Friday, September 28, 2012

Post # 71: NTTF Recommendation 1

So let's dig in to the NRC's Near Term Task Force (NTTF) recommendations as documented in the NTTF Report:

Recommendation 1.  "The Task Force recommends establishing a logical, systematic, and coherent regulatory framework for adequate protection that appropriately balances defense-in-depth and risk considerations.

1.1 Draft a Commission policy statement that articulates a risk-informed defense-in-depth framework that includes extended design-basis requirements in the NRC's regulations as essential elements for ensuring adequate protection

1.2 Initiate rulemaking to implement a risk-informed, defense-in-depth framework consistent with the above recommended Commission policy statement.

1.3 Modify the Regulatory Analysis Guidelines to more effectively implement the defense-in-depth philosophy in balance with the current emphasis on risk-based guidelines.  The Task Force beleives that the Regulatory Analysis Guidelines could be modified by implementing some of the concepts presented in the technology-neutral framework (NUREG-1860) to better integrate safety goals and defense-in-depth.

1.4 Evaluate the insights from the IPE and IPEEE efforts as summarized in NUREG-1560, "Individual Plant Examination Program: Perspectives on Reactor Safety and Plant Performance," issued December 1997, and NUREG-1742, "Perspectives Gained from the Individual Plant Examination of External Events (IPEEE) Program, " issued April 2002, to identify potential generic regulations or plant-specific regulatory requirements."

There's a lot nuclear safety and NRC jargon in the text I just quoted from the NTTF report.  I could spend several posts drilling down into the nuances of these recommendations and their potential implications.  Of all the recommendations presented by the NTTF, this is the one that has the greatest potential long-term impact for the commercial nuclear power industry.  I think of it as the "Super Recommendation"  I'll limit myself here to what I consider to be the most important high-level implication of Recommendation 1: Increased uncertainty and angst in the commercial power industry...

While Recommendation 1 and its sub-recommendations do not go so far as to state the current U.S. NRC regulatory framework is fatally flawed, the recommendation clearly communicates the NTTF's position that the current regulatory framework does not adequately integrate traditional deterministic reactor safety design approach (such as the use of design basis accidents, Design Criteria, "defense-in-depth", etc.) and the risk-based or probabilistic safety considerations (core melt probability, large early release LER probabilities, expected public health impacts, etc.) that have evolved in the post-TMI-2 era.

This challenge is not new.  During the past twenty years, the NRC has evolved toward increased usage of risk-based criteria in the examination of the requirement of plant backfits, conduct of plant maintenance, and in the articulation of risk-based safety-goals. Still it is the fact that the accident at Fukushima Dai-ichi did NOT violate current NRC public safety goals (because they are expressed solely in terms of expected public fatalities as a direct result of an accident, and there were no such fatalities at Fukushima). This fact obviously raises the question of whether the NRC's currently risk-based public safety goals are sufficiently comprehensive to protect society from Fukushima-like accidents.  (For instance, many individuals from within and outside of the nuclear industry are now advocating the addition of additional risk-based public impact criteria – such as land contamination.)

The NRC staff is currently considering Recommendation 1 and options for response to it.  We have been told to expect a "SECY" paper early in calendar year 2013.  That paper will  provide an initial roadmap for a (no-doubt long-term) re-examination and revision of the fundamental regulatory framework of commercial nuclear power plants in the U.S.

The potential implications of Recommendation 1 are huge.  The fundamental design of future nuclear power plants, the siting options and policies for new nuclear power plants, and the day-to-day operations of existing and future nuclear power plants might be affected in ways we cannot predict at this moment.

All of this comes, of course, at a time when the nuclear industry is laboring mightily to respond to the suite of "Tier-1" recommendations the NRC identified in SECY-11-0124 as requiring immediate or near-term action.   I'll talk more about Tier-1 recommendations in my next post.


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