Process of REP Program Manual Public Comment Adjudication
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Transcript of Process of REP Program Manual Public Comment Adjudication
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Process of REP Program Manual Public Comment Adjudication March 30, 2010
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Agenda Purpose/Drivers for Revision of REP Program Manual
Comment Adjudication
Timeline and Milestones/Next Steps
Implementation Phase/Process
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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
Purpose of a Program Manual
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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
Key Drivers for RPM Revisions
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Key Policy Changes 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
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Public Comment Process 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
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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
8April 22, 2023
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.
Adjudication Process
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Adjudication Comment Dispositions
April 22, 2023
Accepted
Rejected
Noted
Modified
Elevated
Requires Joint Adjudication
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FEMA RPM/Supp 4 Milestones*
* subject to change and revision to maintain alignment with the Nuclear Regulatory Commission.
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Implementation Process
Representation from Training, HSEEP,
HAB, Policy, Outreach/External Affairs,
OCC, and PCAT
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
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
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