View source for RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events

{{Adams
| number = ML062370311
| issue date = 02/02/2007
| title = Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events
| author name = Case M
| author affiliation = NRC/NRR/ADRA/DPR
| addressee name = 
| addressee affiliation = 
| docket = 
| license number = 
| contact person = 
| document report number = RIS-07-002
| document type = NRC Regulatory Issue Summary
| page count = 6
}}
{{#Wiki_filter:UNITED STATES
                             NUCLEAR REGULATORY COMMISSION
                         OFFICE OF NUCLEAR REACTOR REGULATION
                                 WASHINGTON, D.C. 20555-0001 February 2, 2007 NRC REGULATORY ISSUE SUMMARY 2007-02:
           CLARIFICATION OF NRC GUIDANCE FOR EMERGENCY
           NOTIFICATIONS DURING QUICKLY CHANGING EVENTS

==ADDRESSEES==
All holders of operating licenses for nuclear power reactors, except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.

==INTENT==
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory information summary (RIS) to clarify NRC guidance for making emergency notifications during quickly changing events in which the emergency classification changes before the notification is made to the offsite response organizations (OROs) and the NRC. This RIS requires no action or written response by addressees.

==BACKGROUND==
The Commissions regulations in Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.47(b) and Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities, require, in part, that power reactor emergency preparedness plans describe a standard four-level emergency classification scheme and that procedures are in place to notify OROs of the emergency conditions. The licensees emergency response organization (ERO) is required to assess the emergency conditions, declare the appropriate classification, and notify the OROs of the emergency. Should the plant conditions deteriorate further, the ERO is to re-classify the event, declare the escalated emergency, and notify the OROs. These requirements are intended to ensure timely ORO
response and actions to protect the health and safety of the public. For timely ORO response to occur, the licensee must make timely and accurate classifications and notifications.

Power reactor licensees are specifically required by Section IV.D.3 of Appendix E to have the capability to notify responsible State and local government agencies within 15 minutes after declaring an emergency. This requirement applies to a licensees initial declaration and any subsequent declaration of an escalated emergency classification.

==SUMMARY OF ISSUE==
Degrading plant conditions during a rapidly evolving event can cause an escalated emergency classification to be declared before the notifications for the previous (or initial declaration) are made. The NRC has become aware of at least one instance in which a licensee revised its procedures to state that it was permissible to restart the 15-minute notification clock if degrading plant conditions cause an escalation in the declared emergency while the notification for the previous declaration was in progress. The procedure went on to specify that the 15- minute time requirement for the notification of the previous declaration does not apply and the notification is not made in these cases. Consequently, a notification could be delayed for up to
30 minutes. However, since the procedure doesnt limit the use of this clock restart, an initial notification may be further delayed if the emergency escalates again before a notification can be made.

This notification protocol is not in compliance with the requirements of Appendix E as the procedure change reduces the licensees capability to notify State and local governmental agencies within 15 minutes after declaring an emergency. Since the OROs implement actions in a staged approach depending on the emergency classification level, deferring a required notification could reduce their ability to implement timely actions to protect the health and safety of the public.

The NRC recognizes that there could be exigent circumstances for exceeding this 15-minute criterion during an actual emergency response and the emergency preparedness cornerstone of the Reactor Oversight Program provides for this eventuality. Nonetheless, the licensee is required by regulation to have the capability of making the notification within 15 minutes of declaring an emergency. Licensees should ensure their notification procedures and ERO
training provide the capability for making notifications to State and local governmental agencies within 15 minutes after declaring an emergency, as required by Appendix E.

Further, it is suggested the licensees consult with their offsite counterparts when structuring an approach for handling notifications associated with rapidly evolving events to ensure that the approach addresses the ORO needs while complying with Appendix E. Acceptable approaches include:
*       If the plant condition degrades and a higher classification emergency is declared before the notifications are made for the lesser emergency declaration, the licensee should update the notification to reflect the higher emergency classification and complete the updated notifications within 15 minutes of the lesser emergency declaration.

Note: Since the OROs will take actions consistent with the higher emergency classification, it is not necessary to identify the lesser classification in the updated notification. However, the plant conditions that gave rise to the lesser classification should be identified, if still present, in the followup notifications.

*       If the notification cannot be updated and completed within 15 minutes of the lesser emergency declaration, the ERO should make the notification for the lesser emergency within 15 minutes of its declaration. The notification could contain the caveat that a change in classification was forthcoming. In parallel, the licensee should prepare the notification for the higher emergency classification and make an additional notification within 15 minutes of its declaration. *        If the notifications are made serially and the notifications for the lesser emergency declaration are in progress when the escalation is declared, the remaining notifications should be completed so that all OROs have the same classification information.

Remaining notifications could contain a caveat that a change in classification was forthcoming. In parallel, the licensee should prepare the notification for the higher emergency classification and make an additional notification within 15 minutes of the escalated declaration.

==BACKFIT DISCUSSION==
This RIS requires no action or written response. Any action by addressees to implement changes to their emergency plans or procedures in accordance with the guidance in this RIS is strictly voluntary and, therefore, is not a backfit under 10 CFR 50.109. Consequently, the NRC
staff did not perform a backfit analysis.

===FEDERAL REGISTER NOTIFICATION===
A notice of opportunity for public comment on this RIS was not published in the Federal Register because the RIS is informational and pertains to a staff position that does not depart from current regulatory requirements and practices.

===CONGRESSIONAL REVIEW ACT===
This RIS is not a rule as designated by the Congressional Review Act (5 U.S.C. &sect;&sect; 801-808)
and, therefore, is not subject to the Act.

===PAPERWORK REDUCTION ACT STATEMENT===
This RIS does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501, et seq.). Existing requirements were approved by the Office of Management and Budget (OMB), approval number 3150-0011.

Public Protection Statement The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information collection requirements unless the requesting document displays a currently valid OMB control number.

==CONTACT==
Please direct any questions about this matter to the technical contact listed below.

/RA by TQuay for/
                                            Michael Case, Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Technical Contacts:   Stephen F. LaVie, NSIR/DPR
                      301-415-1081 E-mail: sfl@nrc.gov Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.

ML062370311                                 *prior concurrence OFFICE     DPR:NSIR       Tech Editor     TL:DPR:NSIR       BC:DPR:NSIR       DD:DPR:NSIR       D:DPR:NSIR
NAME         SLaVie*       CBladey*         RKahler*          EWeiss*           NMamish*          ELeeds*
DATE        8/25/2006     11/08/2006       10/5/2006         10/23/2006         11/21/2006       1127/2006 OFFICE    BC:ITSB:DIRS      D:DORL            OE           OGC (SBREFA)         OGC (NLO)          PMAS
NAME        TKobetz*       CHaney*          DSolorio*        NSanchez*            STreby*         JHarves*
DATE       11/29/2006      12/6/2006       12/8/2006         12/152006          12/20/2006       12/21/2006 OFFICE         OIS        LA:PGCB:DPR:NRR          PGCB:DPR:NRR          BC:PGCB:DPR:NRR       D:DPR(A):NRR
NAME        MJanney*         CHawes CMH               AWMarkley               CJackson             MCase DATE         1/11/07            1/19/2007              1/30/2007              1/30/2007          2/06/2007
}}

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