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.
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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