Process of REP Program Manual Public Comment Adjudication

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

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

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 3

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 4

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

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

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 7

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. 14 June 2021 8

Adjudication Comment Dispositions § Accepted § Rejected § Noted § Modified § Elevated § Requires Joint Adjudication

Comments – Stakeholders 10

Public Comment Summary Reasonable Assurance 1% Public Information 9% PAGs 1% PADs 3% KI 2% Extend Comment Period 3% Beyond the Scope 3% ANS 13% ALC 1% NIMS/ICS 8% Dosimetry 6% EPZ 1% ETE 2% MOU/LOA 6% Formatting 5% HSEEP 19% HAB Scenarios 17% 11

FEMA RPM/Supp 4 Milestones* PCAT/JCAT Adjudication Review/Finalize Adjudication Report and RPM/Supp 4 Initial FEMA NRC Concurrence Review Jan - Feb 2010 Adjudication Report and RPM/Supp 4 Mar 2010 PCAT/JCAT Adjudication Review/Finalize FEMA/NRC Concurrence Possible SGE/NAC/NEMA REP Involvement Adjudication Report, RPM/Supp 4, and FRN 30 days 60 days DHS Concurrence OMB Concurrence Publication Adjudication Report, RPM/Supp 4, and FRN 90 days Dec 2010 – March 2011 Nov 2009 – Jan 2010 * subject to change and revision to maintain alignment with the Nuclear Regulatory Commission. 12

Implementation Process § 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 1 pm– Craig Fiore, FEMA REPP Deputy Chief • Speaking in depth about Implementation Plans, the proposed revision to NUREG 0654, and Supplement 3 § Representation from Training, HSEEP, HAB, Policy, Outreach/External Affairs, OCC, and PCAT 13

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