Even the Best Guidance Can Be Updated
May 27, 2014
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Regulatory Improvements Team Leader
Office of Nuclear Security and Incident Response
Well-written documents can stand the test of time – just look at the Declaration of Independence. The NRC and FEMA aimed for durability 30 years ago as we responded to the Three Mile Island accident. We co-wrote criteria for nuclear power plants to prepare and evaluate emergency response plans and preparedness programs. That guidance document has been the go-to standard for plant staff, and emergency preparedness managers at the state, local and tribal level.
The NRC and FEMA realized, however, that when a document starts showing its age it’s time for a revision. That’s why a joint NRC/FEMA team is revising NUREG-0654/FEMA-REP-1. This is an update rather than a complete rewrite. Our aim is to make the guidance more user-friendly by restructuring and streamlining it with a focus on evaluation criteria.
Evaluation criteria, by the way, are the parts of emergency plans and preparedness programs that directly respond to NRC or FEMA requirements. Both agencies use evaluation criteria when reviewing emergency plans to make sure the preparedness programs are acceptable.
Before starting on the revision, the NRC and FEMA took suggestions from the public and interested groups. Our writing teams used that information to refocus preliminary evaluation criteria language on capabilities and overall program elements. We’ve moved more detailed information on evaluation criteria implementation to a new NRC emergency preparedness guidance document and to the FEMA Radiological Emergency Preparedness Program Manual.
These changes reduced the number of criteria from 381 to about 190. Both the NRC and FEMA believe the updated criteria will provide an appropriate basis for U.S. nuclear power plants and state/local/tribal governments to develop radiological emergency plans and improve emergency preparedness.
Our writers have also been updating and adding several topics to the document’s introduction. The updated intro will address the document’s purpose, scope, and background, as well as the basis for developing emergency plans. New introduction topics include how the document will be used and how the document relates to regulations and other guidance documents. It also includes information on the alternative approaches used to meet NRC and FEMA requirements.
We expect to have the revised preliminary draft ready by the end of May. We’ll make the document available for public review and discussion, including holding another public meeting/webinar in late June at NRC headquarters. We expect to have a formal public comment period on the draft document starting in October 2014.