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Process of REP Program Manual Public Comment Adjudication

Process of REP Program Manual Public Comment Adjudication . March 30, 2010. Agenda . Purpose/Drivers for Revision of REP Program Manual Comment Adjudication Timeline and Milestones/Next Steps Implementation Phase/Process. Purpose of a Program Manual.

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Process of REP Program Manual Public Comment Adjudication

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  1. Process of REP Program Manual Public Comment Adjudication March 30, 2010

  2. Agenda Purpose/Drivers for Revision of REP Program Manual Comment Adjudication Timeline and Milestones/Next Steps Implementation Phase/Process

  3. Purpose of a Program Manual • Provides FEMAs interpretation of regulations and guidance in: • 44 CFR 350 • NUREG 0654/FEMA-REP-1, Rev. 1 • Provides a consolidated source of policy and guidance for REP employees, licensees, State, local, and Tribal preparedness personnel (i.e., a desk reference) • Aligns FEMA offsite activities under 44 CFR 350 with NRC regulations in 10 CFR 50 and NRC’s proposed rulemaking activities

  4. Key Drivers for RPM Revisions Align REP policy/guidance with tenets of NIMS, NRF, and HSEEP Enhance scenario realism and eliminate pre-conditioned exercise activities Establish “Part II,” embedding planning guidance that was not included in 2002 Interim version Incorporate and retire FEMA REP’s legacy operative policy and program memoranda

  5. Preparing for and responding to hostile action-based (HAB) events Aligning the REP Program with national preparedness systems and initiatives (e.g., NIMS/ICS and HSEEP) Ensuring more challenging drills and exercises to enhance exercise activities Ensuring backup means for Alert & Notification System Key Policy Changes

  6. REP Program Manual and Supplement 4 released May 18, 2009 for 150 day comment period FEMA received over 120 submissions containing over 2300 individual comments FEMA convened the Public Comment Adjudication Team (PCAT): 10 FEMA Regional representatives 5 FEMA Headquarters staff Public Comment Process

  7. Adjudication Process Public Comment Adjudication Team (PCAT) – internal FEMA team to analyze and recommend comment resolutions, consisting of Regional, HQ and select REP and NPD SMEs Joint Comment Adjudication Team (JCAT) – joint FEMA/ NRC team to analyze and recommend comment resolutions on cross-cutting issues between proposed NRC rulemaking and FEMA offsite guidance

  8. Adjudication Process • The PCAT was chartered with the following objectives: • To accurately document all considerations, decisions, and rationales; • To achieve an effective consensus in a timely manner; • To determine which issues need to be elevated to management and/or require joint adjudication with the NRC; • To incorporate all approved comment resolutions into the final RPM and Supplement 4.

  9. Adjudication Comment Dispositions • Accepted • Rejected • Noted • Modified • Elevated • Requires Joint Adjudication

  10. Comments – Stakeholders

  11. Public Comment Summary

  12. FEMA RPM/Supp 4 Milestones* * subject to change and revision to maintain alignment with the Nuclear Regulatory Commission.

  13. Implementation Process Representation from Training, HSEEP, HAB, Policy, Outreach/External Affairs, OCC, and PCAT • FEMA and NRC will be creating a team in Spring 2010 – charged with creating the Implementation Plan • Timeline for implementation of changes • Impact on new reactor applications and existing reactors • Open Forum • Thursday April 1, 2010 1pm– Craig Fiore, FEMA REPP Deputy Chief • Speaking in depth about Implementation Plans, the proposed revision to NUREG 0654, and Supplement 3

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