Plan reviews is shown 

in Exhibit IV-5. The plan review report format 

lists the Planning Standards and Evaluation 

Criteria from NUREG-0654/FEMA-REP-1 in 

bold italics. The most current wording of each 

Evaluation Criterion is included, along with a 

footnote citing the applicable official revision 

document. Planning Standards and Evaluation 

Criteria applicable only to utilities are not listed 

in the plan review format since they do not apply 

to reviews of ORO plans/procedures.

For each Evaluation Criterion applicable to the 

plans/procedures under review, the reviewer 

records the following information as concisely 

as possible: 

 Statement: Briefly describe how the 

plans/procedures address, or fail to address, 

the requirements of the Evaluation 

Criterion. The reviewer states only the facts 

and lists any recommended changes under 

the Evaluation section. If the Evaluation 

Criterion is not applicable to the 

organization, the reviewer enters N/A (not 

applicable) and skips or deletes Reference

and Evaluation.

 Reference: Lists the principal section(s) of 

the plans/procedures that address the 

Evaluation Criterion.

 Evaluation: Enters the appropriate rating 

(Adequate, Adequate – Corrections Must 

Be Made, or Inadequate) based on the 

reviewer‘s statement. The reviewer lists 

specific recommended changes to correct 

any rating of ―Adequate – Corrections Must 

be Made,‖ or ―Inadequate.‖ Typographical 

and other minor errors noted are also listed 

for correction, even if the rating is 

―Adequate.‖
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REP Program Manual Page IV-42 October 2011

Exhibit IV-5: Portion of Sample Plan Review Format for “Franklin County”

(List the complete title and date of the plan.)

Review and Evaluation against Planning Standards and Evaluation Criteria

of NUREG-0654/FEMA-REP-1, Revision 1

(Evaluation elements applicable only to utilities are not listed.)

A. Assignment of Responsibility (Organization Control) Planning Standard: Primary responsibilities 

for emergency response by the licensee, and by state and local organizations within the 

emergency planning zones (EPZs), have been assigned; emergency responsibilities of the various 

supporting organizations have been specifically established; and each principal response 

organization has staff to respond and augment its initial response on a continuous basis.

A.1.a. Evaluation Criterion: Each plan shall identify the State, local, Federal, and private-sector 

organizations (including utilities) that are intended to be part of the overall response organization 

for EPZs. 

A.1.a. Statement: A listing of participating agencies is included in the cover section of the plan. 

This listing identifies the types of agencies: that is, city, county, state, Federal, and private-sector 

organizations. The roles and responsibilities for each response agency are defined in the plan. 

Tables IV-2 and IV-3 show the Franklin County organizational functional assignments for the

EOC and field locations, as well as the primary and support responsibilities of the response 

organizations.

A.1.a. Plan Reference: Basic Plan, Section IV, Tables IV-2 and IV-3.

A.1.a. Evaluation: Adequate.

A.1.b. Evaluation Criterion: Each organization and sub-organization having an operational role shall 

specify its concept of operations and relationship to the total effort.

A.1.b. Statement: The Concept of Operations Section describes the overall emergency response, 

including notification of emergency responders, notification of the public, establishing emergency 

worker/assistance centers, protective measures, public information, communications, and use of 

the EOC as the command post for a coordinated response. Table IV-1 provides the Franklin 

County response actions for the four emergency classification levels (ECLs) for a radiological 

emergency at the NPP. 

A.1.b. Plan Reference: Plan Overview, Sections IV and I.1.4, and Table IV-1.

A.1.b. Evaluation: Adequate.

A.1.c. Evaluation Criterion: Each plan shall illustrate these interrelationships in a block diagram.

A.1.c. Statement: Table IV-2 provides a detailed description of the Franklin County 

organizational functional assignments and organizational flow. Table IV-2a shows an 

organizational block diagram for most, but not all, EOC positions.

A.1.c. Plan Reference: Section IV.1.4, Tables IV-2 and IV-2a.
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REP Program Manual Page IV-43 October 2011

A.1.c. Evaluation: Inadequate. Table IV-2a does not include the following positions, which, in other 

sections of the plan, are shown to be part of the EOC Operations and Support Group: American 

Red Cross Representative, State Department of Agriculture Liaison Officer, State Department of 

Health Liaison Officer, and National Guard Liaison Officer. These positions need to be added to 

Table IV-2a. 

A.1.d. Evaluation Criterion: Each organization shall identify a specific individual by title who shall be in 

charge of the emergency response.

A.1.d. Statement: The Board of County Commissioners of Franklin County is responsible for 

overall emergency planning and activities in the county. To execute this responsibility, it has 

designated the first County Commissioner to be contacted by Dispatch as the Emergency Chair, 

to serve as the primary decision maker during emergency operations. The Franklin County Sheriff 

will act as the Emergency Chair prior to assumption of those duties and responsibilities by a 

County Commissioner. 

A.1.d. Plan Reference: Basic Plan, Sections IV.3.0 and IV.5.3.

A.1.d. Evaluation: Adequate – Corrections Must Be Made. The section listed in the Plan‘s 

NUREG-0654/FEMA-REP-1 Cross Reference for Evaluation Criterion A.1.d needs to be 

corrected to sections IV.3.0 and IV.5.3. 

A.1.e. Evaluation Criterion: Each organization shall provide for 24-hour-per-day emergency response, 

including 24-hour-per-day manning of communications links.

A.1.e. Statement: The Plan states that each organization has the capability of continuous 

operation during an emergency and can send personnel to the Franklin County EOC and other 

emergency response facilities in a timely manner. The most senior representative from each 

agency who responds to the EOC is responsible for assigning personnel to staff agency 

emergency functions on a 24-hour-per-day basis. 

A.1.e. Plan Reference: Basic Plan, Sections IV and IV.1.1.

A.1.e. Evaluation: Adequate.
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REP Program Manual Page IV-44 October 2011

Rating Summary for [list plan title and date]

Element Rating Element Rating Element Rating

A.1.a Adequate H.3 Adequate M.1 Adequate

A.1.b Adequate H.4 Adequate M.3 N/A

A.1.c Inadequate H.7 Adequate M.4 N/A

A.1.d Adequate—Corrections 

Must be Made 

H.10 Adequate N.1.a Adequate

A.1.e Adequate H.11 Adequate N.1.b Adequate

A.2.a Adequate H.12 N/A N.2.a Adequate

A.2.b Adequate I.7 N/A N.2.c Adequate

A.3 Adequate I.8 N/A N.2.d Adequate

A.4 Adequate I.9 N/A N.2.e N/A

C.1.a N/A I.10 N/A N.3.a Adequate

C.1.b N/A I.11 N/A N.3.b Adequate

C.1.c Adequate J.2 Adequate N.3.c Adequate

C.2.a Adequate J.9 Adequate N.3.d Adequate

C.3 N/A J.10.a Adequate N.3.e Adequate

C.4 Adequate J.10.b Adequate N.3.f Adequate

D.3 Adequate J.10.c Adequate N.4 Adequate

D.4 Adequate—Corrections 

Must be Made 

J.10.d Adequate N.5 Adequate

E.1 Adequate J.10.e Adequate O.1 Adequate 

E.2 Adequate J.10.f Adequate O.1.b Adequate 

E.5 Adequate—Corrections 

Must be Made

J.10.g Adequate O.4.a Adequate

E.6 Adequate J.10.h Adequate O.4.b N/A

E.7 Adequate J.10.i Adequate O.4.c N/A

F.1.a Adequate J.10.j Adequate O.4.d Adequate

F.1.b Adequate J.10.k Adequate O.4.f Adequate 

F.1.c Adequate J.10.l Inadequate O.4.g Adequate

F.1.d Adequate J.10.m N/A O.4.h Adequate 

F.1.e Adequate J.11 Adequate O.4 Adequate

F.2 Adequate J.12 Adequate O.5 Adequate

F.3 Adequate K.3.a Adequate P.1 Adequate

G.1 Inadequate K.3.b Adequate P.2 Adequate

G.2 Adequate K.4 Adequate P.3 Adequate

G.3.a Adequate K.5.a Adequate P.4 Adequate

G.4.a Adequate K.5.b Adequate P.5 Adequate

G.4.b Adequate L.1 Adequate P.6 Adequate 

G.4.c Adequate L.3 N/A P.7 Adequate 

G.5 Adequate L.4 Adequate P.8 Adequate 

P.10 Adequate

Rating Categories:

Adequate: Statements and concepts in plans/procedures adequately address planning criterion.

Adequate—-Corrections Must Be Made: Statements and concepts in plans/procedures adequately address planning criterion, but before a 

determination can be made as to whether they can be implemented, corrections must be made to the plans/procedures or supporting 

measures must be demonstrated.

Inadequate: Statements and concepts in plans/procedures do not adequately address planning criterion.

N/A: Planning criterion is not applicable to this ORO.
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REP Program Manual Page IV-45 October 2011

Q. CONDUCTING SCENARIO REVIEWS

1. SCENARIO REVIEW PREPARATION

Outlined below is the sequential process to be used in evaluating the technical efficacy of proposed 

scenarios for FEMA REP biennial exercises. The times listed below are the estimated number of hours to 

complete the requirements of each step.

Exhibit IV-6: Scenario Review Process

STEP ONE: Conduct an inventory and very rudimentary review of the REP Exercise Scenario 

package provided. Use the REP Exercise Scenario Review Checklist to ensure that 

all documentation necessary to perform the scenario review is present. 

(2 Hours)

STEP TWO: Conduct comprehensive technical review of REP exercise scenario package to 

determine whether or not the scope, characteristics, and content of the scenario are 

adequate to drive the necessary demonstration of the selected Demonstration 

Criteria by the offsite jurisdictions for a plume and/or ingestion exposure pathway 

exercise. This step will include: 

 Review of the scope of the scenario to ensure that: 

 All impacted jurisdictions are included; 

 Map(s) of the plume and/or ingestion EPZ is included;

 Expected offsite actions are consistent with the Extent-of-Play 

Agreements.

 Review of the proposed accident scenario to determine:

 Type of threat (potential plant conditions-versus-simulated radiological 

release;

 Radiological release characteristics (radionuclide mixture), if 

appropriate; 

 Degree of risk to the public (U.S. Environmental Protection Agency 

(EPA) Protective Action Guides (PAG) or state equivalent to be 

exceeded and to what degree); 

 Meteorological conditions (including wind and weather); 

 Technical adequacy of the scenario‘s offsite data to support technical 

controller injects. 

 Review of the controller injects‘ content (technical) to determine: 

 Technical adequacy to drive the various components of offsite plume 

and ingestion exposure pathway exercise play (exposure rates, air 

concentrations, dosimeter readings, surface contamination levels, food 

and water contamination levels, data gradients, etc.). 

(10 Hours Plume)

(16 Hours Ingestion)
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REP Program Manual Page IV-46 October 2011

STEP THREE: Perform the necessary calculations, modeling, or other evaluations to determine 

whether the potential plant conditions, simulated radiological release, or controller 

injects will result in a sufficient dose, exposure rate, or concentrations to drive the 

appropriate decisions and actions by offsite officials necessary to demonstrate the 

agreed upon Demonstration Criteria in the jurisdictions to be exercised. Verify the 

area affected by the plume or deposition footprint. 

(2 Hours – Plume)

(2 Hours – Ingestion)

STEP FOUR: Analyze the time sequences and intervals between planned exercise events. Ensure 

that adequate time has been allowed for the appropriate offsite response 

organizations to demonstrate the selected Demonstration Criteria (technically) 

sufficiently. 

(2 Hours)

STEP FIVE: Discuss the preliminary results of the scenario review with the RAC Chair or 

designee in the FEMA Region(s). Identify and offer recommendations for resolving 

any recognized or potential scenario problems. If no problem areas are identified, 

proceed to Step Seven. Otherwise, prepare a brief summary of the results of the 

recognized scenario problems in writing to the FEMA Region(s) RAC Chair.

(4 Hours – more may needed if more than one FEMA Region is involved) 

STEP SIX: Assist and support the FEMA Region(s) RAC Chair in negotiating scenario 

changes with the state(s) and/or licensee, as requested. 

(4 Hours)

STEP SEVEN: Review all exercise scenario revisions received. Document the results of the 

scenario review and related findings in writing to the FEMA Region(s) RAC Chair 

and provide a copy to the Radiological Emergency Preparedness Section, FEMA 

Headquarters. Retain a detailed record of the scenario review with the contractor‘s 

files.

(6 Hours)
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REP Program Manual Page IV-47 October 2011

2. RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE SCENARIO REVIEW

CHECKLIST

The following information is provided to the scenario review contractor to facilitate the conduct of a 

comprehensive technical review of the submitted REP exercise scenario. The data listed below are not 

intended to include all of the data that are needed for the scenario. The FEMA Region(s) RAC Chair 

makes appropriate arrangements assuring that the information listed is provided to the contractor.

FACILITY: ________________________________________

CHECK IF 

INCLUDED

I. PRE-EXERCISE AGREEMENTS AND EXERCISE BACKGROUND MATERIALS

________ 1.* Assessment Areas to be demonstrated by designated state and local jurisdictions

________ 2

.* Pre-exercise agreements, including extent of play by Assessment Area

________ 3.*Previous exercise evaluation report and related information on any technical issues 

________ 4.* Radiological portions (e.g., emergency worker exposure limits, PAGs, air sampling procedures, dose 

calculation procedures, etc.) of the most recent version of the state, local, and appropriate agency 

plans/procedures, including detailed and readable maps showing pre-selected reference points.

________ 5.* NUREG-0654/FEMA-REP-1 cross-reference index to the state, local, and appropriate agency 

plans/procedures

* Indicates those items that FEMA Region(s) are responsible for providing to the scenario review contractor.

II. SCENARIO INFORMATION – GENERAL

________ 1. Utility/state/local scenario timelines

________ 2. All controller injects and messages with data in appropriate units, including those triggering the 

demonstration of specific technical objectives (any additional data or information needs will be identified 

during the detailed technical review)

III. SCENARIO INFORMATION – RELEASE PARAMETERS

________ 1. Potential-Only or Simulated Release

________ 2. Either gross noble gas, gross radioiodine, and gross particulate release rate, or isotopic release rates. If 

gross release rates are given, the accident type must be stated. Isotopic release rates are required for postplume phase activities.

________ 3. Site characteristics and topography assumed to affect the dispersion

________ 4. Release point information (height – elevation ground, or mixed; etc.)

________ 5. Time of reactor shutdown

________ 6. Start time and duration of release

________ 7. Meteorological data used

________ 8. Atmospheric mixing depth (if not provided, 1250 meters will be used)

________ 9. Whether decay is, or is not, included in the calculations
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IV. SCENARIO INFORMATION – PLUME PHASE DATA

________ 1. Centerline and isopleths of atmospheric dilution factors (X/Q) plotted on a map, including date and times 

of data values

________ 2. Direct radiation readings and locations

________ 3. Environmental samples – descriptions, locations, date, times, and results in appropriate units related to 

offsite instruments and procedures

________ 4. Radioiodine and particulate calculation results in appropriate units related to offsite instruments and 

procedures

________ 5. Map(s) that are readable and detailed for the plume phase data with plume location plotted at selected 

time periods

________ 6. Estimated doses and exposure rates calculated along the plume centerline. If different models are used by 

the state and Utility, included data for both

V. SCENARIO INFORMATION – INGESTION/RELOCATION PHASE DATA (See Section I., Item Number 1.)

________ 1. Centerline and isopleths of dilution factions X/Q plotted on a map, including date and times of data 

values

________ 2. Direct radiation readings and locations

________ 3. Environmental samples – descriptions, locations, date, times, and results in appropriate units related to 

offsite instrument and procedures

________ 4. Map(s) that are readable and detailed for the ingestion/relocation phase data with the deposition footprint 

locations indicated at selected time periods and results in appropriate units related to offsite instruments 

and procedures

________ 5. Estimated doses calculated along the plume centerline for the ingestion/relocation Phase 

________ 6. Any planned inconsistencies between plume and ingestion/relocation data

Certification

The scenario information and data provided by the FEMA Region(s) RAC Chair and items checked on 

this form have been provided.

____________________________ _____________________________ ________

Name Company Date
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R. ANNUAL LETTER OF CERTIFICATION

1. GUIDANCE

To facilitate monitoring of REP planning and 

preparedness requirements as prescribed in 

NUREG-0654/FEMA-REP-1 and 44 CFR Part 

350, each state that has a REP program submits 

an ALC to the appropriate FEMA Regional 

Administrator. The ALC assists FEMA in 

making reasonable assurance findings and 

determinations regarding offsite radiological 

emergency plans/procedures and preparedness. 

Each November, the FEMA Regional Office 

submits a letter to the state requesting the ALC. 

The ALC submission for a given year is required 

by January 31 of the following year. The ALC 

may address more than one site within the state.

By the end of February, FEMA Regional 

personnel review the ALC and mail to the state

either an approval letter for each site or a letter 

requesting additional information for completing 

the review. FEMA personnel may verify 

information during SAVs. FEMA Regional 

personnel will provide FEMA Headquarters with 

a copy of the state‘s ALC cover letter and the 

Region‘s final approval letter.

The following review guide assists state and 

FEMA Regional personnel with development, 

submission, and review of the ALCs and 

development of public education and 

information materials. Each element of the guide 

is supported by the appropriate regulation and/or 

guidance. Regional personnel may send the 

review guide to their respective states as 

attachments to the November letter requesting 

the ALC. A sample transmission letter is 

included at the end of this section. 

The ALC must include assurances that all 

requisite activities have been undertaken or 

completed, as appropriate, by OROs. At a 

minimum, documentation of the items listed 

below must be included in, or attached to, the 

ALC. 

 24-Hour Staffing (Planning Standard A): 

Certification that the ORO has sufficient 

trained and capable staff to maintain a 24-

hour capability for protracted activation.

 Public Education and Information (Planning 

Standard G): Means used to disseminate 

information, dates conducted, participants, 

sponsoring organizations, and identification 

and description of any programs conducted 

to increase public and media radiological 

emergency planning and response 

awareness.

 Emergency Facilities and Equipment 

(Planning Standard H): List of 

equipment/instrument types, quantity, and 

dates of check/test.

 Exercises (Planning Standard N): Testing of 

all major elements, in an exercise or by 

other means as appropriate, and testing 

plans/procedures for implementing 

ingestion pathway and post emergency 

measures. (FEMA-evaluated exercises are 

documented in AARs; only non-evaluated 

exercises need to be reported in the ALC.)

 Drills (Planning Standard N): Types, dates 

held, and participating organizations 

(FEMA-evaluated drills are accounted for 

in AARs; only non-evaluated drills need to 

be reported in the ALC.)

 Radiological Emergency Response Training 

(Planning Standard O): Scope and purpose 

of training, dates held, number of 

participants, agencies represented, and 

sponsors of training.

 Update of plans/procedures and Letters of 

Agreement (Planning Standard P): 

Verification that plans/procedures and 

letters of agreement have been reviewed 

and appropriate changes made. Updates of 

plans/procedures include telephone 

numbers, call-down lists, ingestion pathway 

information, and maps.

 Alert and Notification (NUREG0654/FEMA-REP-1, Appendix 3): Types of 

tests conducted in accordance with 

established schedule, dates held, and 

operability percentage achieved based on 

periodic testing.
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2. SAMPLE ANNUAL LETTER OF CERTIFICATION COVER LETTER 

SAMPLE COVER LETTER FOR ANNUAL LETTER OF CERTIFICATION AND PUBLIC EDUCATION 

AND INFORMATION104 REVIEW GUIDES

(Date)

State Director/Administrator

Emergency Management Division

Location

Street

City, State, Zip Code

Dear Ms./Mr. (Name):

The Annual Letter of Certification (ALC) assists the Federal Emergency Management Agency (FEMA) 

in making reasonable assurance findings and determinations regarding offsite radiological emergency 

plans/procedures and preparedness. Enclosed is a review guide for use by your staff when developing 

your site-specific certifications. 

Also enclosed for your use is the public education and information materials review guide. Our staff will 

use this guide to review public education and information materials submitted with the ALC.

The ALC is due in this office no later than January 31, (year). If you have any questions concerning the 

review guides or the ALC submission, please contact (name of site specialist) at (phone number).

Sincerely,

Regional Assistance Committee Chair

FEMA Region (number)

Enclosures: ALC Review Guide

Public Education and Information Review Guide

 

104 The Public Education and Information Review Guide is found in the next section.
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3. ANNUAL LETTER OF CERTIFICATION REVIEW GUIDE

Department of Homeland Security

Federal Emergency Management Agency

Radiological Emergency Preparedness Program

ANNUAL LETTER OF CERTIFICATION REVIEW GUIDE

(Date)

Purpose:

To provide guidance for review and evaluation of the Annual Letter of Certification (ALC) submitted by 

the states for compliance with periodic requirements.

Scope: Requirement:

The state ALC is reviewed to determine whether all 

information/documentation is included pursuant to 

laws and regulations and the Federal Emergency 

Management Agency (FEMA) Radiological 

Emergency Preparedness (REP) Program Manual. 

Information contained in the ALC is compared 

with the offsite response organizations (ORO) 

plans/procedures and the Alert and Notification 

System (ANS) design reports for consistency and 

accuracy.

 44 CFR part 350

 NUREG-0654/FEMA-REP-1 Planning 

Standard

A. 24-Hour Staffing Capability

G. Public Education and Information

H. Emergency Facilities and Equipment

N. Exercises and Drills

O. Radiological Emergency Response 

Training

P. Responsibility for the Planning Effort 

 FEMA-REP-10 

 FEMA REP Program Manual

Confirm that the ALC includes the following items:

Update of Plans/Procedures and Letters of Agreement Yes No N/A

1. A statement that ORO plans/procedures and Letters of Agreement 

(LOAs) have been reviewed for accuracy and completeness of 

information, and appropriate changes made. Updated LOAs and 

plan/procedure amendments must be submitted if not received 

previously.

Public Education and Information 

1. A statement that annual dissemination of information to the public was performed, and that the 

information includes how the public will be notified and what their actions should be in an 

emergency. This may be accomplished by, but not necessarily limited to, annual publications, 

periodic information in utility bills, and information in telephone books. (NUREG-0654/FEMA-REP1, Evaluation Criteria G.1 and G.2)

This statement must include the: Yes No N/A

a. Dates of dissemination

b. Means of dissemination

c. Identification of recipients
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d. Copies of all public information materials

2. A statement that emergency information was disseminated to locations frequented by transient 

populations in the emergency planning zone (EPZ), including (if applicable) hotels, motels, gas 

stations, phone booths, parks, marinas, boats, and other recreational areas. This may be accomplished 

by, but need not be limited to, decals, posters, or brochures/pamphlets. (NUREG-0654/FEMA-REP1, Evaluation Criteria G.1 and G.2) 

This statement must include: Yes No N/A

a. Dates of dissemination

b. Means of dissemination

c. Identification of locations where information was 

distributed or posted

d. Copies of all public information materials

e. Organizations responsible for distribution

3. A statement (if applicable) that yearly maintenance and updates on emergency public information 

signs located along rivers, parks, and other recreational areas were performed. 

(NUREG-0654/FEMA-REP-1, Evaluation Criteria G.1 and G.2) 

This statement also: Yes No N/A

a. Certifies that parks and other recreational areas were not 

expanded, nor were new transient areas added to the 

plume EPZ. If expansions or additions were made, a 

statement must be provided that the appropriate 

additional signs were installed.

b. Identifies organizations responsible for maintenance/ 

updates

4. A statement that emergency public information materials for the ingestion pathway were updated and 

distributed. (NUREG-0654/FEMA-REP-1, Evaluation Criteria G.1 and G.2) 

This statement must include: Yes No N/A

a. Means of dissemination

b. Copies of public information materials

5. A statement that annual media program was conducted to acquaint news media with emergency 

plans/procedures, information concerning radiation, and points of contact for release of public 

information in emergency. (NUREG-0654/FEMA-REP-1, Evaluation Criterion G.5) 

This statement must include: Yes No N/A

a. Date(s) held

b. Agencies/organizations invited/ participated

c. Organizations that sponsored program

d. Description of program

NOTE: In instances of poor attendance, in lieu of a meeting, a statement that program materials covering 

requisite topics were mailed to media representatives must be provided.
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Radiological Emergency Response Training

1. A statement that initial training and annual retraining of personnel who implement radiological 

emergency response plans/procedures have been accomplished. (NUREG-0654/FEMA-REP-1, 

Evaluation Criterion O.5)

Statement must include the following for all training conducted: Yes No N/A

a. All required organizations were offered training pursuant 

to ORO plans/procedures

b. Scope and purpose

c. Dates training were held

d. Number of participants

e. Agencies/organizations represented

f. Agencies/organizations invited, but who did not attend.

g. Organizations that sponsored the training.

Drills 

NOTE:These drills shall not be part of a regularly scheduled exercise (NUREG-0654/FEMA-REP-1, 

Evaluation Criterion N.2), with exception of the annual medical drill. Only non-evaluated drills need to 

be reported in the ALC.

1. A statement that communication drills (NUREG-0654/FEMA-REP-1, Evaluation Criterion N.2.a) 

were conducted:

Yes No N/A

a. Monthly between the state and OROs within plume EPZ

b. Quarterly between state and Federal emergency response 

organizations and states within ingestion pathway EPZ

c. Annually between NPP, state, and local emergency 

operations centers, and radiological field monitoring 

teams

d. Dates of communication drills and participating 

organizations

2. A statement that radiological monitoring drill related to plume EPZ was conducted annually and 

included collection and analyses of all sample media (e.g., water, vegetation, soil, and air) with 

provisions for communication and record keeping. Where a state is responsible for more than one 

site, the state portion of drills need not be done at each site. (NUREG-0654/FEMA-REP-1, 

Evaluation Criterion N.2.d)

This statement must include: Yes No N/A

a. Dates of monitoring drills

b. Organizations that participated

NOTE: These drills must involve personnel and resources for field team coordination and field teams.
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3. A statement that health physics drills were conducted semiannually with licensees that included 

response to, and analyses of, simulated elevated airborne and liquid samples and direct radiation 

measurements in environment. Where a state is responsible for more than one site, the state portion 

of drills need not be done at each site. (NUREG-0654/FEMA-REP-1, Evaluation Criterion N.2.e)

This statement must include: Yes No N/A

a. Dates of health physics drills

b. Organizations that participated

NOTE: Health physics drills must involve personnel and resources for dose assessment. 

24-Hour Staffing 

(NUREG-0654/FEMA-REP-1, Evaluation Criterion A.1.e) Yes No N/A

1. A statement that sufficient trained and capable staff is available to 

maintain 24-hour capability for protracted activation.

Emergency Facilities and Equipment

(NUREG-0654/FEMA-REP-1, Evaluation Criteria H.3; G.3.a; J.10.h; J.12; K.5.b)

1. Identification of facilities that are new or have had substantial changes in structure or mission since 

initial evaluation. A substantial change is one that has a direct affect or impact on the emergency 

response operations performed in those facilities. 

This statement must include: Yes No N/A

a. Verification that the facility has been evaluated, or the 

expected date of the evaluation

2. Certification that no substantial changes in structure or mission of previously reported facilities have 

occurred since initial evaluation.

This statement must affirm that: Yes No N/A

a. There are no other new emergency response facilities, 

communications systems, or congregate care facilities

b. None of the other current facilities, communications 

systems, or congregate care facilities in the 

plans/procedures has undergone substantial changes

3. A statement that inspection, inventory, and operational checks were made of survey instruments 

utilized for radiological monitoring (evacuee and emergency worker) and environmental monitoring 

and analysis (radiological field monitoring teams and radiological laboratory) at least once each 

calendar quarter and upon each use. (NUREG-0654/FEMA-REP-1, Evaluation Criterion H.10)

This statement must include: Yes No N/A

a. Type of equipment

b. Quantity of equipment

c. Location of equipment 

d. Calibration frequency

e. Dates of inspection/inventory check
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4. A statement that survey instruments utilized for measuring radiation during environmental 

monitoring and analysis (field teams and radiological laboratories) were calibrated at intervals 

recommended by supplier of equipment (NUREG-0654/FEMA-REP-1, Evaluation Criterion H.10)

If calibration occurred, the statement must include: Yes No N/A

a. Type of equipment

b. Quantity of equipment

c. Location of equipment 

d. Dates of calibration

5. A statement that direct-reading dosimetry has been tested for accuracy. All Direct-Reading 

Dosimeters (DRDs) shall be inspected for electrical leakage at least annually. CDV-138s must be 

inspected for electrical leakage quarterly. Dosimeters shall be recharged or replaced as necessary. 

(NUREG-0654/FEMA-REP-1, Evaluation Criterion H.10)

This statement must include: Yes No N/A

a. Type of equipment

b. Quantity of equipment

c. Location of equipment 

d. Dates of calibration

6. A statement that sufficient quantities of potassium iodide (KI) are available for emergency workers, 

institutionalized individuals, and if the plan calls for it, the general public. (NUREG-0654/FEMAREP-1, Evaluation Criterion J.10.e) If quantities of KI were not verified by FEMA during most recent 

biennial exercise: 

This statement must include: Yes No N/A

a. Amounts of KI available

b. Storage locations

c. Expiration date(s)

Alert and Notification

1. A statement that a routine siren testing program was completed pursuant to the design report. (FEMAREP-10)

This statement must include: Yes No N/A

a. Type of tests conducted in accordance with established 

schedule

b. Dates of tests

c. Number of sirens tested operable and inoperable
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2. Analysis of percentage of operable sirens. (FEMA-REP-10)

This must be at least 90 percent and include: Yes No N/A

a. Computation of siren operability (percentage of sirens 

operable) for the immediately preceding calendar year. 

This is determined by simple average of all regularly 

conducted tests employed as part of testing program (e.g., 

silent, growl, full cycle). Calculations will be checked by 

specialist to substantiate results.

b. Description (or calculations) of method used to calculate 

siren operability percentage

3. A statement (if applicable) that a maintenance program for residential tone alert radios has been 

properly implemented. (FEMA-REP-10)

This statement must specify the type and frequency of residential 

tone alert radio (as part of primary ANS) tests conducted and 

include assurances that:

Yes No N/A

a. Registers, containing list of addresses where equipment is 

located, have been updated to reflect additions or changes

b. Registers include individuals who have refused this 

equipment

c. Equipment operating checks have been completed or 

offered to residents with this equipment

d. Tests identifying frequency were conducted offering the 

public a means to self-test its receivers

e. Necessary written guidance was provided that addressed:

1. General usage

2. Self-testing frequency and method

3. Suggested placement to facilitate efficient use

4. Maintenance program details

5. Telephone numbers for repair or replacement

4. A statement specifying type and frequency of routine testing of all applicable alerting systems, other 

than sirens and tone alert radios. This testing must be performed at least annually. (FEMA-REP-10)

Alerting methods may include: Yes No N/A

a. Mobile route alerting and notification

b. Aircraft route alerting and notification

c. Institutional alerting mechanisms in schools, hospitals, 

nursing homes, etc.

d. Automatic telephone dialers/switching equipment

e. Modulated power lines

f. Type and frequency of residential tone alert radio (as part 

of primary ANS) tests conducted
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5. A statement (if applicable) that a maintenance program for alerting systems other than sirens and tone 

alert radios (e.g., radios in schools/hospitals) has been properly implemented. (FEMA-REP-10)

This statement must include assurances that: Yes No N/A

a. Registers, containing list of addresses where equipment is 

located, have been updated to reflect additions or changes

b. Registers include organizations that have refused this 

equipment or information

c. Equipment operating checks have been completed or 

offered

d. Necessary written guidance was provided that addressed:

1. General usage

2. Suggested placement to facilitate efficient use

3. Maintenance program details

4. Telephone numbers for repair or replacement

6. A statement (if applicable) for exception areas requiring alert and notification methods, other than 

sirens and tone alert radios (e.g., aircraft and/or mobile route alerting and notification) that routes, 

alerting methods, and resources remain unchanged. If changes did occur, design report must be 

updated to reflect modifications.

7. A statement that siren sound pressure/population density requirements have been met. (FEMA-REP10)

This statement must include assurances that: Yes No N/A

a. In areas where siren sound pressure level is less than 60 

dBc, population remains below 2,000 persons per square 

mile

b. If population has increased to the level of 2000 persons 

per square mile, siren sound pressure levels must be 

increased and design report modified

8. A statement (if applicable) that in areas not covered by sirens, no permanent population has relocated 

into these areas. In areas of EPZ where no permanent population exists and transients would not 

frequent, a letter certifying this fact was provided with initial design report. State must certify that this 

condition remains unchanged; no permanent or transient population has relocated in these areas. If 

relocation did occur, sirens, tone alert radios, or other means for alerting these individuals would then 

be required.
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S. PUBLIC INFORMATION GUIDE AND PROCESS

1. GUIDANCE

Purpose: To provide guidance for review and 

evaluation of public information materials 

distributed by offsite response organizations 

(OROs) and licensees for nuclear power plants 

(NPPs). 

Scope: Public information materials are 

reviewed prior to distribution to determine 

whether information and emergency instructions 

have been included and disseminated pursuant to 

laws and regulations, Federal Emergency 

Management Agency (FEMA) Headquarters and 

Regional policy determinations, the Radiological 

Emergency Preparedness (REP) Program 

Manual, and the REP series documents.

Emergency information and instructions 

contained in the public information materials 

will be compared to ORO plans/procedures for 

consistency and accuracy. Emergency 

information material is to be updated and 

distributed annually. If the updates affect 

ingestion public information material, then that 

material must also be updated and reviewed by 

FEMA. 

Basis: 44 CFR § 350.5 (a.7), NUREG0654/FEMA-REP-1, Revision 1, Evaluation 

Criteria A.1.e, E.5, E.6, E.7, G.1, G.2, J.9, 

J.10.a, J.10.c, J.10.d, J.10.h, and J.11.

2. REVIEW STEPS

Effective preparedness depends on an ongoing, 

comprehensive public education effort. Public 

education increases community awareness about 

emergency self-protection. Public education 

efforts go beyond the distribution of materials. 

The public needs to be familiarized with 

commercial NPP emergencies and related 

procedures. Clear public communication of NPP 

emergency procedures will result in a better 

public understanding of written emergency 

materials and instructions. The following items 

are considered when developing or reviewing 

emergency public information and educational 

materials.

Exhibit IV-7: Public Information Review Checklist

Y N N/A

BASIC INFORMATION

There is a clear statement of purpose.

The cover clearly states that the document contains important emergency instructions.

The date of issue and name of the issuing agency are clearly indicated.

The cover design encourages recipients to open and read the publication.

Informational and educational materials have clear emergency focus. They explain 

what to expect and in what sequence, and what actions, in order of priority, are taken.

The content is consistent with the ORO plans/procedures, public information materials, 

and emergency alert system (EAS) broadcast messages.

Emergency telephone numbers are provided along with instructions on the procedures 

to be followed and instructions on their use (e.g., transportation assistance, pickup 

points). ―Hotline‖ telephone numbers for emergencies are separate from information 

numbers used during non-emergencies.

Names, addresses, and telephone numbers of the appropriate organizations to contact 

in non-emergency situations are provided.
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Y N N/A

Public inquiry numbers are provided.

General education material, if included, is placed after the emergency procedures 

information.

Blank space is provided in the emergency procedures section for personal notes. 

There is a statement on when this information will be updated.

An emergency planning zone (EPZ) map with landmark descriptions of sub-areas or 

sub-zones is included.

Siren test dates (i.e., day of the week and time) are identified.

ORGANIZATION OF MATERIAL

The cover has a highly visible statement that identifies the materials as instructions or 

information for use in an emergency.

The layout is easy to follow from paragraph to paragraph and page to page. Page and 

section breaks are consistent with the logic and organization of the materials.

The information is presented in a logical sequence of topics. The flow of information 

is smooth and not disjointed.

Within a given topic, actions to be taken come first, followed by rationale or 

explanation.

Key symbols or graphic images are used to help locate and/or understand the text.

COMPREHENSION

Vocabulary is simple, comprising non-technical terms likely to be used by the intended 

audience.

Sentences are brief and concise.

The reading level is appropriate based on one of the following:

 The entire emergency procedures section has a reading level of grade 9 or below, 

as characterized by a readability formula such as Dale-Chall; or

 The entire emergency procedures section has a reading level equivalent to that of 

the target audience, as characterized by a readability formula; or

 Most of the emergency procedures section of the document has a reading level of 

grade 9 or below, as characterized by a readability formula. However, a higher 

level is acceptable since the somewhat longer, more natural sentence structures 

make use of simple language.

Typography is easy to read.

The choice of colors meets the needs of colorblind individuals.

The format and text size for the emergency information included in the document is 

appropriate.

Photographs, maps, charts, tables, and artwork are used effectively to enhance the text 

and are not distracting.

The various elements of graphic design work together harmoniously to achieve the 

desired effect.

The format encourages retention.
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REP Program Manual Page IV-60 October 2011

Y N N/A

Color is used to enhance and highlight important details about the emergency 

information.

When the public is referred to written materials, this reference can be easily 

understood.

Sentences are brief and easy to understand.

Messages are internally consistent.

Public education passages, if included, are not distracting.

PERSONS WITH DISABILITIES AND ACCESS/FUNCTIONAL NEEDS

Provisions that address persons with disabilities and access/functional needs (e.g., 

hearing/mobility-impaired, transportation-dependent, etc.) are provided.

Information is made accessible to transients and visitors through appropriate means.

The system for addressing needs of persons with disabilities and access/functional 

needs is identified.

A method of identifying that those individuals within the EPZ in need of assistance 

during an evacuation have been provided information (e.g., pre-paid postcard) in such 

a way that it cannot be lost during shipment or during initial reading of the public 

information material, etc. Information includes instructions that registration is 

necessary (e.g., the card is to be returned) if the resident requires special assistance.

Discusses information as it relates to the care of public and private school children 

(including pre-schools and licensed daycare centers), hospital patients, nursing home 

residents, persons with disabilities and access/functional needs, persons subject to 

judicial restraint, and occupants of other special institutions identified in the plan.

INGESTION PATHWAY INFORMATION

The information explains protective actions provided for all types of agricultural 

products in the ingestion pathway for the site, including the following:

Milk

Vegetables and Fruits

Meat and Meat Products

Poultry

Soils

Grains 

Water

Other products (e.g., Honey, Fish and Marine Life)

The effects of radiation and radioactive material deposits on the human food supply 

are clearly stated.

The public information materials explain how the farmers, food processors, and 

distributors will be notified of an emergency.

The public information materials explain how the farmers, food processors and 

distributors will be advised of appropriate actions to take.
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Y N N/A

NOTIFICATION PROCEDURES

Information is provided regarding alert and notification procedures.

Identification of emergency broadcast stations/channels is provided, to include which 

ones are primary and operate 24 hours per day.

School provisions, including guidelines or instructions for parents, are included.

Instruction on the care and feeding of livestock during an emergency, if appropriate to 

the area, is included.

The public is encouraged to alert neighbors, by means other than the telephone, to 

ensure they also heard and understood the warning signals.

Public EAS broadcast instructions have a clear emergency focus and explain what to 

do.

Instructions are consistent with the ORO plans/procedures, public information 

materials, and previous EAS messages.

The emergency instructions are released by a recognized ORO authority.

The emergency broadcast messages are presented in a foreign language when 

appropriate.

Messages inform the public located in areas under protective action decisions and 

those outside those areas via geographic landmark descriptions.

Information regarding emergency classification levels is included. 

Transportation provisions are included.

SHELTERING

Sheltering is defined according to the ORO plan.

Sheltering procedures and instructions for the general population, private and public 

school children (including pre-schools and licensed daycare centers), hospital patients, 

nursing home residents, persons with disabilities and access/functional needs, persons 

subject to judicial restraint, and occupants of other special institutions as identified in 

the plans/procedures, are included.

EVACUATIONS

Evacuation routes are described in the text and illustrated directions on an evacuation 

map of the EPZ are provided.

Reasons for evacuation are discussed.

Respiratory protection while evacuating is described.

Distribution of evacuees to reception centers is identified.

POTASSIUM IODIDE

Very basic information on the emergency hazard is included in the emergency 

information materials to inform the public of potential health implications.

Enough educational information on radiation is given to provide an understanding of 

sources and relative effects, or this information is provided in separate materials.
PART IV – REP PROGRAM ADMINISTRATION

REP Program Manual Page IV-62 October 2011

Y N N/A

Radio-protective drugs such as potassium iodide (KI) (if adopted by ORO for use by 

the general public) are explained.

RECEPTION CENTERS/CONGREGATE CARE CENTERS 

Reception centers or congregate care centers are listed, including recommending 

evacuees to register at reception centers even if they are not planning to use the 

congregate care facilities. This would include a brief description of the services and 

supplies provided.

An EPZ map indicating evacuation routes and directions to and location of reception 

centers/congregate care centers. Evacuation routes are clearly labeled with the 

highway number/name. The map includes a legend and compass rose (direction 

indicator) to assist the reader.

PRE-PLANNING

A section on family preplanning is provided.

An emergency supplies checklist to have in the home is included.

A supplies checklist for use during evacuation is included.

Home preparation for sheltering is discussed.

3. FOREIGN LANGUAGE TRANSLATION 

– LEGAL REQUIREMENTS AND 

LOCATION OF INFORMATION

English is the principal language used for EAS 

messages, special news/follow-up broadcasts, 

media releases, and other important information 

for the public during a radiological incident. 

However, if 5 percent of the voting-age 

population of the at-risk county speaks a single 

language other than English, all the 

aforementioned information must also be 

provided in that language. This section explains 

the legal background and provides a list of states 

and counties where messages in languages other 

than English are needed.

a. Legal Background

The National Voting Rights Act of 1965 (42 

U.S.C. Part 1973-1973aa-6, as amended) 

includes provisions to ensure that minorities that 

speak a language other than English are not 

discriminated against in voting. Specifically, 

Section 203 of the Act provides that if more than 

10,000 people or 5 percent of the voting age 

population within a jurisdiction are members of 

a single-language minority group and do not 

adequately speak or understand English, all 

voting information is required to be in the other 

language also. Covered language minorities are 

limited to American Indians, Asian Americans, 

Alaskan Natives, and Spanish-heritage citizens –

the groups that Congress found to have faced 

barriers in the political process. After each 

census, the Census Bureau identifies and lists, 

via Federal Register notice, those jurisdictions 

covered by the requirement. For further 

information on section 203 of the act, including 

its text, a list of covered jurisdictions, and the 

Attorney General‘s Minority Language 

Guidelines, see the website 

www.usdoj.gov/crt/voting/sec_203/

activ_203.htm. 

b. REP Requirements

The REP Program has adopted similar 

requirements for providing EAS messages and 

other advisory information to language 

minorities. For REP Program purposes, the 

county will be the lowest jurisdictional 

subdivision to which the language minority 

requirements will apply, i.e., the requirement 

applies to the entire population of any county 

wholly or partially in the EPZ. In cases where a 
PART IV – REP PROGRAM ADMINISTRATION

REP Program Manual Page IV-63 October 2011

county lies only partially in the EPZ, it would be 

very difficult to divide out the EPZ. People in 

parts of the county outside of the EPZ will hear 

the EAS messages and need to understand them.

The state/site specialist reviews 

plans/procedures to verify that, if applicable, all 

emergency information and public information 

material are in the required languages. During 

exercises, messages are broadcast (simulated) in 

English and any other required languages.

For additional state information, visit the state

Data Center that can be found on each state

website, or, go to www.census.gov and select 

the state/county quick facts (on the right side); 

click on the appropriate state, then select 

summary, where there is a choice of data sets.

T. DISASTER INITIATED REVIEW

The purpose of a Disaster Initiated Review 

(DIR) is to determine the capability of offsite 

emergency response infrastructure following an 

extended plant shutdown, or shutdown caused 

by electric grid blackouts, malevolent act, 

pandemic or natural disaster (e.g., hurricane, 

tornado, flood, and earthquake) in the vicinity of 

commercial nuclear power reactors.

The SOG should be implemented consistent 

with the agreements of the Memorandum of 

Understanding (MOU) between the FEMA REP 

Program and the NRC contained in Section I, 

―Recovery from Disasters Affecting Offsite 

Emergency Preparedness,‖ of 44 CFR Part 353, 

Appendix A. In this regard, if a disaster causes 

damage or changes to the emergency response 

infrastructure around a licensed operating 

nuclear power plant to the extent that the 

damage raises serious questions about the 

continued adequacy of offsite emergency 

preparedness, the identifying agency (FEMA 

REP Program/NRC) will inform the other 

promptly. These procedures are consistent with 

those of the NRC Inspection Manual Chapter 

1601.

These guidelines apply when a power reactor is 

shutdown and an offsite review of emergency 

preparedness infrastructure is required. If the 

power reactor is operating and there is a 

compromise of ―reasonable assurance‖, damage 

to the offsite emergency preparedness 

infrastructure or any portion of offsite 

emergency preparedness is degraded, the FEMA 

REP Program Regional and HQ management, in 

consultation with the OROs, and the NRC, will 

decide on the necessary actions to ensure 

adequate protection of public health and safety. 

These guidelines have been developed and are 

provided to support decision making regarding 

offsite preparedness under these shutdown 

conditions. This SOG can be tailored and 

modified by the FEMA Regional Assistance 

Committee Chairperson (RAC Chair) and the 

DIR Team based on the extent of damage and 

the urgency for plant startup.
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-64 October 2011

U. LIST OF COMMERCIAL NUCLEAR POWER PLANTS

The following list of commercial nuclear power plant (NPP) sites includes all operating sites as well as 

proposed sites engaged in the licensing process as of the date of publication of this document. The last 

two digits of each Utility Billable Plant Site Code are used as the initial part of the standardized exercise 

issue numbering system. For more information on individual NPP sites, see the NRC web site at 

www.nrc.gov .

Site 

Code Site Name Number of Units Location

24 001 Arkansas Nuclear One Operating: 2 London, AR

24 002 Salem Nuclear Generating Station/Hope Creek 

Generating Station(formerly Artificial Island)

Operating: 3 Hancocks Bridge, NJ

24 003 Beaver Valley Power Station Operating: 2 Shippingsport, PA

24 004 Bellefonte Nuclear Station Proposed: 2 Jackson County, AL

24 006 Braidwood Station Operating: 2 Braceville, IL

24 007 Browns Ferry Nuclear Plant Operating: 3 Athens, AL

24 008 Brunswick Steam Electric Plant Operating: 2 Southport, NC

24 009 Byron Station Operating: 2 Byron, IL

24 010 Callaway Plant Operating: 1

Proposed: 1

Fulton, MO

24 011 Calvert Cliffs Nuclear Power Plant Operating: 2

Proposed: 1

Lusby, MD

24 012 Catawba Nuclear Station Operating: 2 York, SC

24 013 Clinton Power Station Operating: 1 Clinton, IL

24 014 Comanche Peak Nuclear Power Plant Operating: 2

Proposed: 2

Glen Rose, TX

24 015 Donald C. Cook Nuclear Plant Operating: 2 Bridgman, MI

24 016 Cooper Station Nuclear Station Operating: 1 Brownville, NE

24 017 Crystal River Nuclear Generating Plant Operating: 1 Crystal River, FL

24 018 Davis-Besse Nuclear Power Station Operating: 1 Oak Harbor, OH

24 019 Diablo Canyon Power Plant Operating: 2 Avila Beach, CA

24 020 Dresden Nuclear Power Station Operating: 2 Morris, IL

24 021 Duane Arnold Energy Center Operating: 1 Palo, IA

24 022 Joseph M. Farley Nuclear Plant Operating: 2 Columbia, AL

24 023 Fermi Operating: 1

Proposed: 1

Newport, MI

24 024 James A. FitzPatrick Nuclear Power Plant Operating: 1 Scriba, NY

24 025 Fort Calhoun Station Operating: 1 Ft. Calhoun, NE

24 027 R. E. Ginna Nuclear Power Plant Operating: 1 Ontario, NY

24 028 Grand Gulf Nuclear Station Operating: 1

Proposed: 1 

Port Gibson, MS

24 030 Shearon Harris Nuclear Power Plant Operating: 1

Proposed: 2

New Hill, NC

24 031 Edwin I. Hatch Nuclear Plant Operating: 2 Baxley, GA

24 032 Indian Point Nuclear Generating Station Operating: 2 Buchanan, NY

24 033 Kewaunee Power Station Operating: 1 Kewaunee, WI

24 034 LaSalle County Station Operating: 2 Marseilles, IL

24 035 Limerick Generating Station Operating: 2 Limerick, PA

24 036 William States Lee III Nuclear Station Proposed: 2 Cherokee County, SC

24 037 McGuire Nuclear Station Operating: 2 Huntersville, NC

24 038 Millstone Power Station Operating: 2 Waterford, CT

24 039 Monticello Nuclear Generating Plant Operating: 1 Monticello, MN

24 040 Nine Mile Point Nuclear Station Operating: 2

Proposed: 1

Scriba, NY
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-65 October 2011

Site 

Code Site Name Number of Units Location

24 041 North Anna Power Station Operating: 2

Proposed: 1

Louisa, VA

24 042 Oconee Nuclear Station Operating: 3 Seneca, SC

24 043 Oyster Creek Generating Station Operating: 1 Forked River, NJ

24 044 Palisades Nuclear Plant Operating: 1 Covert, MI

24 045 Palo Verde Nuclear Generating Station Operating: 3 Wintersburg, AZ

24 046 Peach Bottom Atomic Power Station Operating: 2 Delta, PA

24 047 Perry Nuclear Power Plant Operating: 1 Perry, OH

24 048 Pilgrim Nuclear Power Station Operating: 1 Plymouth, MA

24 049 Point Beach Nuclear Plant Operating: 2 Two Rivers, WI

24 050 Prairie Island Nuclear Generating Plant Operating: 2 Welch, MN

24 051 Quad Cities Nuclear Power Station Operating: 2 Cordova, IL

24 053 River Bend Station Operating: 1

Proposed: 1

St. Francisville, LA

24 054 H. B. Robinson Steam Electric Plant Operating: 1 Hartsville, SC

24 055 St. Lucie Plant Operating: 2 Jensen Beach, FL

24 056 San Onofre Nuclear Generating Station Operating: 2 San Clemente, CA

24 057 Seabrook Station Operating: 1 Seabrook, NH

24 058 Sequoyah Nuclear Plant Operating: 2 Soddy-Daisy, TN

24 060 South Texas Project Operating: 2

Proposed: 2

Bay City, TX

24 061 Virgil C. Summer Nuclear Station Operating: 1

Proposed: 2

Jenkensville, SC

24 062 Surry Power Station Operating: 2 Surry, VA

24 063 Susquehanna Steam Electric Station Operating: 2 Luzerne County, PA

24 064 Three Mile Island Nuclear Station Operating: 1 Middletown, PA

24 066 Turkey Point Nuclear Generating Operating: 2

Proposed: 2

Homestead, FL

24 067 Vermont Yankee Nuclear Power Station Operating: 1 Vernon, VT

24 068 Vogtle Electric Generating Plant Operating: 2

Proposed: 2

Waynesboro, GA

24 069 Columbia Generating Station (Formerly WPSS2) Operating: 1 Richland, WA

24 070 Waterford Steam Electric Station Operating: 1 Killona, LA

24 071 Watts Bar Nuclear Plant Operating: 1 Spring City, TN

24 072 Wolf Creek Generating Station Operating: 1 Burlington, KS

Bell Bend Nuclear Power Plant Proposed: 1 Luzerne County, PA

Levy County Proposed: 2 Levy County, FL
PART IV: PROGRAM ADMINISTRATION

REP Program Manual Page IV-66 October 2011

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APPENDIX A: ABBREVIATIONS AND ACRONYMS USED IN THE REP PROGRAM

REP Program Manual Page A-1 October 2011

Appendix A: ABBREVIATIONS AND

ACRONYMS USED IN THE REPPROGRAM

A atomic mass

A ampere

A activity of isotope

AAC After Action Conference

AAR After Action Report

AAR/IP After Action Report/Improvement

Plan

AC alternating current

ACP access control point

AEC U.S. Atomic Energy Commission

AECB U.S. Atomic Energy and Control

Board

AEOD analysis and evaluation of operation

data

AGL above ground level

ALARA as low as reasonably achievable

ALC Annual Letter of Certification

AMA American Medical Association

AMS Aerial Measuring System

AMTOR Amateur Telegraphy over Radio

A&N alert and notification

ANI American Nuclear Insurers

ANL Argonne National Laboratory

ANS Alert and Notification System

ANSI American National Standards Institute

Anti-Cs anti-contamination clothing

APR air-purifying respirator

ARC American Red Cross

ARCA Area Requiring Corrective Action

ARES Amateur Radio Emergency Services

ARG Accident Response Group

ARM aerial radiological monitor

ASLB U.S. Atomic Safety and Licensing

Board

 alpha particle

 beta particle



+

+ particle (positron)



-

ˉ particle (electron)

Ba barium

BEIR biological effects of ionizing radiation

Btu British thermal unit

BWR boiling water reactor

CAP Civil Air Patrol

CAP Corrective Action Program

CA Cooperative Agreement

CC congregate care

CCC congregate care center

CD Civil Defense

CD V Civil Defense Victoreen

CDC U.S. Centers for Disease Control and

Prevention (HHS)

CDE committed dose equivalent

CDRG Catastrophic Disaster Response Group

C&O Concepts and Objectives (Meeting)

C/E Controller and Evaluator

CEDE committed effective dose equivalent

CEM Certified Emergency Manager

CEMP Comprehensive Emergency

Management Plan

CFA Cognizant Federal Agency

CFAO Cognizant Federal Agency Official

cfm cubic feet per minute

CFR Code of Federal Regulations

CHEMTREC Chemical Transportation

Emergency Center

Ci curie

CNSNS Commission for Nuclear Safety and

Safeguards

CPG Comprehensive Preparedness Guide

cpm counts per minute

CRCPD Conference of Radiation Control

Program Directors

CSEPP Chemical Stockpile Emergency

Preparedness Program

Cs cesium

DAC Disaster Application Center

DBA design-basis accident

DECON decontamination

DFO Disaster Field Office

DHEW U.S. Department of Health,

Education, and Welfare

DHS U.S. Department of Homeland

Security
APPENDIX A: ABBREVIATIONS AND ACRONYMS USED IN THE REP PROGRAM

REP Program Manual Page A-2 October 2011

FEMA U.S. Department of Homeland

Security/Federal Emergency

Management Agency

DIL derived intervention level

DIR Disaster-Initiated Review

DNA U.S. Defense Nuclear Agency

DOC U.S. Department of Commerce

DOD U.S. Department of Defense

DOE U.S. Department of Energy

DOH U.S. Department of Health

DOI U.S. Department of the Interior

DOL U.S. Department of Labor

DOS U.S. Department of State

DOT U.S. Department of Transportation

DPM disintegrations per minute

DRD direct-reading dosimeter

DRL derived response levels

DRP Division of Radiation Protection

(DOH Division)

DRSS Division of Radiation Safety and

Safeguards

DSO Director of Site Operations (NRC)

E 911 Enhanced 9-1-1

EAB Exclusion Area Boundary

EACT Emergency Action and Coordination

Team

EAL Emergency Action Level

EAS Emergency Alert System [formerly

Emergency Broadcast System (EBS)]

EBS Emergency Broadcast System

[replaced by the Emergency Alert

System (EAS)]

ECC Emergency Communications Center

ECCS emergency core cooling system

ECL Emergency Classification Level

ED Exercise Day

EDE effective dose equivalent

EEG Exercise Evaluation Guide

EEM Exercise Evaluation Methodology

(obsolete term)

EENET Emergency Educational Network

EICC Emergency Information Coordination

Center (FEMA)

EIS Emergency Information System

EM emergency management

EMI Emergency Management Institute

(FEMA)

EMPO Emergency Medical Preparedness

Office

EMS Emergency Medical Services

EMT Emergency Medical Technician

EO Emergency Office

E.O. Executive Order of the President

EOC Emergency Operations Center (state,

tribal or local government)

EOF Emergency Operations Facility

(utility)

EOP Emergency Operations/Operating Plan

or Procedure

EOP extent of play

EOV emergency operations vehicle

EP Emergency Preparedness

EPA U.S. Environmental Protection

Agency

EPD electronic personnel dosimeter

EPG Exercise Preparation Guide

EPO Environmental Protection Officer

EPT Exercise Planning Team

EPZ Emergency Planning Zone

ER emergency room

ERC Emergency Response Coordinator

ERDA Energy Research and Development

Administration

ERPA Emergency Response Planning Area

ERPG Emergency Response Guidelines

ERPS Effluents Radiation Protection Section

ERT Emergency Response Team

ERT-A Emergency Response Team –

Advance

ESF Emergency Support Function

ESP Early Site Permit

EST Emergency Support Team (FEMA)

ETA estimated time of arrival

ETE Evacuation Time Estimate

ETS Evacuation Time Study

EW emergency worker

EWAC emergency worker and assistance

center

EWC emergency worker center

EWMDS emergency worker monitoring and

decontamination station

ExPlan Exercise Plan

FAA Federal Aviation Administration

FBI Federal Bureau of Investigation

FCC U.S. Federal Communications

Commission

FCO Federal Coordinating Officer

FCP Field/Forward Command Post

FDA U.S. Food and Drug Administration
APPENDIX A: ABBREVIATIONS AND ACRONYMS USED IN THE REP PROGRAM

REP Program Manual Page A-3 October 2011

FECC Federal Emergency Communications

Coordinator

FEMA Federal Emergency Management

Agency

FFE Federal Field Exercise

FMT Field Monitoring Team

FNF fixed nuclear facility

FNSS Functional Needs Support Services 

FOC Forward Operations Center

FPC Federal Preparedness Coordinator

FPC Final Planning Conference

FR Federal Register

FRC Federal Regional Center

FRC Federal Response Center

FRERP Federal Radiological Emergency

Response Plan

FRMAC Federal Radiological Monitoring and

Assessment Center

FRMAP Federal Radiological Monitoring and

Assistance Plan

FRMT Field Radiological Monitoring Team

FRPCC Federal Radiological Preparedness

Coordinating Committee

FRSSB Facilities Radiological Safety and

Safeguards Branch

FSA Forward Staging Area

FSAR Final Safety Analysis Report

FTC Field Team Coordinator

FTS Federal Telecommunications System

 gamma ray (photon)

GE General Emergency

GCF ground concentration factor

Ge (Li) lithium drifted germanium

GIS geographic information system

GM Guidance Memorandum

G-M Geiger-Mueller (radiation detector)

GMT Greenwich Mean Time (a.k.a. UTC or

Zulu)

GPS global positioning system

GSA U.S. General Services Administration

H2 hydrogen (molecular)

H2O water

HAB hostile action-based

HAZMAT hazardous materials

HEAR Hospital Emergency Administrative

Radio

HEPA high-efficiency particulate air (filters)

HF high frequency

HF hydrogen fluoride

HHS U.S. Department of Health and 

Human Services

HOO Headquarters Operations Officer

(NRC)

HP health physicist

HPSI high pressure safety injection

HPT health physics technician

HSEEP Homeland Security Exercise and

Evaluation Program

HSPD Homeland Security Presidential

Directive

HUD U.S. Department of Housing and

Urban Development

HQ headquarters

I iodine

I exposure intensity

IAEA International Atomic Energy Agency

IC Incident Commander

ICPAE Interagency Committee for Public

Affairs in Emergencies

ICP Incident Command Post

ICS Incident Command System

IDLH immediately dangerous to life or

health

IEP Ingestion Exposure Pathway

IMAAC Interagency Modeling and

Atmospheric Assessment Center

INEEL Idaho National Engineering and

Environmental Laboratory

INPO Institute for Nuclear Power

Operations

IP implementing procedure

IP Improvement Plan

IPC Initial Planning Conference

IRAC Interagency Radiological Assistance

Committee

IRAP Interagency Radiological Assistance

Plan (replaced with FRMAP)

IRZ Immediate Response Zone

IS Independent Study

ISCORS Interagency Steering Committee on

Radiation Standards

JIC Joint Information Center

JIS Joint Information System

JNC Joint News Center

JOC Joint Operations Center

JPIC Joint Public Information Center
APPENDIX A: ABBREVIATIONS AND ACRONYMS USED IN THE REP PROGRAM

REP Program Manual Page A-4 October 2011

KI potassium iodide

kV kilovolt

kW kilowatt

kWh kilowatt hour

lbf pound force

LANL Los Alamos National Laboratory

LAO Lead Agency Official

LD lethal dose

LEPC Local Emergency Planning

Committee

LERN Law Enforcement Radio Net

LFA Lead Federal Agency

LLEA Local Law Enforcement Agency

LLNL Lawrence Livermore National

Laboratory

LOA Letter of Agreement

LOCA loss of coolant accident

LPN licensed practical nurse

LPZ low population zone

LWR light water reactor

MAC Monitoring and Analysis Coordinator

MAELU Mutual Atomic Energy Liability

Underwriters

MERRT Medical Emergency Radiological

Response Team

MERS Mobile Emergency Response Support

MET meteorological

MHz megahertz

MIC Media Information Center

MOA Memorandum of Agreement

MOU Memorandum of Understanding

MPC maximum permissible concentration

MPC Mid-term Planning Conference

mR milliroentgen/millirem

mR/h milliroentgen per hour

mRem millirem

MRV mobile response vehicle

MS-1 Medical Services (term from retired

guidance memorandum)

MSEL Master Scenario Events List

MSHA U.S. Mine Safety and Health

Administration

MT metric ton

MW megawatt

MWH megawatt hour

MUDAC Meteorological and Unified Dose

Assessment Center

μ micro

μCi microcuries

NAAQS National Ambient Air Quality

Standards

NAERG North American Emergency Response

Guidebook

NaI(Tl) sodium iodide doped with thallium

(scintillator)

NARAC National Atmospheric Release

Advisory Center (DOE)

NARP Nuclear Accident Response Plan (or

Procedures)

NASA National Aeronautics and Space

Administration

NAWAS National Warning System

NCC National Coordinating Center for

Telecommunications

NCP National Contingency Plan

NCRP National Council on Radiation

Protection and Measurements

NCS National Communications System

NDA National Defense Area

NEI Nuclear Energy Institute

NEMA National Emergency Management

Association

NEP National Exercise Program

NESC National Exercise Coordination 

Center

NESP National Environmental Studies

Project (NUMARC)

NETC National Emergency Training Center

(FEMA)

NEXS National Exercise Schedule

NFPA National Fire Protection Association

NGO non-governmental organization

NIFC National Interagency Fire Center

NIMS National Incident Management

System

NIOSH U.S. National Institute for

Occupational Safety and Health

NIST U.S. National Institute of Standards &

Technology [formerly National

Bureau of Standards (NBS)]

NMSS Nuclear Materials Safeguards and

Security

NOAA U.S. National Oceanic and

Atmospheric Administration

NOUE Notification of Unusual Event

NPD National Preparedness Directorate

NPP nuclear power plant

NPS U.S. National Park Service

NRC U.S. Nuclear Regulatory Commission
APPENDIX A: ABBREVIATIONS AND ACRONYMS USED IN THE REP PROGRAM

REP Program Manual Page A-5 October 2011

NRF National Response Framework

NRIA Nuclear/Radiological Incident Annex

(NRF)

NRT National Response Team

NSA National Security Area

NTS Nevada Test Site

NTSB U.S. National Transportation Safety

Board

NUMARC Nuclear Management and

Resources Council

NUREG Nuclear Regulation (NRC Documents

Reference)

NUREG-0654 NUREG-0654/FEMA-REP1, Revision 1, Criteria for

Preparation and Evaluation of

Radiological Emergency Response

Plans and Preparedness in Support of

Nuclear Power Plants, November

1980

NVLAP National Voluntary Laboratory

Accreditation Program

NWS U.S. National Weather Service

OAR Office of Air and Radiation

OCRWM Office of Civilian

Radioactive Waste Management

OFA Other Federal Agencies

OEM Office of Emergency Management

OMB Office of Management and Budget

OOS Out of Sequence

ORIA Office of Radiation and Indoor Air

(EPA)

ORNL Oak Ridge National Laboratory

ORO Offsite Response Organization

OSC Operational Support Center

OSC On-Scene Coordinator/Commander

OSHA U.S. Occupational Safety and Health

Administration

OST Operation Support Team

PA Public Address

PA Public Affairs

PAs Protective Actions

PAD Protective Action Decision

PAG Protective Action Guide

PAO Public Affairs Officer

PAR Protective Action Recommendation

PAZ Protective Action Zone

PFO principal Federal official

PEL permissible exposure limit

PHS Public Health Service

PIC pressurized ion chamber

PIO Public Information Officer

PKEMRA Post-Katrina Emergency

Management Reform Act

PL Public Law

POR Point of Review

PPE personal protective equipment

ppm parts per million

PRD Permanent Record Dosimeter

psi pounds per square inch

psia pounds per square inch absolute

psig pounds per square inch gage

Pu plutonium

PWR pressurized water reactor

PZ Precautionary Zone

§ Part (see CFR)

Q release rate of activity

Qi otopic release rate

QT total activity released

R roentgen

R/h roentgen per hour

Ra radium

RA Regional Administrator

RAC Regional Assistance Committee

RAC AC Regional Assistance Committee

Advisory Council

RACES Radio Amateur Civil Emergency

Services

rad radiation absorbed dose

RADLAB radiological laboratory

RAM radioactive material

RAP Radiological Assistance Program

(DOE)

RASCAL Radiological Assessment

System for Consequence Analysis

RC reception/relocation center

RCC reception and congregate care

RCF release conversion factor

RCS reactor coolant system

RCT Response Coordination Team

RDO Radiological Defense Officer

RDO Regional Duty Officer

REA Radioactive Emergency Area

REDAM Radiological Emergency Dose

Assessment Model

REL recommended exposure limit

rem roentgen equivalent man/mammal

REP Radiological Emergency Preparedness
APPENDIX A: ABBREVIATIONS AND ACRONYMS USED IN THE REP PROGRAM

REP Program Manual Page A-6 October 2011

RERO Radiological Emergency Response

Operations

RERP Radiological Emergency Response

Plan

RERT Radiological Emergency Response

Team

RF radio frequency

RG Review Guide

R/h roentgens per hour

RIS Regulatory Issue Summary

RM Radiological Monitor

RMT Radiological Monitoring Team

RO Radiological Officer

ROST Regional Office Support Team

rpm revolutions per minute

RPT radiation protection technician

RRAC Regional Radiological Assistance

Committee

RRCC Regional Response Coordination

Center

RRF Regional Response Force

RRT Radiological Response Team

RRT Regional Response Team

RX reactor

SAA State Administrative Agency

SAE Site Area Emergency

SAR search and rescue

SAR Safety Analysis Report

SARA Superfund Amendments and

Reauthorization Act of 1986

SAV Staff Assistance Visit

SBA U.S. Small Business Administration

SCBA self-contained breathing apparatus

SCO State Coordinating Officer

SEOC State Emergency Operations Center

SERF Standard Exercise Report Format

SFO senior FEMA official (FRERP)

SGTR steam generator tube rupture

SGTS standard gas treatment system

SME subject matter expert

SOG standard operating guidelines

Sr strontium

SRD self-reading dosimeter

SRF Service or Agency Response Force

SRSC Strategic Review Steering Committee

SRV safety relief valve

SSA Senior State Advisor

SSE safe shutdown earthquake

ST-DOSE source term to dose

SWAT special weapons and tactics

T&EPW Training and Exercise Planning 

Workshop

TBA thyroid blocking agent (see KI)

TCL Target Capabilities List

TCP traffic control point

TDD telecommunications device for the

deaf

TEDE total effective dose equivalent

TEP Training and Exercise Plan

TH technological hazards

THD Technological Hazards Division

(FEMA)

TL Team Leader

TLD thermoluminescent dosimeter

TMI Three Mile Island Generating Station

TSC Technical Support Center

TSP total suspended particulates

TTC Technical Training Center

TTX Tabletop Exercise

U uranium

μCi microcurie

UHF ultra high frequency

UO2F2 uranyl fluoride

US&R urban search & rescue

USACE U.S. Army Corps of Engineers

USC United States Code

USCG U.S. Coast Guard

USDA U.S. Department of Agriculture

UTC Coordinated Universal Time (a.k.a.

GMT or Zulu)

V volt

VA U.S. Veterans Administration

VFD Volunteer Fire Department

VFR visual flight rules

VHF very high frequency

VOAD Voluntary Organization Active in

Disaster

W watt

WB whole body

WP Warning Point

Wt weight

Z atomic number

Z Zulu (a.k.a. UTC or GMT)

Zr zirconium
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-1 October 2011

Appendix B: GLOSSARY OF REPTERMS

Absorbed dose: when ionizing radiation passes

through living tissue, some of its energy is

imparted to the tissue, which absorbs it. The

amount of ionizing radiation absorbed per unit

mass of the irradiated tissue is called the

absorbed dose. It is measured in rads and rems.

Access control: all activities accomplished for

the purpose of controlling entry or reentry into

an area that has either been evacuated or is under

a sheltering protective action decision to

minimize the radiation exposure of individuals

because of radiological contamination. This

function is needed to prevent the general public

from entering restricted areas (sheltered and/or

evacuated) and permitting only emergency

workers with essential missions and limited

members of the general public to enter.

Access and functional needs: Those actions, 

services, accommodations, and programmatic, 

architectural, and communication modifications 

that a covered entity must undertake or provide 

to afford individuals with disabilities a full and 

equal opportunity to use and enjoy programs, 

services, activities, goods, facilities, privileges, 

advantages, and accommodations in the most 

integrated setting, in light of the exigent 

circumstances of the emergency and the legal 

obligation to undertake advance planning and 

prepare to meet the disability-related needs of 

individuals who have disabilities as defined by 

the ADA Amendments Act of 2008, P.L. 110-

325, and those associated with them. Access and 

functional needs may include modifications to 

programs, policies, procedures, architecture, 

equipment, services, supplies, and 

communication methods. Examples of ―access 

and functional needs‖ services may include a 

reasonable modification of a policy, practice, or 

procedure or the provision of auxiliary aids and 

services to achieve effective communication, 

such as: (1) an exception for service animals in 

an emergency shelter where there is a no pets 

policy; (2) the provision of way-finding 

assistance to someone who is blind to orient to 

new surroundings; (3) the provision of 

transferring and toileting assistance to an 

individual with a mobility disability; and (4) the 

provision of an interpreter to someone who is 

deaf and seeks to fill out paperwork for public 

benefits.

Accident assessment: the evaluation of the

actual and potential consequences of a

radiological incident.

Accident Response Group (ARG): Department

of Energy response group. A team of scientists,

engineers, and technicians that is trained,

organized, and equipped to respond to a nuclear

weapons accident/incident.

Action levels: see trigger/action levels.

Activated: an emergency operations center or

other facility is considered activated as soon as

notification of an incident is received and the

Director/Commissioner/responsible

Representative makes the determination to

activate the facility. The facility is not

considered operational until it is ready to carry

out full emergency operations with key decision

makers in place.

Activation of personnel: the process by which

emergency response personnel are notified of an

incident and instructed to report for duty.

Acute exposure: an exposure to radiation that

occurs over a short period of time, usually less

than an hour.

Adequate: as used in reviews of radiological

emergency response plans/procedures, adequate

means that the plan/procedure contents are

consistent and in full compliance with the

requirements delineated in the NUREG0654/FEMA-REP-1 Planning Standards and

Evaluation Criteria or alternative approaches

approved by FEMA.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-2 October 2011

Administration/Finance Section: as applied to

an exercise planning team organized according

to Incident Command System principles, the

team members providing grant management and

administrative support throughout exercise

development. This group is also responsible for

the registration process and coordinates

schedules for the exercise planning team, the

exercise planning team leader, participating

agencies, and the host community or

communities.

Advisory Team (A-Team): an emergency 

response group within the Federal Radiological 

Preparedness Coordinating Committee tasked 

with providing protective action 

recommendations to state and local governments 

on behalf of its member agencies. The Advisory 

Team is incorporated into the National Response 

Framework and is comprised of the individuals 

from represented agencies who have been 

activated to respond as members of the Advisory 

Team during a radiological incident.

Aerial Measuring System (AMS): a

Department of Energy asset consisting of an

integrated remote-sensing capability for rapidly

determining radiological and ecological

conditions of large areas of the environment. In

conjunction with modern laboratory and

assessment techniques, state-of-the-art airborne

equipment is used for extremely low-level

gamma radiation detection, high-altitude

photography, airborne gas and particulate

sampling, and multi-spectral photography and

scanning.

After Action Conference (AAC): as soon as

possible after completion of the draft After

Action Report, the lead evaluator, members of

the evaluation team, and other members of the

exercise planning team conduct an After Action

Conference to present, discuss, and refine the

draft After Action Report, and to develop an

Improvement Plan. This conference is a chance

to present the After Action Report to

participating entities in order to solicit feedback

and make necessary changes. A list of corrective

actions is generated identifying what will be

done to address the recommendations, who

(what agency or person) is responsible, and the

timeframe for implementation.

After Action Report / Improvement Plan

(AAR/IP): the main product of the evaluation

and improvement planning process is the

AAR/IP. The AAR/IP has two components: an

AAR, which captures observations of an

exercise and makes recommendations for postexercise improvements; and an IP, which

identifies specific corrective actions, assigns

them to responsible parties, and establishes

targets for their completion. The lead evaluator

and the exercise planning team draft the AAR

and submit it to conference participants prior to

the After Action Conference. The draft AAR is

completed first and distributed to conference

participants for review no more than 30 days

after exercise conduct. The final AAR/IP is an

outcome of the After Action Conference. Final

REP AAR/IPs are published no more than 90

days after exercise conduct. Even though the

AAR and IP are developed through different

processes and perform distinct functions, the

final AAR and IP are printed and distributed

jointly as a single AAR/IP following an

exercise. However, sensitive material may be

included in appendices that are not released to

the public.

Agreement state: a state that has entered into an

agreement under the Atomic Energy Act of

1954, as amended, in which the Nuclear

Regulatory Commission has relinquished to

such states the majority of its regulatory

authority over source, by-product, and special

nuclear material in quantities not sufficient to

form a critical mass.

Airborne radioactivity: any radioactive

material dispersed in the air in the form of dusts,

fumes, mists, vapors, or gases.

Air sampler: a device used to collect a sample

of radioactive particulates suspended in the air.

ALARA: acronym meaning ―as low as

reasonably achievable.‖

Alert: licensee emergency classification level

indicating that events are in process or have
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-3 October 2011

occurred that involve an actual or potential

substantial degradation in the level of plant

safety or a security event that involves probable

life threatening risk to site personnel or damage

to site equipment because of intentional

malicious dedicated efforts of a hostile act.

Releases are expected to be limited to small

fractions of the Environmental Protection

Agency protective action guide exposure levels.

Alerting of personnel: transmission of a signal

or message that places personnel on notice that

an incident has developed that may require that

they report for emergency duty.

Alerting the public: activating an attentiongetting warning signal through such means as

sirens, tone alert radios, route alerting, and

speakers on cars, helicopters, and boats.

Alert system: the hardware system(s) used to

get the attention of the public within the plume

emergency planning zone. An alert system may

include a combination of sirens; tone activated

radios; vehicles (including boats and airplanes)

that utilize loud speakers/sirens, and other

equipment that provides an alert signal.

Alpha particle: a positively charged particle

ejected spontaneously from the nuclei of some

radioactive elements. It is identical to a helium

nucleus that has a mass number of 4 and an

electrostatic charge of plus 2. It has lowpenetrating power and short range. The most

energetic alpha particle will generally fail to

penetrate the skin. Alpha is hazardous when an

alpha-emitting isotope is introduced into the

body. Alpha particles are the least penetrating of

the three common types of radiation (alpha, beta,

and gamma) and can be stopped by a piece of

paper (cannot penetrate skin).

Alternate Emergency Operations Center: an

emergency operations center outside the

emergency planning zone to which an

emergency response organization may relocate if

they must evacuate the ―home emergency

operations center‖ due to possible radioactive

exposure.

Area Requiring Corrective Action (ARCA):

an observed or identified inadequacy of

organizational performance in an exercise that is

not considered, by itself, to adversely impact

public health and safety. Correction of ARCAs

is verified before or during the next biennial

exercise at that site.

Assessment: the evaluation and interpretation of

radiological measurements and other

information to provide a basis for decisionmaking. Assessments can include projections of

offsite radiological impact.

Atom: the smallest particle of an element that

cannot be divided or broken up by chemical

means. It consists of a central core called the

nucleus, which contains protons and neutrons.

Electrons revolve in orbits in the region

surrounding the nucleus.

Atomic energy: energy released in nuclear

reactions, more appropriately called ―nuclear

energy.‖ Of particular interest is the energy

released when a neutron initiates the breaking up

or fissioning of an atom‘s nucleus into smaller

pieces (fission), or when two nuclei are joined

together under millions of degrees of heat

(fusion).

Background radiation: the level of naturally

occurring radiation in the environment. Sources

include air, water, soil, potassium-40 in the body

and cosmic radiation from the sun. The usually

quoted individual background radiation

exposure in man‘s natural environment is an

average of 125 millirem per year.

Beta particle: a charged particle emitted from a

nucleus during radioactive decay, with a mass

equal to 1/1827 that of a proton. A negatively

charged beta particle is identical to an electron.

A positively charged beta particle is called a

positron. Large amounts of beta radiation may

cause skin burns, and beta emitters are harmful

if they enter the body. Most beta particles can be

stopped by aluminum foil.

Body burden: the amount of radioactive

material present in the body of a human or an

animal.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-4 October 2011

Boiling water reactor (BWR): a nuclear reactor

in which water, used both as coolant and

moderator, is allowed to boil in the reactor

vessel. The resulting steam is used directly to

drive a turbine.

Breeder reactor: a nuclear reactor that produces

or ―breeds‖ more fissionable material than it

consumes. The reactor is built with a core of

fissionable plutonium-239, surrounded by a

blanket of uranium-238. As the plutonium

fissions, neutrons bombard the uranium

converting the uranium blanket to more

plutonium-239.

Btu: a British thermal unit. The amount of heat

required to change the temperature of one pound

of water one degree Fahrenheit at sea level.

Buffer zone: an area adjacent to a restricted

zone, to which residents may return, but for

which protective measures are recommended to

minimize exposure to radiation.

Buffer zone (medical facilities): an area (within

a hospital or other medical facility) adjacent to

the radiological emergency area (restricted zone)

for which protective measures are recommended

to minimize both exposure to radiation and the

spread of radiological contamination to

radiologically clean areas of the facility.

Calibration: the check or correction of the

accuracy of a measuring instrument to ensure

proper operational characteristics.

Cask: a heavily shielded container used to store

and/or ship radioactive materials. Lead and steel

are common materials used in the manufacture

of casks.

Chain-of-custody form: the documentation of

the transfer of samples from one organization

and individual to another with respect to the

name of the organization and individual and

dates of acceptance and/or transfer of samples.

Chain reaction: a fission chain reaction occurs

when a fissionable nucleus absorbs a neutron

and fissions, relating additional neutrons. These

in turn can be absorbed by other fissionable

nuclei, releasing more neutrons. A chain

reaction is achieved when this process becomes

self-sustaining.

Check source: a radioisotope with a known,

relatively fixed activity level used to determine

the responsiveness of survey instruments.

Chronic exposure: exposure to small doses of

radiation over an extended period of time.

Cladding: the outer jacket of nuclear fuel

elements. It prevents corrosion of the fuel and

the release of fission products into the coolant.

Aluminum or its alloys, stainless steel and

zirconium are common cladding materials.

Cobalt-60 (Co-60): a radioactive isotope of

cobalt formed from natural cobalt-59 by neutron

activation in reactors. It is used for medical and

industrial applications.

Cognizant Federal Agency (CFA): the Federal

agency that owns, authorizes, regulates, or is

otherwise deemed responsible for the

radiological activity causing the emergency and

that has the authority to take action on site.

Cognizant Federal Agency Official (CFAO):

lead official designated by the Cognizant

Federal Agency to manage its response at the

site of a radiological emergency.

Command Staff: as applied to an exercise

planning team organized according to Incident

Command System principles, the team members

responsible for coordinating all exercise

planning activities. Within this group is the

exercise planning team leader, who assigns

exercise activities and responsibilities, provides

guidance, establishes timelines, and monitors the

development process. The safety controller and

the liaison coordinator report directly to the

exercise planning team leader.

Commercial nuclear power plant (NPP):

facility licensed by the Nuclear Regulatory

Commission to use a nuclear reactor to produce

electricity for sale to the general public. While

there are many types of nuclear facilities,
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-5 October 2011

FEMA‘s responsibility for offsite planning and

preparedness and the guidance in the REP

Program Manual are applicable only to

commercial nuclear power plants.

Committed dose: the dose that will be received

over a period of 50 years from the ingestion or

inhalation of a particular quantity of a

radionuclide or a specific mix of radionuclides.

Committed dose equivalent (CDE): the dose

equivalent to organs or tissues of reference that

will be received from an intake of radioactive

material by an individual during the 50-year

period following ingestion.

Committed effective dose equivalent (CEDE):

the sum of the 50-year committed doses to

individual organs from inhalation (or ingestion)

of radionuclides, where the individual organ

doses have been weighted so that the associated

risk of fatal cancer can be added to the risk of

fatal cancer from whole-body dose.

Concepts and Objectives (C&O) Meeting: the

formal beginning of the exercise planning

process. It is held to ensure that exercise

planners agree upon the already-identified type,

scope, capabilities, objectives, and purpose of

the exercise. For less complex exercises and for

entities with limited resources, the C&O

Meeting can be conducted in conjunction with

the Initial Planning Conference; however, when

exercise scope dictates, the C&O Meeting is

held first. Representatives from the sponsoring

agency or organization, the exercise planning

team leader, and senior officials typically attend

the C&O Meeting to identify an overall exercise

goal, develop rough drafts of exercise

capabilities and objectives, and identify exercise

planning team members.

Congregate care (CC): the provision of

temporary housing and basic necessities for

evacuees.

Congregate care center (CCC): a facility for

temporary housing, care, and feeding of

evacuees.

Containment: the provision of a gas-tight shell

or other enclosure around a reactor that confines

fission products and prevents their release to the

environment in an accident.

Contaminated: the condition resulting from the

adhesion of radioactive particulates to the

surface of structures, areas, objects, or

personnel.

Contaminated injured individuals: individuals

who are: (1) contaminated with radioactive

material that cannot be removed by the simple

methods described in NUREG-0654/FEMAREP-1, Evaluation Criteria J.12 and K.5.b; or (2)

contaminated and otherwise physically injured.

Individuals exposed to high levels of radiation

may be injured but not contaminated.

Contamination: refers to radioactive materials

not in their intended containers. Whether the

contamination is considered ―fixed‖ or ―loose‖

depends on the degree of effort required to unfix

or remove the contamination from a surface.

Contextual inject: a controller-introduced 

message to a player to help build the exercise 

operating environment. For example, if the 

exercise is designed to test information-sharing 

capabilities, a Master Scenario Events List inject 

can be developed to direct a controller to select 

an actor to portray a suspect. The inject could 

then instruct the controller to prompt another 

actor to approach a law enforcement officer and 

inform him/her that this person was behaving 

suspiciously. 

Contingency inject: a controller message 

introduced verbally to a player if players are not 

performing the actions needed to sustain 

exercise play. This ensures that play moves 

forward, as needed, to adequately test 

performance of activities. For example, if a 

simulated secondary device is placed at an 

incident scene during a terrorism response 

exercise, but is not discovered, a controller may 

want to prompt an actor to approach a player to 

say that he/she witnessed suspicious activity 

close to the device location. This prompts the 

responder‘s discovery of the device, and result 
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-6 October 2011

in subsequent execution of the desired 

notification procedures.

Control cell: exercise personnel who facilitate

interfaces with nonparticipating groups, such as

ORO officials and persons with disabilities and 

access/functional needs.

Control rod: a rod containing a material that

readily absorbs neutrons (such as boron). It is

used to control the power of a nuclear reactor.

By absorbing neutrons, a control rod slows the

fission chain reaction by preventing neutrons

from causing further fission.

Control room: the area in a nuclear power plant

from which most of the plant power production

and emergency safety equipment can be

operated by remote control.

Controlled area: a defined area in which the

occupational exposure of personnel to radiation

or radioactive material is under the supervision

of an individual in charge of radiation

protection.

Controller: the individual directing the flow of

scenario events in order to ensure that the

conduct of an exercise is conducted in

accordance with the agreed-upon exercise

objectives and the extent of play.

Controller/Evaluator (C/E) briefing: a preexercise overview for controllers, evaluators,

and exercise administrative staff. The briefing

summarizes the C/E Handbook (or the

Controller/Staff Instructions and Evaluation

Plan) and focuses on explaining the roles and

responsibilities of controllers and evaluators.

This is the time to address any changes in the

exercise and answer final questions. It is

generally 1-2 hours in length and is conducted

the day before an operations-based exercise.

Controller/Evaluator (C/E) Handbook: an

exercise overview and instructional manual for

controllers and evaluators. A supplement to the

Exercise Plan, it contains more detailed

information about the scenario, and describes

controllers‘ and evaluators‘ roles and

responsibilities. Because the C/E Handbook

contains information on the scenario and

exercise administration, it is distributed only to

those individuals specifically designated as

controllers or evaluators. Larger, more complex

exercises may use a separate Controller/Staff

Instructions and Evaluation Plan in place of the

C/E Handbook.

Controller injects: the introduction of events,

data, and information into exercises to drive the

demonstration of objectives.

Coolant: a substance, usually water, circulated

through a nuclear reactor to remove or transfer

heat.

Cool down: the gradual decrease in reactor fuel

rod temperature caused by the removal of heat

from the reactor coolant system.

Cooling tower: a heat exchanger designed to aid

in the cooling of water that was used to cool

exhaust steam exiting the turbines of a power

plant. Cooling towers transfer exhaust heat into

the air instead of into a body of water.

Coordinate: to bring into common action so as

not to unnecessarily duplicate or omit important

actions (does not involve direction of one

agency by another).

Core: the central portion of a nuclear reactor

containing the fuel elements, moderator, neutron

poisons, and support structures.

Core melt accident: a reactor accident in which

the fuel core melts because of overheating.

Corrective action: corrective actions are the

concrete, actionable steps outlined in

Improvement Plans that are intended to resolve

preparedness gaps and shortcomings

experienced in exercises or real-world events.

Corrective action plan (CAP): an element of

improvement planning through which corrective

actions from the After Action

Report/Improvement Plan are prioritized,

tracked, and analyzed continuously until they

have been fully implemented and validated.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-7 October 2011

Counting: using an instrument to detect

individual particles or gamma rays which

interact with the detector on the instrument. For

example, ambient radiation can be counted, or,

alternatively, the radiation emitted by specific

samples can be counted in units of counts per

minute (cpm) or counts per second (cps).

Criticality: a term used in reactor physics to

describe the state when the number of neutrons

released by fission is exactly balanced by the

neutrons being absorbed (by the fuel and

poisons) and escaping the reactor core. A reactor

is said to be ―critical‖ when it achieves a selfsustaining nuclear chain reaction.

Cumulative dose (radiation): the total dose

resulting from repeated exposure to radiation of

the same body region, or of the whole body.

curie (Ci): the basic unit to describe the

intensity of radioactivity in a sample of material.

One curie is equal to 37 billion disintegrations

(nuclear transformations) per second. So, in one

curie, 37 billion atoms decay in one second.

Several commonly used fractions of the curie

include:

millicurie: 1/1,000 of a curie, (one

thousandth of a curie,

abbreviated mCi)

microcurie: 1/1,000,000 of a curie, (one

millionth of a curie, abbreviated

μCi)

nanocurie: 1/1,000,000,000 of a curie, (one

billionth of a curie, abbreviated

nCi)

picocurie: 1/1,000,000,000,000 of a curie

(one trillionth of a curie,

abbreviated pCi)

Daycare center: a specialized program or

facility that provides care for children from

infants through preschool age, usually within a

group framework, and dependent children or

adults, either as a substitute for or an extension

of home care. Daycare centers may be licensed

or unlicensed.

Debrief: a forum for planners, facilitators,

controllers, and evaluators to review and provide

feedback after the exercise is held. It is a

facilitated discussion that allows each person an

opportunity to provide an overview of the

functional area they observed and document

strengths and areas for improvement. The

exercise planning team leader facilitate debriefs,

and results are captured for inclusion in the

After Action Report/Improvement Plan. (NOTE:

Other sessions, such as a separate debrief for

hospitals during an operations-based exercise,

may be held as necessary.) A debriefing is

different from a hot wash, in that a hot wash is

intended for players to provide feedback.

Decay (radioactive): the decrease in the

radiation intensity of any radioactive material

with respect to time.

Decontamination: the process of making any

person, object, or area safe by absorbing,

destroying, neutralizing, making harmless, or

removing chemical or biological agents, or by

removing radioactive material clinging to or

around it.

Decontamination station: a building or location

suitably equipped and organized where

personnel and material are cleansed of chemical,

biological, or radiological contaminants.

Deficiency: an observed or identified

inadequacy of organizational performance in an

exercise that could cause a finding that offsite

emergency preparedness is not adequate to

provide reasonable assurance that appropriate

protective measures can be taken in the event of

a radiological emergency to protect the health

and safety of the public living in the vicinity of a

nuclear power plant. Deficiencies must be

corrected within 120 days of the exercise.

Demonstration Criterion: one of the 34

specific demonstration standards outlined in the

FEMA REP Program Manual for offsite

response organization response capability that

are evaluated during a REP exercise.

Depleted uranium: uranium having a

percentage of uranium-235 smaller than the

0.7% found in natural uranium. It is obtained

from spent (used) fuel elements or as byproduct
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-8 October 2011

tails or residues from uranium isotope

separation.

Derived intervention levels (DILs): 

concentration derived from the intervention level 

of dose at which the Food and Drug 

Administration recommends consideration of 

protective measures. DILs correspond to the 

radiation concentration in food throughout the 

relevant time period that, in the absence of any 

intervention, could lead to an individual 

receiving a radiation dose equal to the protective 

action guide or in international terms the 

intervention levels of dose.

Derived response level (DRL): the calculated

concentration of a particular radionuclide in a

particular medium (e.g., food) that will produce

a dose equal to a protective action guide.

Design and development: building on the

exercise foundation, consists of identifying

capabilities, tasks, and objectives; designing the

scenario; creating documentation; coordinating

logistics; planning exercise conduct; and

selecting an evaluation and improvement

methodology.

Direction and control: the management of

emergency functions within a particular context

(e.g., an emergency operations center) through

leadership and use of authority.

Direct-reading dosimeter (DRD): a small

ionization detection instrument that indicates

radiation exposure directly. An auxiliary

charging device is usually necessary. DRDs can

be read in real time by the user. A DRD is also

referred to as a ―pocket dosimeter.‖

Dose: the quantity of energy absorbed from

ionization per unit mass of tissue. The rad is the

unit of absorbed dose.

Dose equivalent: (1) A term used to express the

amount of effective radiation when modifying

factors have been considered. (2) The product of

absorbed dose multiplied by a quality factor

multiplied by a distribution factor. It is

expressed numerically in rem. (3) The product

of the absorbed dose in rad, a quality factor

related to the biological effectiveness of the

radiation involved and any other modifying

factors.

Dose limits for emergency workers: the

allowable accumulated dose during the entire

period of the emergency. Action to avoid

exceeding the limit is taken based on actual

measurements of integrated gamma exposure. In

contrast, protective action guides are

trigger/action levels of projected dose at which

actions are taken to protect the public. These

actions are taken prior to the dose being

received.

Dose rate: the radiation dose delivered per unit

time. The dose rate may be expressed

numerically in rads per second or rads per hour.

Dosimeter: a portable device such as a

thermoluminescent film badge or direct-reading

ionization chamber used for measuring and

registering the total accumulated exposure to

ionizing radiation.

Dosimetry: the measurement of radiation doses.

It applies to both the devices used (dosimeters)

and to the techniques.

Drill: an event involving organizational

responses to a simulated accident to develop,

test, and monitor specialized emergency skills

that constitute one or more components of

emergency plans/procedures.

Early phase: (also referred to as the plume or

emergency phase) the period at the beginning of

a nuclear incident when immediate decisions for

effective use of protective actions are required

and must therefore usually be based primarily on

the status of the nuclear power plant and the

prognosis for worsening conditions. When

available, predictions of radiological conditions

in the environment based on the condition of the

source or actual environmental measurements

may also be used. Precautionary actions may

precede protective actions based on the

protective action guides. This phase lasts hours

to several days and ends when the radioactive

release ends.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-9 October 2011

Effective dose equivalent (EDE): the sum of

the products of the dose equivalent to each organ

on a weighting factor, where the weighting

factor is the ratio of the risk of mortality from

delayed health effects arising from irradiation of

a particular organ or tissue to the total risk of

mortality from delayed health effects when the

whole body is irradiated uniformly to the same

dose.

Electron: a stable, negatively charged

elementary particle of matter. Electrons orbit the

positively charged nucleus of the atom.

Element: one of the 103 known chemical

substances that cannot be broken down further

without changing its chemical properties. Some

examples include hydrogen, nitrogen, gold, lead,

and uranium.

Emergency: an unexpected event during the

operation of a nuclear power plant that has a

significant effect on the safety of the facility,

personnel or the public.

Emergency Action and Coordination Team

(EACT): the Department of Energy senior

management team at Department of Energy

headquarters that coordinates the initial National

Response Framework response to a radiological

emergency.

Emergency Alert System (EAS): a system of

radio and television stations responsible for

providing official government instructions to the

public (formerly the Emergency Broadcast

System).

Emergency Classification Level (ECL):

classifications used by the licensee to classify

incidents. The four ECLs are Notification of

Unusual Event, Alert, Site Area Emergency, and

General Emergency.

Emergency Information and Coordination

Center (EICC): the FEMA 24-hour national

emergency center from which the Emergency

Support Team operates. Emergency Information

and Coordination Center communications link

the Senior Federal Official, FEMA Regional and

headquarters staff, and other Federal

departments and agencies at the national level

with one another.

Emergency information: material designed to

improve public knowledge or understanding of

an emergency.

Emergency instructions: information provided

to the general public during an emergency

pertaining to protective action recommendations

for actions such as evacuation and sheltering.

Emergency Operations Facility (EOF): a

facility that is the primary base of emergency

operations for the Licensee in a radiological

incident. An onsite operations facility provided

by the NRC Licensee to facilitate the

management of an overall emergency response.

Utility and state officials, and a very limited

number of Federal personnel may be

accommodated.

Emergency Operations Center (EOC): a

facility that is the primary base of emergency

operations for an offsite response organization in

a radiological emergency.

Emergency phase: see ―early phase.‖

Emergency Planning Zone (EPZ): a

geographic area surrounding a commercial

nuclear power plant for which emergency

planning is needed to ensure that prompt and

effective actions can be taken by offsite response 

organizations to protect the public health and

safety in the event of a radiological accident.

The plume pathway EPZ is approximately 10

miles in radius, while the ingestion pathway

EPZ has a radius of approximately 50 miles.

Emergency protective actions: protective

actions to isolate food to prevent its introduction

into commerce and to determine whether

condemnation or other disposition is

appropriate.

Emergency response planning area: see

―planning area.‖

Emergency Support Team (EST): the FEMA

Headquarters‘ team that carries out notification,
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-10 October 2011

activation, and coordination procedures from the

FEMA Emergency Information and

Coordination Center. The EST is responsible for

Federal agency headquarters coordination, staff

support of the FEMA Administrator, and

support of the Senior Federal Official.

Emergency worker (EW): individual who has

an essential mission to protect the health and

safety of the public who could be exposed to

ionizing radiation from the plume or from its

deposition. Some examples of emergency

workers are: radiation monitoring personnel;

traffic control personnel; fire and rescue

personnel, including ambulance crews; medical

facilities personnel; emergency operations center

personnel; personnel carrying out route alerting

procedures; and essential services or utility

personnel; and evacuation vehicle (e.g., bus,

van, etc.) drivers. Note that evacuation vehicle

drivers who will be transporting individuals or

groups out of the emergency planning zone and

who are not expected to return to the emergency

planning zone are not considered ―Emergency

Workers.‖

Essential emergency functions: these include

communications, direction and control of

operations, alert and notification of the public,

accident assessment, information for the public

and media, radiological monitoring, protective

response, and medical and public health support.

Evacuation (Citizen Evacuation): a population

protection strategy involving orderly movement

of people away from an actual or potential

hazard, and providing reception centers for those

without their own resources for temporary

relocation.

Evacuation Time Estimate (ETE): an estimate,

contained in emergency plans/procedures, of the

time that would be required to evacuate general

and persons with disabilities and 

access/functional needs within the plume

pathway emergency planning zone under

emergency conditions.

Evaluation: the process of observing exercise

performance to document strengths and

opportunities for improvement in an entity‘s

preparedness and response capability.

Evaluation is the first step in the improvement

process.

Evaluation module: the former term for a tool

used by evaluators to document exercise

performance. The current terminology for this

tool is Exercise Evaluation Guide.

Evaluation team: a group of individuals trained 

to observe and record player actions. These 

individuals are familiar with the exercising 

entity‘s plans, policies, procedures, and 

agreements.

Evaluator: a qualified individual who observes, 

measures, and assesses performance, captures 

issues, and analyzes exercise results. Evaluators 

assess and document players‘ performance 

against established emergency plans/procedures 

and Demonstration Criteria. Evaluators note the 

actions/decisions of players without interfering 

with exercise flow.

Exception area: an area located approximately

5 to 10 miles from a nuclear power plant and

specifically designated in an offsite response

organization‘s plans/procedures for which

FEMA has granted an exception to the

requirement for the capability to complete alert

and notification of the public within 15 minutes. 

Most exception areas are recreation areas or

similar low-population within the emergency

planning zone. Offsite response organizations

must have the capability to complete alert and

notification of the public in approved exception

areas within 45 minutes.

Exclusion area: the area surrounding a nuclear

reactor in which the facility operator has the

authority to determine all activities, including

exclusion or removal of personnel and property

from the area. A specific area off-limits

(expressed in miles) from a nuclear power plant.

Exercise: see Radiological Emergency

Preparedness (REP) Exercise.

Exercise Evaluation Guides (EEGs):

documents that support the exercise evaluation

process by providing evaluators with consistent
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-11 October 2011

standards for observation, analysis, and After

Action Report/Improvement Plan development.

Each EEG is linked to a target capability and

provides standard activities, performance

measures, and tasks to be evaluated based on the

exercise objectives. Additionally, an EEG

contains a Capability Narrative section, in which

evaluators provide a general chronological

narrative of exercise events associated with the

capability; and an Evaluator Observations

section in which evaluators provide specific

strengths and areas of improvement linked to the

capability. The consistent guidelines provided in

EEGs facilitate creation of After Action

Report/Improvement Plans resulting in

actionable Improvement Plans that target

specific personnel, planning, organization,

equipment, and training needs within

capabilities.

Exercise issue: a problem in organizational

exercise performance that is linked with specific

NUREG-0654/FEMA-REP-1 Planning

Standards and applicable Evaluation Criteria.

There are two categories of exercise issues:

Deficiencies and Areas Requiring Corrective

Action.

Exercise Plan (ExPlan): general information

document that helps operations-based exercises

run smoothly. The ExPlan is published and

distributed prior to the start of exercise and

provides a synopsis of the exercise. In addition

to addressing exercise objectives and scope, the

ExPlan assigns activities and responsibilities for

successful exercise execution. It enables

participants to understand their roles and

responsibilities in exercise planning, execution,

and evaluation. The ExPlan is intended for use

by exercise players and observers—therefore, it

does not contain detailed scenario information

that may reduce the realism of the tasks to be

performed. Players and observers review all

elements of the ExPlan prior to exercise

participation.

Exercise planning team (EPT): group of 

individuals responsible for all aspects of an

exercise, including exercise planning, conduct,

and evaluation. The planning team determines

exercise capabilities, tasks, and objectives;

tailors the scenario to the entity‘s needs; and

develops documents used in exercise simulation,

control, and evaluation. The exercise planning

team is ideally comprised of representatives

from each major participating jurisdiction and

agency, but should be kept to a manageable size.

While entities may find it advantageous to

include team members with previous exercise

planning experience, membership can be

modified to fit the type or scope of an exercise.

Planning team members are ideal selections for

controller and evaluator positions during the

exercise because advanced scenario knowledge

renders them ineligible to participate as players.

An exercise planning team leader manages the

exercise planning team, which can be structured

using the principles of the Incident Command

System, with Command Staff, Planning Section,

Logistics Section, Administration/Finance

Section, and Operations Section.

Exercise Planning Team Leader: individual 

who oversees the exercise planning team;

develops the exercise project management

timeline and the exercise project management

assignment list; assigns exercise responsibilities;

provides overall guidance; and monitors the

development process.

Exercise Program Management: the functions

required for an entity to sustain a variety of

exercises targeted toward preparedness priorities

on an ongoing basis. It includes project

management, budgeting, grant management,

staff hiring, funding allocation, and expenditure

tracking. Program management functions

cyclically. First, a Multi-Year Training and

Exercise Plan is developed in consideration of

an entity‘s preparedness priorities. Next, specific

exercises are carried out according to the multiyear plan‘s timelines and milestones. Finally,

Improvement Plan corrective actions identified

through exercises are taken into account when

developing priorities for the next multi-year

plan. Responsibilities for these tasks are

complementary and require that all relevant

parties collaborate to successfully administer

exercises.

Exposure: the absorption of radiation or

ingestion of a radionuclide. The exposure at a
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-12 October 2011

given point is a measurement of radiation in

relation to its ability to produce ionization. The

unit of measurement of the exposure is the

roentgen. A measure of radiation dose received

by a person, usually broken down and used to

refer to whole-body exposure compared with

exposure to the hands only.

Exposure rate: the amount of gamma radiation

that an individual would receive in one hour as

measured in air (typically expressed in units of

microrem per hour, millirem per hour or rem per

hour).

Extent of play: the level of play vs. simulation

at an emergency response exercise. Each REP

Demonstration Criterion contains a ―default‖

extent of play that evaluators and response

organizations use to define parameters for the

expected performance under that criterion.

Extent-of-Play Agreement: a document

negotiated during the exercise planning process

that customizes the default performance

expectations found in the Assessment Area

Demonstration Criteria. The Extent-of-Play 

Agreement may include identification of the

Demonstration Criteria that will or will not be

evaluated during the exercise, entities

responsible for demonstrating specific criteria,

equipment (including vehicles to be used),

personnel to be deployed, facilities to be

activated, etc.

Extremities: the hands and forearms and, with

restrictions, the head, feet, and ankles.

(Permissible radiation exposures in these regions

are generally greater than in the whole body

because they contain less blood-forming

material and have smaller volumes for energy

absorption.)

Facility: any building, center, room(s), or

mobile unit(s) designed and equipped to support

emergency operations.

Federal or other support organizations:

Federal agencies such as FEMA, Department of

Energy, the Nuclear Regulatory Commission, or

any other governmental, quasi-governmental, or

private organizations (e.g., American Red Cross,

Civil Air Patrol, Amateur Radio Emergency

Services, and Radio Amateur Civil Emergency

Services, cooperating state compact radiological

monitoring or sampling personnel, and national

or university laboratories) that may provide

assistance in radiological emergencies.

Federal Coordinating Officer (FCO): the

Federal official appointed by the President upon

declaration of a major disaster or emergency

under Public Law 93-288 to coordinate the

overall Federal response.

Federal Emergency Management Agency

(FEMA): the agency responsible for

establishing Federal policies for and

coordinating all civil defense and civil

emergency planning, management, mitigation,

and assistance functions of executive agencies.

FEMA assists state, local, and tribal agencies in

their emergency planning. Its primary role is one

of coordinating Federal, state, local, tribal, and

volunteer response actions.

Federal Radiological Emergency Response

Plan (FRERP): a former plan for coordinating

Federal response to any type of peacetime

radiological emergency requiring significant

Federal response. Issued in 1996 (61 FR 20944),

it superseded the Interagency Radiological

Assistance Plan and the Federal Radiological

Monitoring and Assessment Plan. The FRERP

has been superseded by the National Response

Framework.

Federal Radiological Monitoring and

Assessment Center (FRMAC): a center usually

located at an airport near the scene of a

radiological emergency from with the

Department of Energy Offsite Technical

Director conducts the National Response

Framework response. This center need not be

located near the onsite or Federal-state

operations centers as long as its operations can

be coordinated with them.

Federal Radiological Monitoring and

Assessment Plan (FRMAP): a former plan to

provide coordinated radiological monitoring and

assessment assistance to the offsite response

organizations in response to radiological
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-13 October 2011

emergencies. The FRMAP was superseded in

1996 by the Federal Radiological Emergency

Response Plan. The Federal Radiological

Emergency Response Plan has been superseded

by the National Response Framework.

Federal Radiological Preparedness

Coordinating Committee (FRPCC): the

National level coordination mechanism to

provide technical assistance to offsite response

organizations (see 44 CFR Part 35l).

Federal Response Center (FRC): the on-scene

focal point established by the Senior FEMA

Official, as required, for coordinating the

Federal response to an incident. Representatives

of other Federal, state, local, tribal, and

volunteer agencies will be located in the center.

Feed water: water supplied to the reactor

pressure vessel (in a boiling water reactor) or the

steam generator (in a pressurized water reactor)

that removes heat from the reactor fuel rods by

boiling and becoming steam. The steam

becomes the driving force for the plant turbine

generator.

Field Command Post (FCP): a center, either

mobile or fixed, set up in a location convenient

to the accident site, to facilitate emergency

response, especially, for example, accident

assessment activities such as direction of the

field monitoring teams.

Field Team Coordinator (FTC): the individual

who manages the functions of field teams and

coordinates data with the dose assessment group

located in emergency operation centers and

facilities.

Film badge: a photographic film packet to be

carried by personnel, usually in the form of a

badge, used for measuring and permanently

recording gamma ray dosage. A

thermoluminescent dosimeter is a type of film

badge.

Field Monitoring Team (FMT): includes

groups used to detect and monitor radiation in

the environment (e.g., measuring the

concentration of radiation in the air, water,

vegetation, soil, etc.).

Final Planning Conference (FPC): the final

forum for the exercise planning team to review

the process and procedures for exercise conduct,

final drafts of all exercise materials, and all

logistical requirements. During the FPC, there

are no major changes made to either the design

or the scope of the exercise, nor to any

supporting documentation. The FPC ensures all

logistical requirements have been arranged, all

outstanding issues have been identified and

resolved, and all exercise products are ready for

printing.

Fission: the splitting of an atomic nucleus into

two approximately equal parts accompanied by

the release of large amounts of energy and one

or more neutrons.

Fission gases: those fission products that exist

in the gaseous state. Primarily the noble gases

(e.g., krypton, xenon, radon).

Fixed nuclear facility (FNF): a stationary

nuclear installation that uses or produces

radioactive materials in its normal operations.

Fixed nuclear facilities include commercial

nuclear power plants and other fixed facilities.

Fixed contamination: contamination that

remains after loose contamination has been

removed by decontamination.

Fixed (reproducible) geometry: a method of

measuring levels of radioactivity in samples by

using a standard size or volume of samples held

at a fixed distance from the measuring

instrument.

Food chain: the pathway of any material

through the environment to edible plants,

animals and ultimately to humans.

Forward emergency operations center: if the

state emergency operations center is a

significant distance from the plant site, the

plans/procedures may indicate that a near-site or

forward emergency operations center will be

established at the time of an accident.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-14 October 2011

Forward Command Post (FCP): a location

near the affected area used to direct the activities

of state field personnel performing emergency

tasks in support of local government response.

This location may also be used for location for

field team coordination.

Forward Operations Post: a location in or near

the affected area used to coordinate the

monitoring and sampling activities of the

Radiological Emergency Response Teams.

Forward Staging Area (FSA): location near the

incident site for collection and preparation of

resources for deployment.

Fuel cycle: the series of steps involved in

supplying fuel for nuclear power reactors. It

includes mining, fabrication of fuel elements and

assemblies, their use in a reactor, reprocessing

spent fuel and refabrication into new fuel

elements.

Fuel element: a rod or other form into which

nuclear fuel is fabricated for use in a nuclear

reactor.

Full participation exercise: per 44 CFR

350.2(j), a joint exercise in which: (1) state, 

local, and tribal organizations, licensee

emergency personnel, and other resources are

engaged in sufficient numbers to verify the

capability to respond to the actions required by

the accident/incident scenario; (2) the integrated

capability to adequately assess and respond to an

accident at a commercial nuclear power plant is

tested; and (3) the implementation of the

observable portions of state, local, and tribal

plans/procedures is tested.

Full-Scale Exercise: an exercise that engages all 

ORO entities in real-time hands-on response 

activities including all of those specified in the 

Demonstration Criteria extent-of-play sections. 

A site‘s qualifying exercise is full-scale, as well 

as at least one exercise in every 8-year cycle.

Functional Exercise: an exercise that 

sufficiently engages organizations to test their 

abilities to respond to the scenario, but 

participation is less than full-scale. Most REP 

biennial joint exercises are functional exercises 

because they simulate some response 

capabilities or demonstrate them out of sequence 

from the scenario, and the exercise may not 

require participation of all offsite entities that 

would respond in a real radiological emergency. 

Functional Needs Support Services (FNSS): 

Services that enable children and adults to maintain 

their usual level of independence in a general 

population shelter. FNSS includes reasonable 

modifications to policies, practices, and procedures, 

durable medical equipment (DME), consumable 

medical supplies (CMS), personal assistance services 

(PAS), and other goods and services as needed. 

Children and adults requiring FNSS may have 

physical, sensory, mental health, and cognitive and/or 

intellectual disabilities affecting their ability to 

function independently without assistance. Others 

who may benefit from FNSS include women in late 

stages of pregnancy, elders, and those needing 

bariatric equipment. 

Fusion: the formation of a heavier nucleus from

two lighter ones, with the release of energy.

Gamma rays: the most penetrating of the three

types of ionizing radiation, gamma rays are

electromagnetic radiation like light, radio waves

and microwaves. Similar to X-rays, but usually

more powerful, they have no mass; they are only

energy. Gamma rays are best stopped or

shielded against by dense material such as

concrete or lead.

Geiger-Mueller (G-M) detector: a type of

radiation detector that can be used to measure

the gamma, or beta plus gamma radiation

depending on whether the detector is covered by

a beta shield.

General Emergency (GE): licensee emergency

classification level indicating that events are in

process or have occurred that involve actual or

imminent substantial core degradation or

melting, with potential for loss of containment

integrity or security events that result in an

actual loss of physical control of the facility.

Releases can reasonably be expected to exceed

Environmental Protection Agency protective
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-15 October 2011

action guide exposure levels offsite for more

than the immediate site area.

Groundshine: gamma and/or beta radiation

from radioactive material deposited on the

ground.

Half-life: the time required for the activity of a

given radioactive substance to decrease to half

of its initial value due to radioactive decay. The

half-life is a characteristic property of each

radioactive species and is independent of its

amount or condition. The effective half-life of a

given isotope on the body is the time in which

the quantity in the body will decrease to half as a

result of both radioactive decay and biological

elimination. Half-lives vary from millionths of a

second to billions of years.

Health physics: the science of recognizing,

evaluating and controlling health hazards from

ionizing radiation.

Health physics technician (HPT): an

individual trained in radiation protection.

High exposure rate: an exposure rate greater

than 2.5 milliroentgens per hour.

High levels of radiation exposure: doses of

100 rem or greater.

High-level waste: materials from nuclear

operations that are no longer useful and have

radioactivity concentrations of hundreds to

thousands of curies per gallon or cubic foot.

Homeland Security Exercise Evaluation

Program (HSEEP): a capabilities- and

performance-based exercise program that

provides standardized policy, doctrine, and

terminology for the design, development,

conduct, and evaluation of homeland security

exercises. HSEEP also provides tools and

resources to facilitate the management of selfsustaining homeland security exercise programs.

Homeland Security Presidential Directive-5

(HSPD-5): an Executive-Branch-issued policy

requiring the Department of Homeland Security

to coordinate with other Federal departments

and agencies, as well as state, local, and tribal

governments to establish the National Response

Framework and the National Incident

Management System.

Homeland Security Presidential Directive-8

(HSPD-8): an Executive-Branch-issued policy

drafted to strengthen the preparedness of the

United States to prevent and respond to

threatened or actual domestic terrorist attacks,

major disasters, and other emergencies by

requiring a national domestic all-hazards

preparedness goal; establishing mechanisms for

improved delivery of Federal preparedness

assistance to state and local governments; and

outlining actions to improve the capabilities of

Federal, state, and local entities. HSPD-8 has 

been superseded by Presidential Policy 

Directive-8 (PPD-8).

Host/support jurisdiction: a geographical area

that is at least 5 miles, and preferably 10 miles,

beyond the boundaries of the 10-mile plume

pathway emergency planning zone (i.e., 15-20

miles from the commercial nuclear power plant)

where functions such as congregate care,

radiological monitoring, decontamination, and

registration are conducted.

Host regional office: the FEMA Regional

Office that has program jurisdiction for a site

because of the location of a commercial nuclear

power plant within its regional borders.

Hostile action: as defined in Nuclear Regulatory

Commission Bulletin 2005-02, Emergency

Preparedness and Response Actions for

Security-Based Events, a hostile action is ―an act

toward a nuclear power plant or its personnel

that includes the use of violent force to destroy

equipment, take hostages, and/or intimidate the

licensee to achieve an end. This includes attack

by air, land, or water using guns, explosives,

projectiles, vehicles, or other devices used to

deliver destructive force.‖

Hot spot: region in a contaminated area in

which the level of radioactive contamination is

considerably greater than in neighboring

regions.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-16 October 2011

Hot wash: a facilitated discussion held

immediately following an exercise among

exercise players from each functional area. It is

designed to capture feedback about any issues,

concerns, or proposed improvements players

may have about the exercise. The hot wash is an

opportunity for players to voice their opinions

on the exercise and their own performance. This

facilitated meeting allows players to participate

in a self-assessment of the exercise play and

provides a general assessment of how the entity

performed in the exercise. At this time,

evaluators can also seek clarification on certain

actions and what prompted players to take them.

Evaluators take notes during the hot wash and

include these observations in their analysis. The

hot wash should last no more than 30 minutes.

Implementing procedure: instructions used by

personnel that provide a detailed description,

including checklists, of the operations that are to

be conducted by either a specific group of

individuals or a designated position.

Implementing procedures are also referred to as

standard operating guidelines.

Improvement Plan (IP): for each task, lists the

corrective actions that will be taken, the

responsible party or agency, and the expected

completion date. The IP is included at the end of

the After Action Report.

Inadequate: as used in reviews of radiological

emergency response plans/procedures,

inadequate means the plan/procedure contents

do not meet the intent of a particular NUREG0654/FEMA-REP-1 Planning Standard and/or

Evaluation Criterion.

Incident: an occurrence, natural or man-made,

that requires a response to protect life or

property. Incidents can include major disasters,

emergencies, terrorist attacks, terrorist threats,

civil unrest, wildland and urban fires, floods,

hazardous materials spills, nuclear accidents,

aircraft accidents, earthquakes, hurricanes,

tornadoes, tropical storms, tsunamis, war-related

disasters, public health and medical

emergencies, and other occurrences requiring an

emergency response.

Incident Command Post (ICP): the field

location where the primary response functions

are coordinated. The ICP may be co-located

with other incident facilities.

Incident Command System (ICS): a

standardized management tool for meeting the

demands of small or large emergency or

nonemergency situations.

Ingestion Exposure Pathway Emergency

Planning Zone (EPZ): a geographic area,

approximately 50 miles in radius surrounding a

commercial nuclear power plant, in which it has

been estimated that the health and safety of the

general public could be adversely affected

through the ingestion of water or food which has

been contaminated through exposure to radiation

primarily from the deposition of radioisotopes

after a radiological accident. The duration of

such exposures could range in length from hours

to months.

Ingestion Pathway exercise: an exercise

involving ingestion exposure pathway protective

action decision-making and implementation. A

state fully participates in the ingestion pathway

portion of exercises at least once every 8 years.

In states with more than one site, the state

rotates this participation from site to site.

Ingestion phase: see ―intermediate phase.‖

Initial Planning Conference (IPC): typically

the first step in the planning process and lays the

foundation for the exercise. Its purpose is to

gather input from the exercise planning team on

the scope; design requirements and conditions

(such as assumptions and artificialities);

objectives; level of participation; and scenario

variables (e.g., location, threat/hazard selection),

and Master Scenario Events List. During the

IPC, the exercise planning team decides on

exercise location, schedule, duration, and other

details required to develop exercise

documentation. Planning team members are

assigned responsibility for the tasks outlined in

the conference.

Injects: events, typically planned through

entries on the Master Scenario Events List, that
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-17 October 2011

controllers must simulate, including directives,

instructions, and decisions. Exercise controllers

provide injects to exercise players to drive

exercise play towards the achievement of

objectives. Injects can be written, oral, televised,

and/or transmitted via any means (e.g., fax,

phone, e-mail, voice, radio, or sign). See also

contextual injects and contingency injects.

Institutionalized individuals: individuals who

reside in institutions, such as nursing homes or

correctional facilities, who may need to depend

on others for assistance with protective actions.

Institutionalized individuals may or may not

have disabilities and access/functional needs.

Interagency Radiological Assessment Plan

(IRAP): former Federal response plan published

in 1965, revised in 1975. Superseded by the

Federal Radiological Monitoring Assistance

Plan, Federal Radiological Emergency Response

Plan, and the National Response Framework.

Intermediate phase: the period beginning after

the utility has verified that the release has been

terminated. Reliable environmental

measurements are available for use as a basis for

decisions on additional protective actions. It

extends until these additional protective actions

are terminated. This phase may overlap the late

phase and may last from weeks to many months.

The intermediate phase encompasses REP postplume activities associated with both ingestion

and relocation.

Internal radiation: the nuclear radiation

resulting from radioactive substances in the

body. Some examples are iodine-131 found in

the thyroid gland, and strontium-90 and

plutonium-239 found in bone.

Iodine (I): an element of the periodic table.

Only one stable isotope exists, the rest are

radioactive and artificially created. The most

common, iodine-131 and iodine-125, are used

for medical treatment of the thyroid gland and in

research.

Ion: an atom or molecule with a negative or

positive electrical charge.

Ionization: the process of adding or removing

electrons from atoms or molecules, thereby

creating ions. High temperatures, electrical

discharges or nuclear radiation can cause

ionization.

Ionizing radiation: any radiation that displaces

electrons from atoms or molecules, thereby

producing icons. Alpha, beta and gamma

radiation are examples. Ionizing radiation may

damage skin and tissue.

Irradiation: exposure to radiation.

Isotope: nuclides having the same number of

protons in their nuclei and the same atomic

number, but differing in the number of neutrons

and atomic mass number. Some isotopes of a

particular element may be radioactive while the

others are not.

Joint Information Center (JIC): a central point

of contact for all news media at the scene of the

incident. News media representatives are kept

informed of activities and events via public

information officials from all participating

Federal, state, and local agencies, which, ideally,

are collocated at the JIC.

Joint Information System (JIS): a structure

that integrates incident information and public

affairs into a cohesive organization designed to

provide consistent, coordinated, accurate,

accessible, timely, and complete information

during a crisis or incident operations. The

mission of the joint information system is to

provide a structure and system for developing

and delivering coordinated interagency

messages; developing, recommending, and

executing public information plans/procedures

and strategies on behalf of the Incident

Commander; advising the incident command

concerning public affairs issues that could affect

a response effort; and controlling rumors and

inaccurate information that could undermine

public confidence in the emergency response

effort.

Just-in-time training: instructions provided to

personnel immediately prior to performing the

assigned task or function.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-18 October 2011

Key staff: those emergency personnel, sufficient

in numbers and functions, necessary to carry out

emergency operations as set forth in the

plans/procedures.

KI (potassium iodide): see potassium iodide.

Late phase: the period beginning when recovery

action designed to reduce radiation levels in the

environment to acceptable levels for unrestricted

use are commenced, and ending when all

recovery actions have been completed. This

period may extend from months to years. REP

post-plume activities associated with return and

recovery occur during the late phase.

Lead Agency Official (LAO): the designated

official on scene from each participating Federal

agency authorized to direct that agency‘s

response.

Lessons Learned: knowledge and experience

(both positive and negative) derived from

observations and historical study of actual

operations, training, and exercises. Exercise

After Action Report/Improvement Plans identify

lessons learned and highlight best practices, and

should be submitted to FEMA for inclusion in

the lessons learned /best practices website,

www.llis.gov, which serves as a national

network for generating, validating, and

disseminating lessons learned and best practices.

Letter of Agreement (LOA): a document

executed between two or more parties outlining

specific agreements relating to the

accomplishment of an action. REP letters of

agreement may cover personnel, equipment, or

other types of emergency support, and may take

the form of letters, contracts, purchase orders, or

other procurement mechanisms.

Licensed material: source material, special

nuclear material, or by-product material

received, possessed, used, or transferred under a

general or special license issued by the NRC or a

state.

Licensee: the utility or organization that has

applied for or has received from the Nuclear

Regulatory Commission (1) a license to

construct or operate a commercial nuclear power

plant, (2) a possession-only license for a

commercial nuclear power plant, with the

exception of licensees that have received an

NRC-approved exemption to 10 CFR § 50.54(q)

requirements, (3) an early site permit for a

commercial nuclear power plant, (4) a combined

construction permit and operating license for a

commercial nuclear power plant, or (5) any

other NRC license that is now or may become

subject to requirements for offsite radiological

emergency planning and preparedness activities.

Limited response: response to a request for

radiological assistance that involves limited

Department of Energy or other agency resources

and does not require the formal field

management structure.

Local government: the government of a town,

city, county, or region at a local level by locally

elected politicians.

Logistics Section: as applied to an exercise

planning team organized according to Incident

Command System principles, the team members

providing the supplies, materials, facilities, and

services that enable the exercise to function

smoothly without outside interference or

disruption. This group consists of two

subsections: service and support. The service

section provides transportation, barricading,

signage, food and drinks, real-life medical

capability, and exercise-site perimeter security.

The support section provides communications,

purchasing, general supplies, very important

personnel (VIP)/observer processing, and

recruitment/management of actors.

Low-level waste: wastes containing types and

concentrations of radioactivity that require little

or no shielding against personnel exposure.

Master Scenario Events List (MSEL): a

chronological timeline of expected actions and

scripted events that controllers inject into

exercise play to generate or prompt player

activity. It ensures necessary events happen so

that all objectives are met. Larger, more

complex exercises may also employ a
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-19 October 2011

Procedural Flow, which differs from the MSEL

in that it only contains expected player actions

or events. The MSEL links simulation to action,

enhances exercise experience for players, and

reflects an incident or activity meant to prompt

players to action. Each MSEL record contains a

designated scenario time; an event synopsis; the

name of the controller responsible for delivering

the inject; and, if applicable, special delivery

instructions, the task and objective to be

demonstrated, the expected action, the intended

player, and a note-taking section.

Maximally exposed individual: a hypothetical

individual who receives the greatest possible

projected dose in the area of highest radiation

levels over a specified period of time.

May: The term may denotes an option, neither

requirement nor recommendation. See also shall

and should.

Measuring: refers to counting to detect

radiation levels or determining other parameters,

such as the energy of radiation or physical

characteristics of samples, such as the volume of

an air sample.

Media center: a facility staffed by public

information officers from multiple emergency

response organizations for the purpose of

providing a single designated point of contact

with the news media and to facilitate exchange

and coordination of information among public

information officers from different

organizations. This type of facility is also

referred to as a Public Information Center, a

Joint Information Center, a Public Affairs

Center, or an Emergency News Center.

Medical Services Hospital: designated

hospitals with staff trained and capable of

treating members of the general public who may

be injured and/or considered to have substantial

radiation related injuries, or who may have been

exposed to and contaminated by radioactive

materials.

Medical Services Drill: a drill in which offsite

response organizations demonstrate the ability of

the transportation services and medical facilities

to handle a contaminated individual without

spreading contamination.

Met: the status of a REP exercise Demonstration

Criterion indicating that the participating offsite

response organization performed all activities

for the criterion to the level required in the

Extent-of-Play Agreement, with no Deficiencies

or Areas Requiring Corrective Action assessed

in the current exercise for that criterion and no

unresolved prior Areas Requiring Corrective

Action.

Meteorological Unified Dose Assessment

Center (MUDAC): an area within or near the

facility which houses the personnel responsible

for the coordination of radiological monitoring

teams, collection of radiological monitoring

data, calculation of dose projections and the

recommendation of protective actions for the

emergency planning zones.

micro: A prefix that divides a basic unit by one

million. It is represented by the Greek letter

―mu‖ (―μ‖). Example: 1 micrometer = 1 μm =

1/1,000,000 meters (1x10-3 m).

microcurie (μCi): a one-millionth part of a

curie (see curie).

Mid-term Planning Conference (MPC): an

operations-based exercise planning conference

used to discuss exercise organization and

staffing concepts; scenario and timeline

development; and scheduling, logistics, and

administrative requirements. It is also a session

to review draft documentation (e.g., scenario,

Exercise Plan, Controller/Evaluator Handbook,

Master Scenario Events List).

Milestone: a date at which FEMA recommends

that a specified task in the planning,

development, conduct, and documentation of

exercises be completed. Milestones are

measured by the number of calendar days before

or after the date of a REP exercise. Some

milestones are dictated by regulations.

milli: A prefix that divides a basic unit by one

thousand. It is represented by the Greek letter
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-20 October 2011

―m.‖ Example: 1 millimeter = 1 mm = 1/1,000

meters (10-3 m).

millicurie (mCi): a one-thousandth part of a

curie (see curie).

millirem (mrem): a one-thousandth part of a

rem (see rem).

milliroentgen (mR): a one-thousandth part of a

roentgen (see roentgen).

mrem/yr: amount of radiation received in l year

(see rem).

Mobility impaired: those without

transportation, including those without their own

cars, those who are unable to drive and those

who need assistance, any of whom will need

transportation assistance to evacuate.

Mobilized organization: an organization that

has completed the activation process and is able

to carry out the essential emergency functions,

as required by scenario events and as set forth in

emergency response plans/procedures.

Monitoring: the act of detecting the presence of

radiation and the measurement of radiation

levels, usually with a portable survey

instrument.

Monitoring and decontamination facility: a

temporary facility established outside the plume

emergency planning zone for the purpose of

monitoring and decontaminating emergency

workers and their vehicles and equipment used

in the plume and/or areas contaminated by the

plume.

Multi-Year Training and Exercise Plan: the

foundational document guiding a successful

exercise program. The multi-year plan provides

a mechanism for long-term coordination of

training and exercise activities toward an

entity‘s preparedness goals. This plan describes

the program‘s training and exercise priorities

and associated capabilities, and aids in

employing the building-block approach for

training and exercise activities. Within the

Multi-Year Training and Exercise Plan, the

multi-year schedule graphically illustrates

training and exercise activities that support the

identified priorities. The schedule is color-coded

by priority and presents a multi-year outlook for

task and priority achievement. As training and

exercises are completed, the document can be

annually updated, modified, and revised to

reflect changes to the priorities and new

capabilities that need to be assessed. The Multiyear Training and Exercise Plan and schedule

are produced through the work completed at the

Training and Exercise Planning Workshop. The

Training and Exercise Planning Workshop

focuses on discussion of capabilities-based

planning, overview of the National Priorities,

review of the entity‘s priorities, and analysis of

previous training and exercises. After this

information is synthesized, participants develop

the plan and schedule for their entity.

nano: a prefix that divides a basic unit by one

billion (109). It is represented by the Greek letter

―n.‖ Example: 1 nanocurie = 1 nCi =

1/1,000,000,000 Ci (1x10-9 Ci)

nanocurie (nCi): one-billionth part of a curie

(see curie).

Narrative: a body of text, prepared by the

exercise evaluator, to describe an organization‘s

performance under the Demonstration Criterion

and document in narrative form the events that

transpired during the exercise. The narrative also

identifies and describes pertinent exercise issues

(Deficiencies, Areas Requiring Corrective

Action, or Plan Issues), and recommends

appropriate corrective actions for each issue

identified by the evaluator.

National Atmospheric Release Advisory

Center (NARAC): a Department of Energy

asset capable of providing a computer-generated

model of the most probable path of the

radioactive contamination released at a

radiological accident site.

National Exercise Schedule (NEXS): a

compilation of all national-level, Federal, state,

and local exercises. The National Exercise 

Schedule provides basic information on each

planned exercise including the exercise name,
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-21 October 2011

location, date, major participants, and points of

contact. It also serves as a management tool and

reference document for exercise planning and

enables exercise visibility to planners and

leadership.

National Incident Management System

(NIMS): a set of principles that provides a

systematic, proactive approach to guide

departments and agencies at all levels of

government, nongovernmental organizations,

and the private sector to work seamlessly to

prevent, protect against, respond to, recover

from, and mitigate the effects of incidents,

regardless of cause, size, location, or

complexity, in order to reduce the loss of life

and property and harm to the environment.

Neutron: an uncharged particle found in the

nucleus of every atom heavier than hydrogen.

Neutrons sustain the fission chain reaction in a

reactor.

Noble gases: the chemically inert radioactive

gases that are released during an accident at a

nuclear power plant.

Non-participating organizations: offsite

response organizations that are not participating

in emergency planning and preparedness for

incidents at a commercial nuclear power plant.

Not Demonstrated: term applied to the status of

a REP exercise Demonstration Criterion

indicating that, for a justifiable reason, the

jurisdiction or functional entity did not perform

activities under the Demonstration Criterion as

specified in the Extent-of-Play Agreement or at

the frequency required in the FEMA REP

Program Manual. In general, an organization

may justify not demonstrating a criterion

because of (1) the offsite response

organization‘s response to a real-life emergency

during the time that the exercise was being

conducted or (2) extenuating circumstances,

such as a fire, flood, or other emergency, at the

facility that was to be demonstrated.

Notification and mobilization of personnel:

the transmission of messages to emergency

personnel informing them of an incident and

directing them to report for emergency duty at

their assigned duty stations.

Notification of Unusual Event (NOUE):

licensee emergency classification level

indicating that unusual events are in process or

have occurred that indicate a potential

degradation in the level of plant safety or

indicate a security threat to facility protection.

No releases of radioactive material requiring

offsite response or monitoring are expected,

unless further degradation of safety systems

occurs.

Notifying the public: distributing an

instructional message, either through the

Emergency Alert System or some other system.

Nuclear Weapon Accident Response

Procedures (NARP) Manual: Department of

Defense and Defense Nuclear Agency Manual.

Nuclear radiation: the particulate and

electromagnetic radiation emitted from atomic

nuclei in various nuclear processes. The

important types of nuclear radiation (from the

weapons standpoint) are alpha and beta particles,

gamma rays and neutrons. All nuclear radiations

are ionizing radiations, but the reverse is not

true.

Nucleus: the dense, central, positively charged

core of an atom. All nuclei contain protons and

neutrons except the nucleus of hydrogen, which

has a single proton.

Nuclide: a general term referring to all known

isotopes, both stable (279) and unstable (about

5,000), of the chemical elements.

Objective: formerly, one of the 33 areas of ORO

capability defined in FEMA-REP-14 and

FEMA-REP-15 that are evaluated during a REP

exercise. Objectives have been replaced by the

Assessment Areas and associated Sub-elements

and Demonstration Criteria.

Observer: observers do not directly participate

in the exercise; rather, they observe selected

segments of the exercise as it unfolds, while

remaining separated from player activities.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-22 October 2011

Observers view the exercise from a designated

observation area and are asked to remain within

the observation area during the exercise. A

dedicated group of exercise controllers should

be assigned to manage these groups.

Offsite: beyond the boundaries of the ownercontrolled area around a commercial nuclear

power plant.

Offsite Response Organization (ORO): any

state, local, and tribal government; supporting

private industry and voluntary organizations;

and Licensee offsite response organizations (that

are formed when state, local, and tribal

governments fail to participate in the REP

Program) that are responsible for carrying out

emergency functions during a radiological

emergency.

On-scene: the area surrounding a site that is, or

potentially could be, impacted by an incident.

This area includes both onsite and offsite areas.

Onsite: beyond the boundaries of the ownercontrolled area around a commercial nuclear

power plant.

Onsite personnel: Licensee or contract

personnel working at commercial nuclear power

plants.

Operational: status of a facility (e.g.,

emergency operations center, emergency

operations facility, media center, assistance

center, emergency worker center, laboratory,

etc.) when all key decision makers, as identified

in plans/procedures, are at their duty stations and

capable of performing all emergency functions

assigned to that facility.

Operationally mobilized organization: an

organization that has completed the activation

process required by events and their emergency

response plans/procedures. Operational

mobilization is achieved when all key personnel

are at their duty stations.

Operations Section: as applied to an exercise

planning team organized according to Incident

Command System principles, the team members

providing most of the technical or functional

expertise for the participating entities. This

group develops scenarios, selects evaluation

tools, and has personnel with the expertise

necessary to serve as evaluators.

Out of sequence demonstration: demonstration

of criteria not conducted in conjunction with the

scenario timeline. For the purposes of

demonstrating required criteria, activities

conducted during the exercise week may be

considered in-sequence as negotiated as part of

the Extent-of-Play Agreement.

Partial Participation Exercise: as set forth in

44 CFR 350.2(k), the engagement of state, local, 

and tribal personnel in an exercise sufficient to

adequately test direction and control functions

for protective action decision-making related to

the emergency action levels and communication

capabilities among affected offsite response

organizations and the licensee.

Participants: players, controllers, evaluators,

and staff involved in conducting an exercise.

Particulate radiation: radiation in the form of

particles (e.g., neutrons, electrons, alpha and

beta particles) as opposed to electromagnetic

radiation.

Persons with disabilities and access/functional 

needs: individual(s) within a community that 

may have additional needs before, during, and 

after an incident in one or more of the following 

functional areas: maintaining independence, 

communication, transportation, supervision, and 

medical care. Individual(s) in need of additional 

response assistance may include those who have 

disabilities (sensory, motor skills, 

mental/emotional); who live in institutionalized 

settings; who are elderly; who are children; who 

are from diverse cultures; who have limited or 

no English-speaking proficiency; or who are 

transportation-disadvantaged.

pico: a prefix that divides a basic unit by one

trillion (10-12). It is represented by the letter ―p.‖

For example, 1 picocurie = 1 pCi =

1/1,000,000,000,000 Ci (1x10-12 Ci).
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-23 October 2011

picocurie (pCi): one-trillionth part of a curie

(see curie).

Plan Issue: an identified inadequacy in the

organization‘s emergency plan/procedures,

rather than in the organization‘s performance.

Plan Issues are required to be corrected through

the revision of the appropriate plans/procedures

during the next annual plan review and update,

submitted for FEMA review, and reported in the

state‘s Annual Letter of Certification.

Planning Area: a pre-designated geographic

subdivision of the plume exposure pathway

EPZ. In some plans/procedures, it may be

referred to as an Emergency Response Planning

Area or an equivalent term.

Planning Conferences: the exercise planning

team holds planning conferences as forums to

design and develop exercises. The scope, type,

and complexity of an exercise determine the

number of conferences necessary to successfully

conduct an exercise. These milestones of the

exercise planning process are typically

comprised of the Initial Planning Conference,

the Midterm Planning Conference, and the Final

Planning Conference.

Planning Section: as applied to an exercise

planning team organized according to Incident

Command System principles, the team members

responsible for compiling and developing all

exercise documentation. To accomplish this

effectively, the Planning Section also collects

and reviews policies, plans, and procedures that

will be validated during the exercise. During the

exercise, the Planning Section may be

responsible for developing simulated actions by

agencies not participating in the exercise and

setting up a Simulation Cell for exercises that

necessitate one (such as Functional Exercises).

Plans/Procedures: an organization‘s

documented concept of operations and

implementing procedures for managing its

internal response to emergencies and

coordinating its external response with other

organizations. The term plans/procedures as

used in this manual includes radiological

emergency preparedness/response plans,

associated implementing procedures such as

Standard Operating Guides, and other

supporting and referenced materials, all of which

are subject to review. The generic term

plans/procedures is used specifically for

flexibility. Procedures may be either

incorporated in the main plans or into separate

procedural documents at the discretion of the

offsite response organization.

Player: players have an active role in

preventing, responding to, or recovering from

the risks and hazards presented in the exercise

scenario, by either discussing (in a discussionbased exercise) or performing (in an operationsbased exercise) their regular roles and

responsibilities. Players initiate actions that will

respond to and/or mitigate the simulated

emergency.

Plume: generally a gaseous atmospheric release

from a nuclear power plant, in an accident or

emergency, which may contain radioactive

noble gases and volatile solids. While

emergency plans/procedures must recognize the

very low probability that particulates could be

released in a serious accident, primary emphasis

is given to the development of protective actions

against the release of noble gases and volatiles

such as radioiodines. This cloud is not visible to

the eye, but can be measured, or ―seen‖ with

radiation measurement equipment.

Plume phase: see ―early phase.‖

Plume dose projections: estimates of dosage to

the public from exposure to the plume, over a

period of time, in the absence of any protective

actions.

Plume Exposure Pathway: (1) For planning

purposes, the area within approximately a 10-

mile radius of a commercial nuclear power plant

site. (2) A term describing the means by which

whole body radiation exposures occur as a result

of immersion in a plume release. The area in

which plume exposures are likely is described in

NUREG-0396 as an area extending out

approximately 10 miles from the reactor site and

forming roughly a ―keyhole‖ shape, with the

keyhole oriented downwind. In the plume
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-24 October 2011

emergency planning zone, actions may be

required to protect the public from the effects of

whole-body external exposure to gamma

radiation from the plume and from deposited

materials and inhalation exposure from the

passing radioactive plume‘s released materials.

The duration of exposure in this mode could

range from hours to days in the case of

particulate deposition.

Plume Exposure Pathway Emergency

Planning Zone: a geographic area

approximately 10 miles in radius surrounding a

commercial nuclear power plant within which

the health and safety of the general public could

be adversely affected by direct whole body

external exposure to gamma radiation from

deposited materials as well as inhalation

exposure from the passing radioactive plume

during a radiological accident. The duration of

such exposures could range in length from hours

to days.

Plutonium (Pu): an element of the periodic

table that is an artificially-produced fissile

material. The Pu-239 isotope is used primarily in

nuclear weapons.

Population dose projection: projection made

by a Federal agency under the Federal 

Radiological Monitoring and Assistance Plan

pertaining to the levels of radiation to which the

population within the emergency planning zone

will be exposed.

Portal monitor: a radiation monitor consisting

of several radiation detectors arranged in a fixed

position within a frame that forms a passageway

for individuals being monitored.

Post-emergency phase: the Environmental

Protection Agency term for the period beginning

after the utility determines that the release has

terminated, and the responsible offsite response

organization determines that public safety is

ensured by appropriate protective actions in

accordance with applicable protective action

guides and that valuable property has been

protected. See also ―post-plume phase.‖

Post-plume phase: includes REP activities

(ingestion, relocation, reentry, and return) that

occur after a release has been terminated. These

activities can be demonstrated in an exercise

with the plume phase or separately.

Potassium-40 (K-40): a naturally occurring

radioactive isotope of potassium, which is an

element of the periodic table. It is a beta and

gamma emitter and has an exceedingly long

half-life. The average person receives about 20

millirems a year from the K-40 in his/her body.

Potassium iodide (KI): a prophylactic

compound commonly referred to as a

radioprotective drug containing a stable (i.e.,

non-radioactive) form of iodide that can be used

effectively to block the uptake of radioactive

iodine by the thyroid gland in a human being.

Potential dose: the radiation dose that could

result from a particular set of plant conditions,

not based on estimated or measured releases or

environmental levels.

Precautionary protective actions: any

preventive or emergency protective actions

implemented without the verification of

radionuclide measurements by field monitoring

or laboratory analysis.

Pre-operational exercise: an exercise

conducted prior to the issuance of a full-power

license of a commercial nuclear power plant by

the Nuclear Regulatory Commission.

Presidential Policy Directive-8 (PPD-8): On 

March 30, 2011, PPD-8 on National 

Preparedness was signed. This directive replaces 

Homeland Security Presidential Directive 

(HSPD)-8 (National Preparedness), issued 

December 17, 2003, and HSPD-8 Annex I 

(National Planning), issued December 4, 2007, 

which are hereby rescinded, except for 

paragraph 44 of HSPD-8 Annex I. Individual 

plans developed under HSPD-8 and Annex I 

remain in effect until rescinded or otherwise 

replaced.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-25 October 2011

Pressure vessel: a strong-walled container

housing the core of most types of power

reactors.

Pressurized water reactor (PWR): a power

reactor in which heat is transferred from the core

to the heat exchanger by water kept under high

pressure. The primary system is pressurized to

allow the water to reach high temperatures

without boiling. Steam is generated in a

secondary circuit.

Preventive protective actions: protective

actions to prevent or reduce contamination of

milk, food, and drinking water such as covering

water sources and providing dairy cows with

stored feed. Preventive protective actions also

include washing, brushing, scrubbing, or peeling

fruits and vegetables to remove surface

contamination.

Primary coolant: water used to cool and carry

heat away from the core of a pressurized water

reactor. Heat is transferred from the primary

coolant to a secondary loop using a heat

exchanger, producing steam to drive the turbine.

Principal Federal Official (PFO): pursuant to

the Homeland Security Act of 2002 and HSPD5, the Secretary of Homeland Security is the

principal Federal official for all domestic

incidents requiring multiagency Federal

response. The Secretary may elect to designate a

single individual to serve as his or her primary

representative to ensure consistency of Federal

support as well as the overall effectiveness of

the Federal incident management. When

appointed, such an individual serves in the field

as the Principal Federal Official for the incident.

Projected dose: the estimated or calculated

amount of radiation dose to an individual from

exposure to the plume and/or deposited

materials, over a period of time, in the absence

of protective action.

Protective Action Decision (PAD): measures

taken in anticipation of, or in response to, a

release of radioactive material to the

environment. The purpose of PADs is to provide

dose savings by avoiding or minimizing the

radiation exposure received by individuals,

thereby minimizing the health risks resulting

from radiation exposure. Sheltering and

evacuation are the two PADs relied upon for

limiting the direct exposure of the general public

within the plume exposure emergency planning

zone. Preventive and emergency PADs are two

categories of PADs relied upon for limiting

exposure from contaminated food and water in

the ingestion exposure emergency planning

zone.

Protective Action Guide (PAG): projected dose

to an individual in the general population that

warrants the implementation of protective

action. The Food and Drug Administration and

Environmental Protection Agency have

recommended specific protective action guides

in terms of the level of projected dose that

warrants the implementation of evacuation and

sheltering, relocation, and limiting the use of

contaminated food, water, or animal feed.

Protective Action Recommendation (PAR):

advice to the state on emergency measures it

should consider in determining action for the

public to take to avoid or reduce their exposure

to radiation.

Protective response: implementation of a

protective action, including authority to request

Federal assistance and to initiate other protective

actions.

Proton: a positively charged atomic particle.

Protons, along with neutrons, are the prime

components of atomic nuclei. The atomic

number of an atom is equal to the number of

protons in its nucleus.

Public instruction: instructions (warning

messages) that are protective action

recommendations for the public. Instructions are

given by a public official and delivered directly

to the public via the notification system (i.e.,

Emergency Alert System radio). Message

content and timeliness are very important.

Messages are repeated by the notification system

at least every 15 minutes until updated by public

authorities. If applicable, public instructions are

coordinated with other authorities.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-26 October 2011

Public information: information delivered to

the media via press conferences, interviews,

technical briefings, printed media releases, and

telephonic distribution of printed releases.

Information needs to be current, accurate, and

timely. All printed releases are coordinated with

other authorities before distribution to the media.

Ideally, information released in news

conferences, briefings, and interviews is

coordinated before release. If pre-coordination

does not occur, then post-notification of other

authorities of critical points discussed in

interviews, conferences, etc., is necessary.

rad: radiation absorbed dose, the basic unit of

absorbed dose radiation. One rad represents the

absorption of 100 ergs of nuclear (or ionizing)

radiation per gram of the absorbing material or

tissue (see roentgen).

Radiation Safety Officer: a health physicist or

other individual experienced in radiation

protection who advises medical facility staff

regarding the hazards associated with high levels

of radiation.

Radiation sickness: the complex of symptoms

characterizing the disease known as radiation

injury, resulting from excessive exposure of the

whole body (or large part) to ionizing radiation.

Radioactivity: the spontaneous decay or

disintegration of an unstable atomic nucleus,

usually accompanied by the emission of ionizing

radiation, generally alpha or beta particles, often

accompanied by gamma rays from the nuclei of

an unstable isotope.

Radioisotope: an unstable isotope of an element

that decays or disintegrates spontaneously,

emitting radiation. Approximately 5000 natural

and artificial radioisotopes have been identified.

Radiological Assistance Program (RAP)

team: a team dispatched to the site of a

radiological incident by the Department of

energy Regional Office responding to the

incident.

Radiological emergency: a type of radiological

incident that poses an actual or potential hazard

to public health or safety or loss of property.

Radiological emergency area: an area

established either on an ad hoc basis or preidentified in a medical facility for monitoring,

decontamination, and treatment of contaminated

injured individuals, and for contamination

control.

Radiological Emergency Preparedness (REP)

Exercise: an event involving organizational

responses to a simulated commercial nuclear 

power plant incident with radiological and other

offsite consequences. The purpose of an exercise

is to test the integrated capabilities of involved

offsite response organizations to implement

emergency functions set forth in offsite response

organization radiological emergency response

plans/procedures.

Radiological Emergency Response Plan

(RERP): a detailed plan that describes and

coordinates the emergency response

organizations, responsibilities, and capabilities

of utilities, offsite response organizations, and

private organizations to ensure public health and

safety during an incident in which there is a

potential for radiological release.

Radiological Emergency Preparedness (REP)

Program: the FEMA program that administers

emergency preparedness for all commercial

nuclear sites.

Radiological Emergency Response Team

(RERT): a team located near the affected area

that coordinates all field teams and sampling

activities.

Radiological survey: the directed effort to

determine the distribution of radiological

material and dose rates in an area.

Radiology: that branch of medicine dealing with

the diagnostic and therapeutic applications of

radiant energy, including x-rays and

radioisotopes.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-27 October 2011

Radionuclide: a radioactive isotope of a

particular element.

Range of Reading Sticker: indicates the

acceptable range of readings that the meter

indicates when it is response checked using a

standard test source. If the response check

results in readings that fall outside of the range

specified on the sticker, the instrument is

removed from service and not used for recording

activity levels.

Rapidly-escalating incident: an incident that

develops potential or actual severe core damage

within a short time. Such an incident results in

an initial declaration of or rapid escalation to a

Site Area Emergency or General Emergency.

Reasonable Assurance: a determination that 

state, local, tribal, and utility offsite plans and 

preparedness are adequate to protect public 

health and safety in the emergency planning 

areas of commercial nuclear power plants.

Reasonable time: (usage specific to backup

alert and notification of the public) the

responsible offsite response organization

personnel/representatives demonstrate

appropriate actions with a recommended goal of

45 minutes, taking into account but not limited

to the effects of weather, topography, population

density, and existing organization resources.

Reception center (RC): see

Reception/relocation center.

Reception/relocation center (RC): a predesignated facility located outside the plume

exposure pathway emergency planning zone (at

a minimum 15 miles from the nuclear power

plant) at which the evacuated public can register;

receive radiation monitoring and

decontamination; receive assistance in

contacting others; receive directions to

congregate care centers; reunite with others; and

receive general information. It generally refers

to a facility where monitoring, decontamination,

and registration of evacuees are conducted. A

reception/relocation center is also referred to as

a registration center or public registration and

decontamination center.

Recommendation(s): as used in the Homeland

Security Exercise Evaluation Program, the

identification of areas for improvement as noted

during an exercise and listed in all After Action

Report/Improvement Plans.

Recommended: (as used in this document) a

Federally-approved approach for meeting the

intent of regulatory requirements.

Recovery: the process of reducing radiation

exposure rates and concentrations of radioactive

material in the environment to acceptable levels

for return by the general public for unconditional

occupancy or use after the emergency phase of a

radiological emergency.

Recovery plan: a plan developed by the state to

restore the affected area with Federal assistance

if needed.

Recovery worker: an individual who is

permitted to enter the restricted zone under

controlled conditions to perform work or to

retrieve valuable property.

Reentry: the provisions for the return of the

public after evacuation, when the radiation risk

has been reduced to acceptable levels.

Reentry recommendation: advice provided to

the state by the Cognizant Federal Agency in

conjunction with the Senior Federal Official and

appropriate Federal departments and agencies

concerning offsite response organization

guidance or recommendations that may be

issued to the public for returning to an area

affected by a radiological emergency.

Regional Office Support Team (ROST): a

FEMA Regional team that supports the

Emergency Response Team. The Regional 

Office Support Team facilitates deployment of

the Emergency Response Team; interfaces with

the Emergency Support Team at FEMA

Headquarters, with other regional departments

or agencies, and with state, local, or tribal

agencies and organizations during deployment;

provides regional support during deployment;
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-28 October 2011

and assists with recall of the Emergency

Response Team.

Regional Radiological Assistance Committee

(RAC): a committee of representatives from a

number of Federal agencies which have agreed

to assist the FEMA Region in providing

technical assistance to offsite response

organizations and to evaluate radiological

emergency response plans/procedures and

exercises on the basis of their special authorities,

missions, and expertise.

Regional Response Force (RRF): force

identified in the Nuclear Accident Response

Capabilities Listing (at the Joint Nuclear

Accident Coordinating Center) belonging to

Department of Defense or Department of Energy

installations, facilities, or activities within the

US and its territories. The Regional Response 

Force may be tasked with taking emergency

response actions necessary to maintain

command and control onsite pending arrival of

the Service or Agency Response Force.

Functions with which the Regional Response 

Force may be tasked, within its capabilities, are:

(1) rescue operations; (2) accident site security;

(3) firefighting; (4) initial weapon emergency

safing; (5) radiation monitoring; (6) establishing

command, control and communications; and (7)

public affairs activities.

Release: escape of radioactive materials into the

environment.

Relocation: the removal or continued exclusion

of people (households) from contaminated areas

to avoid chronic radiation exposure.

Relocation center (RC): see

Reception/relocation center.

rem: The unit of dose of any ionizing radiation

that produces the same biological effect as a unit

of absorbed dose of ordinary x-rays. A unit of

dose for measuring the amount of ionizing

radiation energy absorbed in biological tissue.

Remedial exercise: an exercise that tests

deficiencies of a previous joint exercise that are

considered significant enough to potentially

impact the public health and safety. A remedial

exercise is conducted within 120 days after the

biennial REP exercise for the purpose of

demonstrating remedial actions to correct one or

more deficiencies.

REP Branch Chief: FEMA Headquarters

individual responsible for implementation of the

national Radiological Emergency Preparedness

Program.

Residual contamination: contamination that

remains after steps have been taken to remove it.

These steps may consist of nothing more than

allowing the contamination to decay naturally.

Responsible offsite response organization

(responsible ORO): an organization designated

in emergency response plans/procedures as that

organization responsible for a specific

emergency function.

Responsible school official: the school official

participating in an exercise or drill, who is

responsible for implementing school emergency

procedures according to the plan.

Restricted zone: an area of controlled access

from which the population has been evacuated,

relocated or sheltered-in-place.

Return: reoccupation of areas cleared for

unrestricted residence/use by previously

evacuated or relocated populations.

roentgen (r): a unit of exposure of gamma (or

X-ray) radiation in field dosimetry. One

roentgen is essentially equal to one rad (see

―rad‖). A unit for measuring the amount of

radiation energy imparted to a volume of air.

The roentgen can be used only to measure Xrays or gamma rays.

roentgen equivalent man/mammal (rem): one

rem is the quantity of ionizing radiation of any

type which, when absorbed by man or other

mammals, produces a physiological effect

equivalent to that produced by the absorption of

1 roentgen of X-ray or gamma radiation.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-29 October 2011

Rumors: information circulated by individuals

and organizations during an emergency that may

or may not be true. (Usually, rumors originate

and are spread on an ad hoc, not official basis.)

Sampling: collecting specimens of materials

(e.g., particles or radioiodine in the air, animal

feed, vegetation, water, soil, or milk) at field

locations.

Scenarios: time-based simulations of emergency

incidents postulated to allow the demonstration

of response capabilities.

Schools: in the context of the REP Program, the

term ―schools‖ refers to public and private

schools, and licensed or government supported

pre-schools and daycare centers. 

Scram (Safety Control Rod Axe Man): the

sudden shutdown of a nuclear reactor, usually by

rapid insertion of the control rods. Emergencies

or deviations from normal reactor operation

cause the reactor to automatically scram.

Senior FEMA Official (SFO): official

appointed by the director of FEMA, or his

representative, to direct the FEMA response at

the scene of a radiological emergency.

Service animal: dogs that are individually 

trained to do work or perform tasks for people 

with disabilities. Examples of such work or tasks 

include guiding people who are blind, alerting 

people who are deaf, pulling a wheelchair, 

alerting and protecting a person who is having a 

seizure, reminding a person with mental illness 

to take prescribed medications, calming a person 

with Post Traumatic Stress Disorder (PTSD) 

during an anxiety attack, or performing other 

duties. Service animals are working animals, not 

pets. The work or task a dog has been trained to 

provide must be directly related to the person‘s 

disability. Dogs whose sole function is to 

provide comfort or emotional support do not 

qualify as service animals under the ADA.105

 

105 Department of Justice, Americans with Disabilities Act (ADA), 

42 USC 1201 et seq., implementing regulations at

28 CFR § 36.104.

Shall: language in the REP Program Manual

quoted directly from regulatory material uses

both shall and should to denote requirements.

The remaining text in the REP Program Manual

uses the terms shall, must, and require to denote

mandatory items originating in regulatory

material including NUREG-0654/FEMA-REP-1

and the Code of Federal Regulations. The terms

should, suggest and recommend denote guidance

outlining a Federally-approved means of

meeting the intent of the REP regulations. If an

offsite response organization wishes to employ

an alternative approach or method for meeting

the intent of the regulations, they may do so

according to the information in Part I.D.3 of this

document. The term may denotes an option,

neither requirement nor recommendation.

Shelter-In-Place: a protective action that

includes going indoors listening to an

Emergency Alert System radio or television

station, closing all windows and doors, closing

exterior vents, and turning off heating and air

conditioning equipment using outside air.

Shield: material used to reduce or stop radiation.

Should: language in the REP Program Manual

quoted directly from regulatory material uses

both shall and should to denote requirements.

The remaining text in the REP Program Manual

uses the terms shall, must, and require to denote

mandatory items originating in regulatory

material including NUREG-0654/FEMA-REP-1

and the Code of Federal Regulations. The terms

should, suggest and recommend denote guidance

outlining a Federally-approved means of

meeting the intent of the REP regulations. If an

offsite response organization wishes to employ

an alternative approach or method for meeting

the intent of the regulations, they may do so

according to the information in Part I.D.3 of this

document. The term may denotes an option,

neither requirement nor recommendation.

Site Area Emergency (SAE): licensee

emergency classification level indicating that

events are in process or have occurred that

involve actual or likely major failures in the

plant functions needed for protecting the public

or security events that result in intentional
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-30 October 2011

damage or malicious acts; (1) toward site

personnel or equipment that could lead to the

likely failure of or; (2) prevents effective access

to equipment needed for the protection of the

public. Releases are not expected to exceed

Environmental Protection Agency protective

action guide exposure levels beyond the site

boundary.

Special facility: includes schools, licensed

daycare centers, hospitals, nursing homes,

certain types of industrial plants that may require

a lengthy shutdown period, etc., within the

plume emergency planning zone that need to be

considered separately from the general

population when planning for an incident or

accident at a nuclear power plant.

Special nuclear material: by law, includes

plutonium, uranium-233, and uranium

containing more than the natural concentration

of uranium-235.

Spent fuel: nuclear reactor fuel that has been

irradiated to the extent that it can no longer

effectively sustain a chain reaction.

Standard Operating Guideline (SOG): see

implementing procedures

State Coordinating Officer (SCO): an official

designated by the governor of an affected state

to work with the Cognizant Federal Agency

Official and Senior FEMA Official in

coordinating the response efforts of Federal,

state, local, tribal, volunteer, and private

agencies.

Strontium: a high-energy beta source that can

be used as an energy source for satellites, remote

weather stations and navigation buoys. Four

naturally stable and 12 unstable isotopes of

strontium exist. The most common unstable

isotope is strontium-90, a product of nuclear

fallout that has a half-life of 28 years.

Substantial change: a change in

plans/procedures, equipment, or facilities that

has a direct effect or impact on emergency

response operations. Examples of substantial

changes include: changing emergency planning

areas, modifying the size or configuration of an

emergency operations center, adding more

function to a center, or changing the equipment

available for use in a center.

Support jurisdiction: see host/support 

jurisdiction

Survey meter: a portable instrument used in

radiological monitoring to detect and measure

ionizing radiation.

Tabletop Exercise: a discussion-based exercise 

that may test single or multiple scenarios and 

outcomes. OROs may use tabletop exercises to

assess key elements in decision-making and 

implementation. 

Target Capabilities List (TCL): a list of

capabilities that provides guidance on the

specific capabilities that Federal, state, local, and 

tribal entities are expected to develop and

maintain to prevent, protect against, respond to,

and recover from incidents of national

significance, including terrorism or natural

disasters, in order to maintain the level of

preparedness set forth in the National

Preparedness Goal.

Thermoluminescent dosimeter (TLD): a type

of dosimetry badge used to measure an

individual‘s level of exposure to ionizing

radiation. It is characteristic of

thermoluminescent material that radiation

produces internal changes that cause the

material, when subsequently heated, to give off a

measurable amount of light directly proportional

to the radiation dose. This type of dosimeter

cannot be read directly by the wearer; it must be

read by a laboratory.

Thyroid exposure: exposure of the thyroid

gland to radiation from radioactive isotopes of

iodine that have been either inhaled or ingested.

Timeline: the tabular illustration, in an After

Action Report, of the time at which significant

events occurred at all participating offsite

response organizations in a biennial REP

exercise.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-31 October 2011

Timely (timely manner): the responsible offsite

response organization personnel/representatives

demonstrate appropriate actions with a sense of

urgency and without undue delay.

Total effective dose equivalent (TEDE): the

sum of the deep dose equivalent (for external

exposures) and for committed effective dose

equivalent (for internal exposures).

Traffic control: all activities accomplished for

the purpose of facilitating the evacuation of the

general public in vehicles along specific routes.

Training and Exercise Planning Workshop

(T&EPW): usually conducted in order to create

a Multi-Year Training and Exercise Plan. During

the workshop, participants review priority

preparedness capabilities and coordinate

exercise and training activities that can improve

those capabilities. As a result of the workshop,

the Multi-Year Training and Exercise Plan

outlines multi-year timelines and milestones for

execution of specific training and exercise

activities.

Transient persons: non-residents. Persons who

do not permanently reside in the plume exposure

pathway emergency planning zone, but may be

present during an emergency.

Transuranic elements: all elements above

uranium on the periodic table — those with an

atomic number greater than 92. All transuranics

are produced artificially and are radioactive.

Trigger/Action levels: is a designated value

whereby an individual is directed to perform a

specific action. Also, the threshold for

contamination levels that trigger the need for

decontamination established in the

plans/procedures.

Tritium: the one radioactive isotope of

hydrogen. A small percentage of natural

hydrogen is tritium, but the primary source of

tritium is nuclear reactors. It has a half-life of 12

years, but will remain in the body only a few

days if taken internally. It is not considered a

major health hazard since it is a very weak beta

emitter and not harmful unless consumed in very

large quantities.

Trusted agent/confidential representative:

individuals on the exercise planning team who

are trusted to not reveal scenario details to

players prior to exercise conduct.

Uranium: an element of the periodic table.

There are two primary isotopes: uranium-238,

which accounts for 99 percent of all uranium;

and uranium-35, the fissionable isotope that

sustains the fission reaction in a nuclear reactor.

Vapor: the gaseous form of substances that are

normally in liquid or solid form.

Whole-body exposure: an exposure of the body

to radiation, in which the entire body rather than

an isolated part is irradiated. Where a

radioisotope is uniformly distributed throughout

the body tissues, rather than being concentrated

in certain parts, the irradiation can be considered

as a whole-body exposure.

X-ray: a penetrating form of electromagnetic

radiation that is used in medical and industrial

applications.
APPENDIX B: GLOSSARY OF REP TERMS

REP Program Manual Page B-32 October 2011

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APPENDIX C: REP GUIDANCE REFERENCES

REP Program Manual Page C-1 October 2011

Appendix C: REPGUIDANCE REFERENCES

The following documents inform the REP Program. For a listing of documents that have been retired

and/or superseded by the final publication of this edition of the REP Program Manual, see Appendix D.

FEMA-REP SERIES DOCUMENTS

1. NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological 

Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Washington

D.C., November 1990.

2. NUREG-0654/FEMA-REP-1, Rev.1, Supplement 1, Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants –

Criteria for Utility Offsite Planning and Preparedness, Final Report, Washington D.C., September

1988.

3. NUREG-0654/FEMA-REP-1, Rev.1, Supplement 2, Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants –

Criteria for Emergency Planning in an Early Site Permit Application, Draft Report for Comment,

Washington D.C., Draft, April 1996.

4. NUREG-0654/FEMA-REP-1, Rev.1, Supplement 3, Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants –

Guidance for Protective Action Strategies, Washington D.C., October 2011.

5. NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological 

Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Addenda,

Washington D.C., March 2002.

6. NUREG-0654/FEMA-REP-1, Rev.1, Supplement 4, Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants –

Criteria for National Preparedness Initiative Integration, Exercise Enhancement, and Backup 

Alert and Notification Systems, October 2011.

7. FEMA-REP-2, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 1 –

Airborne Release, Washington D.C., June 1990.

8. FEMA-REP-5, Revision 2, Guidance for Developing State, Tribal, and Local Radiological 

Emergency Response Planning and Preparedness for Transportation Accidents, Washington D.C.,

November 2000.

9. FEMA-REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power 

Plants, Washington D.C., November 1985. (Pre-decisional draft) (Under revision).

10. FEMA-REP-12, Guidance on Offsite Emergency Radiation Measurement Systems, 

Phase 2 – The Milk Pathway, Washington D.C., September 1987.

11. FEMA-REP-13, Guidance on Offsite Emergency Radiation Measurement Systems, 

Phase 3 – Water and Non-Dairy Food Pathway, May 1990. (Pre-decisional draft)

12. NUREG-1442, Revision 1/FEMA-REP-17, Revision 1, The Emergency Response Resources 

Guide for Nuclear Power Plant Emergencies, July 1992.
APPENDIX C: REP GUIDANCE REFERENCES

REP Program Manual Page C-2 October 2011

13. FEMA-REP-21, Contamination Monitoring Standard for a Portal Monitor Used for Radiological 

Emergency Response, Washington D.C., March 1995.

14. FEMA-REP-22, Contamination Monitoring Guidance for Portable Instruments Used for 

Radiological Emergency Response to Nuclear Power Plant Accidents, Washington D.C., October

2002.

OTHER FEMA-REP GUIDANCE DOCUMENTS

15. FEMA GM-8, Revision 1, RAC Coordination With Utilities, October 3, 1983.

16. Federal Register Volume 58, No. 176, p. 47996, Memorandum of Understanding between Federal 

Emergency Management Agency and Nuclear Regulatory Commission, September 14, 1993.

17. FEMA‘s REP Program Guidance to State and Local Governments for Shelf-Life Extension of 

Potassium Iodide (KI), April 12, 2007

18. Federal Register, Vol. 67, No. 7, pp.1355-1357, Federal Policy on Use of Potassium Iodide (KI), 

Federal Emergency Management Agency, January 10, 2002.

19. FEMA Comprehensive Preparedness Guide (CPG) 101: Developing and Maintaining Emergency 

Operations Plans, Version 2.0, November 2010.

20. FEMA Guidance on Planning for Integration of Functional Needs Support Services in General 

Population Shelters, November 2010

21. Program Manual: Radiological Emergency Preparedness, October 2011.

NIMS/NRF GUIDANCE

22. National Incident Management System, December 2008.

23. Homeland Security Exercise Evaluation Program (HSEEP), Volumes I-III, February 2007.

24. Homeland Security Exercise Evaluation Program (HSEEP), Volume IV, March 2008.

25. National Response Framework, January 2008.

26. National Response Framework, ESF#15 – External Affairs Annex, January 2008.

27. National Response Framework, Public Affairs Support Annex, January 2008.

28. National Response Framework, Nuclear/Radiological Incident Annex, June 2008.

29. National Response Framework, Mass Evacuation Annex, June 2008.

OTHER FEDERAL AGENCY GUIDANCE

30. Respiratory Protective Devices Manual, American Industrial Hygiene Association, 1963.

31. NUREG-75/014, Reactor Safety Study: An Assessment of Accident Risks in the U.S. Commercial 

Nuclear Power Plants, WASH-1400, October 1975.

32. EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.

33. Federal Register, Volume 63, No. 156, pp.43402-43403, Accidental Radioactive Contamination of 

Human Food and Animal Feeds: Recommendations for State and Local Agencies, Food and Drug 

Administration, August 13, 1998.
APPENDIX C: REP GUIDANCE REFERENCES

REP Program Manual Page C-3 October 2011

34. Federal Register Volume 66, , No. 13, pp. 5427-5440, Consideration of Potassium Iodide in

Emergency Plans, Final Rule, Nuclear Regulatory Commission, January 19, 2001.

35. Notice from Paul Lohaus (NRC) to All Agreement and Non-agreement States' State Emergency

Response Directors dated January 26, 2001 on "Revisions to NRC Regulations on the Use of

Potassium Iodide in Emergency Response (STP-01-006)."

36. Federal Register, Volume 66, No. 238, pp.64046-64047, Guidance on Use of Potassium Iodide as 

a Thyroid Blocking Agent in Radiation Emergencies, Food and Drug Administration, December 

11, 2001.

37. Guidance for Federal Agencies and State and Local Governments: Potassium Iodide Tablets Shelf 

Life Extension, Food and Drug Administration, March 2004.
APPENDIX C: REP GUIDANCE REFERENCES

REP Program Manual Page C-4 October 2011

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APPENDIX D: HISTORICAL REP GUIDANCE REFERENCES

REP Program Manual Page D-1 October 2011

Appendix D: HISTORICAL REPGUIDANCE

REFERENCES

The following documents have been retired and/or superseded by the final publication of this edition of

the REP Program Manual.

FEMA-REP DOCUMENTS

1. FEMA-REP-6, Exercise Evaluation and Simulation Facility Evacuation Events Models: Part I –

PREDYN Users Guide, Washington D.C., April 1984.

2. FEMA-REP-7, Exercise Evaluation and Simulation Facility Evacuation Events Models: Part II –

Users Manual, Washington D.C., April 1984.

3. FEMA-REP-8, Application of the I-DYNEV System (To Compute Estimates of Evacuation Travel

Time at Nuclear Power Stations), Washington D.C., December 1984.

4. FEMA-REP-11, A Guide to Preparing Public Information Materials and Emergency Alert System

Instructions for Radiological Emergencies, Washington D.C., Draft, March 1985.

5. Revised Emergency Exercise Frequency Rule, IE Information Notice No. 85-55, July 15, 1985

6. Evacuation: An Assessment of Planning and Research, RR-9, Federal Emergency Management

Agency, November 1987.

7. Check List for Review and Evaluation of Emergency Public Information Brochures for Ingestion

Pathway Measures, Federal Emergency Management Agency, July 1990.

8. FEMA-REP-14, Radiological Emergency Preparedness Exercise Manual, Washington D.C.,

September 1991.

9. FEMA-REP-15, Radiological Emergency Preparedness Exercise Evaluation Methodology,

Washington D.C., September 1991.

10. FEMA-REP-18, Statements of Consideration for FEMA-REP-14 and FEMA-REP-15,

Washington D.C., January 1992.

11. RG REP 05, Rev. 1, REP Evacuation Time Study Review Guide (Checklist), Federal Emergency

Management Agency, April 1993.

12. Radiological Emergency Preparedness Program, Standard Exercise Report Format, FEMA,

October 1995.

13. Emergency Alert System, Civil Preparedness Guide, 1-40, Federal Emergency Management

Agency, Interim Use, June 1996.

14. Emergency Alert System: A Program Guide for State and Local Governments, CPG 1-41, Federal

Emergency Management Agency, Interim Use, June 1996.

15. Guide for All-Hazard Emergency Operations Planning, Federal Emergency Management Agency,

State and Local Guide (SLG) 101, September 1996.

16. RG REP 01, Rev. 4, REP Emergency Information Materials/Brochures Review Guide, Federal

Emergency Management Agency, January 1998.

17. RG REP 04, Rev. 6, Pre-Exercise Activities, January 1998
APPENDIX D: HISTORICAL REP GUIDANCE REFERENCES

REP Program Manual Page D-2 October 2011

18. RG REP 06, Emergency Alerting System, February 1998

19. Initiative 1.2: Reduce Frequency of Evaluation, October 1, 1999.

20. Initiative 1.3: Negotiate the Use of Out-of-Sequence Demonstrations, October 1, 1999.

21. Initiative 1.4: Give Direct Feedback, October 1, 1999.

22. Initiative 1.5: Correct Issues Immediately, October 1, 1999.

23. Initiative 1.7: New Scenario Options, October 1, 1999.

24. Policy Paper on "Evaluation of Emergency Medical Services Drills," approved by Kay Goss,

effective October 1, 1999.

25. Federal Register, Volume 66, No. 112, pp. 13142-31362, Radiological Emergency Preparedness: 

Exercise Evaluation Methodology, June 11, 2001.

26. Federal Register, Volume 66, No. 112, pp. 31362-31363, Radiological Emergency Preparedness:

Alert and Notification, June 11, 2001.

27. Federal Register, Volume 66, No. 177, pp. 47546-47548, Radiological Emergency Preparedness:

Alert and Notification, September 12, 2001.

28. Federal Register, Volume 67, No. 80, pp. 20580-20602, Radiological Emergency Preparedness:

Exercise Evaluation Methodology, April 25, 2002.

29. Initiative 1.6: Expand the use of Exercise Credit, November 30, 2002.

30. Initiative 3.0: Use State, Tribal, and Local Personnel as REP Exercise Evaluators, April 11, 2002.

31. Federal Register, Volume 68, No. 160, pp. 49783-49785, Radiological Emergency Preparedness: 

Planning and Preparing for a Fast-Breaking Event, August 19, 2003.

FEMA REP GUIDANCE MEMORANDA

32. GM PI-1, FEMA Action to Pilot Test Guidance on Public Information Materials and Provide 

Technical Assistance On Its Use, October 2, 1985.

33. GM PR-1, Policy on NUREG-0654/FEMA-REP-1 and 44 CFR Periodic Requirements, October 4,

1985

34. GM FR-1, Federal Response Center, December 3, 1985.

35. GM MS-1, Medical Services, November 13, 1986.

36. GM EV-2, Protective Actions for School Children, November 13, 1986.

37. GM AN-1, FEMA Action to Qualify Alert and Notification Systems Against NUREG-0654/FEMAREP-1 and FEMA-REP-10, Attachment 1, April 21, 1987.

38. GM EX-3, Managing Pre-Exercise Activities and Post-Exercise Meetings, February 26, 1988

39. GM IN-1, The Ingestion Exposure Pathway, February 26, 1988.

FEMA REP POLICY AND GUIDANCE CLARIFICATIONS: MEMORANDA AND LETTERS

40. Memorandum from Louis O. Giuffride to Regional Directors on October 18, 1981 on "Procedural

Policy on Radiological Emergency Preparedness."

41. Memorandum from Dave McLoughlin to Regional Directors on December 1, 1982 on "Interim

Policy Guidance on Potassium Iodide."
APPENDIX D: HISTORICAL REP GUIDANCE REFERENCES

REP Program Manual Page D-3 October 2011

42. Memorandum from Edward Jordan to Richard Krimm on May 9, 1983 on "NRC Position

concerning 15 minutes public notification capability.‖

43. Memorandum from Dave McLoughlin to Regional Directors on August 5, 1983 on "Procedural

Policy on Radiological Emergency Preparedness Plan Review, Exercise Observations and

Evaluations and Interim Findings."

44. Memorandum from Associate Director, initials DM, to the Director on March 7, 1984 on "Alpha

Radiation in Radiological Emergencies."

45. Memorandum from Joseph Mouhaun to Associate Directors of Region I and III on April 2, 1984.

Memo on "Radiation Hazards."

46. Memorandum from Robert Wilkerson to R. Dell Greer on April 30, 1985 on "State of Arkansas

Questions on Population Exposure."

47. Memorandum from Richard Krimm to Frank Finch dated May 17, 1985, on "Congregate Care

Facilities."

48. Memorandum from Robert Wilkerson to Frank Begley on July 15, 1985 on "Five-year Exercise

Requirement."

49. Letter from J.M. Keller to Steward Glass dated October 4, 1985 on "Clarification of NUREG-0654

Element J.12."

50. Memorandum from Robert Wilkerson to Richard Leonard on October 23,1985 "Guidance on Alert

and Notification of Transient Populations within the Emergency Planning Zone.‖

51. Memorandum from Richard Krimm to NTH Division Chiefs, FEMA Regional Offices dated

December 24, 1985, on "Guidance on NUREG-0654/FEMA-REP-1 Evaluation Criterion J.12."

52. Memorandum from Samuel Speck to Regional Director of Region IX dated January 28, 1986 on

"Section C of Guidance Memorandum (GM) PR-1, Policy on NUREG-0654/FEMA-REP-1

Periodic Requirements."

53. Memorandum from Robert Wilkerson to Roger Kowieski dated February 26, 1986 "State of NJ

request for Exception from the 15-minute Alerting Requirement for the Artificial Island

(Salem/Hope Creek) Generating Station."

54. Memorandum from Glenn Woodard to Richard Krimm dated March, 18, 1986 on "Clarifications

concerning 15-min Public Notification Capability."

55. Memorandum from Samuel Speck to John Coleman dated April 3, 1986 on "Radiological

Emergency Preparedness (REP) Policy Issues."

56. Memorandum from Richard Krimm to Glenn Woodard dated April 22, 1986 on "Clarification of

the 15-Minute Design Objective for Alert and Notification Systems."

57. Memorandum from Frank Begley to Richard Krimm dated August 6, 1986 on "Clarification of

NUREG-0654 Element J.12."

58. Memorandum from Richard Donovan to Robert Wilkerson dated August 19, 1986 on "Exercise

Objective  ̳Total Population Exposure‘."

59. Memorandum from Robert Wilkerson to Frank Begley dated September 12, 1986 on "Use of

Landmark Descriptions in Public Information Releases."

60. Memorandum from Richard Krimm to Edward Jordan dated December 11, 1986 on "Generic

Safety Concerns regarding Alert and Notification Systems."
APPENDIX D: HISTORICAL REP GUIDANCE REFERENCES

REP Program Manual Page D-4 October 2011

61. Memorandum from Robert Wilkerson to Frank Begley dated December 23, 1986 on "Mobilization

of Emergency Response Personnel."

62. Memorandum from Edward Jordan to Richard Krimm dated February 3, 1987 on "Scaling of Alert

and Notification Design Objectives."

63. Memorandum from Dave McLoughlin to Robert Connor and J. D. Overstreet dated February 5,

1987 on "Off-Site Planning and Preparedness Issues for the LaCrosse Plant.‖

64. Memorandum from Richard Krimm to Regional Directors and ONTH Chiefs dated February 5,

1987 on "Annual Letter of Certification (ALC)."

65. Memorandum from Frank Begley to Dave McLoughlin dated March 3, 1987 on "Split Jurisdiction

and Emergency Planning Zones in a Radiological Emergency Preparedness Program."

66. Memorandum from Dave McLoughlin to All Regional Directors dated March 17, 1987 on "Split

Jurisdictions and Emergency Planning Zones in a Radiological Emergency Preparedness

Program.‖

67. Memorandum from Dave McLoughlin to Jerome Overstreet dated September 8, 1987 on

"Comprehensive Cooperative Agreement (CCA) Funding for maintenance and calibration of

Radiological Instruments for Peacetime Purposes and Compliance REP Periodic Requirements.‖

68. Memorandum from Richard Krimm to Frank Begley dated September 23, 1987 on "Alternate

Emergency Operations Center (EOC)."

69. Memorandum from Julius Becton Jr. to Regional Directors dated November 4, 1987 on "Policy on

Interim and 350 Findings and Determinations.‖

70. Memorandum from J.D. Overstreet to Julius Becton dated November 20, 1987 on "Radiological

Emergency Preparedness Policy on Interim Findings.‖

71. Memorandum from Richard Krimm to Frank Begley dated December 9, 1987, on "Quad Cities

Emergency Planning Zone (EPZ) Boundary Determination (split jurisdiction)."

72. Memorandum from Julius Beckton Jr. to Regional Directors dated December 31, 1987 on "Policy

on Interim and 350 Findings and Determinations.‖

73. Memorandum from Richard Krimm to Frank Begley dated January 5, 1988, on "Radiological

Monitoring."

74. Memorandum from Richard Krimm to NTH Division Chiefs dated February 9, 1988, on

"Clarification of Selected Provisions of Guidance Memorandum (GM) MS-1, Medical Services."

75. Memorandum from Frank Begley to Richard Krimm on February 16, 1988 on" Evacuation

Monitoring -Time established for Personnel monitoring.‖

76. Memorandum from Frank Begley to Richard Krimm on February 19, 1988 on "Request for Policy

Guidance on Peak Transient Populations.‖

77. Memorandum from Richard Krimm to Frank Begley dated February 26, 1988 on "Annual Letter

of Certification."

78. Memorandum from Richard Krimm to Frank Begley dated March 4, 1988 on "Radiological

Monitoring.‖

79. Memorandum from Grant Peterson to Regional Directors dated March 7, 1988, on "Guidelines for

Regions to Use in Implementing NUREG-0654/FEMA-REP-1, Rev. 1, Supplement 1, With

Qualifying Exercises."
APPENDIX D: HISTORICAL REP GUIDANCE REFERENCES

REP Program Manual Page D-5 October 2011

80. Memorandum from Frank Begley to Richard Krimm on March 14, 1988 on Medical Services and

RAD Monitoring Guidance.‖

81. Memorandum from Richard Krimm to Frank Begley dated March 24, 1988 on "Peak Transient

Populations.‖

82. Memorandum from Richard Donovan to Richard Krimm dated April 22, 1988 on "Review and

Evaluation of Public Information Material for the Seabrook Plan for Massachusetts Communities.‖

83. Memorandum from Frank Begley to Richard Krimm dated April 29, 1988 on "Relocation Centers

beyond 5 miles of the EPZ.‖

84. Memorandum from Richard Krimm to Wallace Weaver dated May 03, 1988 on " REP Issues from

Region V.‖

85. Memorandum from Glen Woodard to Region IV (Directors, State Emergency Management Orgs,

State Radiological Health Orgs managers, Nuclear Emergency Preparedness (Utilities) Regional

Assistance Committee) dated May 9, 1988 on ―Medical Services and Drills.‖

86. Memorandum from Richard Krimm to Richard Donavon dated May 11, 1988 on ―Review and

Evaluation of Public Information Material for the Seabrook Plan for Massachusetts Communities.‖

87. Memorandum from Glenn Woodard to Richard Krimm dated June 13, 1988 on "Guidance

Memorandum MS-1.‖

88. Memorandum from Richard Krimm to Edward Thomas dated June 20, 1988 on ―Annual Letter of

Certification‖ (includes criteria and references a checklist).

89. Memorandum from Glenn Woodard to Richard Krimm on August 9, 1988 on "FEMA Guidance

Memorandum.‖

90. Memorandum from William Fucik to Craig Wingo on August 11, 1988 on "Revised FEMA Policy

to a 2.206 Petition Concerning Receiving Schools around the Perry Nuclear Power Plant.‖

91. Letter from Leann Diehl to Vern Wingert dated September 2, 1988 on generic ingestion brochure.

92. Memorandum from Richard Krimm to Glen Woodard on September 9, 1988 on "June 13, 1988,

Memorandum on Guidance Memorandum MS-1, Medical Services.‖

93. Memorandum from Richard Krimm to Frank Begley dated September 19, 1988, on "Radiological

Monitoring."

94. Memorandum from Craig Wingo to William Fucik dated September 20, 1988 on "FEMA Policy

Concerning Receiving Schools Around the Perry Island NPS."

95. Memorandum from Richard Krimm to Frank Begley dated September 22, 1988 on "Interpretation

of 'Shall' and 'Should' as used in NUREG-0654/FEMA-REP-1 and Off-Hours Unannounced

Drills/Exercises."

96. Memorandum from Glenn Woodard to Richard Krimm on September 26, 1988 on "Krimm to

Begley Memo September 19, 1988 concerning medical services.‖

97. Memorandum from Vanessa Quinn to Woodie Curtis dated September 29, 1988 on "Alternative

Approach by State of Michigan for Dose Assessment."

98. Letter from Richard Krimm to Leann Diehl dated October 14, 1988 on ―generic ingestion

brochure.‖

99. Memorandum from Frank Begley to Richard Krimm on November 4, 1988 on "Landmark

Descriptions State of NE Cooper Deficiency.‖
APPENDIX D: HISTORICAL REP GUIDANCE REFERENCES

REP Program Manual Page D-6 October 2011

100. Memorandum from Richard Krimm to Frank Begley dated December 7, 1988, on "Landmark

Descriptions."

101. Memorandum from Grant Peterson to Victor Stello dated March 28, 1989 on ―20% rule.‖

102. Memorandum from Richard Leonard to State Directors and staff on May 8, 1989 on

"Demonstration of Objective 16, Use of KI.‖

103. Memorandum from Richard Leonard to file on June 20, 1989 on "Rationale for Iowa Temporary

Relocation Center (TRC) Spaces for the FT Calhoun Stations.‖

104. Memorandum from Richard Leonard to Rick Semm on June 27, 1989 on "Bus Drivers as

Emergency Workers.‖

105. Letter from Dennis Kwiatkowski to Ellen Gordan dated July 7, 1989 on two policy issues

106. Memorandum from Grant Peterson to Paul Giordano dated December 7, 1989, on "Guidance on

Ingestion Pathway Exercises."

107. Memorandum from Grant Peterson to Regional Directors dated December 14, 1989 on "Revisions

to Guidance Memorandum (GM) EX-1 Remedial Exercises."

108. Memorandum from Grant Peterson to Regional Directors dated January 12, 1990 on "Distribution

and Use of the Generic Ingestion Pathway Brochure, entitled  ̳Radiological Emergency

Information‘."

109. Memorandum from Richard Leonard to State Directors on March 19, 1990 on "Requirement of

landmark Descriptions in REP Plans.‖

110. Memorandum from Frank Begley to Kenneth V. Miller (Missouri Department of Health) dated

March 23, 1990 on "Exercise Demonstration of Two Radiological Monitoring Field Teams."

111. Letter from William H. Spell to Robert Morris dated April 3, 1990 on ―funding for RERO training

course.‖

112. Memorandum from Grant Peterson to Regional Directors dated July 31, 1990 on "Scenario criteria

for use in Radiological Emergency Preparedness Exercises."

113. Memorandum from Grant Peterson to Regional Directors on August 6, 1990 on Draft GM-RG-1

"Regional Implementation of FEMA's Radiological Emergency Preparedness (REP) Program.‖

114. Letter from Dennis Kwiatkowski to Diane Tefft dated October 4, 1990, on ―Response of the

Federal Emergency Management Agency (FEMA) to issues raised by the executive board of the

Conference of Radiation Control Program Directors (CRPCD) in its April 25, 1990

correspondence concerning radiological emergency preparedness.‖

115. Memorandum from Dennis Kwiatkowski to William Tidball dated November 2, 1990 on "Request

from the State of New York for Waiver of Self-Reading Dosimetry Requirements for Emergency

Workers."

116. Memorandum from Dennis Kwiatkowski to FEMA Regional Directors on November 7, 1990 on

"Response to FEMA to Issues Raised by the Conference of Radiation Control Program Directors.‖

117. Memorandum from Robert Bissell, Chief/RAC Chairman Tech Hazards Branch, to State Directors

on February 12, 1991 on "Draft GM MS-1, Medical Services

Revision 1.‖

118. Letter from Stephen Harrell to Kenneth Miller dated April 25, 1991 on "Exercise Demonstration of

Radiological Field Monitoring Teams."
APPENDIX D: HISTORICAL REP GUIDANCE REFERENCES

REP Program Manual Page D-7 October 2011

119. Memorandum from Stephen Harrell to Dennis Kwiatkowski on October 7, 1991 on "Resolution of

Open Region VII Requests for REP Guidance.‖

120. Memorandum from Dennis Kwiatkowski to Stephen Harrell dated January 16, 1992, on "Response

to Request from Region VII for Resolution of Radiological Emergency Preparedness (REP)

Program Issues."

121. Memorandum from Dennis Kwiatkowski to Walter Pierson dated March 26, 1992 on "Response to

Region III's Request for Guidance on Ingestion Pathway Exercise Demonstration."

122. Memorandum from Dennis Kwiatkowski to Walter Pierson dated Mary 15, 1992, on "Objective

13: Alert, Notification, and Emergency Information – Public Instructions."

123. Memorandum from Dennis Kwiatkowski to Robert Adamcik dated January 13, 1993, on

"Pennsylvania Emergency Management Agency Request for Clarification of FEMA-REP-14

Dosimetry Requirements Under Objective 5, Emergency Worker Exposure Control."

124. Memorandum from William Wark to Joseph Dominguez dated February 21, 1993 on "Annual

Distribution of Emergency Information to the Public."

125. Memorandum from Craig Wingo to Stephen Harrell dated March 5, 1993, on "Response to Policy

Clarification on Radiological Emergency Planning for Day Care Centers."

126. Memorandum from Joseph Moreland to Office of Natural and Technological Hazards Division

Chiefs on March 5, 1993 on "Draft GM RG-2  ̳Guidelines for Regional Implementation of the

FEMA Rule, 44 CFR Part 352‘."

127. Memorandum from Marlee Carroll to Bob Bissell, Joe Schulte, Norm Valentine, Connie

Wisniewski, Jane Young, and Mindy McDaniel dated April 2, 1993 on "REP Procedures Manual

Revisions."

128. Memorandum from H. Joseph Flynn (OGC), (FEMA) Associate General Counsel for Program

Law, to Richard W. Krimm, dated April 30, 1993, on "Legal Opinion on Letters of Agreement."

129. Memorandum from Richard Krimm to Regional Directors dated October 13, 1993 on "Adequate

Demonstration of Objective 16 at Radiological Emergency Preparedness Exercises."

130. Memorandum from Delbert Kohl to Charles Biggs dated March 28, 1994 on "Clarification of

Communication Equipment Needed by Field Monitoring Teams for Radiological Emergency

Preparedness."

131. Memorandum from Joe Flynn (OGC) to Dennis Kwiatkowski dated April 6, 1994 on "Impact of

OSHA's HAZMAT Standard on REP Program."

132. Memorandum from Delbert Kohl to Stuart Rifkind dated May 27, 1994 on "Ingestion Planning –

Indiana."

133. Memorandum from Dennis Kwiatkowski to Regional Directors, Regions I-X, dated July 25, 1994,

on "Environmental Protection Agency's (EPA) Manual of Protective Action Guides (PAGs) and

Protective Actions for Nuclear Incidents (EPA 400-R-92-001)."

134. Memorandum from Robert Fletcher to Stuart Rifkind dated November 9, 1994 on "Clarification on

Alert and Notification System-the Order of Sirens and EBS Messages."

135. Memorandum from Robert Fletcher to Rita Calvan dated December 12, 1994 on "FEMA Review

and Approval Process for the Susquehanna Steam Electric Station Offsite Radiological Emergency

Plans and Preparedness."
APPENDIX D: HISTORICAL REP GUIDANCE REFERENCES

REP Program Manual Page D-8 October 2011

136. Memorandum from Dennis Kwiatkowski to Robert Adamcik dated December 13, 1994 on

"Pennsylvania Emergency Management Agency Request for Exemption from REP-14 and REP-15

EBS Provisions."

137. Memorandum from Robert Fletcher to Charles Biggs dated February 23, 1995 on "Request for

Exemption on Back-up Medical Facilities."

138. Memorandum from Robert Fletcher to Charles Biggs dated March 9, 1995 on "EPA Manual of

Protective Action Guides and Retrospective Determinations of Total Dose."

139. Memorandum from Kay Goss to Regional Directors dated March 17, 1995 on "Distribution of

Portal Monitor Standard Documents."

140. Memorandum from Bill Wark to Larry Bailey dated June 6, 1995 on "Evaluation of Activities at

Designated Radio/Television Stations That Broadcast Emergency Messages."

141. Memorandum from Robert Wilkerson to Region II RAC Chair dated April 7, 1995 on "Redundant

Route Alerting."

142. Memorandum from William Wark to Joseph Dominguez, dated April 12, 1996, on "Precautionary

Evacuation for the Emergency Planning Zone (EPZ) of the Diablo Canyon Site."

143. Memorandum from Vern Wingert to Larry Robertson dated August 21, 1996 on "Dosimeter

Guidance for Emergency Workers."

144. Memorandum from Kay Goss to Regional Directors dated June 23, 1997 on "Monitoring of

Radiation Exposure by States."

145. Memorandum from Ihor Husar to RAC Chairpersons dated January 14, 1998 on "Mandate of the

'One-Third Rule' for the Remaining Radiological Emergency Preparedness (REP) Exercises

Conducted in Fiscal Year 1988."

146. Memorandum from Ihor Husar to Eric Jenkins dated March 5, 1998 on "Review and

Determination on the Nebraska Emergency Management Agency's Petition to Delete Nemaha

County Hospital From the Nebraska Radiological Emergency Response Plans (Cooper Nuclear

Station)."

147. Memorandum from Kay Goss to Regional Directors, dated April 2, 1998 on "Interim-Use

Guidance for Providing Information and Instructions to the Public for Radiological Emergencies

Using the New Emergency Alert System (EAS)."

148. Memorandum from Kay Goss to Regional Directors, dated February 2, 1999 on "Guidance for 

Providing Emergency Information and Instructions to the Public for Radiological Emergencies 

Using the New Emergency Alert System (EAS)."

149. Memorandum from Ihor Husar to Robert Bissell and RAC Chairs dated July 23, 1999 on "Request

for Consensus on the Standard Exercise Report Format (SERF)."

150. Memorandum from Carol Ann Adamcik to Russell Salter dated May 11, 2000 on "Legal Opinion

on Contents of Public Notification Messages for Radiological Emergency Preparedness (REP).‖

151. Memorandum from Kay Goss to Directors, Regions I, II, III, IV, V, VI, VII, IX, and X dated July 

5, 2000 on ―Annual Letter of Certification Reporting Requirements Under 44 CFR Part 350 and 

NUREG-0654/FEMA-REP-1, Revision 1.‖

152. Memorandum from Vanessa Quinn to Woodie J. Curtis dated July 21, 2000 on ―State of Illinois

Determination on KI Inventory Potency.‖

153. Memorandum from Vanessa Quinn to All RAC Chairs dated November 20, 2000 on ―Food and

Drug Administration (FDA) Guidance on Extending the Shelf-life of Potassium Iodide (KI).‖
APPENDIX D: HISTORICAL REP GUIDANCE REFERENCES

REP Program Manual Page D-9 October 2011

154. Letter from Richard Meserve to Thomas Ortciger dated November 9, 2001 on ―fast-breaking

emergencies.‖

155. Memorandum from Richard Krimm to Warren, undated, on ―Granting Credit for Objectives 32

and 33.‖

156. Letter from J. Witt to R. Meserve, undated, on ―NRC Decision to revise regulations to consider use

of KI for the public.‖

OTHER FEDERAL AGENCY GUIDANCE

157. Memorandum of Understanding with Transportation Safety Board dated February 27, 1997.

158. Federal Communications Commission Memorandum 98-329, Legal Report and Order "In the

Matter of Amendment of Part 73, Subpart G, of the Commission's Rules Regarding the Emergency

Broadcast System," released December 23, 1998.
APPENDIX D: HISTORICAL REP GUIDANCE REFERENCES

REP Program Manual Page D-10 October 2011

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INDEX

REP Program Manual

INDEX

"350" approval, I-11

access control

at emergency operations center, II-55

at joint information center, II-48

definition, B-1

during post-plume phase, III-41

equipment for, III-34

implementation, III-46

in HAB incident, II-19

in letter of agreement, II-10

of evacuated areas, II-89

of restricted area, II-86

of restricted areas, II-118

to contaminated vehicles, II-95

access/functional needs

alert and notification considerations, II-28

definition, B-1

EAS messages addressing, II-33

evacuation considerations, II-79

evacuation considerations, II-87

handling sensitive information, II-50

identification of individuals, II-43

monitoring of service animals, II-94

precautionary protective actions for, II-75

protective actions for, IV-12

protective actions for, III-39, III-45

public education materials, II-41

public information for, III-58

public information materials, IV-61

service animals, I-9

service support guidance, I-9

shelter accessibility, II-84

accident assessment

definition, B-1

training of personnel, II-136

action level. See emergency action level, 

trigger/action level

activation

definition, B-1

drills, III-6

exercise credit for, III-27

implementation, III-31

of alert and notification system, II-28, III-55

of alternate personnel, II-19

of communications links, II-35

of emergency response organization, II-6

of facilities, II-56

of field teams, II-65

of joint information center, II-47

of letters of agreement, II-10

of personnel, II-38

of public inquiry function, II-52

of transportation resources, II-79

activity types. See HSEEP: activity types

After Action Conference, III-4, III-26, B-2

After Action Report, III-25, IV-15, B-2

issue numbering, III-23

Alert (emergency classification level), II-21

alert and notification system

activation, III-55

administrative procedures, II-31

annual letter of certification, IV-50, IV-52, 

IV-56

backup systems, II-29, III-56, IV-13

design objectives, II-28

equipment, II-30

exception areas, II-29, III-57

in Public Information Review Guide, IV-62

primary system, II-29

reasonable time, B-27

survey, II-30

alternate communication links, II-35

alternate communications

system, III-33

alternate EAS station, III-56

alternate evacuation routes, II-83, III-47

alternate facility

emergency operations center, II-55

joint information center, II-47

joint information center, II-53

alternate notification pathways in HAB 

incident), II-24

alternate personnel

activation, III-31

in HAB incident, II-19

alternative approach to meeting 

requirements, I-1, I-12, B-2, B-29

alternative evaluation methods

in no/minimal release exercises, III-14

alternative methods

protective action development, II-89, III-38, 

IV-12
INDEX

REP Program Manual

alternative systems for alert and notification, 

II-30

annual letter of certification

correction of planning issues reported in, III27

equipment and supplies reported in, III-34

exercise results in, II-133

guidance, IV-49

ingestion information in, II-127

letters of agreement in, II-10

media briefing materials in, II-54

part of assessment strategy, III-1

public education materials in, II-41

requirement for, II-143, IV-8

review guide, IV-52

siren test reporting, II-31

verification during site assistance visit, IV-37

Area Requiring Corrective Action (ARCA), 

III-21

consideration of in exercise planning, III-18

correction of, III-27

correction of during exercise, III-21

correction of plan/procedures, II-143

definition, III-21, B-3

discussion in public meeting, III-20

in After Action Report, III-25

issue numbering, III-22

multiple assessed as Deficiency, III-22

assessment strategy. See planning and 

preparedness assessment strategy

backup alert and notification. See alert and 

notification systems, backup systems

backup notification

of response organization, II-6

of response organization, II-23

backup route alerting. See alert and 

notification systems, backup systems

calibration

annual letter of certification reporting, IV-55

demonstration of, III-35

for medical services monitoring, II-116

of air sampling equipment, II-67

of laboratory equipment, III-54

records to support demonstration credit, III-28

requirements, II-59

verification in equipment check, II-67

check source, II-59, II-67, II-106, II-116, III35, B-4

Concepts and Objectives Meeting, III-3, III17, B-5

congregate care

center locations map, II-77

clearance to enter, II-95, III-61

demonstration of, III-62

evacuation of students to, III-46

facilities annual letter of certification, IV-55

in public information, IV-63

in public information, II-43

referral to after monitoring, II-85

contamination

control of, II-95

detection. See monitoring

in food, II-92

of animal feed, II-92

daycare centers

definition, B-7

in public information materials, II-42

in Public Information Review Guide, IV-61

participation in exercises, III-46

protective actions for, III-39

protective actions for (J.10.d), II-79

decontamination

after reentry, III-41, III-49

collection of waste water, II-109

determining need for, II-106

during provision of medical services, III-64

following reentry, II-118

of emergency workers and equipment, II-108, 

III-61

of evacuees, III-60

of pets, I-9

procedures, II-94

related to provision of medical services, II112, II-116

trigger/action levels, II-94, II-107

Deficiency, I-11, IV-6

and no/minimal release scenario, III-15

and withdrawal of reasonable assurance, IV-9

classifying issue as, III-21

correction, III-4, III-26

definition, III-21

discussion in public meeting, III-20

for criterion not demonstrated, III-24

in After Action Report, III-25

notifying state, III-24

post-exercise timeline, III-4

reporting, II-133, II-143

demonstration requirements matrix, III-7

disaster-initiated review, IV-64

dose calculation, II-71, II-99
INDEX

REP Program Manual

dose limits, I-17, II-97, II-100, II-104, III-36

authorization to exceed, II-103, III-44

procedures to exceed, II-105

dosimetry

annual letter of certification, IV-56

during reentry, III-41, III-49

for emergency workers, II-98, III-36, III-43

for reentry, II-118

group use, II-100, III-44

in HAB incident, II-103

inventory, II-59, III-34

procedures, II-104, II-111, II-116

record-keeping, II-102

supply, II-58

training, II-134

types, II-59, II-99

verification during SAV, IV-37

early (plume) phase, I-19, II-71, II-99, II-117

emergency alert system

as part of alert and notification system, II-30

demonstration, III-59

evaluation of EAS stations, III-55

in public educational material, II-42

information in Public Information Review 

Guide, IV-59

message requirements, II-32

non-English message requirements, IV-64

use of, II-27

emergency planning zone

changes to, IV-33

description, I-18

evacuation time estimates, II-85, II-87, IV-37

evaluation frequency for Demonstration 

Criteria, III-7

evaluator credentialing, IV-34

exception areas, III-57

exercise credit for actual events, III-7, III-27

exercise cycle

exemption from demonstration, III-28

ingestion demonstration requirement, II-126

length, II-123, IV-13

requirements during, II-122, III-6

scheduling activities and, III-4

exercise evaluation guides, IV-18

sample including REP criteria, IV-19

exercise planning team, III-12

exercises

full-scale, III-5

functional, III-5

issue numbering, III-23

tabletop, III-5

exposure

limits. See dose limits

pathways, I-15

public information on effects, II-53

exposure control

during hostile action incidents, II-102

emergency workers, II-98, II-104, II-105

general public. See protective actions

post-plume, II-117

potassium iodide, II-81

fast breaker incident. See rapidly escalating 

incident

foreign language translation

alert and notification messages, II-33

public information materials, II-45

full participation

versus full scale, II-123, III-5

full-scale exercise, III-5

functional exercise, III-5

hostile actions

as scenario variable, II-125

evacuation during, II-83, II-85, II-89

exposure control during, II-102

in exercise planning, III-14

notification pathways during, II-24, II-37

onsite support during, II-19

program enhancements to address, I-8

protective actions during, II-75, III-37

release of sensitive information during, II-50

use of alternate resources during, II-20

hot wash, III-4, III-19, B-7, B-16

HSEEP

activity types, III-4

exercise documents, III-16

exercise evaluation guides, IV-18

integration with REP, III-1, IV-15

National Preparedness Guidelines and, I-7

planning meetings, III-17

REP assessment strategy and, I-2, I-14

REP requirements and, I-8

use in REP exercises, II-121

ingestion exposure pathway

protective actions, II-91

ingestion pathway

exercise requirement, II-126

public information for, II-44

intermediate (ingestion/relocation) phase, I17, I-19, II-71, II-117, II-119, III-49

issue correction, III-26

during an exercise, III-21
INDEX

REP Program Manual

issues

numbering of, III-23

types, III-21

KI. See potassium iodide

late phase, I-19, II-71, II-117, II-119

media information, II-53

media inquiries

information in media briefing, II-53

JIC capability to handle, II-48

monitoring

drills, II-130

during medical transport, II-115

equipment, II-57, II-59, II-106, III-34

of emergency workers and equipment, II-98, 

III-61

of evacuees, II-84, II-93, III-60

of pets, I-9

of vehicles, II-107

portal monitors, II-59, II-94

procedures, II-107

re-monitoring after decontamination, II-108

training, II-137

no/minimal release scenario

exercise planning for, III-14

requirement for, II-125, III-7

nuclear power plant

list of US commercial plants, IV-66

pets, I-8, B-1, B-29

in public information materials, II-33, II-43

phone survey of alert and notification system, 

II-30

plan issue, III-21

plan review

general guidance, IV-39

planning and preparedness assessment 

strategy, I-2, I-13, III-29

activity types used in, III-4

in Demonstration Criteria, III-1

in no/minimal release exercises, III-15

planning conferences

milestones table, III-3

potassium iodide (KI)

administration as protective action, I-16

decision making guidance, II-82

demonstration requirements, III-9, III-36, III38

effect on TEDE calculation, II-99

federal policy and guidance, IV-38

for emergency workers, II-100, III-43

for persons with disabilities and 

access/functional needs, III-39

for the general public, I-17, III-44

in hostile action incidents, II-103

in media information materials, II-53

in public education materials, II-43

in public information materials, IV-63

inventory reporting, III-6, III-34, IV-37, IV56

planning guidance, II-81

training for emergency workers, II-134

precautionary actions, II-75, II-88, II-91, III-40

messages for the public, II-33

protective action guides, I-17, II-71

protective actions, I-15, II-22, II-72, II-75

decision making, II-88

in public information materials, II-42

ingestion exposure pathway, II-91

messages for the public, II-28, II-33

public information

considerations in HAB incident, II-50

EAS messages, II-33

emergency information, III-58

for the ingestion pathway, II-44, II-46, III-48

for transient populations, II-44, II-47

foreign language requirements, II-45, IV-64

guidance, II-42

media information, II-53

periodic dissemination, II-46

review guide, IV-59

public information officer

roles and responsibilities, II-49

public inquiry, II-33, II-51, II-52, III-59

public meeting

following qualifying exercise, IV-6

for formal 350 approval, IV-2

post-exercise, III-19, III-20

qualifying exercise, I-11

rapidly escalating incident

definition, B-27

planning protective actions for, II-74

requirement for exercises, II-122, II-125, III-6

requirements for alert and notification, II-28, 

III-55

scenario variable, III-14, IV-13

reasonable assurance

Deficiency and, III-21

definition, I-2

demonstration, III-1, III-16, IV-18

disaster-initiated review and, IV-65

FEMA plan review, I-10

in regulations, I-5

ongoing assessment, I-14
INDEX

REP Program Manual

REP-HSEEP integration and, IV-15

role of exercises, II-123

statement for 350 approval, IV-3

statement in annual letter of certification, IV51

statement in exercise report, III-25

withdrawal of, IV-8

reasonable time. See timely manner

registration

evacuees, II-96, III-60

individuals needing assistance in an 

evacuation, II-43

release. See also no/minimal release

during exercise play, I-8, II-125

of information, II-33, II-47, II-50, II-51

protective actions, II-75, II-81, II-88

radiological, I-8, I-15, I-19

REP-HSEEP integration, IV-15

rumor control. See public inquiry

scenario review

reviewer checklist, IV-45

scenario types, III-13

scenario variables, III-14

sensitive information

access/functional needs individuals, II-43

in hostile action incident, II-50

service animals, II-43, II-80, II-84, II-93, III-60, 

III-61, III-63, B-29

definition, I-8

service animals, I-8

site code

in issue numbers, III-22

list of, IV-66

staff assistance visit, IV-36

survey of alert and notification system, II-30

tabletop exercise, III-5

target capabilities

crosswalk with REP criteria, IV-16

relation to REP criteria, III-2

Target Capabilities List, IV-14

timely manner

alert and mobilization, III-31

alert and notification, III-55

alert and notification in exception areas, III-57

definition, B-31

emergency public information, III-58

primary route alerting, III-56

protective action decision making, III-38

providing KI and dosimetry to emergency 

workers, III-36

training and exercise plan and workshop, III12

transient populations

alert and notification of, II-29, II-31, III-55

as scenario variable, II-126, III-15

definition, B-31

included in monitoring capacity estimate, II94

potassium iodide for, III-34

public education materials for, II-41, II-46, 

IV-53, IV-61

public information for, II-44

trigger/action levels for decontamination, II94, II-107
INDEX

REP Program Manual

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