Program Manual

Radiological Emergency Preparedness

FEMA P-1028 / January 2015

Radiological Emergency Preparedness Program Manual i

Administrator’s Foreword

FEMA’s Radiological Emergency Preparedness (REP) program evolved in size and scope and has adapted to structural 

and mission changes by incorporating new operations and organizations, transferring functions as necessary, while still 

maintaining the public health and safety surrounding a nuclear power plant. Regardless of how our mission and structure 

have changed, the fundamental character, inspiration, and motivation of the REP Program remains the same: The desire to 

serve our Nation by helping our people and first responders, especially when they are most in need. 

As we continue to improve FEMA’s REP Program, we must view all the work FEMA does in concert with the emergency 

management community as part of a broad plan for addressing the demands and challenges of a catastrophic disaster. To 

ensure our efforts become part of an interconnected plan of action, we are focused on our “Whole Community” initiative. 

This initiative will continue to effectively leverage the capabilities both governmental and non-governmental entities play 

in preparing for a catastrophic disaster. “Whole Community” uses planning assumptions for catastrophic disasters based 

on the worst case scenarios. These scenarios challenge preparedness at all levels of government and force innovative nontraditional solutions as part of the response strategy to such events. As the name of the initiative indicates, it is truly the 

whole community that must be prepared to respond in ways that extend beyond the previous paradigms in which we have 

traditionally operated.

While preparedness is critical in saving and sustaining lives, the “Whole Community” approach spans not only prevention 

and protection before a disaster, but also recovery, response operations, and mitigation activities that occur before, during, 

and after a catastrophic event. Our experiences helped us realize and appreciate the important role that State, local, and 

Tribal governments play in disaster preparedness, response, and recovery. FEMA’s success with the REP Program is heavily 

dependent upon our ability to communicate, coordinate, and work closely together building on the strengths of local 

communities and citizens and integrating the public as a critical resource.

Each emergency preparedness plan addresses unique considerations that exist in the event of a catastrophic incident 

at a commercial nuclear power plant. We believe that your radiological emergency response plans are a part of your 

comprehensive emergency management program. This provides a “Whole Community” approach to strengthen your 

community’s preparedness against any catastrophic event. 

Most importantly, we know of the great capacity of individuals to care for their families, friends, neighbors and fellow 

community members, making our citizens force multipliers rather than liabilities. Together, we make up the “Whole 

Community,” and we all have an important role to play. We must engage all of our societal capacity, both within and 

beyond FEMA, to work together as a team.

W. Craig Fugate

Administrator
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Contents

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

A. Mission Statement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

B. Purpose. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

C. Scope. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

D. Basis of the REP Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

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

2. Programmatic Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

E. Evaluation of Radiological Emergency Preparedness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

1. NRC-FEMA Memorandum of Understanding. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

2. Specific FEMA Review and Approval Procedures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

3. Federal Delegation of Tasks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

4. Planning And Preparedness Assessment Strategy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

F. Technical Basis for the REP Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

1. Nature of the Hazard. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2. Protective Actions to Reduce Exposure to Radiation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

3. Protective Action Guides. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

4. Emergency Planning Zones. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5. Radiological Incident Phases. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

PART II: REP Program Planning Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

A. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

1. Purpose and Scope. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2. Contents and Organization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

B. Planning Standards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

C. Planning Standards-Core Capability Crosswalk. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

D. Planning Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

1. Planning Standard A – Assignment of Responsibility (Organization Control). . . . . . . . . . . . . . . . . . . 20

2. Planning Standard B – Onsite Emergency Organization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

3. Planning Standard C – Emergency Response Support and Resources. . . . . . . . . . . . . . . . . . . . . . . 31

4. Planning Standard D – Emergency Classification System. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

5. Planning Standard E – Notification Methods and Procedures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

6. Planning Standard F – Emergency Communications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
Radiological Emergency Preparedness Program Manual iii

7. Planning Standard G – Public Education and Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

8. Planning Standard H – Emergency Facilities and Equipment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

9. Planning Standard I – Accident Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75

10. Planning Standard J – Protective Response. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84

11. Planning Standard K – Radiological Exposure Control. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107

12. Planning Standard L – Medical and Public Health Support. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119

13. Planning Standard M – Recovery and Reentry Planning and Post-Accident Operations. . . . . . . . . . 124

14. Planning Standard N – Exercises and Drills. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 128

15. Planning Standard O – Radiological Emergency Response Training. . . . . . . . . . . . . . . . . . . . . . . . 140

16. Planning Standard P – Responsibility for the Planning Effort: Development, . . . . . . . . . . . . . . . . . 147

Periodic Review and Distribution of Emergency Plans

Part III: REP Program Demonstration Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 152

A. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 152

1. Contents and Organization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 152

2. Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 152

B. REP Exercise Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 153

1. Scheduling REP Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 155

2. Conducting Preplanning Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 163

3. Developing REP Exercise Documents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 166

4. Holding Exercise Planning Meetings. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 167

5. Conducting REP Exercises. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 168

6. Documenting REP Exercises. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 170

7. REP Program Credit for Participation in Actual Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 175

C. Exercise Demonstration. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 177

Assessment Area 1: Emergency Operations Management. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179

Assessment Area 2: Protective Action Decision-Making. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 183

Assessment Area 3: Protective Action Implementation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 188

Assessment Area 4: Field Measurements And Analyses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 194

Assessment Area 5: Emergency Notification And Public Information. . . . . . . . . . . . . . . . . . . . . . . . . . 197

Assessment Area 6: Support Operations/Facilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 201

Part IV: FEMA REP PROGRAM ADMINISTRATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 205

A. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 205

B. Regulatory Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 206

1. 44 CFR Part 350 – Review and Approval of State and Local Radiological. . . . . . . . . . . . . . . . . . . 206

Emergency Plans and Preparedness
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2. 44 CFR Part 351 – Radiological Emergency Planning and Preparedness. . . . . . . . . . . . . . . . . . . . 214

3. 44 CFR Part 352 – Commercial NPP: Emergency Preparedness Planning . . . . . . . . . . . . . . . . . . . 214

4. 44 CFR Part 353 – Fee for Services in Support, Review, and Approval of State. . . . . . . . . . . . . . . 214

and Local Government or licensee Radiological Emergency Plans and Preparedness

5. 44 CFR Part 354 – Fee for Services to Support FEMA’s Offsite REP Program. . . . . . . . . . . . . . . . 215

C. Non-participating State, Tribal, and Local Governments (NUREG-0654/FEMA-REP-1, Supplement 1). . . . 216

D. Early Site Permit Applications (NUREG-0654/FEMA-REP-1, Supplement 2). . . . . . . . . . . . . . . . . . . . . 216

E. Protective Action Strategies (NUREG-0654/FEMA-REP-1, Supplement 3). . . . . . . . . . . . . . . . . . . . . . 217

F. Exercise Methodology, More Challenging Drills and Exercises, and Backup Alert and. . . . . . . . . . . . . . 218

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

G. Demonstration Considerations for No/Minimal Release Scenarios. . . . . . . . . . . . . . . . . . . . . . . . . . . 219

H. Integration of REP Demonstration Criteria and Core Capabilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . 224

1. Demonstration Criteria-Core Capability Crosswalk. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 224

2. Exercise Evaluation Guides. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 227

3. Customizing EEGs for an Exercise. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 227

I. Submitting Best Practices on the FEMA Website. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 228

J. Approval Process for Alternative Approaches. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 233

1. Initial submission. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 233

2. Regional Recommendation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 233

3. FEMA Headquarters Approval. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 233

4. Alternative Approach Demonstration. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 234

K. Emergency Planning Zone Boundary Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 234

L. Credentialing Framework. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 235

M. Use of State, Local, and Tribal Personnel as REP Exercise Evaluators. . . . . . . . . . . . . . . . . . . . . . . . 235

1. Administrative Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 235

2. Host Region Responsibilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 236

3. Evaluator Responsibilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 236

4. Evaluator Employer Commitment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 236

5. Conditions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 236

N. Tribal Policies and Procedures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 236

1. Federally Recognized Tribal Nations and the REP Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 236

2. Policy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 236

O. Staff Assistance Visits (SAVs) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 237

P. Evacuation Time Estimates. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 237
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Q. Potassium Iodide for the Public. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 238

R. Conducting Plan Reviews. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 238

1. Radiological Emergency Preparedness Plans/Procedures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 238

2. Division of Functions and Applicability of Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 239

3. Format for Plan Reviews. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 240

S. Conducting Scenario Reviews. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 242

1. Scenario Review Preparation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 242

2. Radiological Emergency Preparedness Exercise Scenario Review Checklist. . . . . . . . . . . . . . . . . . 244

T. Annual Letter of Certification (ALC). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 246

1. Guidance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 246

2. Sample Annual Letter of Certification Cover Letter . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 247

3. Annual Letter of Certification (ALC) Review Guide. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 248

U. Public Information Guide and Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 255

1. Guidance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 255

2. Review Steps. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 255

3. Foreign Language Translation – Legal Requirements and Location of Information. . . . . . . . . . . . . 260

V. Disaster Initiated Review. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 261

Part V: Supplemental Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 262

A. Alert and Notification Systems. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 262

1. Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 262

2. FEMA Evaluation of ANS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 263

3. Evaluation Report Template. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 266

Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 316

List of Appendices

Appendix A: Abbreviations and Acronyms Used in the REP Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 270

Appendix B: Glossary of REP Terms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 277

Appendix C: REP Guidance References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 303

Appendix D: Historical REP Guidance References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 306

Appendix E: List of Commercial Nuclear Power Plants. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 314
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List of Exhibits

Exhibit I-1: Probable Early Effects of Acute Radiation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Exhibit I-2: EPZ Characteristics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Exhibit II-1: NUREG-0654/FEMA-REP-1 Planning Standards-Core Capabilities Crosswalk. . . . . . . . . . . . . . . . 18

Exhibit II-2: Sample Functional Responsibilities Matrix/Table. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Exhibit II-3: Design Objectives for Alert and Notification of the Public. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Exhibit III-1: Milestones for the REP Exercise Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 154

Exhibit III-2: Federal Evaluation Process Matrix. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 158

Exhibit III-3: Illustration of the Standard Exercise Issue Number. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 171

Exhibit III-4: Evaluation Standards for Alert and Notification Systems. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 197

Exhibit IV-1: Plan Review Responsibilities for RAC Agencies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 207

Exhibit IV-2: Considerations for Demonstrating the 10 Criteria during a No/Minimal Release Scenario. . . . . 220

Exhibit IV-3: Demonstration Criteria-Core Capabilities Crosswalk. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 225

Exhibit IV-4: Best Practice Submission Form. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 229

Exhibit IV-5: Photographic/Video/Audio Consent & Release. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 231

Exhibit IV-6: Photographic/Video/Audio Parental Consent & Release. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 232

Exhibit IV-7: Plan Review Responsibility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 240

Exhibit IV-8: Plan Review Format. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 241

Exhibit IV-9: Scenario Review Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 242

Exhibit IV-10: Public Information Review Checklist. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 256
Radiological Emergency Preparedness Program Manual vii

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 (REP) Program policy and guidance. FEMA will review changes to other Federal Agency guidance that 

impacts the REP Program and issue updates to this manual as warranted.
Part I: Introduction to the REP Program Manual

1 Radiological Emergency Preparedness Program Manual

PART I: Introduction to the Radiological 

Emergency Preparedness Program Manual

A. MISSION STATEMENT

The REP Program coordinates the National effort to provide 

State, local, and Tribal governments with relevant and 

executable planning, training, and exercise guidance and 

policies necessary to ensure that adequate capabilities exist 

to prevent, protect against, mitigate the effects of, respond 

to, and recover from incidents involving commercial 

nuclear power plants (NPPs).

The program assists State, local, and Tribal governments 

in the development and conduct of off-site radiological 

emergency preparedness activities within the emergency 

planning zones (EPZs) of Nuclear Regulatory Commission 

(NRC)-licensed commercial nuclear power facilities. 

REP’s historical success lies in its ability to integrate and 

enhance Federal, State, Tribal, and local governments’ 

preparedness planning and response capabilities for all 

types of radiological emergencies.

B. PURPOSE

This manual serves as the principal source of policy and 

guidance for the FEMA 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 NPPs. 

State, local, and Tribal 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 NRC/

FEMA document NUREG-0654/FEMA-REP-11

, 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 

1 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.”

emergency preparedness, 44 CFR § 350.5 incorporates 

by 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. 

NUREG-0654/FEMA-REP-1 Requirement

It is FEMA’s position that, unless an alternative 

approach is proposed and accepted, the associated 

Evaluation Criteria must be met.

Shall and should: The terms shall, must, and require denote 

mandatory items originating in regulatory material 

including NUREG-0654/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. The only exception 

to this is Planning Standard G where should is quoted in 

regulatory language. 
Part I: Introduction to the REP Program Manual

Radiological Emergency Preparedness Program Manual 2

Alternative approaches. The Evaluation Criteria listed in 

NUREG-0654/FEMA-REP-1, as interpreted and applied 

by the NRC, FEMA, and other Federal agencies, represent 

approved approaches for meeting the intent of the Planning 

Standards. Offsite response organizations (OROs) may 

provide written proposals for alternative approaches to 

meeting the Evaluation Criteria to the appropriate FEMA 

Regional Office. The FEMA Regional Offices will review 

the proposal and forward its recommendations to FEMA 

Headquarters for review and approval. The review of 

proposals will include the Regional Assistance Committee 

(RAC). FEMA will also coordinate with the NRC and 

licensees when the alternate approach may affect onsite 

planning and preparedness.

Reasonable Assurance. In the communities surrounding 

commercial nuclear power plants, 44 CFR 350.5 (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 will consider 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 will make its adequacy determination, supported 

by other Federal agencies, as necessary, by conducting 

inspections, providing staff assistance visits (SAVs), 

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 

will be guided by the standards, criteria, and policy 

found in applicable laws, regulations, and contemporary 

emergency preparedness guidance as follows: 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 Planning 

Frameworks, the National Preparedness Goal and System, 

Comprehensive Preparedness Guide (CPG) 101, the 

core capabilities, the National Incident Management 

System (NIMS) and Incident Command System (ICS), 

the Homeland Security Exercise and Evaluation Program 

(HSEEP) and the Integrated Planning System.

Where improvements or corrections are needed, FEMA 

will work closely with Federal, State, local, and Tribal 

government officials and industry stakeholders to resolve 

the issue(s).

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. The REP 

Program Manual includes guidance that allows for an 

ongoing assessment approach through evaluation of a 

broader range of activities than those previously used. The 

Manual’s guidance is consistent with national preparedness 

initiatives and HSEEP, and continues the streamlining of 

Federal, State, and local efforts and resources with 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 stand-alone references. Appendix C lists these stand-alone 

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 to the REP Program Manual

3 Radiological Emergency Preparedness Program Manual

C. 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.

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. 

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 in order to determine 

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.

This manual is divided into five 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 base 

knowledge about the REP Program and describes current 

operations through a synopsis of its evolution.

Part II contains the NUREG-0654/FEMA-REP-1 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 exceed nor replace 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 (KI) 

and Disaster Initiated Reviews (DIRs), scenario reviews, 

plan reviews, the ALC, and other topics. 

Part V contains supplemental guidance that is not covered 

in the Manual’s other Parts. It presents information 

regarding the evaluation of Alert and Notification Systems 

(ANS), which was previously captured in the Guide for the 

Evaluation of Alert and Notification Systems for Nuclear 

Power Plants (FEMA REP-10).

The appendices include acronyms, a glossary, and 

additional REP reference documents. 
Part I: Introduction to the REP Program Manual

Radiological Emergency Preparedness Program Manual 4

D. 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 post-Katrina 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 1974.2

 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 exists a State, local, 

or utility3

 plan which provides reasonable assurance that 

public health and safety is not endangered by operation of 

the facility concerned.”4

 The 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.5

 The NRC revised 

its regulations in 10 CFR Part 50 to incorporate additional 

emergency preparedness requirements, including 

2 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.

3 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.

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

5 Pub.L. 96 295, section 109(b), 94 Stat. 80, 784 (1980).

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 NRC-FEMA 

guidance document NUREG-0654/FEMA-REP-1. 

In June 1996, FEMA initiated a Strategic Review of 

the REP Program in order to improve its efficiency 

and effectiveness.6

 FEMA worked with internal and 

external stakeholders nationwide and published five 

major recommendations in September 1998.7

 These 

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. 

6 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.

7 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.
Part I: Introduction to the REP Program Manual

5 Radiological Emergency Preparedness Program Manual

2. Programmatic Changes 

The lessons learned from September 11, 2001 and Hurricane 

Katrina compelled all Federal agencies – particularly those 

that have a mission to protect public health and safety – to 

examine 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, 2001, 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 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 “all-hazards” 

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 Preparedness8

 established 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 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 National 

Response Framework (NRF). 

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.











National Preparedness Goal – “A secure and resilient 

nation with capabilities required across the whole 

community to prevent, protect against, mitigate, 

respond to, and recover from the threats and hazards 

that pose the greatest risk.” The Goal also defines a 

series of national preparedness elements, called core 

capabilities, needed to achieve the Goal.

Core Capabilities – are distinct critical elements 

necessary to achieve the specific mission areas of 

prevention, protection, mitigation, response, and 

recovery. Capabilities provide a common vocabulary 

describing the significant functions required to deal 

with threats and hazards that must be developed 

and executed across the whole community to ensure 

national preparedness.

National Preparedness System – outlines an 

organized process for everyone in the whole 

community to move forward with their preparedness 

activities and achieve the National Preparedness 

Goal. The National Preparedness System has several 

parts, among them are the estimating, building, and 

sustaining of Core Capabilities and the use of the 

HSEEP methodology to validate a community’s progress 

towards preparedness goals.

National Planning Frameworks – The National 

Planning Frameworks, which are part of the National 

Preparedness System, set the strategy and doctrine for 

building, sustaining, and delivering the core capabilities 

identified in the National Preparedness Goal. They 

describe the coordinating structures and alignment of 

key roles and responsibilities for the whole community 

and are integrated to ensure interoperability across all 

mission areas. The frameworks address the roles of 

individuals, nonprofit entities and nongovernmental 

organizations (NGOs), the private sector, communities, 

critical infrastructure, governments, and the Nation as a 

whole. There is one Framework per mission area.

Comprehensive Preparedness Guide – FEMA’s 

Comprehensive Preparedness Guide (CPG) 101 provides 

general guidelines on developing emergency operations 

plans.9

 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. 

9 FEMA, Comprehensive Preparedness Guide 101: Developing and Maintaining 

Emergency Operations Plans, Version 2.0, November 2010.
Part I: Introduction to the REP Program Manual

Radiological Emergency Preparedness Program Manual 6

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. 

On October 4, 2006, the President signed The Post-Katrina 

Emergency Management Reform Act (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 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 (NESC), 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:





NIMS – The REP Program Manual incorporates NIMS 

features, such as standard terminology and the ICS, to 

ensure consistency with the National Exercise Program. 

NIMS also provides a flexible management template that 

can be scaled appropriately to any incident, regardless 

of cause, size, location, or complexity. 

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 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 action-based (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 200502, “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 

2006-1210 as an acceptable implementation methodology 

for the emergency preparedness program enhancements 

discussed in Bulletin 200502. The NRC also recommended 

pursuing rulemaking for emergency preparedness program 

enhancements for several security incident-related and 

non-security 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.

10 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).
Part I: Introduction to the REP Program Manual

7 Radiological Emergency Preparedness Program Manual

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 preconditioning by increasing the variability of 

exercise events;

2. Enhancing security response capabilities based on postSeptember 11 security initiatives by introducing HAB 

scenarios into the REP exercise cycle; and

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 changes11

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 service animals that are trained 

to perform a specific task are protected by the American 

Disabilities Act (ADA). 

11 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).

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.

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.”12 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.

12 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).
Part I: Introduction to the REP Program Manual

Radiological Emergency Preparedness Program Manual 8

E. EVALUATION OF RADIOLOGICAL EMERGENCY PREPAREDNESS

This manual provides clarifying guidance from FEMA. 

The planning guidance contained in Part II of this manual 

further explains the NUREG-0654/FEMA-REP-1 Planning 

Standards and associated Evaluation Criteria that apply to 

OROs. Certain Evaluation Criteria in NUREG-0654/FEMAREP-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. NR C-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 sitespecific 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). 

If there is reason to believe that reasonable assurance 

may no longer exist at a particular site, FEMA may 

review offsite emergency preparedness on its own 

initiative, or at the request of the NRC, to develop a 

finding.

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 NRC-FEMA 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. S pecific 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 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 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.
Part I: Introduction to the REP Program Manual

9 Radiological Emergency Preparedness Program Manual

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 NUREG-0654/

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 NPP 

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, 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 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 the 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 fails 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. 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. 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);
Part I: Introduction to the REP Program Manual

Radiological Emergency Preparedness Program Manual 10





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 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.13

4. 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.

13 June 2008. See http://www.fema.gov/pdf/emergency/nrf/nrp_

nuclearradiologicalincidentannex.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, SAVs, 

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 full-scale, 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, local, and Tribal 

government 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 to the REP Program Manual

11 Radiological Emergency Preparedness Program Manual

F. 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)14, 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 Roentgen-equivalentman (rem) and includes the biological effect of the radiation 

received (rem = rad x radiation weighting factor15). 

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;

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 re-suspended into the air.

14 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).

15 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.

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.

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 neutron-to-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 

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. 
Part I: Introduction to the REP Program Manual

Radiological Emergency Preparedness Program Manual 12

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. P rotective 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

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

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 (EWs), 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 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. 

Decision-makers 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;
Part I: Introduction to the REP Program Manual

13 Radiological Emergency Preparedness Program Manual





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.16 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.

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

16 Guidance on Accidental Radioactive Contamination of Human Food and 

Animal Feeds, Recommendations for state and Local Agencies, 63 Fed. Reg. 

43402 (August 13, 1998).

EPA also established an intermediate-phase relocation PAG17

of 2 rem whole body exposure in the first year. The longterm 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 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. 

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. 

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.

17 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear 

Incidents, May 1992.
Part I: Introduction to the REP Program Manual

Radiological Emergency Preparedness Program Manual 14

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.

Exhibit I-2: EPZ Characteristics

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 

radiation-induced 

cancer to the thyroid, 

bone marrow, and 

other organs

Size Approximately 

10-mile radius

Approximately 50-mile 

radius

The size of the plume exposure pathway EPZ, about 

10 miles in radius, is based on the following considerations 

from NUREG-0654/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.

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:







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 

exposure 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.
Part I: Introduction to the REP Program Manual

15 Radiological Emergency Preparedness Program Manual

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 II: REP Program Planning Guidance

Radiological Emergency Preparedness Program Manual 16

PART II: REP Program 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 FEMAREP 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 NUREG-0654/FEMA-REP-1.

Subpart C, Planning Standards-Core Capability 

Crosswalk, is an analysis of the relationship between 

the core capabilities from the National Preparedness Goal and 

National Planning Frameworks and the Planning Standards from 

NUREG-0654/FEMA-REP-1. This crosswalk was created 

to provide context for the Planning Standards within 

contemporary emergency preparedness guidance. 

Subpart D, 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; and

Checkmarks indicating to which plans/procedures (i.e., 

licensee, State, or local) each NUREG-0654/FEMAREP-1 Evaluation Criterion is applicable. 

The guidance in this manual applies only to 

offsite response organizations.

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.
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17 Radiological Emergency Preparedness Program Manual

B. PLANNING STANDARDS

Planning Standard A – Assignment of Responsibility (Organization Control) 

Planning Standard B – Onsite 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
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Radiological Emergency Preparedness Program Manual 18

C. PLANNING STANDARDS-CORE CAPABILITY CROSSWALK

Exhibit II-1: NUREG-0654/FEMA-REP-1 Planning Standards-Core Capabilities Crosswalk

NUREG-0654/FEMA-REP-1, Rev. 1 Planning Standard

Core Capabilities 

by Mission Area

Planning Standard APlanning Standard BPlanning Standard CPlanning Standard DPlanning Standard EPlanning Standard FPlanning Standard GPlanning Standard HPlanning Standard IPlanning Standard JPlanning Standard KPlanning Standard LPlanning Standard MPlanning Standard NPlanning Standard OPlanning Standard P

Common

Planning X X X X X X X X X X X X X X X X

Public Information and Warning X X X X X X X

Operational Coordination X X X X X X X X X X X X X

Prevention

Forensics and Attribution

Intelligence and Information Sharing

Interdiction and Disruption

Screening, Search, and Detection X X X

Protection

Access Control and Identity 

Verification X

Cybersecurity

Intelligence and Information Sharing

Interdiction and Disruption

Physical Protective Measures

Risk Management for Protection 

Programs and Activities

Screening, Search, and Detection X X X

Supply Chain Integrity
Part II: REP Program Planning Guidance

19 Radiological Emergency Preparedness Program Manual

Exhibit II-1: NUREG-0654/FEMA-REP-1 Planning Standards-Core Capabilities Crosswalk

NUREG-0654/FEMA-REP-1, Rev. 1 Planning Standard

Core Capabilities 

by Mission Area

Planning Standard APlanning Standard BPlanning Standard CPlanning Standard DPlanning Standard EPlanning Standard FPlanning Standard GPlanning Standard HPlanning Standard IPlanning Standard JPlanning Standard KPlanning Standard LPlanning Standard MPlanning Standard NPlanning Standard OPlanning Standard P

Mitigation

Community Resilience X X X X

Long-Term Vulnerability Reduction X X X

Risk and Disaster

Resilience Assessment X X X X

Threat and Hazard Identification X

Response

Critical Transportation X

Environmental Response/Health 

and Safety X X X X X X

Fatality Management Services

Infrastructure Systems X

Mass Care Services X

Mass Search and Rescue Operations

On-Scene Security and Protection X

Operational Communications X X X X X X X

Public and Private Services 

and Resources X X X X X X

Public Health and Medical Services X X X

Situational Assessment X X X X X X

Recover

Economic Recovery X

Health and Social Services X

Housing X

Infrastructure Systems X

Natural and Cultural Resources X
Part II: REP Program Planning Guidance

Radiological Emergency Preparedness Program Manual 20

D. 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:

P

P

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/ICS into ORO emergency plans/procedures for NPPs will provide greater consistency across 

response jurisdictions and facilitate 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). 
Part II: REP Program Planning Guidance

21 Radiological Emergency Preparedness Program Manual

REFERENCES









National Incident Management System, December 2008.

National Response Framework, second edition, May 2013.

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:

P Specify the organization’s role in an emergency. 

P

EXPLANATION

The plans/procedures describe exactly what the organization or sub-organization1918 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, second edition, May 2013.

N

C

ational Response Framework, Nuclear/Radiological Incident Annex, June 2008.

omprehensive 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 

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

P Include an illustration of each organization and its relationship to the total emergency response effort.19

18 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.

19 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

Radiological Emergency Preparedness Program Manual 22

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, second edition, May 2013.

 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:

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

P 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, second edition, May 2013.

 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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23 Radiological Emergency Preparedness Program Manual

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:

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

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

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

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

P 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 

24hour 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.

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.)20

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

20 NUREG-0654/FEMA-REP-1, Revision 1, Section II. Planning Standards and Evaluation Criteria, Part B – Onsite Emergency Organization, October 1980.
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Radiological Emergency Preparedness Program Manual 24

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

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

P Describe the responsibilities by functional areas

P 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/ICS, these descriptions identify who will carry out the five ICS functions.

REFERENCES

 National Incident Management System, December 2008.

 National Response Framework, second edition, May 2013.

 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

25 Radiological Emergency Preparedness Program Manual

Exhibit II-2: 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
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Radiological Emergency Preparedness Program Manual 26

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:

P Identify the legal authority to assign lead responsibility for emergency preparedness to a particular State agency.

P Indicate who (e.g., the Governor) may declare a “state of emergency” (or “state of disaster emergency”) and what 

special powers may ensue. 

P Identify the legal authority to delegate responsibility and authority for preparedness and response at the local level. 

P Identify any limitations on the authority of Letter of Agreement (LOA) signatories that are relevant to State, local, or 

tribal statues and not policy.

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, second edition, May 2013.

 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:

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

P Include LOAs by reference or in a suitable appendix. 

P Include or reference applicable LOAs between the licensee and ORO including arrangements for access to the NPP site, 

if appropriate.

P State that the LOAs include details on what services will be provided and how the agreements will be activated. 

P State that LOAs are reviewed annually to verify their validity. (See also Criterion P.4)
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27 Radiological Emergency Preparedness Program Manual

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. 

Government agencies whose functions are inherently emergency response-oriented do not require MOUs/LOAs. 

Intergovernmental support is increasingly being secured through mutual assistance compacts and/or 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).

LOAs are required for primary and back-up resources the OROs will utilize in the event of an emergency. OROs can have a 

separate list of resources to use in the case of extreme emergency when their primary and back-up resources are unavailable. 

For example, in the unlikely circumstance that the primary and back-up laboratories are unavailable, the emergency 

manager may have a list of all available resources in the area. This list is not subject to evaluation, but should be considered 

a best practice for the time it will save in the face of an emergency.

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, 

typically through the ALC. 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, second edition, May 2013.

 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

Radiological Emergency Preparedness Program Manual 28

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:

P Identify key individuals, by title/position, who are responsible for ensuring continuity of resources in support of 24-

hour operations.

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

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

P 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.

P Describe the responsibilities by the functional areas listed above.

FEMA HIGHLY RECOMMENDS THAT PLANS/PROCEDURES:

P Describe responsibilities by the five ICS functions. 

EXPLANATION

Emergency response activities for a commercial NPP incident may last longer than 1 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, second edition, May 2013.

 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

29 Radiological Emergency Preparedness Program Manual

2. Planning Standard B – Onsite 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 

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-121 entitled,“Minimum Staffing Requirements for Nuclear Power Plant Emergencies.” The minimum on-shift staffing levels 

21 NUREG-0654/FEMA-REP-1, Revision 1, Table B-1, page 37, October 1980.
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Radiological Emergency Preparedness Program Manual 30

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 

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 B1) 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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31 Radiological Emergency Preparedness Program Manual

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.22 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:

P 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, second edition, May 2013.

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

 National Response Framework, Mass Evacuation 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.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 

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

P A process for identifying potential shortfalls in resources.

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

P 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,23 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 ICS 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:

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

P Identify the general geographical areas for the locations of these facilities and the unique features of the area.

P 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, arriving 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.

23 NUREG-1442, Rev. 1/FEMA-REP-17, Revision 1, Emergency Response Resources Guide for Nuclear Power Plant Emergencies, July 1992, is a good resource for this.
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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:

P 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 

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:

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

radionuclides.

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

foodstuffs, soil samples, and water samples).

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

P Include the location and potential availability of the laboratories.

EXPLANATION

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

P 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, January 2008. 

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and Local Government Emergency Plans, Version 2, 

November 2010.

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.
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35 Radiological Emergency Preparedness Program Manual

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:

P Include provisions to allow ORO law enforcement and other initial first responders prompt access to the NPP site. 

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

P Identify any mutual aid agreements for alternate personnel to supplement local resources (see also Criterion A.3).

P Address radiological training requirements for the primary and alternate personnel. 

P 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.

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

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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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, in the classroom, or as just-in-time training at a frequency determined 

in ORO plans/procedures. 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, 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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37 Radiological Emergency Preparedness Program Manual

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 inplant 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 [NUREG-0654/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:

P Include reference to the standard Emergency Classification Levels (ECLs).24

P 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. 

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.

24 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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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: 

P 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.25 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/FEMA-REP-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.

25 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.
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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:

P 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. 

P 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.

P 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 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 NUREG-0654/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.
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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-toORO 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 “pre-incident” 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 

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

P 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.

P 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.

P 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. 

P Indicate the specific notifications made at each ECL.

P Indicate the means by which notifications will be accomplished (e.g., pagers, telephones, radios, auto dialers).
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41 Radiological Emergency Preparedness Program Manual

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. 

As a best practice, consideration should be given to contacting other States and/or jurisdictions outside the 50 mile EPZ and 

keeping them apprised of the situation as it progresses.

REFERENCES

 National Incident Management System, December 2008.

 National Response Framework, second edition, May 2013.

 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 follow-up 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;

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 
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Radiological Emergency Preparedness Program Manual 42

NUREG CRITERION E.5

State and local government organizations shall establish a system for disseminating to the public appropriate information 

contained in initial and follow-up messages received from the licensee, including the appropriate notification to appropriate 

broadcast media, e.g., the Emergency Alert System (EAS.)26

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

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

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

instructions to the public. 

P 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.)

P 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.

P 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.)

P Establish the interval for broadcasting official information statements. 

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

FEMA HIGHLY RECOMMENDS THAT PLANS/PROCEDURES:

P 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 repeats 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

 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, second edition, May 2013.

26 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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 National Response Framework, Emergency Support Function #15 – External Affairs Annex, May 2013.

 National Response Framework, Public Affairs Support Annex, May 2013.

 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-REP-1] 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 

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

P State that the Alert and Notification System (ANS) is capable of meeting the 15-minute design objective.

P 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.

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

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

(2) activating the system;

P The ANS activation procedures and time required to implement these procedures; and

P 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. For 

further information regarding ANS design objectives and the primary and backup physical means of alert and notification, 

see Section V, Part A of this Manual. NUREG-0654/FEMA-REP-1 Appendix 3 (as amended by Supplement 4) and 44 CFR 

§ 350.5(a) provide addition information and authorities regarding alert and notification.
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Radiological Emergency Preparedness Program Manual 44

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 Section V, Part A of this 

Manual, 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 to the 

entire 10-mile EPZ, including remote and low-population areas within 15 minutes of the decision to notify the public. The 

requirements include alerting and notifying the transient population in remote rural areas, open water 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 of alert and notification. In the event that the 

primary alert and notification fails, the ORO should notify those affected. The notification should occur within 45 minutes 

(recommended goal) from the time the failure is initially acknowledged. 

Design Objectives Are for Worst-Case 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).

Essentially 100 percent

A system must be able to cover 100% of all the 

populated areas of an EPZ. This is not an attempt 

to measure that 100% of the EPZ population was 

reached, only that the ability exists to reach the 

entire population. 
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45 Radiological Emergency Preparedness Program Manual

Exhibit II-3: 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. 

The Integrated Public Alert and Warning System (IPAWS) is a modernization and integration of the nation’s alert and 

warning infrastructure that will save time when time matters; when protecting life and property.

Federal, State, territorial, Tribal, and local alerting authorities may choose to use IPAWS and may also integrate local systems 

that use Common Alerting Protocol (CAP) standards with the IPAWS infrastructure. IPAWS will give public safety officials 

an effective way to alert and warn the public about serious emergencies using the Emergency Alert System (EAS), the 

Commercial Mobile Alert System (CMAS), National Oceanic and Atmospheric Administration (NOAA) Weather Radio, and 

other public alerting systems from a single interface.

FEMA strongly encourages the integration of IPAWS with offsite alert and notification plans. As IPAWS is adopted 

nationwide, technical and planning assistance is available for State, territorial, tribal, and local alerting authorities.

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 
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Radiological Emergency Preparedness Program Manual 46

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 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 NUREG0654/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.27

27 Section V, Part A of this Manual, describes routine siren testing procedures and operability requirements.
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47 Radiological Emergency Preparedness Program Manual

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 GM AN-1, FEMA Action to Qualify Alert and Notification Systems Against NUREG-0654/FEMA-REP-1.

 National Incident Management System, December 2008.

 National Response Framework, second edition, May 2013.

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, May 2013.

 National Response Framework, Public Affairs Support Annex, May 2013.

 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.

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,29F 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.

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:

P EAS message templates that would be modified as necessary and sent to the EAS station(s) for broadcast;

P Provisions for special news broadcasts as supplements to the EAS message;

P Provisions for foreign language translations of EAS messages and special news broadcasts, if required;

P The process for selecting, modifying, approving, and releasing messages; and

P The methodology for EAS message rebroadcast, 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. 
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Radiological Emergency Preparedness Program Manual 48

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 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; and

 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.

Plans/procedures discuss the process for modifying or selecting pre-scripted, including computer-generated, 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 rebroadcast, 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) with a description that 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;

 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; and

 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.
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49 Radiological Emergency Preparedness Program Manual

Non-English language messages: At a minimum, EAS messages and special news broadcasts shall be translated into 

any non-English language spoken by more than 10,000 individuals or more than 5% of the total voting age citizens 

in a single political subdivision (usually a county, but a township or municipality in some States) within the EPZ.28

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

 Memorandum from Margaret Lawless to RAC Chairpersons, Guidance on Planning Requirements Whenever Changes Are Made to 

Existing 10-mile EPZs, June 25, 1993.

 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.

28 See Part IV, Section S. Public Information Guide and Process.
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Radiological Emergency Preparedness Program Manual 50

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.1.a. ORO PLANS/PROCEDURES SHALL:

P 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. 

P 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:

P 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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51 Radiological Emergency Preparedness Program Manual

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:

P Primary and backup communication capability between all local governments within the plume EPZ;

P Primary and backup communication capability between each local government and any associated host/support 

counties located outside the plume EPZ; and

P 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:

P The system(s) available for communicating with Federal response organizations (e.g., ordinary commercial telephone, 

dedicated telephone lines, or radio nets). 

P 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).

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, 
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Radiological Emergency Preparedness Program Manual 52

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:

P The primary and backup communication systems that provide links to the emergency operations facility; and

P 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 to contact a base when operating within the plume EPZ.29 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.

29 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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53 Radiological Emergency Preparedness Program Manual

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:

P Contain a general description of how personnel are activated (i.e., notified of an incident and requested to report to 

their emergency duty station).

P 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, second edition, May 2013.

 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.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:

P Identification of communications links between the ambulance and the designated hospital/medical facilities; and 

P A description of primary and backup communications among the hospital/medical facilities, the jurisdiction’s EOC, 

and the licensee.
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Radiological Emergency Preparedness Program Manual 54

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.

Mobile medical facilities include aid camps, triage stations, and other temporary medical care locations used for response.

REFERENCES

 The Joint Commission: Hospital, Emergency Management Chapter, Standard EM.02.02.05, July 2012.

 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/FEMAREP-1] Evaluation Criteria H.10 and N.2.a, and Appendix 3.)

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

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

P 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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55 Radiological Emergency Preparedness Program Manual

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.30

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:

P 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, new public information brochures/calendars, etc. will be sent to FEMA prior to dissemination for 

a baseline review, and will then be submitted annually thereafter with the ALC or for review during a SAV, exercise, 

separate mailing, etc.

P Provisions for identifying individuals needing assistance with evacuation and how personal information will be 

protected. 

P A description of materials directed to transient populations.

P A description of materials addressing information for the ingestion pathway, if separate from the general public 

information materials.

P A description of each item translated into non-English languages that are spoken within the EPZ as well as information 

accessible to other persons with disabilities and access/functional needs located within the EPZ.31

FEMA HIGHLY RECOMMENDS THAT PLANS/PROCEDURES:

P Include provisions to provide some form of public information for non-English speaking populations 

P That comprise less than 5% or 10,000 persons of the voting age population.

30 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.

31 Refer to Executive Order 13407 (Public Alert and Warning System, June 26, 2006).
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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 day cares.

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.32

 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, 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. 

32 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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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 

day cares (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.33

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 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.

33 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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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. 

 Other emergency protective actions which may involve the interdiction or condemnation of foods, feeds or other 

contaminated products.
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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 total voting age citizens in a single political subdivision (usually a county, 

but a township or municipality in some States) within the EPZ34 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 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; and

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, May 2013.

National Response Framework, Public Affairs Support Annex, May 2013.

Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and Local Government Emergency Plans, Version 2, 

November 2010.

34 See Part IV, Section S. Public Information Guide and Process.
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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:

P 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;

P Methods for distributing ingestion exposure pathway information annually within the 10-mile EPZ, and provisions for 

distribution within the 50-mile EPZ if needed; and

P 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.

REFERENCES

 National Incident Management System, December 2008.

 National Response Framework, Emergency Support Function #15 – External Affairs Annex, May 2013.

 National Response Framework, Public Affairs Support Annex, May 2013.

 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 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:

P Identify the location where the jurisdiction will brief the media, whether at a Joint Information Center (JIC), separate 

facility, or both. 

P 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 ICS, installation of equipment, and rearranging of 

furnishings), for jurisdictions that operate a media facility. 

P 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.

P Describe the organization’s capability to answer media telephone inquiries. 

P 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 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:
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 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, May 2013.

 National Response Framework, Public Affairs Support Annex, May 2013.

 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 

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:

P 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.

P 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. 
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P 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; and

• What physical means (e.g., telephone, fax, or computer network) will be used for communicating information 

between the EOC and the PIO.

P 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 ICS. 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 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 preapproved generic press statements and a procedure requiring that information be approved by a responsible 

official, consistent with ICS, 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). Preapproved 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).
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 National Response Framework, Emergency Support Function #15 – External Affairs Annex, May 2013.

 National Response Framework, Public Affairs Support Annex, May 2013.

 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:

P 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);

P 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:

P Who, by title/position, is responsible for ensuring that the exchange takes place; and

P 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 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 Internetbased 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, May 2013.

 National Response Framework, Public Affairs Support Annex, May 2013.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and Local Government Emergency Plans, Version 2, 

November 2010.
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65 Radiological Emergency Preparedness Program Manual

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:

P 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. 

P 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. 

P 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. 

P 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. 

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 collocated 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.
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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, May 2013.

 National Response Framework, Public Affairs Support Annex, May 2013.

 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 

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

P Provisions for an annual media briefing.

P Distribution of written materials (media kits) covering topics described below. 

P 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. 
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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, May 2013.

 National Response Framework, Public Affairs Support Annex, May 2013.

 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-0696.35

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-0696.36

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: 

P A description of or reference to the location and layout of the EOC;

P A listing of facility equipment necessary to support operations;

P The EOC’s backup power capability, if available;

P Details and methods for access control to the facility;

P Reference to the location of the alternate EOC, if applicable; and

P 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.

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). It 

is expected that the EOC will have provisions for continuous operation in the event of a power failure, which may include 

alternate power sources, alternate locations, the use of a mobile command vehicle, etc. The plans/procedures identify the 

organization and official, by title/position, responsible for maintaining the operational readiness of the EOC. 

35 “Revision 1” was deleted: NUREG-0696 has not been revised as per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 2002.

36 “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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REFERENCES

 National Incident Management System, December 2008. 

 National Response Framework, second edition May 2013.

 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:

P Detailed procedures for activation and staffing of all emergency facilities. 

P Criteria used for declaring facilities operational.

P 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, second edition May 2013.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and Local Government Emergency Plans, 

Version 2, November 2010.

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-REP-1] 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
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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:

P Radiological monitoring equipment, by type and number, that is located or stored near the NPP or that will be brought 

in by the ORO; and

P Fixed radiological monitoring stations near the NPP. 

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.
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71 Radiological Emergency Preparedness Program Manual

NUREG CRITERION H.8

Each licensee shall provide meteorological instrumentation and procedures that satisfy the criteria in [NUREG-0654/FEMAREP-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:

P The organization(s) responsible for maintenance of all radiological equipment; and

P Specifics regarding the inventory, operational checks, and calibration for dosimetry, portal monitors, radiological 

survey equipment, air sampling equipment, and laboratory equipment.

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 
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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. 

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.
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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:

P The number and contents of emergency kits by location and general category; and

P 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:

P The organization(s) responsible for assessing radiological data;

P 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; and

P The coordination and analysis of sample media, including procedures for transporting samples and transferring the 

data from the laboratory to the central point.
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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-073737 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); and

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 

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 

37 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.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: 

P Which organizations have primary responsibility for field monitoring activities; and

P 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 

non-governmental FMTs, such as collection of air samples within the plume and determination of the airborne radioiodine 

concentrations present.

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.
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77 Radiological Emergency Preparedness Program Manual

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:

P The process for activating and notifying field teams;

P The composition of the FMTs (e.g., organizations involved, number of teams [two or more], number of members on 

each team);

P The types and sources of transportation resource(s) for FMTs and estimated deployment times to reach a site from 

various locations, if applicable;

P The location of any staging areas;

P The title/position of the person responsible for directing FMTs to proper locations for monitoring and air sampling;

P The monitoring, sampling, and communications equipment that will be used by FMTs;

P The procedures that will be followed for field monitoring, sample collection, and field sample analysis;

P 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-of-custody records; and

P 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.

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.
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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:

(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. 
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(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 Geiger-Mueller (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 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. 

(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 (mCi/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; and

• Using reproducible geometry when measurements are taken.
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 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 chain-of-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); and

 Methods to prevent cross-contamination. 

(6) Other Information 

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; and

 Ambient radiation exposure rate, which is taken for each sample and recorded on its label. 

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 or other facility for analysis must be completed expeditiously due to decay of short lived radionuclides. If sample 

counting is not performed immediately in the field, which is preferred, samples will be transferred to the laboratory within 

four 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 predesignated 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. 
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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 μCi/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 

TO MEET THE INTENT OF CRITERION I.9, ORO PLANS/PROCEDURES SHALL DESCRIBE:

P The capability to collect air samples within the plume and perform analysis that will detect radioiodine concentrations 

as low as 107

 μCi/cc under field conditions; and

P 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 107 μCi/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.
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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.38 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:

P Personnel and equipment that will be involved in dose assessment;

P Computer software and documentation, including data input procedures, that will be used;

P Alternate methods that may be used (e.g., hand calculations);

P Information/variables to run the model, including proper units of measure;

P Means for obtaining initial information (e.g., from licensee monitors or inventory estimates);

P Use of field data to verify and modify model results; and

P Procedures for comparing dose results with those of other organizations that perform dose assessments.

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.

38 The FDA revised guidance refers to DILs.
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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:

P 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.39 Evacuation time estimates have been developed 

by applicants and licensees and must be updated on a periodic basis.40 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:

P Assistance that will be provided to licensees during an evacuation of the site or a statement that no assistance is 

required;

P The alternatives that will be implemented during inclement weather and/or high traffic densities; and

P 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 non-essential onsite personnel. These procedures take into 

account conditions such as inclement weather, high 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.

39 Sentence added per NUREG-0654/FEMA-REP-1, Revision 1, Addenda, March 2002.

40 Sentence added per NRC rule revision, 2011.
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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.

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 (EPA-400-R-92-001).41 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 

41 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.
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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)42 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 4340243).

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

TO MEET THE INTENT OF CRITERION J.9, ORO PLANS/PROCEDURES SHALL INCLUDE:

P The organization’s procedures for making PADs and implementing protective actions based upon PAGs that are 

consistent with EPA recommendations; and

P 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 and contain predetermined PADs to protect the public in 

these situations.44 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 

42 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.

43 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.

44 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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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 decisionmakers, 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 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.
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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:

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 J1 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:

P Include clearly legible maps of all evacuation routes, evacuation areas, preselected radiological sampling and 

monitoring points (including water supplies), reception and congregate care centers in host/support jurisdictions, 

decontamination facilities, and shelter areas; and

P 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; 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.
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NUREG CRITERION J.10.b

Maps showing population distribution around the nuclear facility. This shall be by evacuation areas45 (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:

P Clear, legible maps showing population distribution around the NPP, possibly in a separate appendix.

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 day cares 

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:

P 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.

45 The term “evacuation areas” used in this criterion corresponds to the term “planning areas” used throughout this document.
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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:

P 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 day cares and persons in nursing homes, hospitals, and correctional 

facilities).

P Describe the methods for determining the number of persons who may need assistance and the type of assistance, per 

planning area.

P Reference lists of documented individuals who need assistance in an evacuation of the EPZ and processes for keeping 

the lists up to date.

P Describe processes for evacuating persons with disabilities and access/functional needs and for sheltering in place those 

who cannot be moved.

P 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, preschools, and licensed day cares) 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. 

The licensing of day cares 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 day care facilities are 

exempt from licensing requirements (e.g., if the day care 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. 

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; and
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 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); and

• Methods (e.g., EAS messages or special news broadcasts) for notifying parents and guardians of the status and 

location of their children.

b. 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.

The plans/procedures should have some form of communication protocol in place so that the evacuation of all types of 

healthcare facilities can avoid traversing the plume. However, if traversing the plume is unable to be avoided, then the 

transport should go to a reception center for monitoring and, if necessary, decontamination prior to transporting patients 

to the receiving facility or the receiving facility should have plans in place to monitor and, if necessary, decontaminate the 

patients it receives. 

The Joint Commission requires hospitals to have plans to provide for radioactive isolation and decontamination. 

Additionally, Occupational Safety Health Act (OSHA) published “Best Practices for Hospital-Based First Receivers of Victims 

from Mass-Casualty Incidents”, which outlines industry-recognized best practices for monitoring and decontamination 

for hazards including radioactive contamination. Since these other agencies place requirements on hospitals to prepare for 

contaminated patients, the REP Program has no need to evaluate these facilities, nor does the ORO have the responsibility to 

provide training or dosimetry.

c. 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. 
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d. 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

 The Joint Commission: Hospital, Emergency Management Chapter, Standard EM.02.02.05, July 2012.

 Occupational Safety Health Act (OSHA), “Best Practices for Hospital-Based First Receivers of Victims from Mass-Casualty 

Incidents”, January 2005.

 National Response Framework, Mass Evacuation Incident 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.

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;46

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

TO MEET THE INTENT OF J.10.e, ORO PLANS/PROCEDURES SHALL DESCRIBE:

P What groups might be advised to take KI;

P Adequate supply of radioprotective drugs for each individual, including quantities, storage locations, and means of 

distribution;

P Adequate maintenance, shelf life extensions, and timely replacement of radioprotective drugs; and

P 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,47 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 

46 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).

47 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.
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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.48 Those 

organizations that have chosen to acquire KI for use by the general public must incorporate distribution procedures into the 

plans/procedures within 1 year of receiving the 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.

 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 predetermined 

conditions under which such drugs may be used by offsite emergency workers;49

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

TO MEET THE INTENT OF CRITERION J.10.f, ORO PLANS/PROCEDURES SHALL:

P Identify, by title/position, those who will make decisions regarding the use of KI during an emergency.

P 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.

48 Manufacturer’s patient information is available on the “Drugs@FDA” Approved Drug Products database website at http://www.accessdata.fda.gov/scripts/cder/

drugsatfda/.

49 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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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 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;50

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:

P Means for controlling traffic to assure a safe and efficient evacuation;

P Procedures for implementing alternate evacuation routes, if warranted;

P Transportation resources, including drivers;

P The methods for determining the number of persons without private transportation, per planning area; and

P 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 

50 In current terminology, this refers to “evacuation.” Relocation is a non-urgent action during the post-emergency phase.
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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. 

REFERENCES

 National Incident Management System, December 2008.

 National Response Framework, Mass Evacuation 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 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:

P All relocation centers and host schools for evacuees and students by name and address;

P Organizations responsible for managing the centers and staffing requirements for each center;

P Arrangements for handling students at relocation centers and/or host schools;

P Arrangements for handling service animals;

P Hospitals, correctional facilities, and nursing homes that will receive evacuees;

P 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.); and

P 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 should plan for a sufficient number of congregate care centers in host/support jurisdictions based on their all-hazard 

sheltering experience and what is historically relevant for that particular area. 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. 

FEMA developed Guidance for Planning for Integration of Functional Needs 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 a general population shelter Standard Operating Procedure (SOP) to ensure that all shelter 

residents benefit equally from programs, services, and activities. The REP Program will not be evaluating FNSS compliance.

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: 

P Reference the evacuation time estimate (ETE) studies and include the results of the ETEs. 

P Reference the traffic capacities of the evacuation routes. 

P 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. 

P 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.
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REFERENCES

 NUREG/CR7002, Criteria for Development of Evacuation Time Estimate Studies.

 National Incident Management System, December 2008.

 National Response Framework, Mass Evacuation 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 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:

P Procedures for controlling road access to sheltered and/or evacuated areas, including organization(s) responsible for 

staffing TCPs and Access Control Points (ACPs);

P Maps identifying TCPs/ACPs (may be incorporated by reference);

P Equipment and resources needed (e.g., cones or barricades);

P Procedures and responsibilities for controlling access via other transportation modes;

P Procedures and responsibilities for controlling ingress and egress to other areas affected by an incident; and

P 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 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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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:

P Resources available (e.g., personnel and equipment) to clear impediments to evacuation and emergency response in 

areas affected by incidents; and

P Responsibility for directing resources and rerouting traffic, as needed.

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:

P Time estimates for evacuation of various sectors or evacuation areas; and

P 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.
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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.51

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

TO MEET THE INTENT OF CRITERION J.10.m, ORO PLANS/PROCEDURES SHALL DESCRIBE:

P The rationales for any preplanned precautionary actions, including the triggering events that would lead to the decision 

to implement these actions;

P The rationales used to make initial PADs; and

P 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.52 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 result 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.

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

52 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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 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).

 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 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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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 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.53

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

TO MEET THE INTENT OF CRITERION J.11, ORO PLANS/PROCEDURES SHALL DESCRIBE: 

P The individual(s), by title/position, and organization with the authority to make decisions in the ingestion pathway 

planning zone.

P The ingestion protective actions planned and the rationale for the selection of actions, also see Criteria J.9. and J.10.m.

P The methodology used to designate the areas of concern where monitoring and sampling will be implemented.

P 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.

P The analytical laboratory capability to analyze various samples and the procedure for reporting analytical results to the 

appropriate organization.

P The location and means of obtaining up-to-date information on licensed agribusiness facilities within the EPZ. This 

information includes dairies, food processing plants, surface water supplies, water intakes, farmers markets, farm 

stands, nurseries, 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. 

P 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.

P The DILs that would warrant implementation of protective actions and the rationale and assumptions used to develop 

the DILs.

P 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.

P 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.

53 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.
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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.54 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 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. Precautionary actions 

related to the embargo of unlicensed agricultural products may be addressed in public messages and other informational 

brochures.

OROs should include methods to track food leaving and limit food entering the EPZ in appropriate plans and procedures.

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.

54 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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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. 

 Condemnation of foodstuff. The foodstuff would not be allowed into commerce and would be disposed of in 

accordance with State and/or Federal regulations. 

 Methods to track food leaving and limit food entering the EPZ by appropriate jurisdictions.

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; and

 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). 
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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. 

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 12hour 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:

P 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.

P Decontamination procedures, including the trigger/action levels that indicate the need for decontamination activities 

and procedures for medical attention referral.

P Contamination control measures, such as safety requirements, decontamination site layout, and decontamination protocol.

P 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.

P 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-to-date 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. 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 
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the time it takes to monitor an 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. Regardless of manufacturer claims, there are 

challenges to using portal monitors on vehicles. However, portal monitors may be used on portions of vehicles if the user 

can demonstrate the sensitivity of the instrument to the standards described in FEMA REP-22. If the 0.0085 μCi/cm2 can 

be detected on certain portions of the vehicle, a portal monitor may be used in tandem with a hand-held monitor. It is 

the responsibility of the user to demonstrate the detection sensitivity of the portal monitor in the scanned zone using the 

planned monitoring technique. Some areas of the vehicle, such as the grill and roof, may still need to be monitored by 

hand. The interior of a vehicle will still need to be monitored by hand. 

The plans/procedures indicate the triggers/action levels requiring decontamination.55 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 highefficiency 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.

55 “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 or their 

vehicle has been placed in a secure area until it can be monitored and decontaminated, if necessary. 

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) or placed in a secure area and do require confirmation that their 

vehicle is free from contamination or is being placed in a secure area 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.56

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 Incident Annex, June 2008.

 Pub.L. 109-295, October 4, 2006.

56 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 520/175/00157) 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 

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-reading58 and permanent record devices.

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

57 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.

58 Self-reading dosimeters are now referred to as “direct-reading” dosimeters.
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TO MEET THE INTENT OF CRITERION K.3.a, ORO PLANS/PROCEDURES SHALL DESCRIBE:

P Methods or options for emergency worker exposure control, to include exposure from inhalation;

P Dose limits for emergency workers;

P Types and quantities of dosimeters and dosimeter chargers available per location and the number of emergency 

workers needing dosimetry devices;

P 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); 

P Specific dosimetry instructions, including when, where, and to whom individuals return their dosimetry devices;

P Dosimetry storage locations;

P Distribution of dosimetry to all emergency workers and, when permitted, members of the public needing access to the 

restricted area; and

P 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; backup 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 may be considered “emergency workers.”

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 (PRD) 

and direct-reading (DRD).





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 N13.11-2009, 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 
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interference depends on the amount of shielding in the dosimeter design and the frequency range. The electronic 

dosimeters should be 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. If the manufacturer 

states there is no radio frequency interference, this may be considered in lieu of test.

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 radioiodine 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 EPA400-R-92-001 guidance is to use a factor of 5 for this 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 1 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.

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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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 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. 
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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. 

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 
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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 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 N13.11-2009, 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:

P The method for obtaining dose information from emergency workers;

P The timeframes for reading dosimeters (e.g., every 15 or 30 minutes);

P The methods for recording doses (e.g., the form used); and

P 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 
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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 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:

P Dose limits (TEDE) for missions, accounting for dose from inhalation;

P Actions taken when exposure limits have been reached;

P Any special conditions requiring additional limitations (e.g., pregnant emergency workers);

P Authorization to exceed pre-authorized exposure limits and management of emergency workers’ exposure above the 

limits;

P 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;

P Information on risk and threshold doses for health effects to be provided to emergency workers volunteering for 

higher dose exposure; and

P 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 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 
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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 an once-in-a-lifetime exposure and is not added to occupational radiation exposure accumulated 

under non-emergency conditions. 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.

 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 

TO MEET THE INTENT OF CRITERION K.5.a, ORO PLANS/PROCEDURES SHALL DESCRIBE:

P Facilities for monitoring and decontaminating emergency workers, equipment, and vehicles, along with operating and 

implementing procedures;

P Locations of monitoring and decontamination facilities (preferably located outside the plume EPZ);

P Methods for controlling the spread of contamination at the emergency worker monitoring facilities;

P Radioactive contamination levels that will trigger decontamination of emergency workers, equipment, and vehicles, 

expressed in applicable units (e.g., cpm, mR/hr);

P Survey instruments (i.e., specific appropriate equipment and sensitivity, including radiation type) used to monitor 

emergency workers, equipment, and vehicles; and

P Procedures for monitoring individuals and equipment. 
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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-REP-21.

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.59

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.

Regardless of manufacturer claims, there are challenges to using portal monitors on vehicles. However, portal monitors may 

be used on portions of vehicles if the user can demonstrate the sensitivity of the instrument to the standards described in 

FEMA REP-22. If the 0.0085 μCi/cm2 can be detected on certain portions of the vehicle, a portal monitor may be used in 

tandem with a hand-held monitor. It is the responsibility of the user to demonstrate the detection sensitivity of the portal 

monitor in the scanned zone using the planned monitoring technique. Some areas of the vehicle, such as the grill and roof, 

may still need to be monitored by hand. The interior of a vehicle will still need to be monitored by hand. 

59 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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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:

P Supplies and equipment for decontamination; 

P Decontaminating people, equipment, and vehicles;

P Re-monitoring people, equipment, and vehicles and recording the results; 

P Criteria for sending individuals with fixed contamination for medical attention; 

P Controlling the spread of contamination;

P Number of people needed to perform decontamination in the event of an emergency; and

P Contaminated waste collection, handling, and storage. 

EXPLANATION

Facilities for decontaminating emergency workers and their equipment may be either collocated 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 
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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.

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.
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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 EPA-400-R-92-001.60

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 

60 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.61

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:

P Reference written agreements or LOAs with hospitals/medical facilities.

P Reference written agreements or LOAs for technical staff that are not employed by the hospital/medical facility.

P Include individual facility capabilities, including the number of radiologically trained medical personnel and support staff.

P Describe hospital/medical facility and support service operations for treating contaminated, injured, or exposed 

individuals.

P 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 (this does not include normal EMS providers) are 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 

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.

61 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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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.62 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; and

 An example of the system used to record patient data.

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.

62 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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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

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: 

P 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 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.
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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:

P The method for determining an appropriate hospital/medical facility and the person, by title/position, responsible for 

the determination;

P Means of transporting individuals, including how to request additional emergency medical services; 

P Communications between the transport crew and hospital/medical facility staff;

P Specifics of radiological monitoring;

P Contamination control measures during transport;

P Decontamination techniques, including trigger/action levels;

P Dosimetry for the transport crew; and

P 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 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 evac, or critical 
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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, and 

responsiveness to an identified check source, 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 Post-Accident 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:

P Continuing environmental radiation measurements and dose assessments;

P Establishing restricted and buffer zones;

P Relocation;

P Controlled reentry into restricted areas;

P Return of the public to previously evacuated areas; and

P 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 PAGs63 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.

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 

63 See Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA 400-R-92-001 (May 1992).
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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.

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, NUREG-0696 (February 1981) and Clarification of TMI Action Plan Requirements, Requirements for 

Emergency Response Capability, NUREG-0737, Supplement 1 (January 1983),64 is an acceptable framework.

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

64 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.
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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 65 

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

P 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; and

P 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, second edition, May 2013.

 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 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: 

P 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 perform the dose assessment process in coordination 

with State agencies.

65 FEMA recognizes that, in some instances, this criterion applies to local response organizations.
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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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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.66

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:

P REP exercises will be conducted in accordance with NRC and FEMA rules and policy.

EXPLANATION

Once plans/procedures have been developed and staff is 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 Planning Workshop (TEPW) and Multi-year Training 

and Exercise Plan (TEP);

 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

 Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

 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.

66 This criterion amended per NUREG-0654/FEMA-REP-1, Supplement 4, (2011).
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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 8-year exercise cycle. Each 

scenario variation shall be demonstrated at least once during the 8-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 8-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 § 350.9.67

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:

P All major elements of the plans/procedures will be tested at minimum at the frequency specified by the REP Program 

Manual, Exhibit III-2; and 

P Scenarios for exercises will be varied from exercise to exercise and include all required scenario variations during the 

exercise cycle.

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.

67 This criterion amended per NUREG-0654/FEMA-REP-1, Supplement 4, (2011).
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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.

This exercise cycle is based on the date of the first joint 

Hostile Action Based scenario exercise conducted after 

December 23, 2011 (the effective date of this manual).

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). States are still required to fully 

participate in at least one of each scenario within the 8-year 

cycle. 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.

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.

In accordance with HSEEP, a true full-scale exercise

is a multi-agency, multi-jurisdictional, multidiscipline exercise involving functional (e.g., joint 

field office, emergency operations centers, etc.) and 

“boots on the ground” response (e.g., firefighters 

decontaminating mock victims). For the purposes 

of the REP Program, a full-scale exercise meets the 

intent of the full-participation exercise. 

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 full-participation exercise. 

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 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.
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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 years68 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 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 (within 30 minutes) 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 

68 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.

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. This concept is further 

discussed in Section IV: Program Administration, 

G. Demonstration Considerations for No/Minimal 

Release Scenarios.
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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).

REFERENCES

 National Incident Management System, December 2008.

 Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

 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 8-year exercise 

cycle. Some drills or exercises should be unannounced.69

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.70

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

69 This criterion added per NUREG-0654/FEMA-REP-1, Supplement 4, (2011).

70 This criterion added per NUREG-0654/FEMA-REP-1, Supplement 4, (2011).
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133 Radiological Emergency Preparedness Program Manual

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

P The State and other OROs (as appropriate) will participate in an ingestion pathway exercise at least once every 8 years.

P 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).

P 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.

P 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.

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.71 The level of participation may vary. 

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 pathway-related 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

71 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/FEMAREP-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 biennial72 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:

P ORO communications systems are tested monthly.

P Communications with the Federal response organizations and States within the ingestion pathway are tested quarterly.

P Communications with the NPP, ORO EOCs, and field assessment teams are tested annually.

P 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. The 

term “content check” means that a message should be read by the initiator and is either repeated back or is otherwise 

verified as accurately received (i.e., fax, etc.).

The only communication drills with Federal agencies that needs to be performed is with FEMA. Any issues that OROs are 

having with federal communication drills should be brought to the attention of the FEMA Regional Administrator.

REFERENCES

 National Incident Management System, December 2008.

 Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and Local Government Emergency Plans, 

Version 2, November 2010.

72 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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135 Radiological Emergency Preparedness Program Manual

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 biennial73

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:

P 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. 

 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. 

73 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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 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.

 Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

 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: 

P 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.

 Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and Local Government Emergency Plans, 

Version 2, November 2010.
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137 Radiological Emergency Preparedness Program Manual

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:

P 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.

 Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

 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;

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 
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Radiological Emergency Preparedness Program Manual 138

TO MEET THE INTENT OF CRITERION N.3, ORO PLANS/PROCEDURES SHALL INDICATE THAT:

P 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.

 Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

 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.74

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: 

P 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.

REFERENCES

 FEMA GM-8, Revision 1, RAC Coordination With Utilities, October 3, 1983.

 National Incident Management System, December 2008.

 Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

 Comprehensive Preparedness Guide 101: Developing and Maintaining State, Territorial, Tribal, and Local Government Emergency Plans, 

Version 2, November 2010.

74 This criterion amended per NUREG-0654/FEMA-REP-1, Supplement 4, (2011).
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139 Radiological Emergency Preparedness Program Manual

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: 

P 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.

 Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

 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

Radiological Emergency Preparedness Program Manual 140

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:

P Identify organizations responsible for coordinating radiological training.

P Identify organizations that will ensure radiological emergency response training will be included as part of fire, police, 

and ambulance/rescue training, if appropriate.

P Describe provisions to ensure availability of just-in-time training on basic radiation protection for all emergency 

workers, as needed.

P 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, ICS, 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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141 Radiological Emergency Preparedness Program Manual

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:

P 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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Radiological Emergency Preparedness Program Manual 142

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: 

P Training programs specific to directors/coordinators;

P Scope of the training programs;

P Time intervals at which these training programs will be offered; and

P 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 75 

TO MEET THE INTENT OF CRITERION O.4.b, ORO PLANS/PROCEDURES SHALL DISCUSS: 

P Training programs specific to accident assessment personnel;

P Scope of the training programs;

P Time intervals at which these training programs will be offered; and

P 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.

75 NRC and FEMA encourage OROs that have these capabilities to continue to include them in their training programs.
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143 Radiological Emergency Preparedness Program Manual

NUREG CRITERION O.4.c

Radiological monitoring teams and radiological analysis personnel;

Applicability and Cross-Reference to Plans: Licensee X State X Local 76 

TO MEET THE INTENT OF CRITERION O.4.c, ORO PLANS/PROCEDURES SHALL DISCUSS: 

P Training programs specific to radiological monitoring teams and radiological analysis personnel;

P Scope of the training programs;

P Time intervals at which these training programs will be offered; and

P 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 77 Local X 

TO MEET THE INTENT OF CRITERION O.4.d, ORO PLANS/PROCEDURES SHALL DISCUSS: 

P Training programs specific to police, security, and firefighting personnel;

P Scope of the training programs;

P Time intervals at which these training programs will be offered; and

P 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.

76 NRC and FEMA encourage State and local governments that have these capabilities to continue to include them in their training programs.

77 NRC and FEMA encourage State and local governments that have these capabilities to continue to include them in their training programs.
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Radiological Emergency Preparedness Program Manual 144

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 78 Local X 

TO MEET THE INTENT OF CRITERION O.4.f, ORO PLANS/PROCEDURES SHALL DISCUSS: 

P Training programs specific to first aid and rescue personnel;

P Scope of the training programs;

P Time intervals at which these training programs will be offered; and

P 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;79

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: 

P Training programs specific to support services personnel;

P Scope of the training programs;

P Time intervals at which these training programs will be offered; and

P Organizations (e.g., licensee, FEMA) that will provide training assistance, if applicable.

EXPLANATION

The plans/procedures discuss training programs specific to support services personnel.

78 NRC and FEMA encourage State and local governments that have these capabilities to continue to include them in their training programs.

79 Civil defense/emergency service personnel are also referred to as emergency management personnel.
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145 Radiological Emergency Preparedness Program Manual

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: 

P Training programs specific to medical support personnel, including specific training for hospital/medical facility staff 

and transportation providers;

P Scope of the training programs;

P Time intervals at which these training programs will be offered; and

P 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: 

P Training programs specific to personnel responsible for transmission of emergency information and instructions;

P Scope of the training programs;

P Time intervals at which these training programs will be offered; and

P Organizations (e.g., licensee, FEMA) that will provide training assistance, if applicable.
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Radiological Emergency Preparedness Program Manual 146

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:

P State which organizations will provide initial training as well as retraining.

FEMA HIGHLY RECOMMENDS THAT PLANS/PROCEDURES INCLUDE: 

P A training matrix that lists all available courses and provides general descriptions of those courses; and

P 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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147 Radiological Emergency Preparedness Program Manual

16. P lanning 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: 

P 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. 

P 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: 

P 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. 

 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

Radiological Emergency Preparedness Program Manual 148

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: 

P 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:

P 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.); 

P A process for correcting plan issues identified in drills and exercises;

P A process for periodic update of maps; and

P A process for periodic updating of ingestion pathway information (e.g., a list of food processing facilities, etc.) (See also 

Criterion J.11.).

EXPLANATION

States are required to submit an ALC80 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. 

80 See Part IV, Annual Letter of Certification.
Part II: REP Program Planning Guidance

149 Radiological Emergency Preparedness Program Manual

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. 

 Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

 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:

P List the organizations and individuals who are given the updated plans/procedures.

P Identify individual(s), by title/position, responsible for distributing plan/procedure updates and what the update cycle is.

P 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. 

 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: 

P A list of supporting radiological emergency plans/procedures. 
Part II: REP Program Planning Guidance

Radiological Emergency Preparedness Program Manual 150

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:

P 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 cross-reference 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.

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:

P A specific table of contents; and

P 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 
Part II: REP Program Planning Guidance

151 Radiological Emergency Preparedness Program Manual

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 5 years.

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

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: 

P 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.
Part III: REP Program Demonstration Guidance

Radiological Emergency Preparedness Program Manual 152

Part III: REP Program 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 

NUREG-0654/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.).

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 for assessment 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. Integration with HSEEP concepts does 

not establish additional exercise requirements for the REP 

Program or replace existing REP Demonstration Criteria.

National Exercise Program (NEP): The DHS NEP uses HSEEP 

exercises to test, assess and improve the nation’s preparedness 

and resiliency. Like National Exercise Program exercises, 

REP exercises verify the ability of OROs to implement 

various aspects of their response plans and demonstrate their 

preparedness. However, in the REP Program, the regulations 

in 44 CFR Part 350 dictate certain capabilities the OROs 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 of the OROs 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 

provide evaluation parameters much like the use of core 

capabilities within an HSEEP exercise. FEMA has identified 

the core capabilities that correlate to the REP Demonstration 

Criteria (see Part IV, Section H. Integration of REP 

Demonstration Criteria and Core Capabilities) so that HSEEP 

exercise documents may be utilized during REP exercises.
Part III: REP Program Demonstration Guidance

153 Radiological Emergency Preparedness Program Manual

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 TEPW and 

multi-year TEP;

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 Exhibit IV-3: Demonstration Criteria-Core 

Capability Crosswalk) relating the REP Demonstration 

Criteria to the core 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

Documenting REP Exercises

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 those that could significantly 

impact the exercise if missed.
Part III: REP Program Demonstration Guidance

Radiological Emergency Preparedness Program Manual 154

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 date81 State, FEMA

200 Identify Exercise Planning Team members State, Utility, FEMA

*180* Conduct Initial Planning Meeting (IPM) to include Concepts and Objectives (C&O) 

Meeting as necessary State, Utility, 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 FRMAC82 State, Utility

90

Conduct Midterm Planning Meeting (MPM). MPM participants 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, Utility, 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 Meeting (FPM) State, Utility, 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

81 For changes to an exercise date due to extenuating circumstances, notice is given to the FEMA Region as soon as possible.

82 120 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: REP Program Demonstration Guidance

155 Radiological Emergency Preparedness Program Manual

Calendar Days 

Before/After 

Exercise

Milestone

Lead/

Responsible 

Organization

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

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 Meeting (AAM) 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; and

Establishing a TEP.

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.
Part III: REP Program Demonstration Guidance

Radiological Emergency Preparedness Program Manual 156

(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 

manner in one of the following types of exercises: 

 Full-Scale Exercises engage all ORO entities in realtime hands-on response activities including all of 

those specified in the Demonstration Criteria extentof-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.

 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 fullparticipation 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. Full participation exercises must occur 

at least biennially.

(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 can 

observe training, seminars and practical demonstrations 

used to assess proficiency, wherever possible. 

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.

(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 TEP. 
Part III: REP Program Demonstration Guidance

157 Radiological Emergency Preparedness Program Manual

(5) Staff Assistance Visits (SAVs)

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 

participation 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 decision-making 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 (within 30 minutes) 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 NUREG-0654/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: REP Program Demonstration Guidance

Radiological Emergency Preparedness Program Manual 158

Exhibit III-2: Federal Evaluation Process Matrix83

Assessment Area and Sub-elements

NUREG-0654/

FEMA-REP-1 

Criteria

Minimum 

Evaluation 

Frequency84

Out-ofSequence 

Evaluation

Actual 

Incident 

Credit

SAV

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.

G.3.a; H.3; J.10.h, 

J.12; K.5.b

No less than once 

every 8 years85 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 YES86 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.3.a; 

K.4 At least biennially NO NO NO

83 See Demonstration Criteria for specific requirements.

84 See NUREG-0654/FEMA-REP-1 Criteria N.1.b and N.1.d for additional details.

85 Facilities evaluated once when they are new and once every 8 years thereafter. Facilities are reevaluated 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.

86 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.
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159 Radiological Emergency Preparedness Program Manual

Assessment Area and Sub-elements

NUREG-0654/

FEMA-REP-1 

Criteria

Minimum 

Evaluation 

Frequency84

Out-ofSequence 

Evaluation

Actual 

Incident 

Credit

SAV

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 Decision-making for the Ingestion Exposure Pathway87

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

87 The post-plume phase (ingestion, relocation, reentry, and return) may be demonstrated separately from the plume phase.
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Radiological Emergency Preparedness Program Manual 160

Assessment Area and Sub-elements

NUREG-0654/

FEMA-REP-1 

Criteria

Minimum 

Evaluation 

Frequency84

Out-ofSequence 

Evaluation

Actual 

Incident 

Credit

SAV

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 biennially88 YES NO NO

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 years89 YES YES YES

d. Implementation of Traffic and Access Control90

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 least biennially 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, 

relocation, and return of individuals during the 

post-plume 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

88 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.

89 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.

90 Physical deployment of resources is not necessary except in a full-scale exercise.
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161 Radiological Emergency Preparedness Program Manual

Assessment Area and Sub-elements

NUREG-0654/

FEMA-REP-1 

Criteria

Minimum 

Evaluation 

Frequency84

Out-ofSequence 

Evaluation

Actual 

Incident 

Credit

SAV

4. FIELD MEASUREMENTS AND ANALYSES

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 

exercise91

YES NO NO

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 decisionmaking. 

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

91 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.
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Radiological Emergency Preparedness Program Manual 162

Assessment Area and Sub-elements

NUREG-0654/

FEMA-REP-1 

Criteria

Minimum 

Evaluation 

Frequency84

Out-ofSequence 

Evaluation

Actual 

Incident 

Credit

SAV

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 years92 YES YES NO

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 years93 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 biennially YES YES NO

92 Participation may be rotated among facilities, but each facility must be evaluated no less than once every 8 years.

93 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.
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163 Radiological Emergency Preparedness Program Manual

c. The Training and Exercise Planning Workshop 

OROs typically develop and review the TEP each year at an 

annual TEPW. REP schedules can align with other HSEEP 

activities through participation in TEPWs, as appropriate. At 

these meetings, OROs review the REP training and exercise 

schedules in the TEP 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 TEPW. 

Before attending the TEPW, OROs and the FEMA Region 

determine: (1) what type(s) of exercise they will schedule; 

and (2) what time period the scheduling will cover. 

Maximizing the TEPW

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.

Activities considered at the TEPW 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 overall goal is to include REP trainings and exercises in 

the local TEPs, as appropriate. Ultimately, the RAC Chairs 

are responsible for ensuring the entry of REP exercises into 

the National Exercise Schedule (NEXS).

2. Conducting Preplanning Activities

a. Establish an Exercise Planning Team

The REP exercise design and development process will 

include establishing an exercise planning team led by 

the State(s) (or designee), with representatives from the 

licensee, OROs, and FEMA REP staff. This exercise planning 

team will hold one or more planning meetings as needed to 

determine exercise scope, design, scenario, and logistics. 

Because exercise planning team members have access to 

scenario-related information, ORO representatives on the 

exercise planning team serve as confidential representatives/

trusted agents (CRs/TAs). They may participate substantially 

in the exercise design but must 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; 

and

 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 
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Radiological Emergency Preparedness Program Manual 164

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; and

 Variations (e.g., varied release conditions, nonsequential ECLs, and incorporation of HAB incidents) 

to reduce exercise predictability and associated negative 

training practices.

Prior to initiating development of a scenario, the exercise 

planning team 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 no later than 30 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. 

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 

Meeting (IPM) 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 NUREG-0654/FEMAREP-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; 
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165 Radiological Emergency Preparedness Program Manual

 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 (within 

30 minutes) 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 exercise planning team 

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. 

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 decision-making. 

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); and

 Seasonal factors impacting the PARs and decision 

process (e.g., transient populations, weather conditions, 

agricultural seasons).
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Radiological Emergency Preparedness Program Manual 166

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. 

For biennial exercises, planners review the 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 IPM 

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-of-sequence 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 outof-sequence 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; and

 MSEL.

Although document development occurs as part of the 

Planning Meetings described in the next section, they are 

explained first here for clarity. Specific information relevant 

to the content and development of the exercise documents 

can be found in Homeland Security Exercise and Evaluation Program 

(HSEEP), April 2013.

a. Exercise Plan

The exercise planning team typically distributes the 

ExPlan to Players and Observers, but should also give it 

to Controllers and Evaluators. The exercise planning team 

brings all information needed to complete the ExPlan to the 

IPM. The exercise planning team develops the draft ExPlan 

prior to the MPM, and creates the Final ExPlan prior to or at 

the FPM.

b. Controller/Evaluator Handbook

Exercise planning team 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 exercise planning team only 

creates C/E Handbooks when it determines a need for them. 

The exercise planning team 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 exercise 

planning team 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).
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167 Radiological Emergency Preparedness Program Manual

c. Exercise Evaluation Guides

FEMA recommends that REP exercise planners develop REPspecific, core capability-based EEGs. The core capabilitybased Master EEGs maintain the integrity of the REP 

exercise criteria while providing useful information that 

helps jurisdictions test and build their core capabilities.

The FEMA Region decides the degree of exercise planning 

team and ORO involvement in tailoring the Master EEGs 

into exercise-specific EEGs. A successful evaluation does not 

require direct ORO involvement in the EEG development 

process. 

FEMA recommends providing all information needed to 

complete the EEGs at the IPM. The exercise planning team 

develops the Draft EEGs prior to the MPM, with the Final 

EEGs being created prior to or at the FPM.

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 Meeting 

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 all-hazards exercise) 

may warrant an MSEL Meeting. 

MSEL Meetings, when used, should include a representative 

from the licensee to ensure that changes in offsite event 

timing do not conflict with the onsite scenario that drives 

licensee actions. Exercise planners must ensure that MSEL 

injects are either timed to be consistent with the onsite 

scenario events or the exercise planning team must conduct 

a MSEL Meeting 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 preplanning activities. 

a. Concepts and Objectives Meeting

A Concepts and Objectives (C&O) Meeting is held to 

identify the type and scope of the exercise, as well as the 

specific Demonstration Criteria that will be evaluated. 

The C&O meeting can be combined with the IPM as 

appropriate. 

b. Initial Planning Meeting

The IPM lays the foundation for exercise development and 

generally occurs at least 6 months before the exercise to 

address:

 REP Demonstration Criteria to be evaluated, including 

location and by whom; 

 Core capabilities;

 Scenario type and variables;

 Out-of-sequence demonstrations and potential exercise 

schedule;

 Roles and responsibilities for exercise document 

preparation; and

 Schedule for upcoming planning meetings.

The FEMA Region identifies any Demonstration Criteria 

that need to be evaluated based on Exhibit III-2 as well 

as any outstanding, uncorrected ARCAs and brings this 

list to the IPM for concurrence and finalization with the 

appropriate OROs.

Following the IPM, and leading up to the MPM, the exercise 

planning team develops the following:

 Final list of Demonstration Criteria/Core Capabilities to 

be evaluated;

 Initial draft Extent-of-Play Agreement;

 Draft ExPlan;

 Draft EEGs; and

 Initial draft of offsite scenario and MSEL.

c. Midterm Planning Meeting

The MPMs generally occur 3 months before the exercise. 

Items to address and accomplish include: 

 Negotiate and finalize the ORO Extent-of-Play 

Agreement.
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Radiological Emergency Preparedness Program Manual 168

 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 

FPM).

 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 exercise planning teams may decide to hold more 

than one meeting to prepare all the items typically covered 

in the MPM, especially if there is a large volume of 

information to review. In any event, the exercise planning 

team finishes drafting and fully reviews the following 

documents before the FPM: 

 C/E Handbook, if needed;

 ExPlan;

 EEGs;

 Scenario (limited to Trusted Agents only); and

 MSEL, if needed (limited to Trusted Agents only).

d. Final Planning Meeting

The purpose of a FPM is to undertake a comprehensive 

review of all finalized exercise documents and identify and 

resolve any outstanding items. Generally speaking, the FPM 

should occur no later than 30 days before the exercise. 

During the FPM, the exercise planning team:

 Reviews all exercise processes and procedures;

 Approves all exercise documents;

 Finalizes exercise logistics;

 Finalizes controller and evaluator assignments;

 Resolves outstanding items or schedules their 

resolution; and

 Determines information to present at the exercise 

briefings.

Following the FPM, the exercise planning team: 

 Compiles Controller Packets (State/OROs);

 Compiles Evaluator Packets (FEMA); and

 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; and

 Post-Exercise Briefings.

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 on-the-job training with a 

FEMA-accepted evaluator. 

b. Pre-Exercise Meetings/Briefings

Prior to the exercise, the exercise planning team 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/core 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. 
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169 Radiological Emergency Preparedness Program Manual

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 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. 
Part III: REP Program Demonstration Guidance

Radiological Emergency Preparedness Program Manual 170

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 post-exercise 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.

(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 re-demonstration. 

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 retrain the staff that performed the criterion activity 

incorrectly. Upon completion of the training, those staff 

will redemonstrate 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 2 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. 
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171 Radiological Emergency Preparedness Program Manual

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.

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 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

|

Plant Site

Identifier

94

|

Exercise

Year

1.b.1

|

Demonstration

Criterion

A

|

Classification: 

Deficiency (D)

ARCA (A)

Plan (P)

01

|

Issue

Number
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Radiological Emergency Preparedness Program Manual 172

(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 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 2 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; 
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173 Radiological Emergency Preparedness Program Manual

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 post-exercise 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 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 reaffirming 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.
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Radiological Emergency Preparedness Program Manual 174

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; and

• NRC Region IV

RIV_FEMADistribution@nrc.gov.

 Hard or electronic copy:

• State(s) Agency/Organization with primary 

responsibility for REP program activity and

• Appropriate RAC members.

An electronic copy of the cover letter of the report will 

be sent to the REPP HQ Branch Chief and their Regional 

Liaison Officer (RLO) within 90 calendar days of the 

exercise. This will be indication for the RLO to go into the 

EET, retrieve the finalized AAR, and save it to Headquarters 

shared drive.

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 AAM, 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 Meeting

The FEMA RAC Chair (or designee) holds an AAM to 

present, discuss, and refine the draft AAR and to develop an 

IP. The FEMA RAC Chair (or designee) should hold the AAM 

as soon as practical after the exercise so that participants 

can easily recall the events. The AAM 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 AAM occurs 2 weeks 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.
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175 Radiological Emergency Preparedness Program Manual

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. 

(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 1 year or during the 

next annual plan review and update. The State submits 

corrections for FEMA review, and reports them in the ALC.

7. R EP 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 real-world incident. The Credit column in Exhibit III-2: 

Federal Evaluation Process Matrix indicates which functions and 

activities FEMA may consider for exercise credit. 

FEMA may consider granting credit for REP 

exercises when an ORO responds to an actual 

incident that compels demonstration of REPspecific criteria or capabilities.

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);
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Radiological Emergency Preparedness Program Manual 176

 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.

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.
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177 Radiological Emergency Preparedness Program Manual

C. EXERCISE DEMONSTRATION

Planning Standard N of NUREG-0654/FEMA-REP-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: 

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.

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

 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
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Radiological Emergency Preparedness Program Manual 178

 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 Post-Plume 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 Post-Plume 

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

179 Radiological Emergency Preparedness Program Manual

Assessment Area 1: Emergency Operations Management

Sub-element 1.a – Mobilization 

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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. (NUREG0654/FEMA-REP-1, A.1.a, e; A.3, 4; 

C.1,4, 6; D.4; E.1, 2; G.3.a; H.3, 4) 

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial exercise, an actual event, 

out-of-sequence evaluation 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-fourhour 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 

ICS, 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.

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, pre-positioning of staff for out-of-sequence 

demonstrations may be used in accordance with the Extentof-Play Agreement. 

The REP program does not evaluate Incident Command Post 

tactical operations (e.g., Law Enforcement hostile action 

suppression techniques), only coordination among the 

incident command, the utility, and all appropriate OROs, 

pursuant to plans/procedures. 

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 must 

be on the ORO’s mobilization list so they can 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-ofPlay Agreement.

Sub-element 1.b – Facilities

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-1, which requires that OROs have facilities to support 

the emergency response.

Criterion 1.b.1: Facilities are sufficient to support the 

emergency response. (NUREG0654/FEMA-REP-1, G.3.a;H.3; 

J.10.h; J.12; K.5.b)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial exercise, an actual event, 

SAVs, or by out-of-sequence evaluations.

Responsible OROs must demonstrate, no less than once 

every 8 years, the availability of facilities to support 

accomplishment of emergency operations (this includes 

all alternate and backup facilities). Evaluations are typically 

performed for EOCs and JICs, as well as other facilities such 

as reception/relocation centers. Some of the areas evaluated 

within the facilities are adequate space, furnishings, 
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Radiological Emergency Preparedness Program Manual 180

lighting, restrooms, ventilation, access to backup power, 

and/or alternate facility, if required to support operations. 

Radio stations, laboratories, initial warning points and 

hospitals are not evaluated under 1.b.1. 

In addition, facilities will be evaluated for this criterion 

during the first biennial exercise after any new or 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-ofPlay Agreement. 

Sub-element 1.c – Direction and Control

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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. (NUREG0654/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 biennial 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 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-ofPlay Agreement. 

Sub-element 1.d – Communications Equipment

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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. (NUREG0654/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 biennial or tabletop exercise, 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 
Part III: REP Program Demonstration Guidance

181 Radiological Emergency Preparedness Program Manual

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-ofPlay Agreement. 

Sub-element 1.e – Equipment and Supplies to 

Support Operations

INTENT

This Sub-element is derived from NUREG-0654/FEMAREP-1, which requires that OROs have emergency equipment 

and supplies adequate to support the emergency response. 

Criterion 1.e.1: Equipment, maps, displays, monitoring 

instruments, dosimetry, potassium iodide (KI) and other 

supplies are sufficient to support emergency operations 

(NUREG-0654/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.94

Dosimetry: Sufficient quantities of appropriate directreading 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. 

94 See part IV, REP Program Administration: Potassium Iodide (KI) for the Public 

– Requirements.
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Radiological Emergency Preparedness Program Manual 182

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 responsechecked 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-ofPlay Agreement.
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183 Radiological Emergency Preparedness Program Manual

Assessment Area 2: Protective Action Decision-Making

Sub-element 2.a – Emergency Worker 

Exposure Control

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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 organ-specific 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. (NUREG0654/FEMA-REP-1, C.6; 

f; K.3.a; 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 biennial 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-ofPlay 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 NUREG0654/FEMAREP-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. 

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. (NUREG0654/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 biennial or tabletop exercise.
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Radiological Emergency Preparedness Program Manual 184

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 prearranged 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-ofPlay 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). (NUREG0654/FEMA-REP-1,A.3; C.4, 6; D.4; 

J.9; J.10.e, 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 biennial 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 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 used 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 

decision-making 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-ofPlay Agreement. 
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185 Radiological Emergency Preparedness Program Manual

Sub-element 2.c – PAD Consideration for the 

Protection of Persons with Disabilities and 

Access/Functional Needs

INTENT

This Sub-element is derived from NUREG0654/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 day cares, 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. (NUREG0654/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 biennial or tabletop exercise that 

would include the use of plant conditions transmitted from 

the licensee. 

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 highrisk 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 decision-making 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).

Since other agencies place requirements on hospitals to 

prepare for contaminated patients, the REP Program has no 

need to evaluate host hospitals95, nor does the ORO have the 

responsibility to provide training or dosimetry. Additionally 

Hospital evacuation plans do not need to be reviewed or 

tested by the REP program.

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-ofPlay Agreement. 

Sub-element 2.d. – Radiological Assessment 

and Decision Making for the Ingestion Exposure 

Pathway

INTENT

This Sub-element is derived from NUREG0654/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. 

(NUREG0654/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 biennial or tabletop exercise that 

would include the use of plant conditions transmitted from 

the licensee. 

95 In this context, “host hospital” refers to a hospital that may treat patients 

potentially contaminated with radiation.
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Radiological Emergency Preparedness Program Manual 186

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.

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 decisionmakers 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. 

These decisions include tracking agricultural products 

entering and leaving the EPZ. Demonstration of plans and 

procedures which use traffic access control points to track 

agricultural products entering and leaving the EPZ may be 

conducted through interview.

OROs will use Federal resources, as identified in the 

Nuclear/Radiological Incident Annex of the NRF and other 

resources (e.g., compacts or nuclear insurers), as necessary. 

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-ofPlay Agreement. 

Sub-element 2.e. – Radiological Assessment and 

Decision Making Concerning Post-Plume Phase 

Relocation, Reentry, and Return

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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. (NUREG0654/FEMAREP-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 biennial 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.

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, 
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187 Radiological Emergency Preparedness Program Manual

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 decisionmaking 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-ofPlay Agreement. 
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Radiological Emergency Preparedness Program Manual 188

Assessment Area 3: Protective Action Implementation

Sub-element 3.a – Implementation of Emergency 

Worker Exposure Control

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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 recordkeeping of the administration of KI to emergency workers. 

(NUREG-0654/FEMA-REP-1, K.3.a, b; K.4)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial 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 pre-established 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 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., direct-reading 

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 EPA400-R-92-001 dose limits for emergency workers 

performing various services (e.g., lifesaving, 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 lifesaving and/or protection of valuable 

property may require an urgent response. 
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189 Radiological Emergency Preparedness Program Manual

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-ofPlay Agreement.

Sub-element 3.b – Implementation of KI 

Decision for Institutionalized Individuals and the 

General Public

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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 is maintained. (NUREG0654/

FEMA-REP-1, J.10.e, f)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial 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 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-ofPlay Agreement.

Sub-element 3.c – Implementation of Protective 

Actions for Persons with Disabilities and Access/

Functional Needs

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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. 

(NUREG0654/FEMA-REP-1, J.10.c, d, e, g)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial 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 
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Radiological Emergency Preparedness Program Manual 190

and instructions to) persons with disabilities and access/

functional needs, including hospitals/medical facilities, 

nursing homes, correctional facilities, and mobilityimpaired 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 actually contacted, as 

negotiated in the extent of play. All actual and simulated 

contacts must be logged.

Since other agencies place requirements on hospitals to 

prepare for contaminated patients, the REP Program has no 

need to evaluate host hospitals, nor does the ORO have the 

responsibility to provide training or dosimetry. Additionally 

Hospital evacuation plans do not need to be reviewed or 

tested by the REP program.

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-ofPlay Agreement. 

Criterion 3.c.2: OROs/School officials implement 

protective actions for schools. (NUREG0654/FEMA-REP-1, 

J.10.c, d, e, g)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial, or tabletop exercise, an 

actual event, staff assistance visit, or by means of drills 

conducted at any time. 

School systems/districts (these include public and private 

schools, kindergartens, preschools, and licensed day 

cares) 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.

If a school facility has emergency plans as a condition of 

licensing, those plans may be submitted to FEMA review 

in place of demonstration or interview pursuant to the 

ORO’s plans/procedures as negotiated in the Extent-of-Play 

Agreement.

Since other agencies place requirements on hospitals to 

prepare for contaminated patients, the REP Program has no 

need to evaluate host hospitals, nor does the ORO have the 

responsibility to provide training or dosimetry. Additionally 

Hospital evacuation plans do not need to be reviewed or 

tested by the REP program.

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-ofPlay Agreement.

Sub-element 3.d. – Implementation of Traffic and 

Access Control

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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. (NUREG0654/FEMA-REP-1, A.3; 

C.1,4; J.10.g, j) 
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191 Radiological Emergency Preparedness Program Manual

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial exercise, an actual event, 

staff assistance visit, 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.

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-ofPlay Agreement.

Criterion 3.d.2: Impediments to evacuation are identified and 

resolved. (NUREG0654/FEMA-REP-1, J.10.k)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial exercise, an actual event, 

staff assistance visit, or by means of drills conducted at 

any time. 

OROs must demonstrate the capability to identify and take 

appropriate actions concerning impediments to evacuations. 

In demonstrating this capability, the impediment must 

remain in place during the evacuation such that re-routing 

of traffic is required and must also result in demonstration 

of decision-making and coordination with the JIC to 

communicate the alternate route to evacuees. Where, due 

to specifics of the scenario or jurisdiction, the impediment 

cannot be located on an evacuation route, it must be located 

so as to impact the evacuation. Where not possible, actual 

dispatch of resources need not be physically demonstrated; 

however, all contacts, actual or simulated, 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-ofPlay Agreement.

Sub-element 3.e – Implementation of Ingestion 

Pathway Decisions 

INTENT

This Sub-element is derived from NUREG0654/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. ( NUREG0654/FEMAREP-1, A.3; C.1, 4; J.11)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial 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 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.
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Radiological Emergency Preparedness Program Manual 192

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-ofPlay Agreement.

Criterion 3.e.2: Appropriate measures, strategies, and preprinted instructional material are developed for implementing 

protective action decisions for contaminated water, food 

products, milk, and agricultural production. (NUREG0654/

FEMA-REP-1, G.1, J.9, 11)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial 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-ofPlay Agreement.

Sub-element 3.f – Implementation of Post-Plume 

Phase Relocation, Reentry, and Return Decisions 

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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, 

relocation, and return of individuals during the post-plume 

phase are coordinated with appropriate organizations and 

implemented. (NUREG0654/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 biennial, or tabletop exercise, or by 

means of drills conducted at any time. 

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 intermediateterm 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 
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193 Radiological Emergency Preparedness Program Manual

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 will use Federal resources as identified in the 

NRF Nuclear/Radiological Incident Annex, and other 

resources (e.g., compacts or nuclear insurers), as necessary, 

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-ofPlay Agreement.
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Radiological Emergency Preparedness Program Manual 194

Assessment Area 4: Field Measurements And Analyses

Sub-element 4.a – Plume Phase Field 

Measurements and Analyses

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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, NUREG0654/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. (NUREG0654/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 biennial exercise. Other means 

may include drills 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 out-of-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. 

OROs will use Federal resources as identified in the NRF 

Nuclear/Radiological Incident Annex and other resources 

(e.g., compacts or the licensee), as necessary. 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-ofPlay 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. 

(NUREG0654/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 biennial exercise. Other means 

may include drills 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 
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195 Radiological Emergency Preparedness Program Manual

need for expedited laboratory analyses of these samples. 

Coordination concerning transfer of samples, including a 

chain-of-custody form(s), to a radiological laboratory(ies) 

must be demonstrated.

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 will use Federal resources as identified in the NRF 

Nuclear/Radiological Incident Annex and other resources 

(e.g., compacts or the licensee), as needed. 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-ofPlay Agreement.

Sub-element 4.b – Post-Plume Phase Field 

Measurements and Sampling

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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 Sub-element 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.

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. (NUREG0654/FEMA-REP-1, C.1; I.8; J.11)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial 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-ofcustody 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 will use Federal resources as identified in the NRF 

Nuclear/Radiological Incident Annex and other resources 

(e.g., compacts, the licensee, or nuclear insurers), as needed. 

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-ofPlay Agreement.

Sub-element 4.c – Laboratory Operations

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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. (NUREG0654/FEMA-REP-1, C.1, 3; J.11)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial, tabletop exercise, or an 

actual event. Other means may include drills, seminars or 

training activities that would fully demonstrate technical 

proficiency. 
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Radiological Emergency Preparedness Program Manual 196

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.

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 will use Federal resources as identified in the NRF 

Nuclear/Radiological Incident Annex and other resources 

(e.g., compacts, the licensee, or nuclear insurers), as needed. 

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-ofPlay Agreement.
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197 Radiological Emergency Preparedness Program Manual

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 NUREG0654/FEMAREP-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 further discussed in Section V, Part A of 

this Manual, Alert and Notification Systems.

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 

5.a.1: ...covering 

essentially 100% 

of the 10-mile EPZ 

X

5.a.4: ...for FEMAapproved 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. 

(NUREG0654/FEMA-REP-1, E.5, 6, 7)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial 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.

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 
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Radiological Emergency Preparedness Program Manual 198

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-ofPlay 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. (NUREG0654/FEMA-REP-1, E.6, Appendix 3.B.2.c)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial 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.

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.

When 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-ofPlay Agreement.

Criterion 5.a.4: 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. 

(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 biennial 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 within 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.
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199 Radiological Emergency Preparedness Program Manual

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 air/water craft, actual routes 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-ofPlay Agreement.

Sub-element 5.b – Subsequent Emergency 

Information and Instructions for the Public and 

the Media

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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, NUREG0654/FEMAREP-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. NUREG0654/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. (NUREG0654/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 biennial 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 predetermined 

individuals and businesses in accordance with the ORO’s 

plans/procedures.
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Radiological Emergency Preparedness Program Manual 200

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-ofPlay Agreement.
Part III: REP Program Demonstration Guidance

201 Radiological Emergency Preparedness Program Manual

Assessment Area 6: Support Operations/Facilities

Sub-element 6.a – Monitoring, Decontamination, 

and Registration of Evacuees 

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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. 

(NUREG0654/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 biennial exercise, an actual event, 

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. 

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-ofPlay Agreement.

Decontamination of evacuees may be simulated and 

conducted by interview. Provisions for separate showering 

and same-sex decontamination 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 
Part III: REP Program Demonstration Guidance

Radiological Emergency Preparedness Program Manual 202

contamination or contamination below the trigger/action 

level or have been placed in a secure area until they can be 

monitored and decontaminated, if necessary. 

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 held in a secure area or monitored and 

decontaminated (if applicable) and do require confirmation 

that their vehicle is being held in a secure area or 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 NUREG0654/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. 

(NUREG0654/FEMA-REP-1, K.5.a, b)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial exercise, drills, an actual 

event, 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 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 decontamination 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.

OROs must demonstrate the capability to register 

emergency workers 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 emergency worker’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 emergency 

workers who cannot be adequately decontaminated for 

assessment and follow-up in accordance with the ORO’s 

plans/procedures. 
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203 Radiological Emergency Preparedness Program Manual

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-ofPlay Agreement.

Sub-element 6.c – Temporary Care of Evacuees

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-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. (NUREG0654/

FEMA-REP-1, J.10.h, J.12)

ASSESSMENT/EXTENT OF PLAY

Assessment of this Demonstration Criterion may be 

accomplished during a biennial exercise, drills, an actual 

event, or SAV.

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 based on their all-hazard sheltering experience 

and what is historically relevant for that particular area. 

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 placed in a secured area or 

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 held in a secure area until they can be 

monitored and decontaminated (if applicable) and do need 

confirmation that their vehicle is being held in a secure area 

or 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-ofPlay Agreement.

Sub-element 6.d – Transportation and Treatment 

of Contaminated Injured Individuals

INTENT

This Sub-element is derived from NUREG0654/FEMAREP-1, which requires that OROs have the capability to 

transport contaminated injured individuals to medical 

facilities with the capability to provide medical services.
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Radiological Emergency Preparedness Program Manual 204

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. (NUREG0654/FEMAREP-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 biennial exercise, an actual event, 

or drills. FEMA has determined that these capabilities 

have been enhanced and consistently demonstrated as 

adequate; therefore, offsite medical services drills need only 

be evaluated 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.

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. 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. 

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. 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. 

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. Medical facilities are expected to have at least 

one trained physician and one trained nurse to perform and 

supervise treatment of contaminated injured individuals. 

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-ofPlay Agreement.
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205 Radiological Emergency Preparedness Program Manual

Part IV: FEMA REP PROGRAM 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. Demonstration Considerations for No/Minimal Release Scenarios;

H. Integration of REP Demonstration Criteria and Core Capabilities;

I. Submitting Best Practices on the FEMA Website;

J. Approval Process for Alternative Approaches 

K. Emergency Planning Zone Boundary Changes;

L. Credentialing Framework;

M. Use of State, Local, and Tribal Personnel as REP Exercise Evaluators;

N. Tribal Policies and Procedures;

O. Staff Assistance Visits (SAVs);

P. Evacuation Time Estimates;

Q. Potassium Iodide for the Public;

R. Conducting Plan Reviews;

S. Conducting Scenario Reviews;

T. Annual Letter of Certification (ALC);

U. Public Information Guide and Process;

V. Conducting a Disaster Initiated Review; and

W. List of Commercial Nuclear Power Plants.
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Radiological Emergency Preparedness Program Manual 206

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. 4 4 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,96

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 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 

96 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)].
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207 Radiological Emergency Preparedness Program Manual

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/FEMA-REP-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

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
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Radiological Emergency Preparedness Program Manual 208

NUREG0654/FEMA-REP-1 FEMA NRC DOE EPA FDA HHS DOT USDA DOI DOC

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
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209 Radiological Emergency Preparedness Program Manual

NUREG0654/FEMA-REP-1 FEMA NRC DOE EPA FDA HHS DOT USDA DOI DOC

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

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
Part IV: FEMA REP Program Administration

Radiological Emergency Preparedness Program Manual 210

NUREG0654/FEMA-REP-1 FEMA NRC DOE EPA FDA HHS DOT USDA DOI DOC

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
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211 Radiological Emergency Preparedness Program Manual

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, 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:

“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 

353, Appendix A). 

 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;

 Results of the exercise (deficiencies noted and 

corrections made);
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Radiological Emergency Preparedness Program Manual 212

 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/FEMAREP-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. 

(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 
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213 Radiological Emergency Preparedness Program Manual

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 years.97 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. 

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 NUREG-0654/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 

97 This requirement was changed from 6 years to 8 years by NUREG-0654/

FEMA-REP-1, Supplement 4.

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 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.
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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. 4 4 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 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. 4 4 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. 4 4 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 sitespecific 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.”
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215 Radiological Emergency Preparedness Program Manual

5. 4 4 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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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 

(NUREG-0654/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 (NUREG-0654/FEMAREP-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. NUREG-0654/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 NUREG-0654/FEMAREP-1, Revision 1. 

NOTE: Although there is no NUREG-0654/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
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217 Radiological Emergency Preparedness Program Manual

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 (NUREG-0654/FEMA-REP-1, Supplement 3)

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, 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.
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Radiological Emergency Preparedness Program Manual 218

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 (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: 

1. Integration of National Preparedness Initiatives into 

ORO Plans and Activities: integration of NIMS/ ICS 

and National Exercise Program/HSEEP concepts into 

offsite emergency response plans and activities. 

2. Coordination between OROs and Licensees during 

a Hostile Action-Based 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; and

 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:

• C.6 – addresses coordination of onsite and offsite 

response in an HAB incident;

• N.1.c – requires off-hours and unannounced 

exercises for the licensee only; and

• 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.
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219 Radiological Emergency Preparedness Program Manual

G. DEMONSTRATION CONSIDERATIONS FOR NO/MINIMAL 

RELEASE SCENARIOS

OROs can utilize these defined methods to address all 

applicable exercise demonstration criteria in a No/Minimal 

Release Scenario that does not progress to a General 

Emergency declaration during a biennial exercise without 

the need to extend the exercise or conduct additional outof-sequence exercises.

A No/Minimal Release Scenario is required once every 

eight years for licensees and is an option for OROs once 

every eight years. If OROs decide not to participate in 

such an exercise, they must participate in a “traditional” 

scenario response that involves a General Emergency 

declaration and a resulting PAR/PAD process. There are 

currently 32 Demonstration Criteria of which 7 apply only

to an Ingestion/Post-Plume scenario and 1 applies only to a 

MS-1 Drill. This leaves 24 criteria focused solely on a plume 

exposure pathway exercise.

Of the 24 plume exposure pathway criteria, 17 are 

required to be demonstrated biennially at each appropriate 

location. The remaining 7 criteria are not required to be 

demonstrated biennially, but no less than once every eight 

years at each appropriate location. These 7 criteria include:

 1.b.1 – Facilities

 3.c.1 and 3.c.2 – Implementation of Protective Actions for 

Persons with Disabilities and Access/Functional Needs

 5.a.3 – Activation of the Prompt Alert and Notification 

System

 6.a.1 – Monitoring, Decontamination, and Registration 

of Evacuees

 6.b.1 – Monitoring and Decontamination of Emergency 

Workers and their Equipment and Vehicles

 6.c.1 – Temporary Care of Evacuees

Of the 17 biennial criteria, 7 criteria are not impacted by 

a No/Minimal Release Scenario and require no special 

considerations in order to be demonstrated: 

 1.a.1 – Mobilization

 1.c.1 – Direction and Control

 1.d.1 – Communications Equipment

 1.e.1 – Equipment and Supplies to Support Operations

 5.a.1 and 5.a.4 – Activation of the Prompt Alert and 

Notification Systems

 5.b.1 – Subsequent Emergency Information and 

Instructions for the Public and the Media

The following 10 criteria may require special consideration 

when being demonstrated during a No/Minimal Release 

Scenario:

 2.a.1 – Emergency Worker Exposure Control

 2.b.1 and 2.b.2 – Radiological Assessment and 

Protective Action Recommendations and Decisions for 

the Plume Phase of the Emergency

 2.c.1 – PAD Consideration for the Protection of Persons 

with Disabilities and Access/Functional Needs

 3.a.1 – Implementation of Emergency Worker Exposure 

Control

 3.b.1 – Implementation of KI Decision for 

Institutionalized Individuals and the Public

 3.d.1 and 3.d.2 – Implementation of Traffic and Access 

Control

 4.a.2 and 4.a.3 – Plume Phase Field Measurement and 

Analyses

The following matrix shows how these remaining 

10 criteria can be demonstrated during a No/Minimal 

Release Scenario.
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Radiological Emergency Preparedness Program Manual 220

Exhibit IV-2: Considerations for Demonstrating the 10 Criteria during a No/Minimal Release Scenario

All activities described below will be negotiated and agreed upon within the Extent of Play Agreement. All demonstrations 

will be completed in accordance with the Extent-of-Play Agreement.

ASSESSMENT AREA 2. PROTECTIVE ACTION DECISION-MAKING

2.a.1 – Emergency Worker Exposure Control

Sub-Element Means of Demonstration per Negotiated Extent of Play

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.

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.

OROs would be expected to make a decision on the need for KI, based 

on relevant factors and appropriate coordination.

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.

The decision on the distribution and administration of KI as a protective 

measure for emergency workers and the authorization process for 

emergency workers to exceed pre-authorized levels can be addressed 

through an interview.

2.b.1 – Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency

Sub-Element Means of Demonstration per Negotiated Extent of Play

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.

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.

OROs would be expected to make a decision on the need for a PAR 

(evacuation and/or sheltering), based on plant conditions, field 

monitoring data, and licensee and ORO dose projections, as well as 

knowledge of onsite and offsite environmental conditions, including 

release and meteorological data provided by the licensee.

The ORO must demonstrate a reliable capability to independently 

validate dose projections. In all cases, calculation of projected dose 

must be demonstrated. 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. Actual data and/

or “what if” calculations will be made to determine the scope of the 

release, including confirming if no release has occurred. 

The decision-making process used to make PARs can be addressed 

through an interview.
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221 Radiological Emergency Preparedness Program Manual

2.b.2 – Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency

Sub-Element Means of Demonstration per Negotiated Extent of Play

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).

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 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 would be expected to make a decision on the need for a PAD 

(evacuation and/or sheltering), considering appropriate factors, and 

necessary coordination. 

The decision-making process used to make PADs can be addressed 

through an interview.

Precautionary actions/measures can be, and are, made by OROs at a 

Site Area Emergency, to include: placing animals on stored feed and 

water, transfer of school children, and establishing air and waterway 

restrictions, etc.

2.c.1 – PAD Consideration for the Protection of Persons with Disabilities and Access/Functional Needs

Sub-Element Means of Demonstration per Negotiated Extent of Play

PADs are made, as appropriate, for groups of people with 

disabilities and those with access/ functional needs.

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.

OROs would be expected to make a decision on the need for a PAD 

(evacuation and/or sheltering), considering appropriate factors and 

necessary coordination.

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.

Many, if not all, OROs accomplish this during an Alert or Site Area 

Emergency. If not, the decision-making process used to make PADs can 

be addressed through an interview.
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Radiological Emergency Preparedness Program Manual 222

ASSESSMENT AREA 3: PROTECTIVE ACTION IMPLEMENTATION

3.a.1 – Implementation of Emergency Worker Exposure Control

Sub-Element Means of Demonstration per Negotiated Extent of Play

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.

OROs must demonstrate the capability to brief personnel; issue 

appropriate dosimetry, KI, and procedures; manage radiological 

exposure to emergency workers; and ensure that emergency workers 

periodically and at the end of each mission read their dosimeters and 

record the readings on the appropriate exposure record or chart.

Many, if not all, OROs accomplish this during an Alert or Site Area 

Emergency. If not, the process to ensure EW exposure control is 

implemented can be addressed through an interview.

3.b.1 – Implementation of KI Decision for Institutionalized Individuals and the Public

Sub-Element Means of Demonstration per Negotiated Extent of Play

KI and appropriate instructions are available if a decision 

to recommend use of KI is made. Appropriate recordkeeping of the administration of KI for institutionalized 

individuals is maintained.

OROs would be expected to make a decision on the need for KI, based 

on relevant factors and appropriate coordination.

The decision-making process on the need to recommend use of KI can 

be addressed through an interview, in accordance with the Extent of Play 

Agreement.

3.d.1 – Implementation of Traffic and Access Control

Sub-Element Means of Demonstration per Negotiated Extent of Play

Appropriate traffic and access control is established.

Accurate instructions are provided to traffic and access 

control personnel.

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, relocation, etc.) in 

a timely manner. Traffic and access control staff must demonstrate 

accurate knowledge of their roles and responsibilities.

These capabilities may be demonstrated by actual deployment or by 

interview, in accordance with the Extent of Play Agreement.

3.d.2 – Implementation of Traffic and Access Control

Sub-Element Means of Demonstration per Negotiated Extent of Play

Impediments to evacuation are identified and resolved.

At least one impediment must remain in place during the evacuation, 

does not necessarily need to occur on an evacuation route, and should 

be such that re-routing of traffic is required. The impediment should 

result in, and must remain in place long enough, for demonstration of 

the decision-making and coordination with the JIC to communicate the 

alternate route to evacuees leaving the area. 

These capabilities may be demonstrated by actual deployment, through 

Controller inject, or by interview, in accordance with the Extent of Play 

Agreement.
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223 Radiological Emergency Preparedness Program Manual

ASSESSMENT AREA 4: FIELD MEASUREMENTS AND ANALYSES

4.a.2 – Plume Phase Field Measurement and Analyses

Sub-Element Means of Demonstration per Negotiated Extent of Play

Field teams (2 or more) are managed to obtain sufficient 

information to help characterize the release and to control 

radiation exposure.

FMTs are dispatched to a standby location, usually at a Site Area 

Emergency, and monitor dose rates. This data would be very limited 

during a No/Minimal Release Scenario, however it would still be vital 

to characterizing the limited release or used to verify that no release 

occurred.

Responsible OROs must demonstrate the capability to brief FMTs on 

predicted plume location, direction, and travel speed and exposure 

control procedures before deployment.

FMTs must be directed to take measurements at such locations and 

times as necessary to provide sufficient information to characterize the 

plume and its impacts.

4.a.3 – Plume Phase Field Measurement and Analyses

Sub-Element Means of Demonstration per Negotiated Extent of Play

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.

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.

As stated above, field teams will be dispatched and monitor dose rates. 

An air sample could be demonstrated at the first location dispatched, 

independent of a trigger level for an air sample, per the negotiated 

Extent of Play. In accordance with plans and procedures, the level at 

which an air sample would be taken could be discussed via interview.
Part IV: FEMA REP Program Administration

Radiological Emergency Preparedness Program Manual 224

H. INTEGRATION OF REP DEMONSTRATION CRITERIA AND 

CORE CAPABILITIES

The REP program has adopted the HSEEP exercise 

documentation format in order 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 core 

capabilities. Integrating the two exercise methodologies 

so that they are “speaking the same language” has several 

major benefits: 

 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 core capability targets; 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 Demonstration Criteria- Core Capability crosswalk 

and REP-specific Exercise Evaluation Guides (EEGs).

The information in this subpart includes the following 

three sections:

 Demonstration Criteria-Core Capability Crosswalk;

 EEGs; and

 Customizing EEGs for an Exercise.

1. D emonstration Criteria-Core Capability 

Crosswalk

The crosswalk was developed as a starting point for 

translating the REP Demonstration Criteria into applicable 

core capabilities from the National Preparedness Goal and 

Frameworks. FEMA reviewed the extent of play associated 

with each REP Demonstration Criterion and compared 

it with the core capabilities to identify similarities. The 

resulting crosswalk provides a “menu” of potential 

correlations between each REP Demonstration Criterion 

and the core capabilities, rather than a “one-size-fits-all” 

prescriptive list. The crosswalk is found in Exhibit IV-3.
Part IV: FEMA REP Program Administration

225 Radiological Emergency Preparedness Program Manual

Exhibit IV-3: Demonstration Criteria-Core Capabilities Crosswalk

REP Assessment Areas and Demonstration Criteria

Operations 

Emergency 

Management Decision-Making

Protective Action Protective Action 

Implementation

Field 

and Analysis

Measurement 

Information

and Public 

Notification 

Emergency Support 

Operations/

Facilities

by Mission Area

Core Capabilities 

1.a.1

1.b.1

1.c.1

1.d.1

1.e.1

2.a.1

2.b.1

2.b.2

2.c.1

2.d.1

2.e.1

3.a.1

3.b.1

3.c.1

3.c.2

3.d.1

3.d.2

3.e.1

3.e.2

3.f.1

4.a.2

4.a.3

4.b.1

4.c.1

5.a.1

5.a.3

5.a.4

5.b.1

6.a.1

6.b.1

6.c.1

6.d.1

Common

Planning

Public Information 

and Warning

X

X

X

X

X

X

X

Operational Coordination

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

Prevention

Forensics and Attribution

Intelligence and 

Information Sharing

X

X

Interdiction and Disruption

Screening, Search, 

and Detection

Protection

Access Control 

and Identity Verification

Cybersecurity

Intelligence and 

Information Sharing

X

X

Interdiction and Disruption

Physical Protective 

Measures

Risk Management for 

Protection Programs and 

Activities

Screening, Search, 

and Detection

Supply Chain Integrity
Part IV: FEMA REP Program Administration

Radiological Emergency Preparedness Program Manual 226 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 Core Capabilities by Mission Area

1.a.1

1.b.1

1.c.1

1.d.1

1.e.1

2.a.1

2.b.1

2.b.2

2.c.1

2.d.1

2.e.1

3.a.1

3.b.1

3.c.1

3.c.2

3.d.1

3.d.2

3.e.1

3.e.2

3.f.1

4.a.2

4.a.3

4.b.1

4.c.1

5.a.1

5.a.3

5.a.4

5.b.1

6.a.1

6.b.1

6.c.1

6.d.1

Mitigation

Community Resilience

Long-Term Vulnerability 

Reduction

Risk and Disaster

Resilience Assessment

Threat and Hazard 

Identification

Response

Critical Transportation X X X X X

Environmental

Response/Health and Safety X X X X X X X X X X X X X X

Fatality Management Services

Infrastructure Systems X

Mass Care Services X X X

Mass Search and Rescue 

Operations

On-Scene Security and 

Protection X

Operational Communications X X X X X X X X X X

Public and Private

Services and Resources X X

Public Health and Medical 

Services X X

Situational Assessment X X X X X X X X

Recover

Economic Recovery X X

Health and Social Services X X

Housing X X

Infrastructure Systems

Natural and Cultural 

Resources X X
Part IV: FEMA REP Program Administration

227 Radiological Emergency Preparedness Program Manual

2. Exercise Evaluation Guides

FEMA has developed REP-specific, core capability-based 

EEGs for use during REP exercises. These EEGs enable users 

to meet the traditional reasonable assurance standards of the 

REP Program as well as address and document performance 

thresholds for each core capability. Each EEG includes the 

following: 

 Core capabilities: The distinct critical elements 

necessary to achieve a specific mission area (e.g., 

prevention). To assess both capacity and gaps, each core 

capability includes capability targets.

 Capability target(s): The performance thresholds 

for each core capability; they state the exact amount of 

capability that players aim to achieve. Capability targets 

are typically written as quantitative or qualitative 

statements.

 Critical tasks: The distinct elements required to 

perform a core capability; they describe how the 

capability target will be met. Critical tasks generally 

include the activities, resources, and responsibilities 

required to fulfill capability targets. Capability targets 

and critical tasks are based on operational plans, 

policies, and procedures to be exercised and tested 

during the exercise.

 Performance ratings: The summary description of 

performance against target levels. Performance ratings 

include both Target Ratings, describing how exercise 

participants performed relative to each capability 

target, and Core Capability Ratings, describing overall 

performance relative to entire the core capability.

Additional information regarding the generic use and 

structure of the core capability-based EEGs can be found 

within Homeland Security Exercise and Evaluation Program (HSEEP), 

April 2013.

The most current versions of the master REP EEGs are 

available on the REP website.

3. Customizing EEGs for an Exercise

During the exercise planning process, the FEMA Region 

customizes the master core capability-based EEGs for 

the objectives and Demonstration Criteria scheduled for 

evaluation during the exercise. The Regions may involve 

the exercise planning team in the customization process. 

The EEGs are customized to reflect the response structure 

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 response approach and the 

applicable REP Demonstration points of review found in the 

Exercise Preparation Guide. 
Part IV: FEMA REP Program Administration

Radiological Emergency Preparedness Program Manual 228

I. SUBMITTING BEST PRACTICES ON THE FEMA WEBSITE

Public Domain Documents

All submitted exercise-related Best Practices must 

be included in the After-Action Report of an exercise. 

This will be considered a public domain document 

and allow FEMA to put it on the website. 

Best Practices are exemplary methods and/or unique 

approaches that lead to innovative, enhanced emergency 

preparedness and response that have been noted by FEMA 

during various REP Program activities. 

The following guide assists State and FEMA Regional 

personnel with development, submission, and review 

of Best Practices for inclusion on the FEMA website. 

These procedures will assure that best practices and 

ideas are available to all communities surrounding 

nuclear power plants. 

When a Best Practice is noticed during an exercise, training, 

or plan review FEMA staff will complete Exhibit IV-4: 

Best Practice Submission Form and submit to the RAC 

Chair, or their designee. Upon RAC Chair approval, the 

information will then be forwarded to FEMA Headquarters. 

Supporting materials (e.g., pictures, documents, videos, 

etc.) should be included with the initial submission. Any 

pictures that are submitted must include a description and 

the names of the individuals in the picture. Any member 

of the public in the photograph must complete the form in 

Exhibit IV-5: Photographic/Video/Audio Consent & Release 

and/or Exhibit IV-6: Parent Consent & Release Form for 

Photographic/Video/Audio Recording. 

Once the proposed approach is received by FEMA 

Headquarters, the proposal will be reviewed by the 

following:

 THD Policy 

 Legal Counsel

 REP Program Branch Chief
Part IV: FEMA REP Program Administration

229 Radiological Emergency Preparedness Program Manual

Exhibit IV-4: Best Practice Submission Form

Best Practice Submission Form

Best Practice Topic

Describe the area of the REP Program that 

this Best Practice applies to (e.g., training, 

exercises, planning, etc.).

Describe the applicable planning standard 

and/or evaluation criteria most appropriate to 

this Best Practice.

Description of Best Practice

Describe, in detail, the Best Practice. This 

should include training, exercise, and/or plan 

information as well as any other information 

being used. Include all relevant supporting 

materials (e.g., documents, forms, video, or 

descriptions of equipment) as attachments. 

Provide any supporting items in electronic 

format so that they may be added to the 

website. Acceptable formats include .tiff, .jpg, 

.png, .txt, and .pdf.

Agency that Employs the Best Practice

Include all entities, be specific.

Submitter’s Contact Information

Include Name, Title, and contact information.

Signature of RAC Chair or Designee
Part IV: FEMA REP Program Administration

Radiological Emergency Preparedness Program Manual 230

Best Practice Submission Form

Additional Information

If applicable, which exercise After-Action 

Report includes this as a Best Practice?

If the Best Practice was not captured within an 

After-Action Report, the appropriate agency/

jurisdiction involved must sign here for 

approval to publish on the FEMA website. 

Additional comments may be added here.
Part IV: FEMA REP Program Administration

231 Radiological Emergency Preparedness Program Manual

Exhibit IV-5: Photographic/Video/Audio Consent & Release

Federal Emergency Management Agency

Photographic/Video/Audio Consent & Release

I consent and agree that the Federal Emergency Management Agency (“FEMA”) and the United States Government (“Government”) 

will have the right to take photographs or record video of me (and of my property), and to record my voice, and to use all these in any 

media format.

I also agree that my name, identity, and the content of my spoken words may be revealed in these media or by descriptive text, 

transcription or commentary. I understand that my likeness, my voice, images of my property or business, and my personal name or 

my business name may be used by FEMA and the Government and disseminated though various media, including the Internet, radio 

and television and via CD-ROM.

I release to FEMA and the Government all rights to exhibit the described works in print, photographic and electronic form publicly 

or privately.

I wave any rights, claims or interest I may have to control the use of my identity or likeness in the photographs or videos taken of 

me, as well as any rights I may have in my recorded voice, or to images of my property or business, and agree that any of these uses of 

the video/photograph/audio may be made without compensation or additional consideration to me.

I represent that I am at least 18 years of age, that I have read and understand the above statement, and that I am competent to 

execute this consent and release.

Name: ____________________________________________ Signature: __________________________________________

Address: ___________________________________________ Phone:_____________________________________________

____________________________________________________________________________________________________________

Witness for FEMA:___________________________________ Photo ID Number: ___________________________________

Federal Emergency Management Agency

Photographic/Video/Audio Consent & Release

I consent and agree that the Federal Emergency Management Agency (“FEMA”) and the United States Government (“Government”) 

will have the right to take photographs or record video of me (and of my property), and to record my voice, and to use all these in any 

media format.

I also agree that my name, identity, and the content of my spoken words may be revealed in these media or by descriptive text, 

transcription or commentary. I understand that my likeness, my voice, images of my property or business, and my personal name or 

my business name may be used by FEMA and the Government and disseminated though various media, including the Internet, radio 

and television and via CD-ROM.

I release to FEMA and the Government all rights to exhibit the described works in print, photographic and electronic form publicly 

or privately.

I wave any rights, claims or interest I may have to control the use of my identity or likeness in the photographs or videos taken of 

me, as well as any rights I may have in my recorded voice, or to images of my property or business, and agree that any of these uses of 

the video/photograph/audio may be made without compensation or additional consideration to me.

I represent that I am at least 18 years of age, that I have read and understand the above statement, and that I am competent to 

execute this consent and release.

Name: ____________________________________________ Signature: __________________________________________

Address: ___________________________________________ Phone:_____________________________________________

____________________________________________________________________________________________________________

Witness for FEMA:___________________________________ Photo ID Number: ___________________________________
Part IV: FEMA REP Program Administration

Radiological Emergency Preparedness Program Manual 232

Exhibit IV-6: Photographic/Video/Audio Parental Consent & Release

Federal Emergency Management Agency

Parent Consent & Release Form for Photographic/Video/Audio 

I consent and agree that the Federal Emergency Management Agency (“FEMA”) and the United States Government (“Government”) 

can take photographs of the child/children named below. I also agree that his/her/their name(s) can be used in photo captions.

These photographs may be posted on the FEMA web site (www.fema.gov) and/or included in the FEMA photo archive, both of 

which are fully accessible by the public. These photographs may be used for information/educational purposes, per the FEMA photo 

usage agreement. The photographs are not intended to be sold.

I release to FEMA and the Government all rights to exhibit the described works in print, photographic and electronic form.

I represent that I have read and understood the above statement, and that I am competent to execute this consent and release.

Name of Parent/Guardian: ____________________________ Date: ______________________________________________

Signature:__________________________________________ Phone:_____________________________________________

Address: _____________________________________________________________________________________________________

____________________________________________________________________________________________________________

Name of Child/Children: _______________________________________________________________________________________

____________________________________________________________________________________________________________

Consent Obtained By: ________________________________ Photo ID Number: ___________________________________

Federal Emergency Management Agency

Parent Consent & Release Form for Photographic/Video/Audio 

I consent and agree that the Federal Emergency Management Agency (“FEMA”) and the United States Government (“Government”) 

can take photographs of the child/children named below. I also agree that his/her/their name(s) can be used in photo captions.

These photographs may be posted on the FEMA web site (www.fema.gov) and/or included in the FEMA photo archive, both of 

which are fully accessible by the public. These photographs may be used for information/educational purposes, per the FEMA photo 

usage agreement. The photographs are not intended to be sold.

I release to FEMA and the Government all rights to exhibit the described works in print, photographic and electronic form.

I represent that I have read and understood the above statement, and that I am competent to execute this consent and release.

Name of Parent/Guardian: ____________________________ Date: ______________________________________________

Signature:__________________________________________ Phone:_____________________________________________

Address: _____________________________________________________________________________________________________

____________________________________________________________________________________________________________

Name of Child/Children: _______________________________________________________________________________________

____________________________________________________________________________________________________________

Consent Obtained By: ________________________________ Photo ID Number: ___________________________________
Part IV: FEMA REP Program Administration

233 Radiological Emergency Preparedness Program Manual

J. APPROVAL PROCESS FOR ALTERNATIVE APPROACHES

The Evaluation Criteria in NUREG-0654/FEMA-REP-1 provide 

approved approaches to meet the regulatory requirements 

of the REP Program. However, FEMA recognizes that other 

approaches may be appropriate and therefore presents a 

process for review and approval of alternative approaches. 

In order for an alternative approach to be considered by 

FEMA, it must meet or surpass current standards. This section 

provides instructions detailing the approval process. 

1. Initial submission

OROs submit a formal written request outlining the 

proposed alternative approach through the State to the 

FEMA Regional Office. 

The request includes:

 Jurisdiction(s) affected/involved

 Relevant evaluation criteria (i.e., A.1, N.2.b, etc.)

 Explanation regarding how the currently approved 

approach is not sufficient for the jurisdiction (e.g., 

statues and regulations prohibit the currently approved 

approach, terrain/weather conditions prohibit the use 

of certain equipment, and/or distance from facilities 

inhibits response times, etc.).

 The alternative approach. This includes sufficient detail 

and any materials (e.g., forms, SOPs, etc.) necessary to 

ensure clarity. Ensure there is no decrease in public 

health and safety. 

 Description of how the proposed alternative approach 

differs from the previous approach and how it will be 

demonstrated.

2. Regional Recommendation

The FEMA Regional Office and RAC Chair will review the 

OROs’ proposal and determine whether to endorse the 

alternative approach. Other RAC members may be consulted 

for additional information. The FEMA Regional Office 

will forward their written recommendation, which will 

include an explanation of how the recommendation was 

formulated, along with the proposal, to FEMA Headquarters 

within 30 days of the initial submission date. 

If the FEMA Regional Office and RAC Chair do not 

recommend acceptance of the proposal, an attempt should 

be made to discuss the proposal with the State and/or 

submitting OROs and determine a mutually acceptable 

solution. If this approach is not successful, then the 

FEMA Regional Office will send the proposal to FEMA 

Headquarters with a written statement explaining why the 

alternative approach was not endorsed.

3. FEMA Headquarters Approval

Once the proposed alternative approach is received by 

FEMA Headquarters, the proposal will be reviewed by the 

following:

 THD Policy 

 Legal Counsel

 REP Program Branch Chief

FEMA Headquarters will send a disposition letter within 

90 days of the initial submission date with an explanation 

of the decision to accept or reject the alternative approach. 

Final approval will be contingent on the successful 

demonstration of the alternative approach.
Part IV: FEMA REP Program Administration

Radiological Emergency Preparedness Program Manual 234

4. Alternative Approach Demonstration

In consultation with the OROs, the FEMA Regional Office 

will determine the appropriate time and location for 

the demonstration of the proposed alternative approach. 

Assessment of alternative approach may be accomplished 

during a biennial exercise, actual event, out-of-sequence 

evaluation, site assistance visits or by means of drills or 

seminars conducted at any time. 

If the alternative approach is related to equipment, then 

system familiarity must demonstrate technical proficiency. 

If the alternative approach requires the use of plant 

conditions, coordination with the licensee is recommended. 

If the demonstration of the alternative approach is during a 

biennial exercise or drill ensure the extent of play is written 

to indicate how to handle an unsuccessful demonstration. 

Assessment of the alternative approach will include FEMA 

Regional and Headquarters representation. The FEMA 

Regional Office, RAC Chair and FEMA Headquarters will 

review the AAR and determine whether to endorse the 

approach. When the alternative approach is demonstrated 

during training then the FEMA Regional Office will need 

to provide a written report detailing the actions taken and 

its’ outcome. If the demonstration was successful, FEMA 

Headquarters will provide the OROs with an approval 

letter containing the alternative approach and the date of its 

successful completion. 

Copies of approved alternative approach proposals and 

supporting documentation will be kept on file with both 

the FEMA Regional Office and FEMA Headquarters.

All approved alternative approaches will be reviewed prior 

to the OROs biennial exercise to ensure the alternative 

approach remains current

K. EMERGENCY PLANNING ZONE BOUNDARY CHANGES 

In accordance with NUREG-0654/FEMA-REP-1, 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

 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 Section V, Part A of this 

Manual, Alert and Notification Systems.
Part IV: FEMA REP Program Administration

235 Radiological Emergency Preparedness Program Manual

L. CREDENTIALING FRAMEWORK

REP Program Credentialing Framework, December 2010

Credentialing is the administrative process for validating 

personnel qualifications and providing authorization to 

perform specific functions. 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; and 

 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.

M. 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: 

 Résumé 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/non-selection letter.

National Registry: FEMA Headquarters maintains a 

national registry of available qualified ORO evaluators.
Part IV: FEMA REP Program Administration

Radiological Emergency Preparedness Program Manual 236

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. 

N. TRIBAL POLICIES AND PROCEDURES

1. F ederally Recognized Tribal Nations 

and the REP Program

In support of the Presidential policy memorandum issued 

April 29, 1994, Federally-recognized Tribal Nations must be 

part of all Federal programs. Pursuant to this Presidential 

policy, the FEMA Tribal Policy was signed into effect on 

June 29, 2010.

2. Policy

FEMA recognizes that the Tribal right of self-government 

flows from the inherent sovereignty of American Indian 

and Alaska Native Tribes as nations and that Federallyrecognized Tribes have a unique and direct relationship 

with the Federal government. Native American and Alaska 

Native Tribal governments are not political subdivisions of 

States, but are recognized by the United States as distinct 

sovereign entities. FEMA recognizes that, as a sovereign 

government, each Tribal government sets its own priorities 

and goals for the welfare of its membership.

FEMA acknowledges the trust responsibility of the Federal 

Government to American Indian and Alaska Native Tribal 

governments as established by specific treaties, court 

decisions, statues, executive orders, regulations, and policies. 

In recognition of this trust responsibility, FEMA will 

evaluate the impact of policies, programs, and activities on 

Tribal trust resources and consider the rights and concerns 

of Tribal government in its decision-making. FEMA will 

encourage cooperation and partnership between and among 

Federal, Tribal, State, local governments, and public and 

private entities. Effective homeland security and emergency 

management require the cooperation, partnership, and 

mutual consideration of neighboring governments.

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. 

Additional information can be found on FEMA’s Tribal 

website (www.fema.gov/tribal). Among the many items 

on the site is the complete FEMA Tribal Policy, letters 

in support of Tribal sovereignty, as well as training 

information for Tribal governments.
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237 Radiological Emergency Preparedness Program Manual

O. STAFF ASSISTANCE VISITS (SAVS) 

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 III-2, 

Federal Evaluation Process Matrix.

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.

P. EVACUATION TIME ESTIMATES

Evacuation Time Estimates (ETEs) are required within the 

plume exposure pathway EPZ by NUREG-0654/FEMAREP-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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Q. 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 ShelfLife 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.

R. CONDUCTING PLAN REVIEWS

1. R adiological 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 
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239 Radiological Emergency Preparedness Program Manual

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, agencyspecific chapters, and step-by-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 flexibility. Procedures may be either incorporated in 

the main plans or into separate procedural documents at the 

discretion of the ORO.

2. D ivision 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 NUREG-0654/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/FEMA-REP-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-7.
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Radiological Emergency Preparedness Program Manual 240

Exhibit IV-7: 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 crosscheck plans/procedures, if necessary, to make sure that each 

point is covered somewhere and the pertinent references 

have been clearly stated in both places. 

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-8. 

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 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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241 Radiological Emergency Preparedness Program Manual

Exhibit IV-8: Plan Review Format

Planning Standard Adequate

Adequate - 

Corrections 

must be made

Inadequate Not

Applicable Comments

A ASSIGNMENT OF RESPONSIBILITY

A.1.a

Each plan shall identify the State/Tribal, 

local, federal and private organizations 

that are intended to be part of the 

overall response organization for EPZ.

Licensee, 

State/Tribal, 

and local 

requirement.

Describe all Federal, State/Tribal, 

local and private-sector organizations 

comprising the overall ORO.

Identify the principal response 

organizations.

A.1.b

Each organization and sub organization 

having an operational role shall specify 

its concept of operations and its 

relationship to the total effort.

Licensee, 

State/Tribal, 

and local 

requirement.

Specify the organization’s role in an 

emergency.

Specify how the organization will carry 

out its role in an emergency.

A.1.c

Each plan shall illustrate these 

interrelationships in a block diagram.

Licensee, 

State/Tribal, 

and local 

requirement.

Include an illustration of each 

organization and its relationship to the 

total emergency response effort.

A.1.d

Each organization shall identify a 

specific individual by title who shall be 

in charge of the emergency response.

Licensee, 

State/Tribal, 

and local 

requirement.

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.

A.1.e

Each organization shall provide for 

24-hour per day emergency response, 

including 24-hour per day manning of 

communications links. 

Licensee, 

State/Tribal, 

and local 

requirement.

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.
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S. 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-9: Scenario Review Process

STEP 1 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 2 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)

STEP 3 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)
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243 Radiological Emergency Preparedness Program Manual

STEP 4 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 5 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 7. 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 6 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 7 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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Radiological Emergency Preparedness Program Manual 244

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 

post-plume 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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245 Radiological Emergency Preparedness Program Manual

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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Radiological Emergency Preparedness Program Manual 246

T. ANNUAL LETTER OF CERTIFICATION (ALC)

1. Guidance

To facilitate monitoring of REP planning and preparedness 

requirements as prescribed in NUREG-0654/FEMAREP-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 (NUREG-0654/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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247 Radiological Emergency Preparedness Program Manual

2. Sample Annual Letter of Certification Cover Letter 

SAMPLE COVER LETTER FOR ANNUAL LETTER OF CERTIFICATION AND PUBLIC EDUCATION AND 

INFORMATION98 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

98 The Public Education and Information Review Guide is found in the next section.
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Radiological Emergency Preparedness Program Manual 248

3. Annual Letter of Certification (ALC) 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.

P 44 CFR part 350

P NUREG0654/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 

P FEMA-REP10 

P FEMA REP Program Manual

Confirm that the ALC includes the following items:

Update of Plans/Procedures and Letters of Agreement

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.

Yes No N/A

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/FEMAREP-1, 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

d. Copies of all public information materials
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249 Radiological Emergency Preparedness Program Manual

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-REP-1, 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. (NUREG0654/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 drills related to plume collection of particulate and radioiodine samples and radiation 

measurements and if applicable any Ingestion Pathway drills that were performed during the period of this ALC. (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)

1. A statement that sufficient trained and capable staff is available to maintain 24-hour capability for protracted activation.

Yes No N/A

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 used 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 used 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/FEMA-REP-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. (REP Program Manual Section V, 

Part A)

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. (REP Program Manual Section V, Part A)

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. 

(REP Program Manual Section V, Part A)

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:

f. General usage

g. Self-testing frequency and method

h. Suggested placement to facilitate efficient use

i. Maintenance program details

j. 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. (REP Program Manual Section V, Part A)

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. (REP Program Manual Section V, Part A)

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:

e. General usage

f. Suggested placement to facilitate efficient use

g. Maintenance program details

h. 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. (REP Program Manual Section V, Part A)

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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U. 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), NUREG-0654/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 selfprotection. 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.
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Radiological Emergency Preparedness Program Manual 256

Exhibit IV-10: Public Information Review Checklist

Y N N/A

BASIC INFORMATION (requirements)

There is a clear statement of purpose.

The date of issue and name of the issuing agency are clearly indicated.

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.

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.

The cover clearly states that the document contains important emergency instructions.

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 (recommendations)

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.
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257 Radiological Emergency Preparedness Program Manual

Y N N/A

COMPREHENSION (requirements)

Vocabulary is simple, comprising non-technical terms likely to be used by the intended audience. 

Sentences are clear 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.

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 (requirements)

Provisions that address persons with disabilities and access/functional needs (e.g., hearing/mobilityimpaired, transportation-dependent, etc.) are provided.

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 preschools 

and licensed day cares), 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.

PERSONS WITH DISABILITIES AND ACCESS/FUNCTIONAL NEEDS (recommendations)

Information is made accessible to transients and visitors through appropriate means.
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Radiological Emergency Preparedness Program Manual 258

Y N N/A

INGESTION PATHWAY INFORMATION (requirements)

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.

INGESTION PATHWAY INFORMATION (recommendations)

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.

NOTIFICATION PROCEDURES (requirements)

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.

The public is encouraged to alert neighbors, by means other than the telephone, to ensure they also 

heard and understood the warning signals.

Instructions are consistent with the ORO plans/procedures, public information materials, and previous 

EAS messages.

Information regarding emergency classification levels is included. 

Transportation provisions are included.

NOTIFICATION PROCEDURES (recommendations)

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.

Public EAS broadcast instructions have a clear emergency focus and explain what to do.

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.
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259 Radiological Emergency Preparedness Program Manual

Y N N/A

SHELTERING (requirement)

Sheltering procedures and instructions for the general population, private and public school children 

(including preschools and licensed day cares), 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.

SHELTERING (recommendation)

Sheltering is defined according to the ORO plan.

EVACUATIONS (requirements)

Evacuation routes are described in the text and illustrated directions on an evacuation map of the EPZ 

are provided.

Distribution of evacuees to reception centers is identified.

EVACUATIONS (recommendations)

Reasons for evacuation are discussed.

Respiratory protection while evacuating is described.

POTASSIUM IODIDE (requirements)

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.

POTASSIUM IODIDE (recommendation)

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 (requirement)

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.

RECEPTION CENTERS/CONGREGATE CARE CENTERS (recommendation)

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.

PREPLANNING

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.
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Radiological Emergency Preparedness Program Manual 260

3. F oreign 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 more than 10,000 people or 5 percent of the 

voting-age population 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

99 The Voting Rights Act of 1965 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 http://www.justice.gov/crt/about/vot/

sec_203/203_brochure.php

99 Pub L. No. 89-110, 79 Stat. 437 (codified as amended at 42 U.S.C. 1973 

(2006)).

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 

(but a township or municipality in some states) will be 

the lowest jurisdictional subdivision to which the language 

minority requirements will apply. The translation will only 

apply to those populations within the EPZ. 

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.
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261 Radiological Emergency Preparedness Program Manual

V. DISASTER INITIATED REVIEW

The purpose of a Disaster Initiated Review (DIR), if 

warranted, is to formally determine the capability of offsite 

emergency response infrastructure and capabilities to 

effectively implement approved emergency plans. 

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 shut 

down 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.
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Radiological Emergency Preparedness Program Manual 262

Part V: Supplemental Guidance

A. ALERT AND NOTIFICATION SYSTEMS

1. Background

No nuclear power plant (NPP) may operate in the United 

States without a license from the Nuclear Regulatory 

Commission (NRC). Before the NRC will grant a license it 

must determine that, among other things, the emergency 

plan provides for adequate measures to ensure public 

health and safety.100 Alert and notification systems (ANS) 

are one of the factors the NRC considers in making this 

determination.101

Although the NRC requires an effective ANS as one of 

the conditions for licensing, it does not determine its 

adequacy independently.102 Since 1980, both Congress and 

the President have required NRC to work with the Federal 

Emergency Management Agency (FEMA) to assess the 

adequacy of radiological emergency response plans—which 

includes ANS—as a condition of obtaining or maintaining 

a license.103 Both the NRC and FEMA address how this 

planning and preparedness assessment occurs in their 

regulations and guidance.104 The regulations include the 

full text of the Memorandum of Understanding (MOU) 

between FEMA and the NRC hat clarifies each agency’s roles 

and responsibilities.105

100 See 42 U.S.C. § 2133(d) (2011) (forbidding any license where, “in the opinion 

of the Commission, the issuance of a license to such person would be inimical 

to... the health and safety of the public”).

101 See, e.g., 10 C.F.R. § 50.47 (requiring emergency plans providing “reasonable 

assurance that adequate protective measures can and will be taken in the event 

of a radiological emergency” before granting a license); id. at § 50.47(b)(5) 

(citing need for alert and notification system).

102 Cf. 42 U.S.C. § 2201(f) (2011) (authorizing the NRC to “utilize or employ 

the services or personnel of any Government agency or any State or local 

government, or voluntary or uncompensated personnel, to perform such 

functions on its behalf as may appear desirable” provided that the agency 

concerned consents).

103 See The Nuclear Regulatory Commission Authorization Act, Pub. L. 96-295 

§ 109 (Jun. 30, 1980) (requiring NRC to consult with FEMA to determine 

whether the emergency plans will protect public health and safety); Exec. 

Order 12,148 § 2-103, 3 C.F.R. 412 (1979), reprinted as amended 42 U.S.C. § 5195 

(2011) (assigning responsibility for “coordination of natural and nuclear 

disaster warning systems” to Secretary of Homeland Security, delegated to the 

FEMA Administrator by DHS Delegation Number 9001.1).

104 See generally 10 C.F.R. Part 50 (presenting NRC regulations); 44 C.F.R. 350 

(presenting FEMA regulations).

105 The text of the Memorandum of Understanding between Federal Emergency Management 

Agency and Nuclear Regulatory Commission is available at 44 C.F.R. Part 353, App. A.

FEMA’s mission and authorities support its role in the NRC 

licensing process. FEMA’s mission is to support our citizens 

and first responders to ensure that as a nation we work 

together to build, sustain, and improve our capability to 

prepare for, protect against, respond to, recover from, and 

mitigate all hazards.106 While FEMA has responsibilities 

within all phases of emergency management, many of 

FEMA’s Radiological Emergency Preparedness (REP) Program 

activities fall under the preparedness umbrella.107 The REP 

Program assesses emergency preparedness for the jurisdictions 

surrounding commercial NPPs in the United States. 

FEMA and NRC use the joint Criteria for Preparation and 

Evaluation of Radiological Emergency Response Plans and Preparedness 

in Support of Nuclear Power Plants (NUREG-0654/FEMA-REP-1) 

for the review, evaluation, and approval of radiological 

emergency plans.108 NUREG-0654/FEMA-REP-1 uses 16 

planning standards labeled A through P.109 NUREG-0654/

FEMA-REP-1 also includes evaluation criteria that further 

define the planning standards. Some of the criteria only 

apply to licensees; some only to State and/or tribal/local 

governments; and some apply to all of these groups.110

Three planning standards apply to ANS: notification 

methods and procedures (planning standard E); emergency 

106 “About FEMA,” FEMA, available at http://www.fema.gov/about-fema (last 

visited Sep. 21, 2012). See also 6 U.S.C. § 313(b)(1) (2011) (establishing primary 

mission for FEMA).

107 See generally 6 U.S.C. § 313(b)(2) (2011) (establishing specific activities for 

FEMA); 6 U.S.C. § 314 (2011) (establishing authority and responsibilities 

for the FEMA Administrator); 42 U.S.C. § 5131(a)-(b) (2011) (addressing 

preparedness authorities); 42 U.S.C. § 5132 (2011) (concerning disaster 

warnings and providing technical assistance to State and local governments 

for effective warnings); 42 U.S.C. §§ 5195-5196 (2011) (concerning 

emergency preparedness).

108 FEMA regulations incorporate this document by reference. See 44 C.F.R. 

§ 350.5(a) (stating “planning and preparedness criteria contained in 

NUREG-0654/FEMA-REP-1, Rev. 1 are to be used by FEMA and the NRC in 

reviewing and evaluating State and local government radiological emergency 

plans and preparedness.”).

109 The planning standards appear in 44 C.F.R. § 350.5(a) and 10 C.F.R. § 50.47(b).

110 See NUREG-0654/FEMA-REP-1, Rev. 1 (1980) (listing which group(s) criteria 

apply to).
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263 Radiological Emergency Preparedness Program Manual

communications (planning standard F); and exercises and 

drills (planning standard N).111

The NRC and FEMA process supports and encourages a 

meaningful, collaborative relationship with the whole 

community regarding preparedness. While the NRC 

possesses direct regulatory authority over the NPP licensees, 

neither FEMA nor the NRC regulate the offsite response 

organizations (OROs).112 FEMA works closely with those 

OROs who elect to participate in the REP program of 

exercises and evaluations.113 In instances where an ORO 

declines or fails to participate, FEMA may work directly 

with the applicant/licensee to ensure adequate offsite 

radiological emergency planning and preparedness.114

Therefore, this process functions as follows: the NRC 

requires specific criteria as licensing conditions; FEMA 

works with either the ORO or the applicant/licensee to 

determine whether appropriate measures exist to adequately 

protect the public health and safety in the event of a 

radiological emergency; FEMA then makes a determination 

regarding its evaluation of offsite plans and preparedness, 

and then forwards to the NRC. 

The alerting and notification of the public is a function 

of the State and local governments’ emergency plans. A 

NPP applicant/licensee is required to demonstrate that 

the administrative and physical means are established for 

alerting the public and providing instructions, regardless 

of who implements the a capability. An applicant/licensee 

may install and maintain the ANS but the responsibility 

for the alerting and notification of the public, as well as 

the activation of the ANS, remains with the State and local 

111 For the full text of these planning standards, see 44 C.F.R. §§ 350.5(5), (6), 

and (14).

112 The Atomic Energy Act lists multiple reasons about why Congress enacted 

legislation to govern nuclear power, including the national interest, military 

reasons, and the commerce clause. See, e.g., 42 U.S.C. § 2012(c) (2011) (stating 

process of creating nuclear power “affect[s] interstate and foreign commerce 

and must be regulated in the national interest.”). For a discussion of OROs, 

please see the REP Program Manual, p. I-3 (defining and explaining term 

“ORO”).

113 See generally 44 C.F.R. Part 350 (setting out program for REP planning, 

evaluation, and exercises). Cf. 44 C.F.R. § 350.7(a) (noting State must “see[k] 

formal review and approval” from FEMA). This function is separate from 

FEMA’s role in the licensing process; FEMA may evaluate a state or local 

plan at the request of NRC for licensing purposes regardless of whether the 

ORO elects to participate. See Pub. L. 96-295 § 109 (1980) (Congressional 

authorization for plan review); 42 U.S.C. § 2201(f) (2011) (authorizing NRC 

to request assistance from other Federal agencies); 10 C.F.R. § 50.47(a)(2) 

(addressing FEMA role in licensing process).

114 See generally 44 C.F.R. Part 352 (establishing how FEMA will work with licensees 

to establish reasonable assurance of protection of public health and safety). See 

also Exec. Ord. 12,657, 3 C.F.R. 611 (1988), reprinted as amended 42 U.S.C. § 5195 

(2011) (directing means for FEMA to work with licensees who certify OROs 

either declined or failed to provide sufficient REP plans and preparedness).

governments. Experience shows that successful ANS design 

and implementation occurs when the licensees, OROs, 

and any other relevant parties collaborate and consider the 

unique geographic, demographic, and technological factors 

for the relevant communities. 

FEMA evaluators should use this guide alongside the REP 

Program Manual and NUREG-0654/FEMA-REP-1, in their 

review of ANS. This guidance includes key ANS evaluation 

concepts and how to construct an evaluation report.115

2. FEMA Evaluation of ANS

Alert and Notification represents a portion of the overall 

planning and preparedness which FEMA reviews in making 

its reasonable assurance determination. Approval of the 

ANS is contained within FEMA’s approval of the State’s 

Radiological Emergency Response Plan in accordance with 

Title 44 of the Code of Federal Regulations (CFR) Part 

350.5-350.7. 

As part of this process, FEMA staff and leadership 

collaborate directly with OROs and/or applicants/licensees, 

when requested. FEMA can offer both planning guidance 

and technical (i.e., scientific, engineering) assistance. 

The initial ANS guidance FEMA and the NRC developed 

in NUREG-0654/FEMA-REP-1, Rev. 1 App. 3 (1980) and 

FEMA-REP-10 (“Guidance for the Evaluation of Alert and 

Notification Systems for Nuclear Power Plants”) (1985) 

predated technology many citizens now take for granted 

(e.g., smartphones, social media, etc.). This updated 

guidance for evaluating ANS allows evaluators to account 

for new technologies, consider updated NRC/FEMA 

guidance, and incorporate REP lessons learned. 

Although updated, this guidance retains many of the 

principles set forth in the earlier documents. FEMA does 

not require any specific ANS system, nor will it endorse 

any system(s). Upon request, FEMA may share examples 

of approved ANS currently in operation (assuming the 

owner of the system grants permission to share). However, 

jurisdictions should remain aware that an ANS that works 

for one community may not necessarily work in another 

community after considering all relevant factors (e.g., 

population, geography). OROs may submit alternative 

systems and other newer technologies for approval if they can 

document that the system meets the minimum acceptable 

115 For FEMA, the evaluation report generally encompasses the content formerly 

contained in the Design Report and the ANS/Communications Plan. See page 

xxx for further explanation.
Part V: Supplemental Guidance

Radiological Emergency Preparedness Program Manual 264

design objectives. OROs may use alternative systems not yet 

approved by FEMA concurrently with approved systems to 

augment the alert and notification process.

a. Evaluation Concepts

ANS alerts people to take an action (e.g., turn on a radio or 

television) in order to receive a notification. In this context, 

alert refers to the process used to get the attention of the 

public, while notification refers to the detailed information 

and instructions from officials. FEMA considers the entire 

system of alerts and notifications, but at times its guidance 

may address the individual components by using the terms 

“alert” or “notification” independently. 

The minimum acceptable design objectives for coverage by 

the system are: (1) the capability to provide both an alert 

signal and an informational or instructional message to the 

population on an area wide basis throughout the 10 mile 

emergency planning zone (EPZ) within 15 minutes; (2) that 

the initial notification system will assure direct coverage 

of essentially 100% of the population within 5 miles of 

the site; (3) that notification methods will be established 

to assure coverage within 45 minutes of essentially 100% 

of the population within the entire plume exposure EPZ 

who may not have received the initial notification. The 

basis for any special requirements exceptions (e.g., large 

water areas with transient boats or remote hiking trails) 

must be documented; and (4) that utility operators identify 

and develop, in conjunction with State, local, and tribal 

governmental officials, the administrative and physical 

means for a backup public alert and notification system 

capable of covering essentially 100% of the population 

within the entire plume exposure EPZ in the event that 

the primary method is unavailable. The backup means of 

alert and notification will be conducted within a reasonable 

time, with a recommended goal of 45 minutes. The basis 

for any special requirements exceptions (e.g., for large 

water areas with transient boats or remote hiking trails) 

must be documented. Assurance of continued notification 

capability may be verified on a statistical basis. The system 

plan must include a provision for corrective measure to 

provide reasonable assurance that coverage approaching 

the design objectives is maintained. The system will be 

operable prior to initial operation of greater than 5 percent 

of rated thermal power of the first reactor at a site. The lack 

of a specific design objective for a specified percent of the 

population between 5 and 10 miles which must receive 

the prompt signal within 15 minutes is to allow flexibility 

in system design. Designers should do scoping studies 

at different percent coverages to allow determination of 

whether an effective increase in capacity per unit cost can be 

achieved while still meeting the objective of item (1) above. 

Although the information above provide for backup ANS 

means separate from the primary ANS, they do not address 

backup power. The only current requirement for providing 

backup power to sirens appears in the Energy Policy Act of 

2005; this provision is based on the size of the permanent 

population within a 50 mile radius in a power plant and 

currently applies to one site (i.e., Indian Point). 

These minimally acceptable design objectives show that 

FEMA makes its assessment based on the capabilities of the 

ANS system. The evaluator will ask questions such as: given 

the geography and population density of the jurisdiction, is 

the ANS capable of notifying “essentially 100%”? Given the 

demographics of the population, does the ANS identify the 

proper channels for notification? How do the ANS operators 

ensure that the system will perform as expected if needed? 

This type of system requires evaluators to adopt a 

performance-based and results-oriented mindset. The 

evaluator cannot simply look at the “what” of an ANS; he or 

she must also look at the “who,” where,” “when,” “why,” 

and “how” of the ANS. 

This method of evaluation requires meaningful analysis 

and avoids prescribing a “one-size-fits-all” or a “cookbook” 

(i.e., listing specific “ingredients” of an ANS) approach. 

It proscribes “out of the box” pre-approval. It requires 

the evaluator to put in additional effort, to study all the 

available data and verify that the solution the jurisdiction 

settled upon can and will function as designed. It prevents 

the evaluator from substituting his or her bias for a type 

of system (e.g., only approving sirens). It appropriately 

emphasizes science, technology, and engineering in the 

ANS realm. Additionally, it eliminates uncertainty for 

the ANS designers, because so long as the design meets 

the minimally acceptable design objectives and the plans 

satisfy the NUREG-0654/FEMA-REP-1, Rev. 1 criteria, the 

evaluator will recommend a finding of reasonable assurance 

as it involves ANS.

“Minimally Acceptable Design Objectives”: The 15 Minute 

Design Objective

FEMA and NRC acknowledge that not every radiological 

emergency at a nuclear power plant will endanger 

the community living within the 10-mile EPZ within 

15 minutes. However, the system must be designed 

according to the worst-case scenarios. Moreover, even if the 

incident does not escalate rapidly, the initial notification 
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265 Radiological Emergency Preparedness Program Manual

should occur without undue delay in order to assure the 

public health and safety. 

b. Initial Planning

When a new ANS, or a change to an existing system is 

proposed, the FEMA Region should be contacted as early 

in the design or conceptual phase as practicable to ensure 

effective coordination of the design, review, and approval 

process. The FEMA Region will make a determination as to 

the significance of the proposal and request Regional and/

or FEMA Headquarters support, as necessary, for the review 

and approval process. A FEMA evaluator will be assigned 

to guide the documentation process and review of the 

proposal.

The FEMA evaluator must evaluate two aspects of the ANS: 

the technical aspects and the planning aspects. Any trained 

FEMA evaluator should possess the capability to assess an 

ANS plan: what will happen, who is responsible, when will 

actions occur, and so forth. This evaluation does not require 

specialized scientific knowledge. The technical evaluation 

requires the FEMA evaluator to collaborate with a FEMA 

engineer to ascertain whether the system described in the 

plan is capable of achieving its stated objectives. Nothing 

precludes the FEMA engineer from also serving as the 

FEMA evaluator of record. 

c. Integrated Public Alert and Warning System

The Integrated Public Alert and Warning System (IPAWS) 

is a modernization and integration of the nation’s alert 

and warning infrastructure that will save time when time 

matters; when protecting life and property.

Federal, State, territorial, tribal, and local alerting authorities 

may choose to use IPAWS and may also integrate local 

systems that use Common Alerting Protocol (CAP) standards 

with the IPAWS infrastructure. IPAWS will give public safety 

officials an effective way to alert and warn the public about 

serious emergencies using the Emergency Alert System 

(EAS), Wireless Emergency Alerts (WAE), National Oceanic 

and Atmospheric Administration (NOAA) Weather Radio, 

and other public alerting systems from a single interface.

FEMA encourages the integration of IPAWS with offsite alert 

and notification plans. As IPAWS is adopted nationwide, 

technical and planning assistance is available for State, 

territorial, tribal, and local alerting authorities.

d. The Evaluation Report

Prior REP practice saw applicants/licensees submitting 

documents about their ANS to FEMA, either directly or 

through the States. These documents became known as 

“Design Reports” that presented the information FEMA 

needed to review before making its reasonable assurance 

determination. Although the goal of the Design Report was 

to have a standardized means of reviewing ANS technology, 

the form and content of the reports varied from site to site. 

Some reports FEMA received were exceptionally thorough; 

other reports required a great deal of follow-up. 

One key function of the Design Report has been to 

document NPP licensee owned and operated and FEMA 

approved ANS systems for Nuclear Regulatory Commission 

inspection purposes. These Design Reports have been 

typically maintained on file by the licensees and, for this 

reason, FEMA will continue to support this documentation 

requirement. Design Reports may not have multiple 

amendments to the baseline report. If more than one 

amendment is required, the Design Report should be 

revised and released incorporating all amendments along 

with an updated revision history. The Design Report 

should be submitted in a commonly used electronic format 

(e.g., Adobe PDF, Microsoft Office Applications, etc.) on 

commonly used media (e.g., CD, DVD, Electronic File 

Transfer, etc.). If other formats or media are desired, the 

licensee should contact their Regional FEMA office.

However, going forward in conducting its ANS reviews, 

FEMA will work jointly with state, local, tribal and 

industry representatives, as applicable, to compile their 

own Evaluation Report that covers the technical aspects 

(previously covered in the Design Report) and the planning 

aspects (ANS/Communications Plans). The next section 

of this document will address the points of review for 

technical review of an ANS. FEMA will evaluate the 

planning aspects under the appropriate NUREG-0654/

FEMA-REP-1, Rev. 1 planning standards and criteria. 

Assigning responsibility for the Evaluation Report to the 

FEMA evaluator does not preclude the evaluator from using 

materials provided by an ORO or a licensee. However, 

FEMA expects its evaluators to provide their findings in a 

standardized format, using the template provided in this 

document. 
Part V: Supplemental Guidance

Radiological Emergency Preparedness Program Manual 266

3. Evaluation Report Template

The Evaluation Report Template should be used as a 

generic guide when preparing the Evaluation Report for 

a jurisdictional ANS. This template is flexible enough to 

account for new systems and/or unconventional approaches. 

Not all headings in this template are applicable in all cases.

 Introduction

• Title Page

• Date

• Revision number, when applicable

• Name of Nuclear Power Plant

• Signature Page

• State/Tribal Emergency Management Official 

• Utility Emergency Preparedness Supervisor, when 

applicable

• Local/County Emergency Management, when 

applicable

• FEMA Regional Representative

• Revision History

• Table of Contents

• Executive Summary

 Body of Report

• Requirements

• Description/Performance

• Verification

• Availability/Reliability

• Security and Privacy

• Procedures, Processes, and Quality Assurance

• Training and Public Outreach

 Attachments

• Maps, diagrams, references, etc.

a. Introduction of the Evaluation Report

Title Page

The Title Page must contain basic information about the 

report such as the name of the report, name of the nuclear 

power plant, date of the report, and applicable revision.

Signature Page

The Signature Page must have signatures of responsible 

officials attesting to the accuracy, completeness, and 

approval of the Evaluation Report. Since Alert and 

Notification is a key component of offsite planning and is 

part of the State’s Radiological Emergency Response Plan 

approval under 44 CFR Part 350, no ANS design, plan, or 

revision may be considered by FEMA without the State’s 

concurrence. 

Other signatories would typically include the utility 

emergency preparedness supervisor, the local or county 

emergency management, the state/tribal emergency 

management, and the FEMA Regional representative.

Revision History

The Revision History should show a summary of the 

current revision as well as the history of past revisions. This 

is typically shown as a table with each past revision and 

associated summary describing the change in each revision.

Table of Contents

Table of Contents should reflect all sections of the report 

and any additional relevant information should be included 

as annexes or appendices. 

Executive Summary

The Executive Summary should provide a one to two 

page overview that describes the overall physical and 

administrative features and functions of the ANS. If the 

Evaluation Report is an update to a previous report, it 

should also include a summary of the changes from the 

previous report. 
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267 Radiological Emergency Preparedness Program Manual

b. Body of the Evaluation Report

Below are general points of review that should be addressed 

in the body of the Evaluation Report, regardless of the 

type of system used. The next section covers the more 

specific points of review by system type(s). The information 

gathered as a result of these points of review, both general 

and specific, will make up the main content of the report. 

The topic areas discussed below are all pulled directly from 

the Evaluation Report template. 

Requirements

The requirements that the system or approach is 

designed to meet should be identified. This includes all 

requirements specific to the implementation, operation, 

and administration of the system. This should also include 

the source of the requirement; which may include NRC 

and FEMA requirements, current applicable Federal, State 

or local laws, codes, specifications and standards (e.g., 

Civil Preparedness Guide 1-17, Outdoor Warning Systems), 

and user and industry requirements. Requirements may 

be qualitative or quantitative and may include commonly 

recognized and accepted standards, such as sound pressure 

levels of 60 and 70dB(C) for areas of differing population 

densities, or standards developed and promulgated by 

industry or standard setting organizations, such as the 

National Emergency Number Association (NENA) for 

Emergency Telephone Notification Systems (ETNS). In all 

cases, the applicable requirement should be identified and 

referenced.

 System Coverage

• Geographical Area – Description of the 

geographical area intended for system coverage. 

This may include the entire EPZ or only a portion 

of it. Those areas not intended for coverage 

should be identified and include an explanation 

for omitting coverage (e.g., unpopulated areas, 

restricted areas, areas addressed by other means 

such as tone alert radios, etc.).

• Population – Description or characterization 

of the population required to be alerted across 

the geographical area. This may include areas 

of relatively high or low population densities or 

populations of special consideration such as those 

within the 1 or 5 mile EPZ, in the plume pathway, 

or within institutions such as prisons or hospitals. 

An acceptable method for estimating population 

densities is to use census blocks.

• Means – One commonly accepted standard is sound 

pressure levels (applicable for sirens) – Description 

of the sound pressure levels required throughout the 

alerting area. This may include requirements such as 

a minimum 70 dB(C) where population densities are 

greater than 2,000 persons per square mile. 

 Population/Demographics – Population groups, 

such as those described below, should be considered 

and any special requirements identified. For example, 

public parks frequented by transient guests may 

initiate a requirement for voice alerting to inform 

those not familiar with local radiological hazards or 

those identified with hearing disabilities may require 

visual cues for alerting. The list below is by no means 

exhaustive, but merely a list of examples:

• Urban and Rural

• Residential and Commercial

• Permanent Residents

• Transient Populations

• Persons with Disabilities

• Foreign Languages

 Inter-Operability – If the system interfaces with other 

systems, describe how that interface is accomplished.

 Operation – Identify all operational requirements. 

This may include requirements for capability to be 

activated via multiple remote modes such as internet or 

mobile phone. Management/Administration – Identify 

the organizations and/or individual(s) responsible 

for management and oversight of the system or the 

administration of third party agreements with vendors. 

 Security/Privacy

• Physical Security – Identify physical security 

requirements such as prevention of unauthorized 

access to system electronics, intrusion detection at 

unattended or remote locations, and/or controlled 

access to control stations. 

• Logical Security – Identify logical security 

requirements such as prevention of unauthorized 

or malicious access to the system or accidental or 

malicious actions resulting in denial of service.

 Maintenance/Repair

• Preventive Maintenance – Identify and describe 

routine and periodic maintenance requirements. 
Part V: Supplemental Guidance

Radiological Emergency Preparedness Program Manual 268

Typically, this includes, but is not limited to, 

manufacturer recommendations, manuals and 

procedures. While copies of the maintenance 

manuals are not required for the body of the report, 

the evaluation must ensure that essential procedures 

and technical resources are readily available.

• Corrective Maintenance – Identify and describe 

procedures and resources for correcting identified 

faults.

 Availability/Reliability – Identify reliability and 

availability requirements. NRC requires greater-than 

94 percent availability or the elimination of all critical 

single point failure modes.116 These requirements may 

also include system operation in all weather conditions 

typical for local climate. 

 Testing – Identify how system performance, availability 

and reliability is tested and verified on a periodic basis. 

This includes the frequency and method of testing and 

what aspects of the system are actually tested. Not all 

systems lend themselves to full operational testing. In 

those instances, passive testing, actual event verification 

and inspection may be considered. In addition, identify 

how the results of periodic and as-needed testing are 

recorded, preserved, and available for inspection. 

 Responsibility – Identify responsibility for system 

maintenance, testing, and repair. This is in addition to 

the operational management and administrative section 

described above.

 Training – Identify initial and ongoing training 

requirements for all associated personnel.

 Quality Assurance – Identify and describe a 

comprehensive, ongoing quality assurance program 

that may include testing, record-keeping, internal and 

external inspections and exercises.

Description/Performance

The evaluation provides a detailed description of the 

overall system or approach; this includes a complete 

description of all the physical, administrative, and 

operational components, and their locations. The physical 

description may include, but is not limited to: system 

components, interfaces, and functional block diagrams. The 

administrative description may include, but is not limited 

116 See NRC Inspection Manual, Inspection Procedure 71114.02-01, pg. 5 for 

further information.

to: a description of organizational responsibilities, how the 

backup ANS is managed, and, where applicable, interfaces 

and management with third parties. The operational 

description may include how the ANS is activated. The 

performance may be shown in a variety of ways including, 

but not limited to: maps, studies, test results, calculations, 

surveys, etc. In addition to the description of the system 

or approach, this section should also demonstrate how 

the ANS addresses the requirements explained in the 

Requirements section noted above. The evaluator should 

exercise caution and not include in the report vendor 

proprietary information or information not appropriate for 

public disclosure (e.g., communication frequencies). 

The following is an example of an outdoor warning system 

utilizing sirens:

Description/Performance

 Overview of Siren System

 Functional Block Diagram

 Control System

• Description of control sub-system

• Control system features and salient characteristics

• Quantity of controllers and locations

• Controller interfaces with other controllers and 

with sirens

• Controller interfaces with sirens

• Controller interfaces with other systems

 Communication System

• Description of communication sub-system

• Communication sub-system block diagram 

(communication and data flow)

• Communication technology

• Operating frequency, if applicable

• Components (e.g., radios, repeaters, transmitters, 

receivers, etc.)

• Commercial communication links 

 Sirens

• Type of siren equipment, including make, model, 

location, elevation

• Salient characteristics of siren equipment, 

including output
Part V: Supplemental Guidance

269 Radiological Emergency Preparedness Program Manual

Verification

Verification refers to documenting that the system or 

approach meets the Requirements identified above. This 

applies to implementation of new or modified systems or 

approaches. It should show objectively that the system or 

approach meets the stated Requirements and can be shown 

by tests, inspections, demonstrations, analysis, studies, or 

any other applicable method. Each of the Requirements 

identified should have a corresponding Verification process. 

For example:

 Siren Coverage – For Outdoor Warning Systems using 

sirens, coverage may be verified using the results of 

Outdoor Sound Propagation Models (OSPM) coverage 

maps depicting 60 dB(C) and 70 dB(C) isopleths with 

population density overlays. 

 Population/Demographics – Population and 

demographics information may be verified by 

identifying credible sources used for the population 

data. Credible sources may include census data, city or 

county records or local organization records.

Availability/Reliability

Availability and Reliability may include, but is not limited 

to, a description of how failures are detected and tracked/

trended, how the system is tested and maintained, and how 

vulnerabilities are identified, reported, and mitigated. 

Security and Privacy

With the current methods and advent of the many new 

ones that may be used for alert and notification, such as 

various social media applications, Security and Privacy 

issues have become a central concern. Security and Privacy 

issues, applicable to the system or approach, should be 

identified and include how these concerns are mitigated.

Procedures, Processes, and Quality Assurance

This section should describe procedures, processes, and 

quality assurance processes that are directly applicable to 

the initial installation, ongoing operation, maintenance, 

and administration of the ANS. Where third party services 

are utilized, this section should describe how quality 

assurance processes will be extended to those third party 

services.

Training and Public Outreach

This section should address training for all applicable 

stakeholders of the ANS. This may include training for 

those who operate and maintain the ANS.

Outreach activities to inform and educate the public 

represent an essential component of ANS. An informed 

population is far more likely to understand and respond 

appropriately to notifications and take action in emergency 

situations.

c. Attachments

Any additional information that will make the evaluation of 

an ANS such as maps, diagrams, and/or references should 

be added to the attachment section.
Appendix A: Abbreviations and Acronyms Used in the REP Program

Radiological Emergency Preparedness Program Manual 270

Appendix A: Abbreviations and Acronyms Used 

in the REP Program

A atomic mass

A ampere

A activity of isotope

AAM After-Action Meeting

AAR After-Action Report

AAR/IP After-Action Report/Improvement Plan

AC alternating current

ACP access control point

ADA American Disabilities Act

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

a alpha particle

b beta particle

b+ b+ particle (positron) 

b- bˉ 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

CAP Common Alerting Protocol

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

CMAS Commercial Mobile Alert System

CNSNS Commission for Nuclear Safety and Safeguards

CPG Comprehensive Preparedness Guide 

cpm counts per minute
Appendix A: Abbreviations and Acronyms Used in the REP Program

271 Radiological Emergency Preparedness Program Manual

CRCPD Conference of Radiation Control Program 

Directors

CSEPP Chemical Stockpile Emergency Preparedness 

Program

Cs cesium

DAC Disaster Application Center

dB Decibel

dBA A-weighted decibel

dBC C-weighted decibel

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

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

EPZ Emergency Planning Zone

ER emergency room

ERC Emergency Response Coordinator

ERDA Energy Research and Development 

Administration
Appendix A: Abbreviations and Acronyms Used in the REP Program

Radiological Emergency Preparedness Program Manual 272

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

ETNS Emergency Telephone Notification System

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

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

FPM Final Planning Meeting

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

g 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)

H2

O 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
Appendix A: Abbreviations and Acronyms Used in the REP Program

273 Radiological Emergency Preparedness Program Manual

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

IPAWS Integrated Public Alert and Warning System

IPM Initial Planning Meeting

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

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

MPM Midterm Planning Meeting

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
Appendix A: Abbreviations and Acronyms Used in the REP Program

Radiological Emergency Preparedness Program Manual 274

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

NENA National Emergency Number Association

NEP National Exercise Program

NESC National Exercise Simulation 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

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 NRC nuclear regulatory publication

NUREG-0654 NUREG-0654/FEMA-REP-1, 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
Appendix A: Abbreviations and Acronyms Used in the REP Program

275 Radiological Emergency Preparedness Program Manual

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

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
Appendix A: Abbreviations and Acronyms Used in the REP Program

Radiological Emergency Preparedness Program Manual 276

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

SPL Sound Pressure Level

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

TEPW Training and Exercise Planning Workshop

TBA thyroid blocking agent (see KI)

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

UO2

F2 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

277 Radiological Emergency Preparedness Program Manual

Appendix B: Glossary of REP Terms

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 NUREG-0654/

FEMA-REP-1 Planning Standards and Evaluation Criteria or 

alternative approaches approved by FEMA.

Administration/Finance Section: as applied to an exercise 

planning team organized according to ICS 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.

Administrative Procedures: describe the interaction of the 

various organizations, as well as the responsibility of each 

organization involved in the alert and notification sequence.

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 
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 278

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, stateof-the-art airborne equipment is used for extremely lowlevel gamma radiation detection, high-altitude photography, 

airborne gas and particulate sampling, and multi-spectral 

photography and scanning.

After-Action Meeting (AAM): as soon as possible after 

completion of the draft After-Action Report (AAR), the 

lead evaluator, members of the evaluation team, and other 

members of the exercise planning team conduct an AAM to 

present, discuss, and refine the draft AAR, and to develop 

an Improvement Plan. This meeting is a chance to present 

the AAR 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 post-exercise 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 meeting participants 

prior to the After-Action Meeting (AAM). The draft AAR is 

completed first and distributed to meeting participants for 

review no more than 30 days after exercise conduct. The 

final AAR/IP is an outcome of the AAM. 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 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 attention-getting 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 used 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 low-penetrating 

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.
Appendix B: Glossary of REP Terms

279 Radiological Emergency Preparedness Program Manual

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 decision-making. 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). 

Automatic Telephone Dialer: a computer programmable 

telephone dialing system where phone numbers from 

a computer managed list are automatically called and 

distributed to destinations.

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.

Backup systems: a separate system capable of covering 

essentially 100% of the population within the entire 

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.

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.

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 1 pound of water 1 degree 

Fahrenheit at sea level.

Buffer zone: an area adjacent to a restr1icted 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.
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 280

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 ICS 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 Mobile Alert System (CMAS): CMAS (also 

known as Wireless Emergency Alerts (WEA) or Personal 

Localized Alerting Network (PLAN)) is a new public safety 

system that allows customers who own an enabled mobile 

device to receive geographically-targeted, text-like messages 

alerting them of imminent threats to safety in their area. 

The new technology ensures that emergency alerts will not 

get stuck in highly congested user areas, which can happen 

with standard mobile voice and texting services. CMAS was 

established pursuant to the Warning, Alert and Response 

Network (WARN) Act. 

CMAS enables government officials to target emergency 

alerts to specific geographic areas through cell towers 

(e.g., lower Manhattan), which pushes the information to 

dedicated receivers in CMAS-enabled mobile devices. 

CMAS complements the existing Emergency Alert System 

(EAS) which is implemented by the FCC and FEMA at the 

federal level through broadcasters and other media service 

providers. 

Wireless companies volunteer to participate in CMAS. 

CMAS is the result of a unique public/private partnership 

between the FCC, FEMA and the wireless industry with the 

singular objective of enhanced public safety. 

Participating wireless carriers were required to deploy 

CMAS by April 7, 2012.

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, 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.

Common Alerting Protocol (CAP): is a digital format for 

exchanging emergency alerts that allows a consistent alert 

message to be disseminated simultaneously over many 

different communications systems.

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 alreadyidentified 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 Meeting (IPM); 

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.
Appendix B: Glossary of REP Terms

281 Radiological Emergency Preparedness Program Manual

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/FEMA-REP-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 informationsharing 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 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 pre-exercise 

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.
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 282

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 Capabilities: distinct critical elements necessary to 

achieve the specific mission areas of prevention, protection, 

mitigation, response, and recovery. Capabilities provide a 

common vocabulary describing the significant functions 

required to deal with threats and hazards that must be 

developed and executed across the whole community to 

ensure national preparedness.

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 AfterAction Report/Improvement Plan are prioritized, tracked, 

and analyzed continuously until they have been fully 

implemented and validated.

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 self-sustaining 

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 1 curie, 37 billion atoms decay in 1 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 (onetrillionth of a curie, abbreviated pCi)

Day cares: 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. 

Day cares may be licensed or unlicensed.

dB(C): the measurement of audio signals. The C weighting 

approximates the human ear sensitivity to relatively high 

sound levels.

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.
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283 Radiological Emergency Preparedness Program Manual

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 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 
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Radiological Emergency Preparedness Program Manual 284

on the protective action guides. This phase lasts hours to 

several days and ends when the radioactive release ends.

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 Center (EOC): a facility that is 

the primary base of emergency operations for an offsite 

response organization in a radiological emergency.

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 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, 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 
Appendix B: Glossary of REP Terms

285 Radiological Emergency Preparedness Program Manual

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.”

Equipment: FEMA currently recognizes fixed sirens, route 

alerting, TARs, and NOAA weather radio as acceptable 

primary and backup alert systems. , EAS, NOAA weather 

radio, and route alerting are acceptable notification systems. 

OROs may submit alternative systems and other newer 

technologies for approval if they can document that the 

system meets the minimum acceptable design objectives. 

OROs may use alternative systems not yet approved by 

FEMA concurrently with approved systems to augment the 

alert and notification process.

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 standards for observation, 

analysis, and After-Action Report/Improvement Plan 

development. Each EEG is linked to a core capability.

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: group of individuals responsible 

for all aspects of an exercise, including exercise planning, 

conduct, and evaluation. The planning team determines 
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 286

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 ICS, 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 

TEP is developed in consideration of an entity’s preparedness 

priorities. Next, specific exercises are carried out according 

to the multi-year 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 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 1 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, quasigovernmental, 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 
Appendix B: Glossary of REP Terms

287 Radiological Emergency Preparedness Program Manual

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 FederalState 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 

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 Meeting (FPM): 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 FPM, 

there are no major changes made to either the design or the 

scope of the exercise, nor to any supporting documentation. 

The FPM 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.

Fixed sirens: FEMA classifies any device used to provide 

an audible alerting signal outdoors from a fixed location 

as a siren. This includes mechanical (e.g., whistles, horns), 

electro-mechanical, and electronic devices capable of 

producing audible tones.

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 
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 288

near-site or forward emergency operations center will be 

established at the time of an accident.

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: in accordance with HSEEP, a full-scale 

exercise is a multi-agency, multi-jurisdictional, multidiscipline exercise involving functional (e.g., joint field 

office, emergency operations centers, etc.) and “boots on the 

ground” response (e.g., firefighters decontaminating mock 

victims). For the purposes of the REP Program, a full-scale 

exercise meets the intent of the full-participation exercise. 

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 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.
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289 Radiological Emergency Preparedness Program Manual

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 

self-sustaining 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. 

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 

NUREG-0654/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 
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 290

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 non-emergency 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 decisionmaking 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 Meeting (IPM): 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 IPM, the exercise planning team 

decides on exercise location, schedule, duration, and other 

details required to develop exercise documentation. 

Injects: events, typically planned through entries on the 

Master Scenario Events List, that 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.

Integrated Public Alert and Warning System (IPAWS):

a comprehensive, coordinated, integrated system that can 

be used by authorized public officials to deliver effective 

alert messages to the American public. IPAWS is the 

nation’s next-generation infrastructure of alert and warning 

networks and ensures the President can alert and warn the 

public under any condition. IPAWS will provide Federal, 

State, territorial, tribal, and local warning authorities the 

capabilities to alert and warn their communities of all 

hazards impacting public safety and well-being via multiple 

communication pathways.

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 

post-plume 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.
Appendix B: Glossary of REP Terms

291 Radiological Emergency Preparedness Program Manual

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.

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 postplume 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 ICS principles, the team 

members providing the supplies, materials, facilities, and 

services that enable the exercise to function smoothly 
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 292

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 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 1 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).

Midterm Planning Meeting (MPM): an operationsbased exercise planning meeting 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 “m.” Example: 

1 millimeter = 1 mm = 1/1,000 meters (10-3 m).
Appendix B: Glossary of REP Terms

293 Radiological Emergency Preparedness Program Manual

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 (TEP): 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 TEP, 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 Multi-year TEP and schedule are 

produced through the work completed at the Training and 

Exercise Planning Workshop (TEPW). The TEPW 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 computergenerated 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, 

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.
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 294

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: distributing an instructional message, either 

through the EAS or some other system.

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)U 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.

NUREG: a Nuclear Regulatory Commission (NRC) nuclear 

regulatory publication.

Objective: formerly, one of the 33 areas of ORO capability 

defined in FEMA-REP-14 and FEMA-REP15 that are 

evaluated during a REP exercise. Objectives have been 

replaced by the Assessment Areas and associated Subelements 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. 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 owner-controlled 

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: the owner-controlled area of 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. 
Appendix B: Glossary of REP Terms

295 Radiological Emergency Preparedness Program Manual

Operations Section: as applied to an exercise planning 

team organized according to ICS 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 Extentof-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).

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 Meetings: the exercise planning team holds 

planning meetings as forums to design and develop 

exercises. The scope, type, and complexity of an exercise 

determines the number of meetings necessary to 

successfully conduct an exercise. These milestones of the 

exercise planning process are typically comprised of the 

Initial Planning Meeting (IPM), the Midterm Planning 

Meeting (MPM), and the Final Planning Meeting (FPM).

Planning Section: as applied to an exercise planning team 

organized according to ICS 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 operations-based 

exercise) their regular roles and responsibilities. Players 

initiate actions that will respond to and/or mitigate the 

simulated emergency.
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 296

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 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 “postplume 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 
Appendix B: Glossary of REP Terms

297 Radiological Emergency Preparedness Program Manual

developed under HSPD-8 and Annex I remain in effect until 

rescinded or otherwise replaced.

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 HSPD-5, 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.

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).
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 298

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 pre-identified 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.

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 (within 30 minutes) 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 pre-designated 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 
Appendix B: Glossary of REP Terms

299 Radiological Emergency Preparedness Program Manual

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 Federallyapproved 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; 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.

Remote and low-population areas: The ANS must possess 

the capability for providing both an alert signal and an 

information or instructional message to the population on 

an area wide basis throughout the 10 mile EPZ within 15 

minutes. The initial notification system will assure direct 

coverage of essentially 100% of the population within 5 

miles of the site. ANS designers must consider all areas, 

including open water, parks, and other remote portions of 

the 10-mile EPZ. However, in rural, low-population areas 

in the 10-mile EPZ that are at least five miles from the NPP, 

FEMA may allow up to 45 minutes for providing an alert 

signal to the permanent and transient populations. FEMA 
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 300

will review these “exception areas” for approval on a caseby-case basis.

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 shelteredin-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 X-rays 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.

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 preschools and day cares. 

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.117

Shall (Must and Require): mandatory items originating in 

regulatory material including NUREG-0654/FEMA-REP-1 

and the CFR. 

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 (Suggest and Recommend): guidance outlining 

a Federally-approved means of meeting the intent of the 

REP regulations. The term may denotes an option, neither 

requirement nor recommendation.

117 Department of Justice, Americans with Disabilities Act (ADA), 42 USC 1201 et 

seq., implementing regulations at 28 CFR § 36.104.
Appendix B: Glossary of REP Terms

301 Radiological Emergency Preparedness Program Manual

Single Point of Failure (SPOF): A single point of 

failure (SPOF) is a potential risk posed by the design, 

implementation, or configuration of a system in which 

one fault or malfunction causes the entire system to stop 

operating. It is “critical” when there are no mitigating 

factors such as back-up or redundant systems.

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 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 day cares, 

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. 

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.

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 Plan (TEP): is the foundation 

document guiding a successful exercise program. The TEP 

articulates overall exercise program priorities and outlines 

a schedule of training and exercise activities designed to 

meet those priorities. The TEP is the result of a Training and 

Exercise Planning Workshop (TEPW). 
Appendix B: Glossary of REP Terms

Radiological Emergency Preparedness Program Manual 302

Training and Exercise Planning Workshop (TEPW):

usually conducted in order to create a Multi-Year Training 

and Exercise Plan (TEP). 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 TEP 

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 C: REP Guidance References

303 Radiological Emergency Preparedness Program Manual

Appendix C: REP Guidance 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 1980.

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-12, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 2 – The Milk Pathway, 

Washington D.C., September 1987.

10. FEMA-REP-13, Guidance on Offsite Emergency Radiation Measurement Systems, Phase 3 – Water and Non-Dairy 

Food Pathway, May 1990. (Pre-decisional draft)

11. NUREG-1442, Revision 1/FEMA-REP-17, Revision 1, The Emergency Response Resources Guide for Nuclear Power Plant 

Emergencies, July 1992.

12. FEMA-REP-21, Contamination Monitoring Standard for a Portal Monitor Used for Radiological Emergency Response, Washington D.C., 

March 1995.

13. FEMA-REP-22, Contamination Monitoring Guidance for Portable Instruments Used for Radiological Emergency Response to Nuclear Power 

Plant Accidents, Washington D.C., October 2002.
Appendix C: REP Guidance References

Radiological Emergency Preparedness Program Manual 304

Other FEMA-REP Guidance Documents

14. FEMA GM-8, Revision 1, RAC Coordination with Utilities, October 3, 1983.

15. FEMA GM-21, Revision 1, Acceptance Criteria for Evacuation Plans, February 29, 1984. 

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. Radiological Emergency Preparedness Exercise Preparation Tool 3.0, 2013.

22. Radiological Emergency Preparedness Program Credentialing Framework, December 2010.

NIMS/NRF Guidance

23. National Incident Management System, December 2008.

24. Homeland Security Exercise and Evaluation Program (HSEEP), April 2013.

25. National Response Framework, second edition, May 2013.

26. National Response Framework, ESF#15 – External Affairs Annex, January 2013.

27. National Response Framework, Public Affairs Support Annex, January 2013.

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

29. National Response Framework, Mass Evacuation Incident Annex, June 2008.

Other Federal Agency Guidance

30. Voting Rights Act of 1965, 42 U.S.C. Part 1973-1973aa-6, as amended.

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. Environmental Protection Agency, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents 

(Draft for Interim Use and Public Comment), March 2013.

34. 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

305 Radiological Emergency Preparedness Program Manual

35. Federal Register Volume 66, No. 13, pp. 5427-5440, Consideration of Potassium Iodide in Emergency Plans, Final 

Rule, Nuclear Regulatory Commission, January 19, 2001.

36. 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).”

37. 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.

38. Guidance for Federal Agencies and State and Local Governments: Potassium Iodide Tablets Shelf Life Extension, 

Food and Drug Administration, March 2004.

39. NUMARC/NESP-007, Revision 2 – Methodology for Development of Emergency Action Levels, January 1992. 

40. Memorandum from Kay Goss to Regional Directors, dated February 2, 1999, Guidance for Providing Emergency 

Information and Instructions to the Public for Radiological Emergencies Using the New Emergency Alert 

System (EAS). 

41. Policy Statement on Respiratory Protection, November 22, 1985. 

42. FEMA-517 – Basic Guidance for Public Information Officers (PIOs).

43. NUREG/CR7002, Criteria for Development of Evacuation Time Estimate Studies

44. American National Standards Institute, Standard N13.11-2009, Personal Dosimetry Performance Criteria for Testing. 

45. 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. 

46. The Joint Commission: Hospital, Emergency Management Chapter, Standard EM.02.02.05, July 2012.

47. Occupational Safety Health Act (OSHA), “Best Practices for Hospital-Based First Receivers of Victims from MassCasualty Incidents”, January 2005.
Appendix D: Historical REP Guidance References

Radiological Emergency Preparedness Program Manual 306

Appendix D: Historical REP Guidance 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 – User’s 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.

18. RG REP 06, Emergency Alerting System, February 1998

19. Initiative 1.2: Reduce Frequency of Evaluation, October 1, 1999.
Appendix D: Historical REP Guidance References

307 Radiological Emergency Preparedness Program Manual

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 and FEMA Action to Qualify Alert and Notification Systems Against NUREG-0654/FEMA-REP-1.

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

Radiological Emergency Preparedness Program Manual 308

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.” 

61. Memorandum from Robert Wilkerson to Frank Begley dated December 23, 1986 on “Mobilization of Emergency 

Response Personnel.”
Appendix D: Historical REP Guidance References

309 Radiological Emergency Preparedness Program Manual

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 “Offsite 

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.” 

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.”
Appendix D: Historical REP Guidance References

Radiological Emergency Preparedness Program Manual 310

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.”

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.”
Appendix D: Historical REP Guidance References

311 Radiological Emergency Preparedness Program Manual

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.”

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.” 
Appendix D: Historical REP Guidance References

Radiological Emergency Preparedness Program Manual 312

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.” 

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 Backup 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.”
Appendix D: Historical REP Guidance References

313 Radiological Emergency Preparedness Program Manual

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 Ihor Husar to Robert Bissell and RAC Chairs dated July 23, 1999 on “Request for Consensus on 

the Standard Exercise Report Format (SERF).”

149. 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).”

150. 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.”

151. Memorandum from Vanessa Quinn to Woodie J. Curtis dated July 21, 2000 on “State of Illinois Determination on 

KI Inventory Potency.”

152. 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).”

153. Letter from Richard Meserve to Thomas Ortciger dated November 9, 2001 on “fast-breaking emergencies.”

154. Memorandum from Richard Krimm to Warren, undated, on “Granting Credit for Objectives 32 and 33.”

155. 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

156. Memorandum of Understanding with Transportation Safety Board dated February 27, 1997.

157. 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 E: List of Commercial Nuclear Power Plants

Radiological Emergency Preparedness Program Manual 314

Appendix E: 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
Appendix E: List of Commercial Nuclear Power Plants

315 Radiological Emergency Preparedness Program Manual

Site Code Site Name Number of Units Location

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

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
Index

Radiological Emergency Preparedness Program Manual 316

Index

“350” approval 8

access control

at emergency operations center 68

at joint information center 62

definition 277

during post-plume phase 186

equipment for 181

implementation 190

in HAB incident 35

in letter of agreement 26

of evacuated areas 100

of restricted areas 97, 124

to contaminated vehicles and equipment 105

access/functional needs

alert and notification considerations 43

definition 277

EAS messages addressing 48

evacuation considerations 90, 98

identification of individuals 57

in public information materials 55, 257

monitoring of service animals 105

precautionary protective actions for 86

protective actions for 185, 189, 217

public information for 199

service animals 7

shelter accessibility 95

accident assessment

definition 277

training of personnel 142

action level. See trigger/action levels

activation

definition 277

drills 156

exercise credit for 175

implementation 179

of alert and notification system 43, 197

of alternate personnel 35

of communications links 50

of emergency response organization 23

of facilities 69

of field teams 77

of joint information center 61

of letters of agreement 26

of personnel 53

of public inquiry function 65

of transportation resources 91

activity types. See HSEEP: activity types

After-Action Meeting 155, 174

definition 278

After-Action Report 173, 224

definition 278

issue numbering 172

Alert and Notification System 262

activation 197

administrative procedures 46

annual letter of certification 246, 248, 252

backup systems 44, 198, 218

design objectives 44

equipment 45

Evaluation Report Template 266

exception areas 44, 198

FEMA evaluation of 263

in Public Information Review Guide 258

primary system 44

reasonable time 298

survey 45

alternate communication links 50

alternate communications

system 181

alternate EAS station 197

alternate evacuation routes 94

alternate facility

emergency operations center 68

joint information center 61, 66

alternate notification pathways in HAB incident 40

alternate personnel

activation 179

in HAB incident 35

alternative approaches

approval process 233

to meeting requirements 2

alternative evaluation methods

no/minimal release exercise 165

alternative methods

protective action development 100, 184, 217

alternative systems for alert and notification 45

annual letter of certification

correction of planning issues reported in 175
Index

317 Radiological Emergency Preparedness Program Manual

equipment and supplies reported in 181

exercise results in 139

guidance 246

ingestion information in 133

letters of agreement in 27

media briefing materials in 67

public information materials in 55

requirement for 148

review guide 248

siren test reporting 46

verification during site assistance visit 237

Area Requiring Corrective Action (ARCA)

consideration of in exercise planning 167

correction of 175

correction of during exercise 170

correction of plan/procedure 148

definition 170, 279

discussion in public meeting 169

in After-Action Report 173

issue numbering 171

multiple assessed as Deficiency 171

assessment strategy. See planning and preparedness assessment strategy

backup alert and notification. See Alert and Notification 

System: backup systems

backup notification

of response organization 23, 39

backup route alerting. See Alert and Notification System: 

backup systems

calibration

definition 279

demonstration of 182

for medical services monitoring 123

of air sampling equipment 78

of laboratory equipment 196

records to support demonstration credit 176

reporting in annual letter of certification 251

requirements 71

verification in equipment check 79

check source 72, 79, 115, 123, 182

definition 279

Concepts and Objectives Meeting 154, 167

definition 280

congregate care

center locations map 88

clearance to enter 106, 202

definition 281

demonstration of 203

evacuation of students to 190

facilities annual letter of certification 251

in public information materials 57, 259

contamination

control of 106

definition 281

detection. See monitoring

in food 102

of animal feed 102

core capabilities 5, 227

definition 282

from the National Preparedness Goal 16

day cares

definition 282

in public information materials 56

in Public Information Review Guide 257

protective actions for 90, 185

decontamination

after reentry 187, 192

collection of waste water 117

definition 282

determining need for 114

during provision of medical services 204

following reentry 124

of emergency workers and equipment 116, 202

of evacuees 201

of pets 7

procedures 105

related to provision of medical services 120, 123

trigger/action levels 105, 116

Deficiency 9, 211

classifying the issue as 170

correction 155, 174

definition 170, 283

discussion in public meeting 169

for criterion not demonstrated 172

in After-Action Report 173

no/minimal release scenario 165

notifying State 172

post-exercise timeline 155

reporting 148

withdrawal of reasonable assurance 213

demonstration requirements matrix 158

Disaster Initiated Review 261

dose calculation 109

dose limits 13, 107, 110, 113, 183

authorizations to exceed 112, 188

definition 283
Index

Radiological Emergency Preparedness Program Manual 318

procedures to exceed 114

dosimetry

annual letter of certification 252

definition 283

during reentry 187, 193

for emergency workers 108, 183, 188

for reentry 125

group use 109, 188

in HAB incident 112

inventory 71, 181

procedures 112, 119, 123

record keeping 111

supply 70

training 140

types 71, 108

verification during site assistance visit 237

early (plume) phase 15, 82, 109, 124

definition 283

Emergency Alert System

as part of alert and notification system 45

definition 284

demonstration 200

evaluations of EAS stations 197

information in Public Information Review Guide 256

in public information materials 56

message requirements 48

non-English message requirements 260

use of 42

Emergency Classification Level 37

definition 284

emergency planning zone

changes to 234

definition 284

description 14

evacuation time estimates 96, 98, 237

definition 285

evaluation frequency for Demonstration Criteria 158

evaluator credentialing 235

exception areas

Alert and Notification System 198

definition 285

exercise credit for actual events 157, 175

exercise cycle

exemption from demonstration 176

ingestion demonstration requirement 133

length 130, 218

requirements during 129, 157

scheduling activities and requirements 155

exercise evaluation guides 167, 227

definition 285

exercise planning team 163

definition 285

exercises

full-scale 156

functional 156

issue numbering 172

tabletop 156

exposure

definition 286

limits. See dose limits

pathways 11

public information on effects 66

exposure control

considerations for hostile action incidents 111

emergency workers 108, 113

general public. See protective actions

post-plume 124

potassium iodide 92

fast breaker incident. See rapidly escalating incident

Final Planning Meeting 154

definition 287

foreign-language translation

public information materials 49, 59

full-participation

definition 288

versus full-scale 130, 156

full-scale exercise 156

definition 288

functional exercise 156

definition 288

hostile actions

as scenario variable 131

definition 289

evacuation during 94, 96, 100

exposure control during 111

in exercise planning 164

notification pathways during 40, 51

onsite support during 35

program enhancements to address 6

protective actions during 87, 183

release of sensitive information during 63

use of alternate resources during 35
Index

319 Radiological Emergency Preparedness Program Manual

hot wash 155, 168, 169, 282

definition 289

HSEEP

activity types 155

exercise documents 166

exercise evaluation guides 227

integration with REP 152, 224

planning meetings 167

REP assessment strategy and 2

REP requirements and 6

use in REP exercises 128

ingestion exposure pathway

protective actions 102

ingestion pathway

public information materials for 58

Initial Planning Meeting 154

definition 290

intermediate (ingestion/relocation) phase 13, 15, 82, 

124, 126, 192

definition 290

issue correction 174

during an exercise 170

issues

numbering of 172

types 170

KI. See potassium iodide (KI)

late phase 15, 82, 124, 126

definition 291

media information 66

media inquiries

information in media briefing 66

JIC capability to handle 61

Midterm Planning Meeting 154

definition 292

monitoring

definition 293

drills 136

during medical transport 123

equipment 70, 71, 115, 181

of emergency workers and equipment 108, 202

of evacuees 95, 104, 201

of pets 7

portal monitors 72, 105

procedures 115

re-monitoring after decontamination 116

training 143

National Incident Management System 5

definition 293

National Preparedness Goal 2, 5, 16, 224

National Preparedness System 5

no/minimal release scenario

exercise planning for 165

requirement for 131, 157

pets 7, 277, 300

in public information materials 48, 57

phone survey of alert and notification system 45

plan issue 170

definition 295

planning and preparedness assessment strategy 2, 10, 177

Demonstration Criteria 152

in no/minimal release exercises 165

used in activity types 155

planning meetings

definition 295

milestones table 154

plan review

general guidance 238

potassium iodide (KI)

administration as protective action 12

decision-making guidance 93

definition 296

demonstration requirements 159, 183, 184

effect on TEDE calculation 109

Federal policy and guidance 238

for emergency workers 110, 188

for persons with disabilities and access/functional needs 

185

for the general public 13, 189

in hostile action incidents 111

in media information materials 66

in public information materials 56, 259

inventory reporting 157, 181, 237, 252

planning guidance 92

training for emergency workers 140

precautionary actions 86, 99, 102, 186

definition 296

messages for the public 48

protective action guides 12, 82, 86

definition 297

protective actions 11, 38, 84, 87

decision making 99

ingestion exposure pathway 102
Index

Radiological Emergency Preparedness Program Manual 320

in public information materials 56

message for the public 44, 48

public information

considerations for HAB incidents 63

definition 297

EAS messages 48

emergency information 199

foreign-language requirements 49, 59, 260

for the ingestion pathway 58, 60, 192

for transient populations 57, 60

guidance 56

media information 66

officer: roles and responsibilities 62

periodic dissemination 60

review guide 256

public inquiry 48, 64, 65, 200

public meeting

following qualifying exercise 211

for formal 350 approval 206

post-exercise 168, 169

qualifying exercise 9

rapidly escalating incident

definition 298

planning protective actions for 86

requirement for exercises 129, 131, 157

requirements for alert and notification 44

scenario variable 165, 218

reasonable assurance

Deficiency and 170

definition 2, 298

demonstration 166

Disaster Initiated Review and 261

FEMA plan review 8

in regulations 4

ongoing assessment 10

REP-HSEEP integration and 224

role of exercises 130

statement for 350 approval 207

statement in annual letter of certification 247

statement in exercise report 173

withdrawal of 213

reasonable time. See timely manner

definition 298

registration

evacuees 106, 201

individuals needing assistance in an evacuation 57

release. See also no/minimal release scenario

definition 299

during exercise play 7, 132

of information 48, 61, 63, 64

protective actions 87, 92, 99

radiological 6, 11, 15

rumor control. See public inquiry

scenario review

reviewer checklist 242

scenario types 164

scenario variables 164

sensitive information

access/functional needs individuals 57

in hostile action incident 63

service animals 7, 57, 91, 95, 104, 201, 203

definition 7, 300

site code

in issue numbers 171

staff assistance visit 237

survey of alert and notification system 45

tabletop exercise 156

definition 301

timely manner

alert and mobilization 179

alert and notification 197

alert and notification in exception areas 198

definition 301

emergency public information 199

primary route alerting 197

protective action decision making 184

providing KI and dosimetry to emergency workers 183

transient populations

alert and notification of 44, 46, 197

as scenario variable 132, 165

definition 302

included in monitoring capacity estimate 104

potassium iodide for 181

public information materials for 55, 57, 60, 249, 257

trigger/action levels

definition 302

trigger/action levels for decontamination 105, 116


FEMA P-1028

Catalog No. 15021-1