Nuclear Power Plant/Electric Grid Regulatory Coordination and Cooperation - ERO Perspective David R. Nevius and Michael J. Assante 2009 NRC Regulatory Information Conference March 11, 2009

NERC Mission  Develop & enforce reliability standards  Assess current and future reliability  Analyze system events for lessons learned & recommend improved practices  Maintain situational awareness of grid reliability  Protect grid infrastructure  Certify grid system operators To ensure the reliability of the North American bulk power system

NERC Vitals  Independent non-profit corporation  Certified by FERC as the Electric Reliability Organization for the U.S.  Certifications from Canadian Provinces by way of MOUs  Authority to set and enforce compliance with Reliability Standards

NRC-NERC MOA  Original agreement signed in 2004 and updated July 2007  Coordination plans: Communication during emergencies Event analyses Exchange of operational experience Participation in NERC committees

Reliability Standards  Apply to all owners, operators, and users of the bulk power system, including nuclear generator owner/operators  Focus on bulk power system reliability  Results-oriented Avoid prescribing practices – allow entities to determine their own “best way” to meet a standard given their individual circumstances Specific & measurable requirements  Approval by FERC before enforceable in U.S.

Nuclear Plant Interface Coordination NUC-001  Required coordination between nuclear plant operators and transmission operators to ensure grid has capacity to support safe operation and shutdown of nuclear units  Nuclear plant licensing and design requirements documented in written agreements  Standard approved by NERC board May 2007 & by FERC October 2008  Agreements in place 15 months after FERC approval  NERC enforcement ~ April 2010

Critical Infrastructure Protection CIP  Critical Cyber Asset ID  Security Management Controls  Personnel & Training  Electronic Security Perimeter(s)  Physical Security of Critical Cyber Assets  Systems Security Management  Incident Reporting and Response Planning  Recovery Plans for Critical Cyber Assets

Applicability of CIP Standards to Nuclear Power Plants  FERC NOPR to clarify scope and applicability of standards for nuclear power plants  NERC comments filed November 2008 Agree on need for clarification Suggested specific revised language  Awaiting FERC decision

Compliance Monitoring and Enforcement  Focus on improving bulk power system reliability  Protect confidentiality of involved parties  Single, defined appeals process whereby resolution can be reached  Reports issued to governmental authorities

About Enforcement  Violating entities can be subject to: Monetary – up to $1 million per day per violation Order a change in practice to mitigate the violation  Penalty levels based on threat to grid reliability  Credit for self-reporting & voluntary corrective actions  Flexible to adapt to all relevant facts  Meets FERC policy statement

Reliability Assessments  Long-Term Reliability Assessments 10 year projections assessing electricity supply and demand Evaluates transmission system adequacy Discusses key issues and trends  Summer and Winter Assessments Assess the adequacy of electricity supplies in the United States and Canada for the upcoming summer and winter peak demand periods  Special Assessments Conducted on a regional, interregional, or interconnection-wide basis as needed

Analyze System Disturbances  Determine what happened  Identify what (if anything) went wrong  Alerts to industry for systemic problems  Share lessons-learned  Suggest changes to standards  NRC staff called on to assist where appropriate, as per MOA

Industry Alerts  Industry Advisories, Industry Recommendations, and requests for Essential Actions  Issued to relevant industry sectors when an issue arises that causes or contributes to an event under analysis Advises the industry to evaluate system status and take action to correct issues affecting reliability

Situational Awareness of Grid  Situational Awareness Monitoring System Information from Reliability Coordinators Provided to FERC, NERC, and Regional Entities  North American Synchro-Phasor Initiative Next generation grid monitoring technology Allow system operators to better visualize the status of the grid in near real-time Supported by U.S. DOE

Protecting Grid Infrastructure  Address both physical and cyber security  Electricity Sector Steering Group  Electricity Sector Coordinating Council  Electricity Sector Information Sharing and Analysis Center (ES-ISAC) Primary point of contact with NRC Headquarters Operations Office, as per MOA