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.


Thursday, September 20, 2012

Post # 70: The Structure of the U.S. Fukushima Response

With this post I begin the promised series in which I hope to provide a structured and concise chronicle of the U.S. nuclear industry's ongoing response to the Fukushima Dai-ichi accident and the the evolving "lessons-learned" from it.

In the wake of the Fukushima Dai-ichi incident, the U.S. Nuclear Regulatory Commission (NRC) convened a "Near-Term Task Force" or "NTTF" to examine the events at Fukushima Dai-ichi and offer recommendations regarding actions the NRC should take to enhance commercial nuclear power safety in the U.S. in the light of evolving lessons learned from the event.  The NTTF report,   "Recommendations for Enhancing Reactor Safety in the 21st Century – the Near-Term Task Force Review of Insights From the Fukushima Dai-ichi Accident," (SECY-11-0093, 12 July 2011) concluded there was imminent danger from continued operation of U.S. nuclear power plants, but did present "Twelve Recommendations" for actions the NRC and its licensees should take to further enhance the safety of commercial nuclear power.  

Following issuance of the NTTF report, the NRC Commission asked (SRM-SECY-11-0093) the NRC Staff to examine the NTTF's Twelve Recommendations, and to prioritize them in a logical manner based on the urgency of required actions, and the inter-relationships and inter-dependencies of the various issues.  The NRC Staff's initial recommendations regarding the subset of actions requiring the most urgent action were presented in SECY-11-0124.  Subsequently,  SECY-11-0137 presented the NRC Staff's recommendations for a three-tired prioritization.  This three-tiered hierarchy was accepted by the NRC Commissioners, and became the organizational foundation of the U.S. response to the accident at Fukushima.

Before I continue, I should point out that, as NRC Chairman Macfarlane said a few days ago in her remarks at the IAEA in Vienna, the current structure of the NRC's and the Industry's response to Fukushima is likely to evolve away from the simple "12 Recommendations" approach presented in the Near-Term Task Force (NTTF) report.  Here are Chairman Macfarlane's words,

" As we move forward in the evolution of our nuclear safety culture, we must address the fact that the majority of post-Fukushima activities were placed in special categories. In the period immediately following Fukushima, this approach made the most sense. In the United States, for example, we established a task force to address the impacts of the accident on our domestic program, and then a special Fukushima-related directorate to implement the ensuing recommendations. The NRC is now beginning to transition these Fukushima lessons-learned programs from special, segregated actions back to the offices that handle these matters on a routine basis. Far from minimizing these activities’ importance, this approach will ensure that the lessons we have learned are fully integrated into our regulatory work in the United States. We believe that by weaving the lessons learned from Fukushima into nearly all of our regulatory activities, we are ensuring their long-term sustainability, and encourage our international colleagues to do the same.

So... now for the Twelve Recommendations as presented in SECY-11-0093....

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

2. The Task Force recommends that the NRC require licenses to reevaluate and upgrade as necessary the design-basis seismic and flooding protection of structures, systems, and components for each operating reactor

3. The Task Force recommends, as part of the longer term review, that the NRC evaluate potential enhancements to the capability to prevent for mitigate seismically induced fires and floods

4. The Task Force recommends that the NRC strengthen station blackout mitigation capability at all operating and new reactors for design-basis and beyond-design-basis external events

5. The Task Force recommends requiring reliable hardened vent designs in boiling water reactor facilities with Mark I and Mark II containments

6. The Task Force recommends, as part of the longer term review, that the NRC identify insights about hydrogen control and mitigation inside containment or in other buildings as additional information is revealed through further study of the Fukushima Dai-ichi accident

7. The Task Force recommends enhancing spent file pool makeup capability and instrumentation for the spent fuel pool.

8. The Task Force recommends strengthening and integrating onsite emergency response capabilities such as emergency operating procedures, severe accident management guidelines, and extensive damage mitigation guidelines.

9. The Task Force recommends that the NRC require that facility emergency plans address prolonged station blackout and multiunit events.

10. The Task Force recommends, as part of the longer term review, that the NRC pursue additional emergency preparedness topics related to multiunit events and prolonged station blackout.

11. The Task Force recommends, as part of the longer term review, that the NRC should pursue emergency preparedness topics related to decision making, radiation monitoring, and public education.

12. The Task Force recommends that the NRC strengthen regulatory oversight of licensee safety performance (i.e., the Reactor Oversight Process) by focusing more attention on defense-in-depth requirements consistent with the recommended defense-in-depth framework.

Things are a bit more complicated than this simple list, because each of the Twelve Recommendations (except for # 3)  were parsed into two or more sub-recommendations (e.g. 1.1, 1.2, 1.3, and 1.4).   Those seeking to monitor U.S. progress in addressing the Twelve Recommendations find their task complicated further because the three-tier prioritization of the Twelve Recommendations was done at the sub-recommendation level rather than at the top level. Thus, Recommendation 5.1 is a Tier-1 priority, while Recommendation 5.2 is a Tier-3 priority.

I will end this post here.  Future posts will discuss the sub-recommendations for each of the Twelve Recommendations, the prioritization of the sub-recommendations, actions taken to date by the U.S. NRC and the nuclear industry to address each sub-recommendation, future directions for continued progress, etc.

Again, my goal in this series of posts is not to provide an exhaustive review of all the safety-related activities in the industry.  I'm simply attempting to "status" U.S. progress in the key areas identified by the NTTF in a structured, clear, and simple manner that enables the non-expert to understand and track the post-Fukushima evolution of U.S. commercial nuclear power safety.


Thursday, September 13, 2012

Post # 69: Monitoring the U.S. Response To Fukushima

This blog is about sustainable energy.  Over the past couple of years I've discussed a wide variety of topics that relate to sustainable energy production and use.  I've frequently noted my conviction that nuclear energy has to be the foundation of any sustainable AND ABUNDANT energy future for this small blue planet.

Those of you who have followed me here for any length of time also know I've spent much of my career in the nuclear reactor safety arena.  More specifically, I spent many years working with my colleagues at Oak Ridge National Laboratory (ORNL), the other national laboratories, and the commercial nuclear industry to improve our understanding of severe accident phenomenology, severe accident progression, and severe accident management strategies in commercial boiling water reactors (BWRs).  Along with all of you, I was deeply saddened by the events of March 2011 in Japan and at the Fukushima Dai-ichi plant.   Several of my previous blogs have dealt with BWR severe accident phenomenology and the events at Fukushima.

As you can imagine, I am closely following the post-Fukushima response of the global commercial nuclear industry and regulatory agencies worldwide.  In fact, at EnergX, we're part of that response.  We've assembled an incredibly talented team of nuclear reactor safety and risk experts – some of whom have been heavily involved in the beyond-design-basis accident and severe accident research and regulatory arenas for over forty years (predating the 1975 Reactor Safety Study (WASH-1400).  Members of our team were on-site during and following the accidents at TMI-2 and Chernobyl.  They served on the Advisory Committee on Reactor Safeguards (ACRS), and they led both industry and national laboratory research efforts for the decades following these accidents.  And, like some of you, our team is engaged in the industry's effort to learn from and respond to the Fukushima Dai-ichi accident.

So it is with this background I've decided to initiate a series of updates here to discuss the status of the U.S. industry's and the U.S. Nuclear Regulatory Commission's response to Fukushima Dai-ichi.  I will attempt to strike a balance between technical detail and clarity so that you do not have to be a nuclear engineer, or a nuclear regulatory expert to following along.  My goal in doing this is not to be an evangelist for the nuclear industry.  The industry needs no evangelist.  Rather, my goal is to chronicle as accurately and clearly as possible how the events at Fukushima are changing the present and the future of nuclear power in the U.S. and abroad.

So visit me regularly in the coming weeks and months to following the unfolding story of how the U.S. commercial nuclear power sector is learning from, and responding to the events at Fukushima.

Oh... and not to worry... I don't plan to entirely abandon the broader sustainable energy topic.  I will continue to post on non-Fukushima and non-nuclear energy matters as my interests and evolving events warrant.