United States Industry Perspectives on Implementation of Post-Fukushima Actions

Andrew Mauer Senior Project Manager, Risk Assessment, Nuclear Energy Institute

Michael Powell

Director, Fukushima Initiatives, Arizona Public Service

28 March 2017 • Vienna, Austria

Highlights

• Bias for action • Regulatory response • FLEX: Cornerstone of U.S. response • Strategic solutions • Summary

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The Nuclear Energy Institute’s Mission

• Foster the beneficial uses of nuclear technology before Congress, the White House and executive branch agencies, federal regulators, and state policy forums; proactively communicate accurate and timely information; and provide a unified industry voice on the global importance of nuclear energy and nuclear technology.

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An Industry United The Way Forward: Building Blocks

• Maintain Focus on Excellence in Existing Plant Performance (INPO)

• Develop and Issue Lessons Learned from the Fukushima Events (INPO)

• Improve the Effectiveness of U.S. Industry Response Capability to Global Nuclear Events (INPO/NEI)

• Develop and Implement a Strategic Communications Plan (NEI) • Develop and Implement the Industry's Regulatory Response

(NEI) • Participate and Coordinate with International Organizations

(INPO/EPRI) • Provide Technical Support and R&D Coordination (EPRI/NSSS

Owners’ Groups)

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A Bias for Action The Way Forward: Guiding Principles

• Ensure equipment and guidance, enhanced as appropriate, result in improvements in response effectiveness, using a diverse, flexible and performance-based approach for beyond design bases activities

• Address guidance, equipment and training to ensure long-term viability of safety improvements.

• Develop response strategies that are performance-based, risk-informed and account for unique site characteristics.

• Maintain a strong interface with federal regulators to ensure regulatory actions are consistent with safety significance and that compliance can be achieved in an efficient manner.

• Coordinate with federal, state and local government and their emergency response organizations on industry actions to improve overall emergency response effectiveness.

• Communicate aggressively the forthright approach the U.S. industry is taking to implement the lessons from the Fukushima Daiichi accident.

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Regulatory Response

• 90 day report – Near Term Task Force Recommendations

• Orders – Address “adequate protection”

• 10 CFR 50.54(f) – Request information to support regulatory decision making

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NRC Orders

• Mitigating Strategies for beyond design basis events (FLEX) EA-12-049

• Reliable Hardened Vent for Mark I and II containments EA-12-050

• Spent Fuel Pool Level Instrumentation EA-12-051

• Severe Accident Capable Hardened Containment Vent System EA-13-109

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NRC Request for Information - 10 CFR 50.54(f)

• Seismic and Flooding - Walkdowns → confirm design basis - Hazard Reevaluations, utilize current

methods of evaluation • Emergency Preparedness

- Staffing and Communications

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Implementation Activities: All On or Ahead of Schedule

2019 VENTS - PHASE 2

LONG-TERM OVERSIGHT 2018

HARDENED VENTS - PHASE 1 SUPPLEMENTAL HAZARD

EVALUATIONS

2017 NRC POST-COMPLIANCE INSPECTIONS NRC DOCUMENTATION OF REVIEWS

MITIGATION OF BEYOND DESIGN BASIS EVENTS RULE 2016

MITIGATION STRATEGIES SPENT FUEL POOL LEVEL INSTRUMENTATION

EMERGENCY PLANNING/RESPONSE UPGRADES REEVALUATION OF FLOODING AND SEISMIC HAZARDS

DISPOSITION TIER 2&3 ACTIVITIES

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Current Challenges

• Knowledge Transfer and Knowledge Management

• Sustainability • Preservation and capitalization of significant

investments • Consistency in implementation – inspections

underway

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Cornerstone of U.S. Response: FLEX NSRC

Call from Affected Site Requesting FedEx ships from NSRC to either Staging NSRC Support Area or to Memphis or Phoenix Airport

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NEI 12-06: Diverse and Flexible Coping Strategies (FLEX) Implementation Guide

• Defined external hazards, challenges and considerations including warning time

• Assumed initial conditions • FLEX capabilities and storage requirements • FLEX strategies and timing, phased approach • Defense in depth concept • Procedure integration • On and off-site resources and capabilities • Mitigation Strategy Assessments

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Issue Resolution • Battery Duty Cycles • Boron Mixing • BWR Anticipatory

Venting • CENTS Code • FLEX Maintenance • MAAP Analysis • Shutdown Modes • NOTRUMP Code

• SHIELD RCP Seals • FLOWSERVE RCP Seals • Westinghouse RCP

Seals • National SAFER

Response Centers • Change processes • Maintenance rule • Hoses and Cables

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Suite of NEI Guidance • NEI 12-01: Guideline for Assessing Beyond-Design-Basis Accident

Response Staffing and Communications Capabilities • NEI 12-02: Industry Guidance for Compliance with NRC Order EA-12-051 to

Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation • NEI 12-06: Diverse and Flexible Coping Strategies (FLEX) Implementation

Guide • NEI 13-06: Enhancements to Emergency Response Capabilities for Beyond-

Design-Basis Accidents and Events • NEI 14-01: Emergency Response Procedures and Guidelines for Beyond-

Design-Basis Events and Severe Accidents • NEI 14-06: Developing an Organization Approach to Beyond-Design-Basis

Event Planning and Response Requirements • NEI 16-06: Crediting Mitigating Strategies in Risk-Informed Decision

Making • NEI 16-08: Guidance for Optimizing the Use of Portable Equipment

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FLEX Approach Phase Strategies

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FLEX Approach – Capability and Storage • Capability

- Diverse set of equipment with flexible deployment options and common connection points

- Maintain core, containment and SFP cooling to mitigate the effects of beyond-design-basis external events

• Storage - Diverse locations or reasonably protected in structures

consistent with commercial standards - Able to be functional in a time frame to preclude core

damage

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Protected Storage Example – Monolithic Dome

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National SAFER Response Centers • Two national response centers capable of delivering

equipment to any site in the U.S. within 24 hours • Enough equipment to support (2) 2-unit sites

simultaneously plus maintenance spares • Each piece is designed to be flown in fixed wing

aircraft and externally by helicopter • Trained personnel deployed with equipment • Standardized color coded connections • Commercial grade equipment • Support from other nuclear stations

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National SAFER Response Center FLEX Equipment

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SAFER Program and Equipment

Electrical – TPC Connectors

Mechanical – Storz Fittings

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SAFER Program and Equipment NSRC

Call from Affected Site Requesting FedEx ships from NSRC to either Staging NSRC Support Area or to Memphis or Phoenix Airport

National Response Center Memphis or Phoenix

FedEx ships from NSRC to either Staging Area or to Memphis or Phoenix Airport

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Strategic Solutions

Maximize Areas of Credit

Maximize FLEXibility

FLEX and Beyond

Expand operational and regulatory credit given to mitigating strategies

Expand where portable equipment is used in plant operations

Be inclusive of all portable equipment beyond just FLEX

Improve SAFETY and efficiency of the nuclear fleet with the use of portable equipment

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Industry Framework Guidance

Improving plant safety and operations using portable equipment

Evaluating portable equipment in risk informed decision making

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Example: Risk RCS Makeup Flowpath

RWT 2A COLD LEG

2B COLD LEG

1A COLD LEG

1B COLD LEG

RCS

SDC HX CS Hdr

CH Pumps (3)

CS

LPSI

HPSI

Other SI Train

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Demineralized Water Storage Tank DWST

Example: SFP RISK Makeup Flowpath

Spent Fuel Pool

FLEX Pump

FLEX+1 Pump

PRIMARY HEADER

ALTERNATE HEADER

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Summary

• Safety is our highest priority • Significant safety enhancements achieved • Substantial completion of Fukushima actions in 2016 • Committed to timely completion of actions to

comply with the NRC rulemaking • Remarkable stakeholder involvement since 2011 has

enabled U.S. success • We appreciate the opportunity to participate in this

important forum

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