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

2. 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

3. 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)

4. 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.

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

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

7. Disconnected Safety Regimes
EPGs
SAMGs

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

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

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

11. 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.

12. 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.

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

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

15. 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.

16. 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.

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

18. 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.

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

20. 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

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

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

23. 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

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

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

26. 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

27. Moving in the right direction, but clearly not there yet