FEMA GRANTS AND PROGRAMS RADIOLOGICAL EMERGENCY PREPAREDNESS PROGRAM (REPP) The purpose of the Radiological Emergency Preparedness Program (REPP) is to systematically guide the FEMA-led assessment of the adequacy of State and local government emergency plans and the capability of the State and local government officials to implement them (e.g., adequacy and maintenance of equipment, procedures, training, resources, staffing levels, qualifications) and report the findings and determinations to the Nuclear Regulatory Commission (NRC). This effort is conducted with the assistance of other Federal agencies. Together, NRC and DHS will determine the 2-year evaluated emergency preparedness exercise requirements for nuclear power plant operators and State and local governments. In this manner, both on-site and off-site emergency preparedness capabilities are adequately evaluated. A biennial exercise requires the licensee and State and local governments to be evaluated and graded by FEMA on their off-site emergency preparedness plans once every 2 years in conformance with 44 Code of Federal Regulations Part 350. Summary of Findings The Analysis of Federal Requirements Team conducted cooperative discussions with 15 States regarding their perceptions of the REPP. All (100%) of the States believed the REPP supported preparedness capabilities statewide. Each of the jurisdictions were asked to reply to a series of questions pertaining to reporting requirements, timeline requirements, grant guidance, grant approval process, resource requirements, and program summary issues. Reporting Requirements Of the 15 States that responded, 100% stated the frequency of the reporting requirements was not a concern. It was pointed out, however, that FEMA s insistence on printed documents and refusal to take electronic submissions caused a great deal of time to be spent printing and mailing paper copies of maps and plans. The majority believed there were no unnecessary reporting requirements. Several States pointed out that this is a mature program that works effectively. There were no suggested improvements offered for reporting requirements. Timeline Requirements There is no program application for the REPP. There is a negotiated contract between the State and affected utility companies that identifies program and exercise activities, etc. Similarly, there are no Federal requirements for financial reporting. A written budget is submitted to the utility company, thereby negating timeline issues. AFR Final Report REPP 1 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs
Grant Guidance Given the mature nature of this program and the fact that the annual award of funds to the States are negotiated between the utility companies and the States, there are few significant issues raised in terms of grant guidance. The only issue raised was that the Buffer Zone Protection Program (BZPP) tends to duplicate existing planning at nuclear power plants and the security planning is not coordinated with the emergency off-site planning. It is recommended the BZPP, especially as it impacts nuclear power plants, needs to be coordinated and shared with the emergency planners at the State and local levels. Grant Approval Process All of the REPP States either did not respond or said there were no issues or concerns regarding the length of the grant approval process. Six (40%) of the 15 States indicated the grant approval process was not applicable to the REPP. Resource Requirements The majority (10) of the States have identified a need for additional personnel to administer the REPP. Five States believed their staffing levels were sufficient to administer the program. The variance in the number of personnel required for the REPP is because of the number of jurisdictions located within the 10-mile emergency planning zone (EPZ). Those areas with small populations and few jurisdictions require far less support than a site with several heavily populated municipalities or counties within the EPZ. States need additional funding to procure and maintain radiological emergency equipment such as dosimetry. Those States having adequate dosimetry require upgrades to modernize the equipment. This is a holistic issue, State legislatures often cap funding for support of the dosimetry and this modernization does not address an even bigger issue of how DHS is funding jurisdictions for a chemical, biological, radiological, nuclear, and/or explosive (CBRNE) response. The Homeland Defense Equipment Reuse Program was an attempt by DHS and other agencies to address the shortage of radiological equipment at the State/local level. Program Summary Issues All States said the REPP improves preparedness. The majority believed the REPP achieves this through its requirements for training and exercises and provides the capability to identify radiological material, respond to accidents and monitor health, safety, and the spread of a radiological plume. In addition, all States responding agreed the program supports their State Strategy for such things as building capability to respond and manage any incidents, to respond to CBRNE and critical infrastructure disasters, and, in general, maintain a higher state of readiness consistent with this strategy. States believed the challenge now is to integrate new security planning and exercises, which will be required as part of the BZPP program into existing plans and exercises with local and State jurisdictions and responders. While many responders will be the same as for a nuclear accident, there will be increased numbers and new skill sets required of responders if terrorists initiate the incident. These new Federal and State players must be integrated into plans and must participate in future exercises. The DHS Comprehensive Review Impact of Federal Program Requirements REPP 2 AFR Final Report FEMA Grants and Programs October 2007
for Nuclear Power Plants must be shared with State and local officials responsible for these plans. States and local jurisdictions want to prioritize homeland security funding to maximize needed capability based on good assessments of the threat and security shortcomings. Program Requirements Impacting State Emergency Management/Homeland Security Agencies 1. Reporting Requirements a. Is the frequency of the reporting requirements a concern of the State? Yes No 14 Unanswered 1 Of the States surveyed, the great majority responded that the frequency of the reporting requirements was not a concern. It was pointed out, however, that FEMA s insistence on printed documents and refusal to take electronic submissions caused a lot of time to be spent printing and mailing paper copies of maps and plans. b. Are there any unnecessary reporting requirements? Yes 2 No 12 Unanswered 1 The only two States that felt there were unnecessary reporting requirements cited the annual letter of certification to FEMA and both the quarterly inventory and the annual calibration report. c. Are any of these reporting requirements covered in other Federal program requirements? Yes 2 No 8 Unanswered 5 Some States felt they were covered in U.S. Department of Agriculture, NRC, National Incident Management System, and Emergency Management Performance Grant (EMPG) requirements. d. Is the electronic reporting submittal process for this program a concern? Yes 1 No 8 Unanswered 6 The assessment tool collected data in four categories: 0% of the respondents said it takes too long to input data. 0% indicated they had system availability issues. AFR Final Report REPP 3 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs
0% indicated they have lost data previously entered. 0% have experienced the system timing out during use. It was again pointed out that FEMA s insistence on paper reporting is problematic. e. Suggested improvements. Several States pointed out that this is a mature program that really works well. There were no suggested improvements. 2. Timeline Requirements a. Are timeline requirements acceptable for submitting the program application? Yes 3 No 1 Unanswered 11 There is no program application. There is a negotiated contract between the State and the utility company. In at least one State, the legislature has set a cap on the funding for this program. b. Are timeline requirements acceptable for Investment Justification plans? Yes No Unanswered 7 N/A 8 There is no Investment Justification plan for this program. c. Are timeline requirements acceptable for financial reporting? Yes 5 No Unanswered 10 There are no Federal requirements for financial reporting. A written budget is submitted to the utility company. The exception is if the money is used as a match for EMPG, then EMPG requirements are met. d. Are timeline requirements acceptable for program reporting? Yes 6 No Unanswered 9 There are no Federal requirements for program reporting. The exception is if the money is used as a match for EMPG, then EMPG requirements are met. Impact of Federal Program Requirements REPP 4 AFR Final Report FEMA Grants and Programs October 2007
e. Are there other timeline issues? No specific comments were received for timeline issues. There may be some opportunities to save time or increase capabilities by ensuring that REPP, BZPP, and, potentially, other program activities are coordinated. f. What recommended improvements do you have regarding the timeline requirements? No specific timeline requirement recommendations were received. 3. Grant Guidance a. Is the grant guidance too lengthy? Yes No 1 Unanswered 14 Only one State replied to this question. b. Is the grant guidance understandable? Yes 1 No Unanswered 14 Only one State replied to this question. c. Is the grant guidance consistent? Yes 1 No 1 Unanswered 13 The one State that responded in the negative suggested that the BZPP tends to duplicate existing planning at nuclear power plants, and the security planning is not coordinated with the emergency off-site planning. d. Is the grant guidance timely? Yes 1 No Unanswered 14 Only one State replied to this question. e. Are there other grant guidance issues? None reported. AFR Final Report REPP 5 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs
f. Any recommended changes for grant guidance improvement? BZPP, especially as it impacts nuclear power plants, needs to be coordinated and shared with the emergency planners at the State and local levels. 4. Grant Approval Process a. Do you have any concerns regarding the length of the grant approval process? Yes No 6 Unanswered 9 All of the REPP States responded with either a No answer or did not answer the question on concerns regarding the length of the grant approval process. Six (40%) of the 15 States indicated the grant approval process was not applicable to the REPP. b. If used, is the Peer Review an acceptable process? Yes No Unanswered 15 None of the States answered the Yes/No portion of the Peer Review process question and no one provided any comments. c. Are there other grant approval process issues? All of the States answered either No, not applicable, or did not answer the question about other grant approval process issues. d. Do you have any recommended improvements to the grant approval process for the program? No recommended improvements to the grant approval process were provided by any of the 15 REPP States surveyed. 5. Resource Requirements a. How many full-time equivalents (FTEs) are required to administer this program? The FTE numbers below summarize the range of personnel requirements identified by State population. FTE for the five large population States (greater than 10 million): Range 3 to 25 FTE for the six medium population States (3 to 10 million): Range 3 to 16.5 FTE for the four small population States (less than 3 million): Range 1 to 12.5 Impact of Federal Program Requirements REPP 6 AFR Final Report FEMA Grants and Programs October 2007
b. Number of FTEs currently assigned to this program. The FTE numbers below summarize the range of personnel currently assigned to this program by population size. FTE for the five large population States (greater than 10 million): Range 3 to 20 FTE for the six medium population States (3 to 10 million): Range 1 to 7.5 FTE for the four small population States (less than 3 million): Range 0.1 to 10.5 The majority (10) of the States have identified a need for additional personnel to administer the REPP. Five States indicated the staffing levels were sufficient to administer the program. The variance in number of personnel required for the REPP is because of the number of jurisdictions located within the 10-mile EPZ. Those areas with small populations and few jurisdictions require far less support than a site with multiple heavily populated municipalities or counties within the EPZ. c. If the FTEs required to administer this program are less than the FTEs currently assigned, why is there a difference? Several variables affect the difference between the number of FTEs assigned to the program and the number required. In those States that had a requirement for additional personnel, the primary reasons are noted below. The States lack the funds to hire personnel. States are short of manpower to accomplish the new requirements such as security drills and distribution guidance for Potassium Iodide (KI). d. Are additional non-personnel resources needed to accomplish this program? Yes 8 No 7 Additional non-personnel resources are required for the successful accomplishment of the REPP. These resources include the following: States need additional funding to procure and maintain radiological emergency equipment such as dosimetry. Those States having adequate dosimetry require upgrades to modernize the equipment. Training is required for the local jurisdictions on both emergency procedures as well as radiological equipment. If or when the new National Response Plan is published and includes animals in evacuations, the States will need additional funding for planning, training, and equipment to accomplish the evacuations around power plants. AFR Final Report REPP 7 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs
States have identified travel as a non-personnel requirement. To administer the program properly, additional travel funds are needed. Local jurisdiction emergency operations centers (EOCs) need computers, software upgrades, personal protective equipment, and modern radiological equipment to include background monitors. e. Other issues related to the personnel/resources for this program. The State receives no Federal funding for the REPP; all funds come from the power generation operator. The Federal Government should provide additional funding. f. Recommended improvements for the personnel/resources for this program. The States recommended several important considerations for the REPP that could improve personnel and other resourcing: Additional funding is needed for laboratory personnel to analyze data from the field. Federal assistance is needed to provide a higher level of staffing at both the State and local levels of government. States would like to improve the current capabilities by the upgrade of the older family of dosimetry to current models. Multi-State and regional exercises need to be improved to ensure the authorities can properly coordinate with agencies outside the normal every day working relationships. Granting security clearances is slow. Security clearances need to be granted on a timely basis. 6. Program Summary Issues a. Does this program improve preparedness in your State? Yes 15 No All States said the REPP improves preparedness. The majority felt strongly enough about it to add comments that focused on the training, exercises, ability to identify radiological material, respond to accidents and monitor health, safety, and the spread of a radiological plume. Two additional comments were that required nuclear power plant exercises improve/maintain EOC activation and operational procedures, and coordination across multiple jurisdictions and disciplines. Impact of Federal Program Requirements REPP 8 AFR Final Report FEMA Grants and Programs October 2007
b. Does this program support your State s Homeland Security Strategy? Yes 14 No Unanswered 1 All States responding agreed the program supports their State Strategy by such things as building capability to respond and manage any incidents, to respond to CBRNE and critical infrastructure disasters, and, in general, maintain a higher state of readiness consistent with this strategy. c. Does the program support the National Preparedness Goal? Yes 15 No All reported positively and four States added comments. The consensus is that the REPP has a close connection to issues of weapons of mass destruction, CBRNE, critical infrastructure, terrorism, and security activities and exercises. There is a direct spinoff of capabilities and support of the National Preparedness Goal. One State stated that Federal agencies should be more involved in these type exercises as a future event will challenge good coordination among local, State, and Federal assets. d. Are there any program requirements or items related to this program not previously discussed? Yes 10 No 5 REPP is an established program with valid requirements for annual plan reviews and improvement plans, certifications, training, and exercises involving the EPZ and the 50-mile Ingestion Zone. Except for the need for Federal funding to support these Federal requirements, it is a good program. The challenge now is to integrate new security planning and exercises, which will be required as part of the BZPP program into existing plans and exercises with local and State jurisdictions and responders. While many responders will be the same as with a nuclear accident, there will be increased numbers and skill sets of responders if terrorists initiate the incident. These new Federal and State players must be integrated into plans and must participate in future exercises. The DHS Comprehensive Review for Nuclear Power Plants must be shared with State and local officials responsible for these plans. States and local jurisdictions want to prioritize homeland security funding to maximize needed capability based on good assessments of the threat and security shortcomings. Other challenges raised are the coordination and eventual agreement among agencies now in or getting into nuclear security issues such as planning guidance where there are differences among the Office of Grants and Training, National Integration Center, U.S. Fire Academy, and FEMA; exercise guidance from NRC and DHS; equipment standards for radiation monitoring from the Department of Energy (DOE), DHS, FEMA, Environmental Protection Agency (EPA), and NRC; and decontamination standards from EPA, NRC, AFR Final Report REPP 9 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs
FEMA, and DOE. None of these organizations should be promoting stovepipe operations in and among nuclear facilities. e. What recommendations for improvement does the State have for this program? Recommendations for improvement included the following: Coordinate the National Infrastructure Protection Plan, BZPP, and REPP programs to maximize benefits from each program and coordinate activities. Involve the Federal Bureau of Investigation in security plans and exercises. Identify nuclear shipments, nuclear power plant security, and radiological transportation planning as eligible for homeland security grant funding. Evaluate the performance of Federal as well as State and local agencies in nuclear/ radiological exercises. Permit homeland security grant funding for new, more complicated security exercises with nuclear facilities. Share the DHS Comprehensive Review Final Report with States and counties so capability needs can be documented and prioritized in the annual homeland security grant funding. f. Has the State identified any other requirements from Federal agencies other than DHS and FEMA that can be associated with or related to this program? NRC Requires notification of transportation of radiological materials to States and from them to all points of contact through which the material will travel, designation of a State Liaison Officer, annual certification of State plans for response and for use of KI for emergency workers and the general population, and increasing activities concerning security exercises. DOE Regular exercises with State and local responders around their nuclear facilities. Centers for Disease Control and Prevention and EPA for planning, decontamination, and health issues of nuclear incidents. Impact of Federal Program Requirements REPP 10 AFR Final Report FEMA Grants and Programs October 2007
REPP PROGRAM Y/N COUNT SUMMARY WORKSHEET Summary Small States (8 Sites Surveyed) Medium States (7 Sites Surveyed) Large States (5 Sites Surveyed) # AFR Impact/Response (Template 3) Y/N Criteria Yes No N/A U Yes No N/A U Yes No N/A U Yes No N/A U 10. Reporting Requirements A. Is the frequency of the reporting requirements a concern of the State? 0 14 1 0 4 0 0 6 0 0 4 1 C. Are there any unnecessary reporting requirements? 2 12 1 0 4 0 1 5 0 1 3 1 E. Are any of these reporting requirements covered in other Federal Program requirements? 2 8 5 1 2 1 1 4 1 0 2 3 G. Is the electronic reporting submittal process for this program a concern? 1 8 6 0 3 1 1 3 2 0 2 3 11. Are Timeline Requirements acceptable for submitting: A. The application for this program? 3 1 11 1 0 3 1 1 4 1 0 4 C. Investment Justification plan? 0 0 8 7 0 0 3 1 0 0 4 2 0 0 1 4 E. Financial reporting? 5 0 10 2 0 2 2 0 4 1 0 4 G. Program reporting? 6 0 9 2 0 2 3 0 3 1 0 4 12. Is the Grant Guidance: A. Too lengthy? 0 1 14 0 0 4 0 1 5 0 0 5 C. Understandable? 1 0 14 0 0 4 1 0 5 0 0 5 E. Consistent? 1 1 13 0 0 4 1 1 4 0 0 5 G. Timely? 1 0 14 0 0 4 1 0 5 0 0 5 13. Grant Approval Process: A. Do you have any concerns regarding the length of the Grant approval process? 0 6 9 0 2 2 0 3 3 0 1 4 C. Is used, is the Peer Review an acceptable process? 0 0 15 0 0 4 0 0 6 0 0 5 14. Resource Requirements: E. Are additional non-personnel resources needed to accomplish this program? 8 7 0 3 1 0 3 3 0 2 3 0 15. Program Summary Issues: A. Does this program improve preparedness in your State? 15 0 0 4 0 0 6 0 0 5 0 0 C. Does this program support your State s Homeland Security Strategy? 14 0 1 4 0 0 5 0 1 5 0 0 E. Does this program support the National Preparedness Goal? 15 0 0 4 0 0 6 0 0 5 0 0 G. Are there any program requirements or items related to this program not previously discussed? 10 5 0 2 2 0 4 2 0 4 1 0 TOTALS 84 63 8 130 23 18 3 32 36 29 4 45 25 16 1 53 AFR Final Report REPP 11 Impact of Federal Program Requirements October 2007 FEMA Grants and Programs
THIS PAGE IS INTENTIONALLY LEFT BLANK Impact of Federal Program Requirements REPP 12 AFR Final Report FEMA Grants and Programs October 2007