Frequently Asked Questions – Program Implementation Guidance Revised 02/01/2012 NEW 12/2/2011 1) Question: Can FEMA clarify the information about implementation of these documents? Answer: FEMA and the NRC created the NRC/FEMA Integrated Transition and Implementation Plan (ITIP) Working Group to work on the next steps for the publication and roll-out of the RPM, Supplement 4, and the NRC rulemaking documents. Upon final publication of the FEMA and NRC documents in the Federal Register, a series of scheduled, joint FEMA/NRC implementation forums with stakeholders will begin. While the guidance contained within the RPM and Supplement 4 are now final, opportunities to engage in additional discussions concerning the implementation of the RPM still exist. On November 8, 2011, NRC and FEMA staff conducted a webcast to explain the changes to the NRC regulations and related NRC and FEMA guidance documents. This meeting acquainted attendees with the documents and where to find certain types of information in them. The remaining meetings, scheduled to take place between November 2011 and February 2012, will offer multi-day opportunities for engagement between the NRC, FEMA, licensees, and OROs in a forum format. Each NRC Region will host a forum, and the NRC will also host one near its Headquarters. At these forums, NRC and FEMA staff will provide brief presentations on the changes, and after each presentation licensees and OROs may ask questions to improve their understanding of how to implement the program changes. Members of the public are invited to observe these meetings and the interaction between NRC, FEMA, licensees, and OROs. Opportunities for members of the public to ask questions will occur at designated times on the agenda. Select meetings will also be available online. For information on how to register to participate by telephone or through the Web, please see the notice for the meeting that you wish to attend on the NRC Web site at http://www.nrc.gov/public-involve/public-meetings/index.cfm, as well as the FEMA REP public webpage. These forums allow NRC and FEMA staff to answer questions about the final rule and related guidance documents; they are not opportunities to negotiate the content of the final rule or guidance documents. FEMA and the NRC encourage meeting participants to review the documents prior to the meetings and to bring their own copies should they wish to refer to them during the meeting. In addition to the implementation forums referenced above, FEMA Regional REP Programs are currently coordinating government-to-government meetings with each State. The Regions will announce the schedule for these meetings as soon as they finalize the details. These meetings will either take place at the individual sites or at a central location for multiple sites to gather, depending on the State preference. 2) Question: What is the difference between release, publication, effective and implementation dates? Answer: The release date was when the RPM and Supp. 4 were made publicly available on the internet which was on October 4, 2011. The publication date is when the documents were published in the Federal Register (November 23, 2011). The effective date is when the documents need to be adhered to, which is 30 days after the publication date (December 23, 2011). The implementation date is 30 months after the publication date (June 23, 2014). For OROs that have their HAB exercise prior to the 30 month deadline, the plans needs to be completed and submitted to the Regional Office for approval 90 days prior to the exercise. 3) Question: Will FEMA be conducting a plan review upon implementation of the plan changes due to the new RPM? Answer: FEMA has determined that these planning and procedural updates must be implemented no later than 30 months from the effective date of the final rule. Each FEMA Regional Office will assist each site’s OROs during via site visits with technical assistance. FEMA provides services to facilitate offsite radiological emergency planning and preparedness such as: provision of support for the preparation of offsite radiological emergency plans/procedures; FEMA coordination of services from other Federal agencies; provision and interpretation of Federal guidance; provision of Federal and contract personnel to offer advice and recommendations for specific aspects of preparedness such as alert and notification and emergency public information. Following development, all plan changes and updates must be submitted to the FEMA Regional Office for review and approval prior to the 30 month deadline. The plans will be expected to meet the information in each planning standard, including the intent “checkmarks” under each standard. For OROs that have their HAB exercise prior to the 30 month deadline, the plans needs to be completed and submitted to the Regional Office for approval 90 days prior to the exercise. 4) Question: On page I-4 of the RPM, “Standard Operating Guidelines” (SOG) was added to the Plans and Procedures definition, with a comment that “FEMA may review all of these documents to the extent necessary.” Does this mean that we will be required to submit all SOGs with our plans for review? Answer: Yes, SOGs/Standard Operating Procedures (SOPs)/Implementing procedures are reviewed as part of the plan review. A comprehensive review and approval of State and local procedures (SOPs, SOGs, etc.) is both necessary and required. This position is supported not only by the fact that procedures are, by their very nature, part and parcel to overall State and local plans (i.e., they are integrally linked, as a plan without procedures to implement it is of little or no utility), but more importantly, the requirement for such reviews is clearly expressed in applicable regulation.  NEW 01/17/2012 5) Question: Are the individual elements of the Public Information Review Checklist considered “shall” or “should”? Answer: The Checklist provided in Part IV is a tool that may be used to provide guidance for the content of the Public Information materials. The items in this checklist are considered “shoulds” or “shalls” based upon the discussion under Planning Standard G.1 in Part II.C. “Shalls” are required items, while “shoulds” are historically approved items that will be included unless the ORO has an alternate method of meeting the item that has been approved by both the FEMA Region and FEMA HQ. NEW 02/01/2012 6) Question: In Part II of the RPM, what is the intent of the Explanation section under the check marked items related to the sub-element criterion? Answer: FEMA added an explanation of each Evaluation Criterion based on current guidance. The intent of the explanation is an interpretation of the check marks. OROs may use this guidance or request approval of an alternative approach from their Region’s RAC Chair. 7) Question: What should OROs use when developing Annual Letter of Certification (ALC)? Answer: On page IV- 49, FEMA has detailed ALC guidance. “The review guide assists state and FEMA Regional personnel with development, submission, and review of the ALCs and development of public education and information materials.” FEMA expects the OROs to use this review guide (page IV-51) for organizing the ALC submission.