ML18134A330
| ML18134A330 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/10/2018 |
| From: | Perkins-Grew S Nuclear Energy Institute |
| To: | Casey M Federal Emergency Management Agency |
| Robert Kahler | |
| References | |
| Download: ML18134A330 (3) | |
Text
SUSAN PERKINS-GREW Senior Director, Nuclear Security and Incident Preparedness 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8016 spg@nei.org nei.org May 10, 2018 Dr. Michael Casey Director, Technological Hazards Division National Preparedness Directorate Federal Emergency Management Agency 400 C Street SW Washington, DC 20472
Subject:
NEI Questions about the Reasonable Assurance Assessment Framework Project Number: 689
Dear Dr. Casey:
Reflecting our previous conversations, the Nuclear Energy Institute (NEI)1 and a member task force have developed the attached list of questions concerning the Reasonable Assurance Assessment Framework (RAAF). These questions were discussed with members of your staff on April 11 and May 10, 2018. As suggested in the May 10th meeting, we are sending this letter to request a written response to our questions.
Should additional information be required, please contact Mr. David Young (202-739-8127 or dly@nei.org).
Sincerely, Susan Perkins-Grew Attachment c:
Mr. William Eberst, FEMA/NPD/THD, DHS Mr. Craig Fiore, FEMA/NPD/THD, DHS Mr. Robert Kahler, NSIR/DPR/POB, NRC 1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
NEI and Member Questions on the RAAF Page 1 of 2 Billing/Fee Questions
- 1. What impact will the RAAF process have on the number of personnel hours billed to the REPP fund, for both FEMA employees and contractors?
- 2. How will the RAAF process affect billable hours during non-exercise years?
- 3. Given the changes contemplated to 44 CFR 354, can sites with relatively more State and local offsite response organizations expect their annual FEMA fees to go up while those with relatively fewer will go down?
- 4. Since FEMA bills and collects fees in advance of expenditures for actual services, how will the fees be determined?
- 5. If the actual cost of billable hours is either greater than or less than that already collected, will the licensee receive a refund or additional bill? What is the expected timing of the refund or bill?
Implementation Questions
- 6. Is State and local implementation of the RAAF mandatory or voluntary (i.e., compliance with REPP requirements could continue through traditional means)?
- 7. Can RAAF implementation occur at the State level only or the local level only (as opposed to both State and local)? What decisions or criteria will determine this?
- 8. How will the RAAF process ensure that THIRA results included within the scope of the REPP are only those needed for compliance with the 16 planning standards of 10 CFR 50.47(b) and/or the requirements of 10 CFR 50, Appendix E?
- 9. How is FEMA ensuring a consistent implementation of the RAAF across all Regions, States and jurisdictions?
- 10. How will FEMA employees and contractors be trained on the RAAF process?
NEI and Member Questions on the RAAF Page 2 of 2
- 11. How will FEMA monitor RAAF implementation so as to ensure consistency across all Regions, States and jurisdictions?
Demonstration Credit Questions
- 12. Are FEMA and the NRC aligned on implementation of the RAAF process and the granting of demonstration credit for the response to a non-REPP drill or exercise, or a real-world, non-nuclear event?
- 13. What process will a State or local agency follow to receive demonstration credit for the response to a non-REPP drill or exercise, or real-world, non-nuclear event? Will the process specify the types of non-REPP drills and exercises, and real-world, non-nuclear events for which demonstration credit may be sought?
- 14. Can a State or local agency receive a REPP finding for a less than satisfactory response to a non-REPP drill or exercise, or real-world, non-nuclear event and, if so, under what conditions?
Process Control and Revision Questions
- 15. The current version of RAAF documents (e.g., National Game Plan and Playbook) are indicated as drafts - when will they be issued as final or Rev. 0?
- 16. What policies and procedures will control the development and revision of the RAAF process and related documents? Will these documents be made available to stakeholders?