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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