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Regulatory Implications of Fukushima for Nuclear Power Plants in the U

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1 Regulatory Implications of Fukushima for Nuclear Power Plants in the U
Regulatory Implications of Fukushima for Nuclear Power Plants in the U.S. Commissioner George Apostolakis U.S. Nuclear Regulatory Commission Carnegie Nuclear Policy Program Conference 6 March 2012

2 NRC Actions After Fukushima
NRC process for reaching decisions has been systematic Promptly conducted inspections at all 104 plants Formed Fukushima Near-Term Task Force to provide recommendations in 90 days NRC senior management review of recommendations Input from external stakeholders Evaluation by Advisory Committee on Reactor Safeguards Commission decisions NRC process for reaching decisions has been methodical and systematic Promptly confirmed the safety of operating nuclear plants through inspections at all 104 plants. Inspections focused on the status of equipment relied on in beyond-design-basis events and the implementation of severe accident mitigation procedures Formed Near Term Task Force to provide recommendations in 90 days Conduct methodical and systematic review of relevant NRC regulatory requirements, programs, and processes Recommend whether the agency should make near-term improvements to our regulatory system NRC senior management review of recommendations Steering Committee of senior managers reviewed Task Force recommendations Input from external stakeholders Through dialogue at public meetings and receipt of written comments on recommendations Evaluation by Advisory Committee on Reactor Safeguards Commission decision

3 High-Priority Actions
Orders Protection of mitigation strategies equipment Reliable hardened vents for BWR Mark I & Mark II containments Spent fuel pool instrumentation Request for information Seismic and flood plant walkdowns Seismic and flood hazard reevaluations Emergency preparedness staffing and communications assessments Rulemaking Revision of station blackout requirements Strengthening and integration of emergency operating procedures, severe accident management guidelines (SAMGs), and extensive damage mitigation guidelines Commission has approved actions that should be taken without delay Perform walkdowns to identify and address plant-specific seismic and flooding vulnerabilities & inform NRC of results Seismic and flood hazard reevaluations against current standards and guidance Revision of Station Blackout requirements to enhance the capability to maintain safety through a prolonged SBO Provide reasonable protection of mitigative strategies equipment from the effects of external events, and establish and maintain sufficient capacity to mitigate multi-unit events Require reliable hardened vent for BWR Mark I containments (NRC staff has since recommended including BWR Mark IIs) Strengthening on-site emergency response capabilities Methodology to integrate onsite emergency response processes, procedures, training and exercises Emergency preparedness Determine the required staff to fill all necessary positions to respond to a multi-unit event Evaluate means to power emergency communications equipment during a prolonged SBO event NRC staff considering additional issues raised during interactions with internal & external stakeholders, such as: Requirements for seismic monitoring instrumentation Spent fuel storage requirements Basis for emergency planning zone size Commission currently considering prioritization of all recommendations

4 My Views on Fukushima (1)
The accident was not of extremely low probability, i.e., it was not “unthinkable” or “unforeseen” Tsunami hazard was underestimated Critical equipment located in lower plant elevations Flooding risk assessment would have identified existing vulnerabilities No single decision maker during the accident Still, there are lessons to be learned The accident was not of extremely low probability, i.e., it was not “unthinkable” Tsunami hazard was underestimated Government of Japan’s report to IAEA: “the assumption on the frequency and scale of tsunamis was insufficient.” 10 earthquakes in the last 10 years worldwide of magnitude 8.4 or less that had generated tsunamis higher than 10m design basis did not include data on tsunamis that occurred more than 1000 years earlier NY Times article (March 26, 2011), an expert referred to Fukushima as involving “a cascade of stupid errors”. Critical equipment located in lower plant elevations Risk assessment for flooding not performed Rather than spending resources on analyzing extremely rare events, we should focus on ensuring the correctness of the design basis This is one of our Task Force recommendations which the Commission has approved

5 My Views on Fukushima (2)
We should be mindful of striking a proper balance between confirming the correctness of the design basis and expanding the design basis of U.S. plants. The public has an understandable sense of urgency. Thoughtful analysis and deliberation should not suffer as a result of a failure to take into account the fact that significant mistakes contributed to the accident. Not every lesson learned from Fukushima is necessarily of higher priority than ongoing work on existing safety issues, e.g., fire protection.

6 Regulatory Approach A Design Basis Accident is a postulated accident that a facility is designed and built to withstand without exceeding the offsite exposure guidelines of the NRC’s siting regulation. Defense in Depth is an element of the NRC’s safety philosophy that employs successive compensatory measures to prevent accidents or mitigate damage if a malfunction, accident, or naturally caused event occurs at a nuclear facility. [Commission’s White Paper, February 1999] These concepts protect against “unknown unknowns”.

7 Regulatory Treatment of Design Basis Accidents
Evaluated using conservative codes Subjected to surveillance, inspection, and maintenance requirements Controlled under rigid quality assurance requirements

8 Regulatory Treatment of Beyond-Design-Basis Accidents
Treatment has been inconsistent (“patchwork”) Some addressed in specific regulations Station Blackout Anticipated Transient Without Scram Loss of large areas due to fires and explosions Some addressed through voluntary industry initiatives Severe accident management guidelines Mark I hardened containment vents Quality requirements vary

9 High-Priority Actions
Orders Protection of mitigation strategies equipment Reliable hardened vents for BWR Mark I & Mark II containments Spent fuel pool instrumentation Request for information Seismic and flood plant walkdowns Seismic and flood hazard reevaluations Emergency preparedness staffing and communications assessments Rulemaking Revision of station blackout requirements Strengthening and integration of emergency operating procedures, severe accident management guidelines (SAMGs), and extensive damage mitigation guidelines Commission has approved actions that should be taken without delay Perform walkdowns to identify and address plant-specific seismic and flooding vulnerabilities & inform NRC of results Seismic and flood hazard reevaluations against current standards and guidance Revision of Station Blackout requirements to enhance the capability to maintain safety through a prolonged SBO Provide reasonable protection of mitigative strategies equipment from the effects of external events, and establish and maintain sufficient capacity to mitigate multi-unit events Require reliable hardened vent for BWR Mark I containments (NRC staff has since recommended including BWR Mark IIs) Strengthening on-site emergency response capabilities Methodology to integrate onsite emergency response processes, procedures, training and exercises Emergency preparedness Determine the required staff to fill all necessary positions to respond to a multi-unit event Evaluate means to power emergency communications equipment during a prolonged SBO event NRC staff considering additional issues raised during interactions with internal & external stakeholders, such as: Requirements for seismic monitoring instrumentation Spent fuel storage requirements Basis for emergency planning zone size Commission currently considering prioritization of all recommendations

10 NRC Backfit Rule Imposition of new requirements is governed by NRC’s Backfit Rule (10 CFR ) A backfit: Is the modification of or addition to systems, structures, components, or design of a facility; or the procedures or organization required to design, construct or operate a facility Results from new or amended NRC regulations or guidance issued after the facility has been licensed to operate

11 Components of Backfit Rule
A backfit can be imposed if it provides a substantial increase in protection to public health and safety that is cost justified Qualitative consideration of benefits also permissible, to account for non-quantifiable (or difficult to quantify) benefits Exceptions Compliance Necessary for adequate protection Defining or redefining what is needed for adequate protection The Commission may administratively exempt proposed NRC action from Backfit Rule

12 Adequate Protection NRC mission is to ensure adequate protection of public health and safety, promote the common defense and security, and protect the environment Adequate protection is not defined by statute or regulation It does not mean zero risk or absolute protection Commission is charged by law with deciding what measures are necessary to provide reasonable assurance that the public will be protected

13 Safety Enhancement “If it so desires, however, the Commission may impose safety measures on licensees or applicants over and above those required by section 182(a)'s adequate-protection standard.” “The exercise of this authority is entirely discretionary. If the Commission wishes to do so, it may order power plants already satisfying the standard of adequate protection to take additional safety precautions. When the Commission determines whether and to what extent to exercise this power, it may consider economic costs or any other factor.” Court of Appeals for the D.C. Circuit (Union of Concerned Scientists v. NRC, 824 F.2d 108, 120 (D.C. Cir. 1987))

14 Probabilistic Risk Assessment
PRA is a structured analytical process that provides both qualitative insights and quantitative estimates of risk. PRA answers the following questions: What can go wrong? How likely is it? What are the consequences?

15 Quantitative Health Objectives 1986
Early and latent cancer mortality risks to an individual living near the plant should not exceed 0.1 percent of the background accident or cancer mortality risk, approximately 5 x 10-7/year for early death and 2 x 10-6/year for death from cancer. Subsidiary goals Core damage frequency: per year Large early release frequency: 10-5 per year

16 Fukushima Near-Term Task Force Recommendation 1
Establish a logical, systematic, and coherent regulatory framework for adequate protection that appropriately balances defense in depth and risk considerations NRC staff proposal to be submitted to Commission in early 2013

17 Risk Management Task Force
Task Force for Assessment of Options for a More Holistic Risk-Informed, Performance-Based Regulatory Approach formed in February 2011 Task Force charter is to develop a strategic vision and options for adopting a more comprehensive and holistic risk-informed, performance-based regulatory approach for reactors, materials, waste, fuel cycle, and transportation that would continue to ensure the safe and secure use of nuclear material Final report in Spring 2012

18 Design Enhancement Category
Risk Management Task Force recommendation: NRC should establish via rulemaking a design enhancement category of regulatory treatment for beyond-design-basis accidents. This category should use risk as the safety measure, be performance-based (including the provision for periodic updates), include consideration of costs, and be implemented on a site-specific basis.

19 Proposed Regulatory Framework: Power Reactors
Design basis event? Adequate protection rule? Current cost-beneficial safety enhancement rule? Included risk-important scenario? Adequate Protection Category Proposed Design Enhancement Category Remaining scenarios Proposed Residual Risk Category

20 Concluding Remarks Highest priority actions are progressing
Plan for remaining actions due this summer Orders raise questions on adequate protection Need for updating the regulatory structure


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