ML25024A129

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Fema/Nrc: IPAWS Public Workshop Presentation
ML25024A129
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Issue date: 01/23/2025
From: Terres A
Policy and Oversight Branch, US Dept of Homeland Security, Federal Emergency Management Agency
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NRC/FEMA Public Workshop:

Integrated Public Alert and Warning System (IPAWS)

January 23, 2025

Meeting Agenda 9:00 - 9:10am - Opening Remarks, Introductions, and discussion of new trends (Cindy Rosales Cooper, NRC and FEMA) 9:10 - 9:45am - FEMA IPAWS Process Overview and Updates (Joshua Barnes, FEMA) 10:00 - 10:15am - NRC Approach to ANS Design Report Reviews (Don Johnson, Dwayne Myal, Alexandra Terres, NRC) 10:15 - 12:00pm - Questions and Answers

FEMA-NRC Workshop Alert and Notifications: Review Processl January 2025

Module 1 Legal Authorities

REPP

  • The REP Program was established by President Carter on December 7, 1979, following the Three Mile Island nuclear power plant (NPP) incident near Middletown, Pennsylvania. President Carter transferred the Federal lead role in offsite radiological emergency planning and preparedness activities around commercial NPPs from the U.S. Nuclear Regulatory Commission (NRC) to the Federal Emergency Management Agency (FEMA).
  • The REP Program uses various methods to safely assess and engage with offsite response organizations (OROs), with expert guidance, policy, planning, exercise, and training support to ensure a Reasonable Assurance of the capability needed to properly respond to and recover from a radiological incident at a commercial NPP (Code of Federal Regulations (CFR), specifically 44 CFR § 350)
  • Reasonable assurance is described in Public Law 96-295 Sec 109 (2) the regulations as needing to both be adequate to protect the health and safety of the public living in the vicinity of the nuclear power facility and be capable of being implemented.

Relation to ANS

  • Code of Federal Regulations (CFR) Radiological Emergency Plans and Preparedness
  • 44 CFR § 350 establishes the policy and procedures for FEMAs review and approval of state and local emergency plans and preparedness for offsite effects of a radiological emergency which may occur at a commercial nuclear power facility.
  • 44 CFR § 350.5(a)(5) provides the specific authority for review and approval of ANS and associated plans/procedures.

It requires that a means to provide early notification and clear instruction to the populace within the plume exposure pathway emergency planning zone (EPZ) have been established.

ANS Design Objectives

  • Any system/approach may be submitted for approval, provided it meets the minimum acceptable design objectives.
  • FEMA makes its assessment based on the capabilities of the ANS and not just on the technical specifications.
  • The focus of the assessment is on the ANS as a whole, in both design and operation, and the accomplishment of the design objectives.

Federal Emergency Management Agency 8

ANS Design Objectives Design Objectives 1

  • The capability to provide both an alert signal and an informational or instructional message to the population throughout the plume exposure pathway emergency planning zone (EPZ) within 15 minutes.
  • The basis for any special requirements/

exceptions (e.g., for large water areas with transient boats or remote hiking trails) must be documented.

Design Objectives 2

  • The initial notification system will ensure coverage of essentially 100% of the population within 5 miles of the site.

Federal Emergency Management Agency 9

ANS Design Objectives Design Objectives 3 (Summarized)

  • Coverage within 45 minutes of essentially 100% of the population within the entire plume exposure pathway EPZ who may not have received the initial notification.
  • The plan must include a provision for corrective measures to provide reasonable assurance that coverage in accordance with the design objectives is maintained.

Design Objectives 4 (Summarized)

  • The capability of the ANS to cover essentially 100% of the plume exposure pathway EPZ, regardless of failures.
  • Administrative and physical means to correct any failures for any segment of the population that did not receive the alert and/or notification.
  • The corrective means/measures will be conducted within a reasonable amount of time, recommended goal of 45 minutes.
  • All failure modes, including total failure, are accounted for and means/measures to overcome them must be documented.

REP Program Manual (RPM)

  • The RPM provides FEMA guidance that interprets the 16 planning standards and associated evaluation criteria in NUREG-0654/FEMA-REP-1, Rev. 2 by providing additional level of detail on what FEMA anticipates will be included in offsite (area beyond the Nuclear Power Plant (NPP) site boundary) radiological emergency plans and procedures. The RPM also provides guidance on how FEMA assesses offsite radiological emergency plans and procedures, as well as supplementary information that addresses the capabilities of the REP Program and its relationship with state and local partners throughout the radiological community.

REP Program Manual (RPM) Part V

  • The NRC relies on FEMA to assess the adequacy of radiological emergency response plans -

which includes ANS - as a condition of obtaining or maintaining a license.

  • OROs and licensees compile and submit the ANS Evaluation Report through the state, local, territorial, and/or tribal government(s) to the appropriate Regional Administrator (RA).
  • FEMA can provide technical assistance to OROs and licensees compiling the ANS Evaluation Report, including the technical aspects of the Design Report and the planning aspects of the ANS Plan.
  • With the assistance of the Regional Assistance Committee (RAC) Chair and using FEMA guidance, the RA determines if the ANS Evaluation Report represents a significant change.

Any system/approach may be submitted for approval, provided it meets the minimum acceptable design objectives.

Module 2 Review and Submission Process - Significant Change

Significant Change Process

  • 44 CFR 350.14(b) states, A significant change is one which involves the evaluation and assessment of a planning standard or which involves a matter which, if presented with the plan, would need to have been considered by the Deputy Administrator for the National Preparedness Directorate in making a decision that State or local plans and preparedness are: (1) 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 the event of a radiological emergency; and (2) Capable of being implemented.
  • 44 CFR 350.14(c). The Regional Administrator may determine that certain procedures, such as holding a public meeting or a complete exercise, would be unnecessary.

Federal Emergency Management Agency 14 Design Report/ANS Evaluation Report Submission Milestones

Federal Emergency Management Agency 15 ANS Significant Change Process (Pre-Federal)

NPP/ORO Initiates Change ORO: Sign up to be an IPAWS User NPP: Check License Obligations Identify Coverage for EPZ Check Demographics/

Population for Accessibility ORO:

Infrastructure

& Planning Needs Coordination:

NPP & ORO (Alerting Authority) must all agree to the proposed change Notify NRC Region & FEMA Region (RAC) of intent FEMA Regional Planners and FEMA HQ Engineering can provide aid Completed Proposed Changes in ANS Evaluation Report submitted to FEMA Region through the State/Tribe/Territ ory

Federal Emergency Management Agency 16 Design Report/ANS Evaluation Report Submission Milestones ANS Evaluation Report received by Region FEMA Regional Administrator determines Significance RAC Chair (and staff) Review for Planning Criteria &

Prepares Recommendation FEMA HQ Engineering Reviews ANS Criteria & Prepares Recommendation FEMA Dep.

Administrator Approves ANS Evaluation Report (aka Design Report)

FEMA HQ sends approval to NRC HQ for regulatory Acceptance of proposed license changes Completed NRC Acceptance sent to FEMA HQ Approval &

Acceptance Letters sent to Region to share with NPP & ORO Clarifications may be requested of the NPP and ORO

IPAWS Updates

Trend - Opting Out

IPAWS-WEA Implementation

IPAWS-WEA Implementation

  • FEMA does not endorse one system over another.
  • Due to questions about IPAWS, and specifically about IPAWS-WEA (Wireless Emergency Alerts):
  • IPAWS meets or exceeds the 94% benchmark for availability/reliability (currently at 98.9-99.9%)
  • IPAWS-WEA meets the 15-minute timing requirement in the Design Objective. (2018/2023 National IPAWS-WEA Test : ~90% of cellphones in <15 seconds.
  • Recommendation: Simultaneous Activation vs Sequential Failure Models
  • Limited to no congestion due to Cloud-Based Services and Broadcast only transmission.
  • Adequacy and Testing: 44 CFR 350.8.d and 350.12.b.2

Literacy

  • To meet the Design Objectives, the public must be reasonably able to read and understand notifications that are provided in the form of written or text-based messaging.
  • As a best practice FEMA will use the National Literacy Rate from the US Department of Educations National Center for Education Statistics (NCES), when assessing written notification materials.
  • Literacy Rates for the jurisdictions within the EPZ will be provided as part of the ANS Evaluation Report (Design Report).
  • Communities that have literacy rates below the national average may be required to take mitigation measures to offset gaps.
  • There is not a minimal rate for acceptance, only the corresponding level of mitigation measures that would be necessary to address gaps.

Federal Emergency Management Agency 22 Mobile Carrier Coverage Maps

Mobile LTE Coverage Map l Federal Communications Commission (fcc.gov)

Updated wired and wireless broadband coverage: Home l FCC National Broadband Map

Voice and Data Coverage for Tier 1 Cellular Carriers: AT&T, T-Mobile-Sprint, US Cellular, and Verizon

Use as source for coverage data in Design Report.

Federal Emergency Management Agency 23 IPAWS Live

Available to the Public: PBS - WARN

Live Feed from the FEMA IPAWS-OPEN Server (slight delay 2-5 minutes)

Can search alerts present nationwide and historically ~1 year

FEMA can use it as confirmation to receive credit for Annual IPAWS-WEA Adequacy/Testing

Federal Emergency Management Agency 24 IPAWS Dashboard

Inside FEMA Firewall access limited to FEMA personnel.

Updated monthly approximately 3 weeks after end of reported month.

Review to identify issues

Three Strikes

Covid Waiver ended Sept 1, 2023

RPM 2023 Updates

LEP - Implementation Change

  • Less than English Proficient (LEP)
  • Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, prohibit recipients of federal financial assistance from discriminating based on national origin by, among other things, failing to provide meaningful access to individuals who are limited English proficient (LEP).
  • Prohibition of discrimination based on national origin includes persons with limited English proficiency. The guidelines for providing meaningful access to federally funded programs and activities by persons with limited English proficiency are outlined in Executive Order 13166, "Improving Access to Services for Persons with Limited English Proficiency." EO 13166 is the primary guidance which instructs federal agencies and recipients.
  • The Safe Harbor provision includes a threshold of 1,000 or 5%, whichever is less.

LEP - Continued

  • Resources:
  • Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons (Apr. 18, 2011),

https://www.govinfo.gov/content/pkg/FR-2011-04-18/pdf/2011-9336.pdf.

  • DHS Language Access Plan: DHS Language Access Plan - November 2023
  • FEMA Language Access Policy: FEMA Policy: Language Access

Demonstration Activities

  • Using IPAWS-Viewer/Monthly Proficiency Tests
  • Monthly Proficiency Test Logs
  • Annual Use of IPAWS-WEA
  • ANS Annual Audit
  • Verification of supporting documentation
  • Training Logs
  • Testing Logs
  • Maintenance
  • Security

Joshua Barnes, Regions: 1, 2, 3 James McKenzie III Regions 5, 7, 9 Matthew Webb Regions 4, 6, 10 Emergency Management Specialist Technological Hazards Division, FEMA FEMA-THD-Engineering@fema.dhs.gov

NRC Updates: Use of Integrated Public Alert and Warning System (IPAWS)

January 23, 2025 Don Johnson Senior Emergency Preparedness Specialist Dwayne Myal Emergency Preparedness Specialist Alexandra Terres General Engineer: Nuclear Regulator Apprentice Policy and Oversight Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response

Since 2019 11 NRC licensees transitioned to use of IPAWS as either Primary or Back-Up ANS Approximately 15 additional sites have indicated plans to transition to use of IPAWS in the next 2 years

Updates to the NRC Review and Acceptance Process

  • Issued 2022, updated 2023
  • Ensures additional staff can review ANS Design Report Changes for IPAWS and other aspects (1 4 qualified staff)
  • Ensures consistency in the NRC reviews
  • Risk-informed assessments and reviews in 2025
  • BeRiskSMART Analysis (NUREG/KM-0016) used for review and approval of ANS designs that use simultaneous ANS methods.
  • Internal procedures will be updated with BeRiskSMART Analysis
  • Exploring Innovative Considerations; i.e. developing a method to use unique quantitative tools and techniques to support the technical review of primary and backup ANS (i.e., scoring analysis tools, etc.).

NRC Risk Informed Approach for ANS Designs with Common Mode Failures in Primary and Back-up Systems

  • Use of risk-informed assessments and thorough reviews for reasonable assurance determination that the public will be alerted and notified in the event of an emergency.
  • Under extreme circumstances and radiological emergencies (including both primary and back-up ANS failures), the Offsite Response Organizations (OROs) will deploy all available resources, technology, and personnel to support public messaging and safety.
  • OROs may also identify and/or utilize alternative means beyond what was otherwise included in the ANS Design reports as tertiary back-up methods.

Defense in Depth

  • Process
  • Technology
  • People

Risk Scoring Approach

  • Exploring innovative ways to capture the salient points of ANS Desing Report evaluations from a holistic perspective:
  • Highlighting the difference between a Sequential (serial) ANS approach vs a Simultaneous (Parallel) ANS approach.
  • Quantifying via risk score and use the resultant data to support the approval of the design and NRC determination of compliance (reasonable assurance).
  • Uses an analytical (quantitative) approach for determining ANS method acceptability for primary and backup ANS.

REASONABLE ASSURANCE Primary Alert and Primary Notification Method Fails Backup Alert and Backup Notification Method Successful Simultaneous Activation of Multiple Alert and Notification Methods Primary Alert and Primary Notification Method Fails Backup Alert and Backup Notification Method Successful SEQUENTIAL APPROACH SIMULTANEOUS APPROACH Sequential vs. Simultaneous Approach to ANS

OROs Design Reports must be consistent with Licensee Approved Emergency Plan REMINDER See Information Notice 24-02, Impact On Licensee Emergency Plans From Changes Made By Offsite Response Organizations To Alert And Notification Systems for additional information.

QUESTIONS?

Thank you for your participation and attendance.

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