COMMISSION BRIEFING SLIDES/EXHIBITS

MEETING WITH FEMA AND

STATE/LOCAL REPRESENTATIVES ON

OFFSITE EMERGENCY PREPAREDNESS ISSUES

AUGUST 12, 2008
0

UNITED STATES NUCLEAR REGULATORY COMMISSION

Protecting People and the Environment

EMERGENCY PREPAREDNESS

(EP) INITIATIVES: Meeting with

FEMA, State and Local

Representatives
0

Cooperation and Collaboration

" Historical Perspective

" Joint Initiatives

* Continuing Outreach

2
1

Hostile Action-Based (HAB) EP Drills

4 What are HAB drills?

http://www.nrc.gov/about-nrc/emerq-preDaredness/resPond-to-emerq/hostile-action.html

* Status

" Lessons Learned

- Incident Command System

- Emergency Response Organization Mobilization

- Protective Action Decision-making

- Timely Communications With Public3
Challenging Exercise Scenarios

* Avoid Preconditioning

* Varying Event Escalation Conditions

" Varying Release Conditions

" Varying Initiating Events

*Informed Process (Stakeholder In put)

" Focus Groups

" Public Meetings

4
Moving Forward

SRulemaking and Guidance Changes

* Coordinated Scheduling

Challenges

5
*)FEMA

Meeting with FEMA, State and Local

Representatives on Offsite Emergency

Preparedness Issues

R. David Paulison, Administrator, FEMA

Dennis Schrader, Deputy Administrator, National

Preparedness, FEMA

James Kish, Director of Technological Hazards, FEMA

/INDFEMA

Augs 2 2008
FEMA

Agenda

U Hostile Action-Based Drills

L) Exercise Scenarios

Q FEMA Guidance Revisions and Support of NRC Rulemaking

Ll Leverage Ongoing Initiatives of National Preparedness

* HSEEP

* Integrated Planning System

2
_FE-MA *

Hostile Action-Based Drills

I3 Primary issue identified during drills: Coordination between onsite

(licensee) and offsite response organization (ORO) resources

-Licensees and OROs may have different protocols for responding to hostile action

based events

* Additional Federal agency resources (e.g., FBI, DHS, DOE) will need to be

included

U REP Program exercise requirements will need to still be demonstrated

through an alternate means (if not during the biennial exercise) for

FEMA to maintain "reasonable assurance

El In-Progress Review (IPR) planned for late September 2008

* Provide status to and solicit additional input from stakeholders

m Exact date and location TBD

3
$3FEMA --

Exercise Scenario Design and Development

Ll Task Force is proposing to increase scenario realism within the. 6-year

exercise cycle to include:

* "No" or minimal release

* Variance of release conditions (e.g., ground, elevated, puff, continuous)

* Non-sequential. escalation of Emergency Classification Levels (ECLs)

* Relax the need to escalate to General Emergency at every exercise

Incorporate hostile action, local hazards, and seasonal conditions into exercise schedule

EL Issues resulting from exercise scenario changes:

* Exercises will need to balance hazards (e.q., natural, technical, hostile action.) while preserving the

essential objectives that form the basis of reasonable assurance' core to the REP program

N Incorporatinq all hazards events into REP presents new functions and criteria to evaluate that are not

currently addressed in REP exercises and in some cases require development of success criteria

E Balancing increased flexibility into the development of scenarios and extents of play for REP

exercises

Li Grant constructive credit for other exercise and real life events

* Incorporate the tenets of HSEEP

* Guidance on this will be included in the Draft REP Program Manual

4
(,& FEMA

.FEMA Guidance Revisions and Support of NRC Rulemaking

D Goal is to align NRC rulemaking and FEMA guidance revisions with

current national preparedness initiatives

O Update of REP Program Manual will be NIMS and HSEEP compliant,

incorporate Hostile Action Based initiating events and allow for

scenarios that reduce predictability

LI FEMAINRC relationship has evolved to ensure alignment

* FEMA/NRC Exercise Scenario Task Force

* Joint FEMA/NRC effort to solicit and incorporate stakeholder feedback

-Accelerated rulemaking process

D Strategy to preserve these efforts following the election under

development

b
FEMA

Federal Register Publication Processes

SEP 2008

FEB 2009

OCT 2008 FEB 2009 NOV 2008

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_IlLLLJLNLOIS' PERSPECTIVE ON

OFFSITE EMERGENCY

PREPAREDNESS

HOSTILE ACTION-BASED DRILLS

CHALLENGES, LESSONS LEARNED, AND

IMPROVING STAKEHOLDER COORDINATION

Joe Klinger

Assistant Director

Illinois Emergency Management Agency

Division of Nuclear Safety
OVERVIEW

* State of Illinois participates in numerous exercises

.each year

- Six nuclear plant sites in Illinois

- Three Radiological Emergency Preparedness (REP) exercises

per year, plus three associated pre-drills

-In 2007 and 2008, this increased with two tabletops and two

hostile action-based drills per year

Amount of effort, e.g. messages, coordination, and data

development, is at least-as much as that required in a normal

REP exercise
LESSONS LEARNED

* Rev 1. to NEI 06-04 is a good methodology for the way

hostile action drills are conducted

* Stay with REP drill concepts; no need to reinvent the,

wheel

* Tabletops were very valuable in improving inter-agency

coordination, cooperation, and communications

. In a hostile action drill the radiation threat is secondary

unlike a typical REP Exercise
LESSONS LEARNED

* When radiation is not the primary threat shelter in place becomes

the preferred strategy

* Licensee reluctant to use the "impediment clause" in their

procedures

* Our standard REP procedures are still effective and used in

response to a hostile action scenario: predictive dose assessment,

KI evaluation, protective action recommendation process

* The radiological field component is also deployed in the response

* The radiological response liaisons are also deployed: JIC, TSC,

EOF and affected counties
THE CHALLENGE

e Everyone is already busy with required exercises and

real events

" The additional two Hostile Action tabletops and two

drills to the existing three REP exercises and pre-drills

have stretched available resources

* Going forward, the hostile action drills need to be used

as one of the existing REP exercises in the six year

exercise cycle.
SPECTRUM OF EXERCISE SCENARIOS

* The extent of play must allow flexibility:

- Exercise scenarios must be realistic otherwise training is

negative

- Source terms used must reflect simulated accident conditions

-. Scenarios must vary so that players do not anticipate actions

always happening at prescribed times

- Allow non-sequential classification progression
SPECTRUM OF EXERCISE SCENARIOS

* Guidance should be flexible to include a wide spectrum

of accidents and release types from no release to

major core failure

e A release is not required to ensure protective action

recommendation analysis is adequate

* Response activities can be demonstrated without a

release occurring, i.e., field team deployment and

environmental monitoring
!

INTEGRATED EMERGENCY

MANAGEMENT

* In Illinois there is already strong integration of

resources among the various counties and the State

* Illinois has established the State Terrorism and

Intelligence Center (STIC) to coordinate all security

threats

* Illinois Mutual Aid-Agreements are in place, i.e. fire,

law enforcement, and public health

* Illinois has addressed interoperability issues by instituting a common radio platform - StarComm2l
CONCLUSION

e Hostile Action drills have provided additional learning opportunities

for utilizing existing and new resources and interfaces

e Hostile Action drills are programmatically equivalent to the

standard REP exercises and should be treated accordingly

* Hostile Action drills should be integrated into the current REP

Program

* Concerns exist that the Hostile Action drills will become an

additional required drill and that prescriptive criteria will be

required in extent of play
Proposed REP Program Changes

State of Ohio

' OHIO DEPARTMENT

OF PUBLIC SAFETY EDUCATION - SERVICE - PROTECTION

TED STRICKLAND, GOVERNOR

HENRY GUZMAN, DIRECTOR

WWW.PUBLICSAFETI•t .OIOSV

Nancy Dragani, Executive Director

Ohio Emergency Management Agency, a Division of the Ohio Department of Public Safety
Challenges and Lessons-Learned from

Hostile Action-Based EP Drills

• Ohio has participated in one hostile action-based drill -

9/12/2007 with PNPP

* Protective action recommendations and decisions require

new considerations

* ICS integration into REP Planning - particularly protective

action decisions

~v" OHIO DEPARTMENT

EDUCATION - SERVICE . PROTECTION

TED STRICKLAND, GOVERNOR

HENRY GUZMAN, DIRECTOR 2.O

Ohio Emergency Management Agency, a Division of the Ohio Department of Public Safety
Challenges and Lessons-Learned from

Hostile Action-Based EP Drills

* First Responders are now engaged on-site rather than

with traditional off-site REP duties

* Many state and local personnel gravitated toward

standard REP exercise concerns

* Development of planning standards must accompany

changes to exercise requirements

~ OHIO DEPARTMENT

OF PUBLIC SAFETY EDUCATION - SERVICE - PROTECTION

TED STRICKLAND, GOVERNOR HENRY GuzmAN, DIRECTOR 3

Ohio Emergency Management Agency, a Division of the Ohio Department of Public Safety
Spectrum of Exercise Scenarios

• Varying exercise scenarios are needed to avoid a

programmed response - minimize predictability

* Current exercise guidelines- do not allow the scenarios to

be varied sufficiently

* A spectrum of scenarios will promote realistic

discussions regarding actions to be taken, rather than an

automatic completion of default actions

* Exercise scenarios should cover less severe accident

scenarios (no release) as well as the very improbable

most severe cases

•'.v OHIO DEPARTMENT

•/r• OF PUBLIC SAFETY

.m M " EDUCATION • SERVICE • PROTECTION

TED HENRY STRICKLAND, GUZMAN, GOVERNOR DIRECTOR 4

WWW.PU BLICSAFETY.OHIO.GOV

Ohio Emergency Management Agency, a Division of the Ohio Department of Public Safety
Spectrum of Exercise Scenarios

* Excessive out-of-sequence activities or activities driven

by controller injects should be avoided

* Probability, possibility, and realism

* A balance must be achieved with respect to the

responsibility to exercise all aspects of the response,

realism, and predictability

•='•., OHIO DEPARTMENT

OF PUBLIC SAFETY EDUCATION . SERVICE . PROTECTION

TED HENRY STRICKLAND, GUZMAN, GOVERNOR DIRECTOR 5

Ohio Emergency Management Agency, a Division of the Ohio Department of Public Safety
Improving Coordination

* Improve REP program guidance to ensure requirements

are clear and applied uniformly across FEMA regions

and through the NRC to licensees.

* NRC / FEMA alignment on exercise issues is paramount

* Increased federal participation during exercises would be

beneficial

* Ensure the integration of REP with more recent FEMA

initiatives

OHIO DEPARTMENT

OF PUBLIC SAFETY EDUCATION - SERVICE ' PROTECTION

TED HENRY STRICKLAND, GUZMAN, GOVERNOR DIRECTOR 6

WWW.PUBLICSAFETY.OHIO.GOV

Ohio Emergency Management Agency, a Division of the Ohio Department of Public Safety
Ohio Emergency Management Agency

2855 West Dublin- Granville Road

Columbus,. OH 43235

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;:-' OHIO DEPARTMENT

OF PUBLIC SAFETY EDUCATION • SERVICE ' PROTECTION

TED STRICKLAND, GOVERNOR

HENRY GUzMAN, DIRECTOR

WWW.PURL CSAFETY.OIIIO.OV

7 *EMA

Ohio Emergency Management Agency, a Division of the Ohio Department of Public Safety
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