ML18101B396

Resolution of Post-Fukushima Tier 2, Tier 3 and Non-Tiered Activities

ML18101B396
Person / Time
Issue date:	03/23/2018
From:	Robert Bernardo Beyond-Design-Basis Engineering Branch
To:
Bernardo R
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Download: ML18101B396 (8)

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Resolution of Post-Fukushima Tier 2, Tier 3, and Non-Tiered Activities 1

• Identification and prioritization of post-Fukushima activities:

• In SECY-11-0137, the NRC staff prioritized the Near-Term Task Force (NTTF) recommendations (SECY-11-0093) into three tiers.

• Tier 2 and Tier 3 items consisted of those items which could not be initiated in the near term because of resource constraints, the need for further technical assessment, or were dependent on activities related to the higher priority Tier 1 issues.

• In addition to the prioritization in SECY-11-0137, the staff identified additional issues (beyond the recommendations of the NTTF report) with a direct nexus to the Fukushima event. Three of these issues were subsequently prioritized as Tier 3 in Enclosure 2 to SECY-12-0025.

• In Enclosure 3 to SECY-12-0025, the staff reviewed additional recommendations made by the Advisory Committee on Reactor Safeguards (ACRS) after their review of the NTTF report. Two of the ACRS recommendations were prioritized as Tier 3.

• Three additional actions were addressed by the staff. Two of these actions were as a result of Commission direction (staff requirements memorandum (SRM)

SRM-COMGBJ-11-0002 and SRM-SECY-12-0012). The third was direction from Congress in the Energy and Water Development Appropriations Act of 2012 for the NRC to fund a study of the accident by the National Academy of Sciences (NAS).

• In SRM-SECY-11-0093, the Commission directed that NTTF recommendation 1 be pursued independently of post-Fukushima activities. As a result, this recommendation was not included in a tier.

• Completion of the non-Tier 1 post-Fukushima activities:

• Several of the Tier 2 and Tier 3 NTTF recommendations involved proposed rulemaking activities:

• In SRM-COMSECY-13-0002, SRM-COMSECY-13-0010, and SRM-SECY-14-0046, the Commission approved the staffs proposed consolidation of various rulemaking activities. This resulted in the rulemaking activities for all tiers being consolidated into a single mitigation of beyond-design-basis events (MBDBE) rulemaking. The staff submitted the draft final rule in SECY-16-0142.

1 Commission Papers (SECY), Staff Requirements Memoranda (SRM) and Commission Action Memoranda (COMSECY) are found in the NRC Library (https://www.nrc.gov/reading-rm/doc-collections/#comm) on the NRC web site (www.nrc.gov).

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• The NRC staff completed an evaluation of the need to expedite transfer of spent fuel to dry storage in May 2014. This was reported in COMSECY-13-0030. NRC staff concluded that, because of the minimal risk, no further generic evaluations should be pursued. The Commission agreed with the staffs recommendation in SRM-COMSECY-13-0030, but directed several follow up items for staff. The NRC staff has completed the follow up actions, including:

• issued Information Notice 2014-14 discussing the benefits of adopting a 1 x 8 spent fuel pool (SFP) loading configuration,

• modified the regulatory analysis (addendum to Enclosure 1 of COMSECY-13-0030) to more fully explain why additional regulatory actions to impose a requirement to establish a 1 x 8 SFP loading pattern were not justified,

• evaluated the existing process for seismic hazard reevaluations to determine if the SFP analysis can be eliminated (the staff concluded an appropriate SFP evaluation should be conducted),

• completed a technical overview of spent fuel rack designs used in other countries,

• provided an information paper (SECY-14-0136) detailing the staffs views about the treatment of limited-term operational vulnerabilities, and

• provided two reports to the Commission on the National Academy of Science's (NAS) study on this topic (SECY-15-0059, Enclosure 6 and SECY-16-0100).

• The NRC staff completed an evaluation of the applicability of lesson-learned to other regulated facilities in June 2015. The evaluation was provided to the Commission in SECY-15-0081. NRC staff determined that no regulatory action is needed for most other facilities, with two exceptions:

• For the three high-power research and test reactors (RTRs), the staff used an audit process per NRR Office Instruction LIC-111 to determine whether additional actions were necessary. Based on the information from the audits, documented in audit reports, the staff has concluded that no further actions are necessary.

• The staff issued Generic Letter (GL) 2015-012 to fuel cycle facilities to gather information to determine if additional regulatory activities are needed. In December 2017, the NRC staff completed all activities associated with GL 2015-01 with no further regulatory activities required.

This completed the action to determine the applicability of the Fukushima lessons-learned to other NRC regulated facilities as directed by SRM-COMGBJ-11-0002.

• The NRC staff completed A Comparison of U.S. and Japanese Regulatory Requirements in Effect at the Time of the Fukushima Accident 3 in November 2013.

This completed the action to perform a comparison study of U.S. and Japanese regulations as directed by SRM-SECY-12-0012.

2 Agencywide Documents Access and Management System (ADAMS) Accession No. ML14328A029 3 ADAMS Accession No. ML13326A991 2

March 23, 2018

• The NRC funded a study by the National Academy of Sciences (NAS) on the lessons-learned from the Fukushima accident. NAS completed the study in two phases:

• Phase 1 4 of the study was published in July 2014. The NRC staff review, provided to the Commission in SECY-15-0059, Enclosure 6, found that ongoing planned NRC and industry activities adequately address the NAS recommendations from Phase 1.

• Phase 2 5 of the study was published in May 2016. The NRC staff review, provided to the Commission in SECY-16-0100, did not identify the need to initiate any new activities to address the Phase 2 recommendations.

This completed the action to fund and evaluate a study on the Fukushima lessons-learned by the NAS as mandated by Congress in the Energy and Water Development Appropriations Act of 2012.

• To address the remaining Tier 2 and Tier 3 items, the NRC staff developed resolution plans in October 2015 and provided them to the Commission in SECY-15-0137. The staffs evaluation considered existing requirements and voluntary measures, the overall risk posed by the issue, and insights gained during work on the Tier 1 activities, to determine if a recommendation would provide a substantial safety improvement if implemented. The remaining Tier 2 and 3 activities were binned into three groups:

• Group 1 - Items that could be closed immediately because enough progress had been made and/or existing processes are in place to address future work. Additional ACRS and/or public interaction was not needed to resolve the recommendation.

- The Commission agreed with closing the Group 1 issues in SRM-SECY-15-0137.

• Group 2 - Items that the staffs initial assessment has concluded should be closed, but for which interaction with ACRS or external stakeholders is warranted prior to finalizing the assessment. Sufficient information was available and the staffs initial technical assessment was complete, but additional interaction with ACRS and/or external stakeholders would be beneficial.

- The staff informed the Commission of the final results of its evaluation in SECY-16-0041 on March 31, 2016.

• Group 3 - Items for which the staff had not yet completed its assessment and/or documentation, along with ACRS or external stakeholder interaction. More detailed documentation of analyses and justification for closure was needed. Interaction with ACRS and/or external stakeholders would be needed after the additional analyses were complete.

- The staffs additional analyses were provided to the Commission on June 2, 2016, in SECY-16-0074, and on December 29, 2016, in SECY-16-0144.

The Commission agreed, with comment, to close the Group 3 items in SRM-SECY-16-0144.

4 https://www.nap.edu/catalog/18294/lessons-learned-from-the-fukushima-nuclear-accident-for-improving-safety-of-us-nuclear-plants 5 https://www.nap.edu/catalog/21874/lessons-learned-from-the-fukushima-nuclear-accident-for-improving-safety-and-security-of-us-nuclear-plants 3

March 23, 2018

Disposition of Tier 2, Tier 3, and Non-Tiered Fukushima Lessons-Learned Activities All non-Tier 1 recommendations have been resolved. A summary list of all the non-Tier 1 activities, the SECY-15-0137 group (if applicable), and the associated completion documentation, is provided in the following table.

NTTF Rec # Recommendation Group Action to Complete Completion or Source 6 Documented 7 1 Establish a logical, systematic, and NA Evaluate in the context of the long term RMRF, SECY-13-0132 coherent regulatory framework for which is outside the scope of the NRC's post- and SRM adequate protection that appropriately Fukushima actions, thus NTTF SECY-14-0114 balances defense-in-depth and risk Recommendation 1 is considered closed. Enclosure 4 considerations.

ACRS The Advisory Committee on Reactor 3 An interim assessment, directed by SECY-16-0144 Safeguards (ACRS) recommended SRM-SECY-15-0137, was provided in Enclosure 1 expanding recommendation 2.1 to SECY-16-0074. The final staff assessment in and SRM include natural hazards other than SECY-16-0144 concluded that no additional flooding and seismic. Also mandated by regulatory actions were necessary. This Congress. recommendation is closed.

2.2 Initiate rulemaking to required licensees 3 Staff proposed to enhance existing processes SECY-16-0144 to confirm seismic and flooding to routinely aggregate and assess new hazard Enclosure 2 (expanded to include all natural hazards) information vice rulemaking. The External and SRM hazards every 10 years Hazards Center of Expertise (EHCOE) will report to the Commission every six months on the implementation of the process. This recommendation is closed.

3 Enhancements to the capability to 1 Given the broad regulatory activities pertaining SECY-15-0137 prevent or mitigate seismically-induced to seismic, fire, and flooding events, operating Enclosure 3 fires and floods (SIFF) experience involving SIFFs, and actions taken and SRM in response to the Fukushima accident, the staff concluded that additional requirements or enhancements are not needed.

6 Near-Term Task Force (NTTF) recommendations can be found in the NTTF report (ADAMS Accession No. ML11186A950) 7 Commission Papers (SECY), Staff Requirements Memoranda (SRM) and Commission Action Memoranda (COMSECY) are found in the NRC Library (https://www.nrc.gov/reading-rm/doc-collections/#comm) on the NRC web site (www.nrc.gov).

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Disposition of Tier 2, Tier 3, and Non-Tiered Fukushima Lessons-Learned Activities (Continued)

NTTF Rec # Recommendation Group Action to Complete Completion or Source Documented 5.2 Evaluate the need for hardened 2 Staff concluded that regulatory actions to SECY-16-0041 containment vents for other containment impose further improvements to containment Enclosure 1 designs venting and hydrogen control are not warranted. This recommendation is closed.

6 Hydrogen and combustible gas control 2 Staff concluded that regulatory actions to SECY-16-0041 within containment impose further improvements to containment Enclosure 1 venting and hydrogen control are not warranted. This recommendation is closed.

ACRS The ACRS recommended that the NRC 2 Staff concluded that enhanced instrumentation SECY-16-0041 consider the need for enhanced does not represent a substantial safety Enclosure 2 instrumentation for beyond-design-basis improvement. This recommendation is closed.

events 7.2-7.5 Spent fuel pool makeup capability NA Consolidated within the Mitigation of COMSECY-Beyond-Design-Basis Events (MBDBE) 13-0002 and rulemaking SRM SECY-14-0046 Enclosure 6 and SRM Staff Evaluate the need to expedite transfer of NA NRC staff concluded that, because of the COMSECY-spent fuel to dry storage minimal risk, no further generic evaluations 13-0030 and should be pursued. The Commission agreed SRM with the staffs recommendation. This item is complete.

In SRM-COMSECY-13-0030, the Commission SECY-15-0059 directed followup actions for the staff. The Enclosure 3 followup actions are complete.

Staff Consider the need to expand the 1 The staff concluded that no further regulatory SECY-15-0137 emergency planning zone (EPZ) beyond action is needed. This item is closed. Enclosure 6 10 miles and SRM Staff Consider the need to pre-stage 1 The staff concluded that no further regulatory SECY-15-0137 potassium iodide (KI) beyond 10 miles action is needed. This item is closed. Enclosure 6 and SRM 2

March 23, 2018

Disposition of Tier 2, Tier 3, and Non-Tiered Fukushima Lessons-Learned Activities (Continued)

NTTF Rec # Recommendation Group Action to Complete Completion or Source Documented 9.1 Emergency planning enhancements for NA Consolidated within the MBDBE rulemaking SECY-14-0046 9.2 multiunit and/or prolonged station Enclosure 6 blackout (SBO) events and SRM 9.3 (P) (Partial): Additional emergency NA Consolidated within the MBDBE rulemaking COMSECY-preparedness (EP) regulatory actions 13-0002 and SRM SECY-14-0046 Enclosure 6 and SRM 9.3 (P) (Partial): Maintain emergency response 1 The staff concluded that this would not result SECY-15-0137 data system (ERDS) capability for in a substantial safety improvement. This Enclosure 7 prolonged SBO event recommendation is closed. and SRM 10.1 Emergency response guidance, NA Consolidated within the MBDBE rulemaking SECY-14-0046 10.2 command and control, for prolonged Enclosure 6 SBO and SRM 10.3 Reliability of ERDS data 1 The staff concluded that this would not result SECY-15-0137 in a substantial safety improvement. This Enclosure 7 recommendation is closed. and SRM 11.1 Evaluate enhanced emergency response NA Consolidated within the MBDBE rulemaking SECY-14-0046 resources Enclosure 6 and SRM 3

March 23, 2018

Disposition of Tier 2, Tier 3, and Non-Tiered Fukushima Lessons-Learned Activities (Continued)

NTTF Rec # Recommendation Group Action to Complete Completion or Source Documented 11.2 Recovery and reentry insights 1 Specific guidance for response to a nuclear or SECY-15-0137 radiological event is contained in the current Enclosure 7 version of the Nuclear/Radiological Incident and SRM Annex 8 (NRIA) to the National Response Framework. The NRIA is being revised to address recovery in addition to response and will include lessons learned from the Fukushima event. The Federal Emergency Management Agency (FEMA) is leading an interagency effort to make those revisions. The NRC works on matters relevant to the NRIA as part of its normal interagency activities. This recommendation is closed.

11.3 Efficacy of real-time radiation monitoring 3 The staff concluded that no further regulatory SECY-16-0144 actions were necessary. This Enclosure 3 recommendation is closed. and SRM 11.4 Training on radiation, radiation safety 1 FEMA engages the public around nuclear sites SECY-15-0137 and KI using lessons learned and sharing best Enclosure 7 practices. This recommendation is closed. and SRM 12.1 Expand the reactor oversight process 1 The staff has identified and implemented SECY-15-0137 (ROP) to more fully include defense in improvements to the ROP based on insights Enclosure 8 depth from Fukushima-related lessons-learned. and SRM Potential future ROP enhancements will be implemented using existing agency processes.

This recommendation is closed.

12.2 NRC staff training on severe accidents 1 Significant progress has been made in SECY-15-0137 addressing this recommendation and Enclosure 9 additional training enhancements are planned. and SRM The staff will use well-established processes to make any necessary future enhancements.

This recommendation is closed.

8 https://www.fema.gov/media-library/assets/documents/25554 4

March 23, 2018

Disposition of Tier 2, Tier 3, and Non-Tiered Fukushima Lessons-Learned Activities (Continued)

NTTF Rec # Recommendation Group Action to Complete Completion or Source Documented SRM- Applicability to other regulated facilities NA The staff concluded that no regulatory action is SECY-15-0081 COMGBJ- needed for most other facilities. This item is 11-0002 closed.

For the three high-power research and test SECY-17-0016 reactors (RTR), the staff requested additional Enclosure 2 information from the licensees to determine whether additional actions were necessary.

Based on analysis of the licensees responses, the staff has concluded that no further actions are necessary.

The staff has closed GL 2015-01 9 for all fuel SECY-17-0016 cycle facilities with no further regulatory Enclosure 2 activities required.

SRM-SECY- Comparison of US and Japanese NA Comparison study 10 was completed in SECY-14-0046 12-0110 regulations November 2013. This item is complete. Enclosure 4 Congress Congress directed the NRC to fund a NA Phase 1 11 complete July 2014. Staff review SECY-15-0059 study by the National Academy of found that ongoing planned NRC and industry Enclosure 6 Sciences (NAS) on the lessons learned activities adequately address the NAS from Fukushima. recommendations from Phase 1.

In SRM-COMSECY-13-0030, the Commission directed the staff to provide Phase 2 12 complete May 2016. The staff SECY-16-0100 an assessment of the NAS report. review did not identify the need to initiate any new activities to address the Phase 2 recommendations.

9 ADAMS Accession No. ML14328A029 10 ADAMS Accession No. ML13326A991 11 https://www.nap.edu/catalog/18294/lessons-learned-from-the-fukushima-nuclear-accident-for-improving-safety-of-us-nuclear-plants 12 https://www.nap.edu/catalog/21874/lessons-learned-from-the-fukushima-nuclear-accident-for-improving-safety-and-security-of-us-nuclear-plants 5

March 23, 2018