Emergency Preparedness: State & Local Developments and Possible Industry Impact Sue Perkins-Grew

Intended Outcome  Government Affairs Task Force awareness of: – Strained relations between Offsite Response Organizations (OROs) and FEMA – Potential financial impact to licensees

EP Regulatory and Guidance Changes  11 Issue Areas – 6 Security-related  5 Guidance Documents – Changes to the EPlan – Interim Staff Guidance – Criteria for Preparation and Evaluation of RERPs – Guidance for Protective Action Strategies – Criteria for Development of Evacuation Time Estimates  Effective Date: December 23, 2011  Implementation over the next 3 years

FEMA Radiological Emergency Preparedness Program (REPP) Manual  Total Re-write from 2002 Interim Draft  Programmatic Changes Include DHS Initiatives and Other Policy Changes: – Post Katrina Emergency Management Reform Act (PKEMRA) – National Incident Management System (NIMS) – National Emergency Preparedness Guidelines…… – Stafford Act 2006 Revision – Service Animals & Pets – DOJ revision to ADA – Functional Needs Service Support

Offsite Response Organization Concerns  The Final REPP Manual is different from the 2009 draft for public comment  Scope creep beyond requirements of NUREG  Unfunded mandates without consideration for impact to OROs  Convergence of all-hazards requirements with REPP – what is required v. guidance

Impact to Industry  Cost to Industry: dollars and resources – State/local assessments  States/locals are overwhelmed  Non-radiological planning components impacting evaluation of programs – reasonable assurance findings

Actions Going Forward  NRC/FEMA Implementation Forums  Some states are appealing to: – National Governors Association – Respective State Attorneys General  Licensee engagement with their OROs  NEI EP Working Group interaction with FEMA leadership  Other actions to be determined