Emergency Preparedness and New Reactor Licensing Process: An Update on Where We Are Now

Federal Emergency Management Agency National Preparedness Directorate Technological Hazards Division Radiological Emergency Preparedness Program

Albert G. Coons

Albert Coons April 21, 2009

FEMA’s Responsibilities

   Take the lead in the review of offsite emergency plans.

Determine whether offsite REP plans are viable by reviewing all plans and evaluating regularly scheduled exercises. Pursuant to 44 CFR 353 Appendix A, respond to any requests by the NRC.

Review 15 of the 16 NUREG-0654 Planning Standards -109 detailed planning criteria -Produce Interim Finding Reports (IFR) Albert Coons April 21, 2009 2

Players in the Review of Applications

FEMA

Oversees

offsite

response planning, review, and evaluation for nuclear activities

NRC

Oversees

onsite

response planning and all regulation, licensing, and monitoring of nuclear facilities

Memorandum of Understanding 44 CFR 353 Appendix A

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Application Site Situations

Situation 1 Situation 2 Situation 3

State X State X State X County Y County Y County Z County Y Albert Coons April 21, 2009 4

FEMA Deliverables - New Reactor Licensing

FEMA Deliverable Acceptance Review Letter IFR for Requests for Additional Information (RAIs)

Applicant Response Time

IFR for Open Items (OIs)

Applicant Response Time

IFR for Reasonable Assurance (RA) Duration 13 Working Days 90 Working Days Situation 1 Site 120 Working Days Situation 2 or 3 site

48 Working Days 63 Working Days Situation 2 or 3 site

30 Working Days

33 Working Days

30 Working Days

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Key Application Components for FEMA Review

 Provided with Application  Jurisdiction REP Plans, existing and proposed   All counties/local jurisdictions in the 10-mile EPZ All States in the 50-mile EPZ  NUREG-0654 Cross-Reference  Additional Review Materials   All-Hazard Emergency Plans (EPs) Letters of Agreement (LOAs) Albert Coons April 21, 2009 6

Standard Operating Procedure

 Supporting the Combined Licensing Application process for new reactors.  Provide an understanding and guidance during the review process from the earliest letter or memo to the completion of the Interim Finding Report (IFR).

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Process Overview

 Acceptance Review  Purpose: Ensures the application is sufficient for FEMA to begin Phase I review  Duration: 13 days  Deliverable: NRC – Acceptance Review Letter  Phase 1/1A Review – IFR for RAIs  Purpose: Define gaps in planning, equipment and training  Duration: 90 days – Situation 1 120 Days – Situation 2 or Situation 3  Deliverable: NRC – IFR for RAIs Applicant – RAIs Albert Coons April 21, 2009 8

Process Overview

 Phase 2/1B Review – IFR for OIs  Purpose: Define unresolved issues  Duration: 30 days  Deliverable: NRC – IFR for OIs Applicant – OIs  Phase 4/2 Review – IFR for Reasonable Assurance  Purpose: Assessment of offsite planning that characterizes preparedness related tasks and conditions that must be completed or met in order to operate the proposed plant  Duration: 30 days  Deliverable: NRC – IFR for Reasonable Assurance Albert Coons April 21, 2009 9

Interim Finding Conditions

44 CFR 350.3

Adequate

Plans are adequate and there is reasonable assurance that they can be implemented with only limited or no corrections needed.

Adequate – Corrections Must be Made

Plans are adequate, but before a determination can be made as to whether they can be implemented, corrections must be made to the plans or supporting measures must be demonstrated (e.g. adequacy and maintenance of procedure, training, resource, staffing levels and qualifications, and equipment).

Inadequate

Plans are inadequate and cannot be implemented until they are revised to correct deficiencies noted in the Federal review Albert Coons April 21, 2009 10

RAI Process

COL Application documents submitted to NRC NRC sends Application to FEMA HQ cc’ing FEMA Region Following Acceptance Review FEMA Region reviews offsite plans to determine reasonable assurance FEMA Region Reviewer contacts Applicant and FEMA HQ with a list of verbal questions – Applicant coordinates answers with State, Tribal, and local agencies as appropriate ¹ Unresolved verbal questions are developed into draft RAIs by FEMA Region FEMA HQ sends Final RAIs to the Applicant cc’ing FEMA Region and NRC for docketing FEMA Region sends draft RAIs to FEMA HQ for review and approval FEMA HQ sends draft RAIs to Applicant cc’ing FEMA Region and NRC for docketing Applicant sends draft RAIs to State and local agencies as appropriate FEMA Region discusses RAIs with applicant, State, Tribal, and local agencies as appropriate and if needed NRC – discussions result in RAIs that are

clear, understood, and attainable

FEMA Region submits IFR for RAIs to FEMA HQ Applicant sends final RAIs to State, Tribal, and local agencies as appropriate Applicant submits RAI responses to FEMA HQ cc’ing FEMA Region and NRC for docketing Any unresolved RAIs will become Open Items If all RAIs are resolved, then FEMA submits an IFR for Reasonable Assurance to the NRC for docketing ¹ Allows Applicant to provide clarification to the FEMA Region with information the reviewer may have overlooked during the COL Application Review.

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Contact

Albert G. Coons [email protected]

202-212-2318 Albert Coons April 21, 2009 12