ML18197A323

2018 NEI EP Summit NRC Dir Process Presentation Janderson

ML18197A323
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Issue date:	07/16/2018
From:	Office of Nuclear Security and Incident Response
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Download: ML18197A323 (9)

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2018 NEI Security and Emergency Preparedness Summit (Orlando, FL)

Disaster Initiated Review Process: NRC Perspective Joseph Anderson Chief, Reactor Licensing Branch Division of Preparedness and Response

Hurricane Irma Lessons-Learned

1. Ensure effective interagency coordination and communication at Regional level (prior to, during & post event)

• Alignment of Inspection Manual Chapter (IMC-1601) and FEMA Standard Operating Guide (SOG)

• April 12 table-top exercise

2. Immediate assessment

• Situational report (SITREP) vs. preliminary capabilities assessment (PCA) / Disaster Initiated Review (DIR)

3. Role of licensee in supporting offsite assessment 2

Hurricane Irma Lessons-Learned

3. Clarify government authority or responsible independent entity for making determinations regarding electric grid stability concerns.

NRC queries regarding electric power grid stability concerns, which may need to be confirmed to support a Commission decision on granting enforcement discretion to allow a reactor to restart or to preclude a shutdown following a severe national disaster (i.e., hurricane), should be directed to the DOE Watch Office.

Upon receiving a call, the DOE Watch Office will transfer the call to either the DOE Unified Coordination Group (UCG), which would be stood up to monitor a severe natural disaster, or to Infrastructure Security & Energy Restoration (ISER) Division / Office of Cybersecurity, Energy Security and Emergency Response (CESER). The UCG would be the Federal point of contact to interface with the Energy Sector Coordinating Council (industry).

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Hurricane Irma Lessons-Learned

4. Senior NRC management engagement regarding licensee restart decisions where offsite response capabilities impacted

5. IMC-1601 alignment with NRC incident response procedure for natural phenomenon

6. Clarify NRC authorities

- Operating reactor (potential shutdown)

- Shutdown (restart)

- Multi-unit site (1 unit shutdown / 1 unit at power) 4

Shutdown of an Operating Reactor A licensee is not required by Commissions regulations to immediately shutdown due to a degraded offsite emergency infrastructure.

• 10 CFR 50.54(s)(2) provides for a 120 day grace period for correction of deficiencies in offsite emergency preparedness (EP).

However, the Commission can order a licensee to shutdown a reactor if deficiencies in offsite EP will cause an immediate radiological public health and safety concerns.

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Shutdown of an Operating Reactor With respect to the 120-day grace period, the Commission has stated: [52 FR 42078; November 3, 1987]

A plant may ordinarily operate for at least four months with deficiencies in emergency planning before the NRC is required event to decide whether remedial action is taken[thus] the 120 day clock provision for emergency planning deficiencies amounts to a Commission finding that, at least for 120 days, even a major deficiency in emergency planning does not automatically raise a substantial health or safety issue with regard to plant operation. By contrast, a major deficiency related to emergency core cooling conditions - for example, the availability of the emergency core cooling system - would warrant immediate shutdown.

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Reactor Restart When a reactor has voluntarily and properly shutdown in compliance with NRC requirements, there is no requirement for license to obtain specific authorization to restart.

Assumptions:

• Licensee has not exceeded a technical specification safety limit, and

• The act of restarting would not create a non-compliance with NRC requirements or terms of the operating license.

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Multi-Unit Site For a natural disaster or event where one unit at a multi-unit site has shut down, but the second unit remains at power, the shutdown unit could restart if it is within its Technical Specification safety limits.

• If the licensees were in noncompliance with an offsite EP requirement, but the licensee for the shutdown unit chose to restart its unit, the licensees would be in the same regulatory positions under 10 CFR 50.54(s)(2)(ii).

• The NRC staff would then have to justify that the deficiencies in offsite EP will cause an immediate public health and safety concern to support consideration by the Commission of an order to shut down, or prevent the restart of the unit(s).

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IMC-1601 Revision In conclusion, our goal is to have revision to Inspection Manual Chapter (IMC) 1601 issued by the July 1, 2018.

• Will be publicly available via the Agencywide Documents Access and Management System (ADAMS)

• Accession No.: ML18093A372 9