Fukushima Regulatory Impacts NRC Region I Spring Seminar May 13, 2014 Dave Lochbaum Director, Nuclear Safety Project Union of Concerned Scientists

Fukushima - Many Barriers Multiple connections to offsite power grid Two emergency diesel generators per unit Eight hour battery backups to grid and EDGs 15-foot tall seawall Multiple onsite fire trucks with diesel pumps Severe accident management guidelines

Fukushima - More Barrier Busters Multiple connections to offsite power grid 9.0 earthquake took away grid Two emergency diesel generators per unit Located in basements vulnerable to floods Eight hour battery backups to grid and EDGs Onsite power outage lasted 9 days 15-foot tall seawall 45-foot tall tsunami wave Multiple onsite fire trucks with diesel pumps Infrastructure damage impaired use Severe accident management guidelines Good on paper (and only on paper)

Fukushima – One Barrier Shy Fukushima had many barriers. Had just one barrier been sufficiently robust, we wouldn’t be here today discussing Fukushima. More importantly, had just one barrier been sufficiently robust, tens of thousands of Japanese civilians would be home today instead of being displaced.

Disconnected Safety Regimes NTTF Recommendation 1 EPGs/SAMGs FLEX PRAs Really just one disconnection with three consequences from this disconnection.

Disconnected Safety Regimes NTTF’s foremost recommendation: Commission moved Recommendation 1 to last place

Disconnected Safety Regimes EPGs SAMGs

Disconnected Safety Regimes Regulatory requirements for safety-related SSCs Hopes about FLEX

Disconnected Safety Regimes PRAs for design basis accidents Fond wishes for severe accidents

Disconnected Safety Regimes – NTTF 1 One way to deal with “cliff-edge” effects is to pretend there are none

Disconnected Safety Regimes – NTTF 1 Commissioner Magwood during March 15, 2012, Senate oversight hearing: I think that our infrastructure, our regulatory approach, our practices at plants, our equipment, our configuration, our design bases would prevent Fukushima from occurring under similar circumstances at a U.S. plant. I just don’t think it would happen.

Disconnected Safety Regimes – NTTF 1 Commissioner Apostolakis during March 15, 2012, Senate oversight hearing: I don’t think what happened in Fukushima can happen here.

Connected Safety Regimes – NTTF 1 A better way is to accept cliffs exist and to manage their hazards

Connected Safety Regimes – NTTF 1 Someone should remind Commissioners Thelma and Louise about the cliff-edge

Disconnected Safety Regimes – NTTF 1 NRC November 2013 report “A Comparison of U.S. and Japanese regulatory requirements in effect at the time of the Fukushima accident” (ML13326A991), page 20: Prior to the Fukushima accident, both Japanese regulators and industry publicly stated that the possibility of severe accidents was sufficiently low, to the extent that a severe accident could not occur from an engineering viewpoint.

Disconnected Safety Regimes – NTTF 1 NRC November 2013 report “A Comparison of U.S. and Japanese regulatory requirements in effect at the time of the Fukushima accident” (ML13326A991), page 3: Staff cautions, however, that there should be no implication that the Fukushima accident and associated consequences could or would have been completely avoided assuming Japan had the same U.S. regulatory framework prior to the accident.

Connected Safety Regimes – NTTF 1 NTTF’s foremost recommendation: Establishes regulatory footprints for design bases and beyond design bases events

Connected Safety Regimes – NTTF 1 Template for viable NTTF 1 connection between design basis and beyond design basis might be operator licensing. NRC will license/relicense reactor operators and senior reactor operators. Under NRC-established conditions monitored by NRC, licensees can perform some of this testing.

Connected Safety Regimes – NTTF 1 There must be a regulatory footprint for design basis and beyond design basis measures.

Disconnected Safety Regimes - SAMGs 100% developed SAMGs 89% had SAMGs in control rooms 72% had SAMGs in EOFs 92% trained workers on SAMGs 77% re-trained workers on SAMGs 75% required SAMGs to reflect plant mods 42% had configuration mgmt for SAMGs

Disconnected Safety Regimes - SAMGs SAMGs protect the public during a severe accident – unless a severe accident occurs

Connected Safety Regimes - SAMGs NRC inspects requirements, not voluntarisms NRC finds compliances, or issues sanctions

Disconnected Safety Regimes - FLEX 100% develop FLEX ??% have adequate quality standards for FLEX ??% have adequate testing standards for FLEX ??% train workers on FLEX ??% re-train workers on FLEX ??% require FLEX to reflect plant mods ??% have configuration mgmt for FLEX FLEX protects the public during a severe accident – unless a severe accident occurs

Disconnected Safety Regimes - PRAs For the RA to truly stand for risk assessment, the P cannot stand for: partial pretend pseudo

Connected Safety Regimes - PRAs must cover all modes of operation, all transients, and all accidents (not just those that follow design basis scripts)

Are we there yet? NTTF recommended nearly 3 dozen ways to reduce vulnerabilities at U.S. reactors Not there yet with even 1 safety IOUs still outstanding Not there yet even when ALL of these safety IOUs are fully and effectively done Only there if NTTF after next disaster finds few vulnerabilities left to remedy

Moving in the right direction, but clearly not there yet