Public Comment Analysis and Adjudication: Supplement 3 to NUREG-0654/FEMA-REP-1, "Guidance for Protective Action Strategies" (NUREG-2112)
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Manuscript Completed: July 2011
Date Published: October 2011
J. Kratchman, R. Sullivan
Office of Nuclear Security and Incident Response
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
This study is a thorough analysis and adjudication of official public comment submissions for Supplement 3, Revision 1, "Guidance for Protective Action Strategies", draft report for comment issued March 2010, to NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," issued November 1980. The staff of the U.S. Nuclear Regulatory Commission (NRC) also developed a comment tracking and analysis process to gain further analytical insights into the nature of stakeholder comments. Comments on the draft version of Supplement 3 were solicited in the Federal Register (Volume 75, Number 44) published March 8, 2010. The NRC and the Federal Emergency Management Agency (FEMA), held a series of public meetings during the comment period to facilitate stakeholder understanding of the document.
The comment analysis approach developed in this study was used in analyzing comments on Supplement 3; however, this methodology can be adapted for other comment collections and reflects the NRC’s desire to gain enhanced insights into stakeholder concerns.