Japan Lessons-Learned Division
When the NRC establishes a new requirement or asks its licensees for information, the agency sets appropriate deadlines. Plants usually meet those deadlines, but sometimes there are complications and a licensee needs more time than was originally anticipated.
The NRC established such deadlines for its post-Fukushima actions and, in some cases, licensees have asked for more time to complete the work. For instance, a plant might need information from the U.S. Army Corps of Engineers to finish reevaluating its flooding hazard.
What happens if the U.S. Army Corps of Engineers is still working on that information as the NRC’s deadline approaches? Another plant might be nearing compliance with all aspects of the Mitigating Strategies Order, but unforeseen prolonged and severe winter weather causes construction delays with the equipment storage building.
Other plants have announced that they will be shutting down in a few years, but after some deadlines for Fukushima-related work will have passed. What do all these plants do? They formally ask the NRC to revise the plant’s deadlines or relieve the plant of its requirement.
The NRC considers many things when reviewing these schedule change requests, including:
- Has the plant adequately justified its request?
- Is the amount of extra time requested reasonable?
- How will the plant continue to ensure safety in the period between the initial and proposed due dates?
If a licensee does not provide enough information for the NRC to make a decision, it will either request additional information from the licensee or deny the request. The NRC takes extension requests very seriously and ensures that each is thoroughly reviewed – by project managers, technical experts, NRC lawyers and enforcement experts, and NRC management (in some cases, up to the Director of the Office of Nuclear Reactor Regulation).
Plants that are permanently shutting down have other options. Depending on the timing of their shutdown, they may request that NRC orders requiring certain actions be cancelled or rescinded for them. The NRC will only rescind an order after the plant has certified it has permanently ceased operations and is no longer an operating reactor. This ensures the requirements stay in place if the plant later decides to keep operating.
Plants can also ask to delay certain work on the orders, which was the case for the recently-approved Oyster Creek relaxation request. The delay is not indefinite, though. If Oyster Creek does not shut down as planned, it must complete the work by a specified date.
Plants would follow a similar process to ask for schedule relaxations on the information requests (for example, the Vermont Yankee licensee requested to be relieved of responding to the request once the plant was shut down).
All of these requests get plenty of NRC review time. The NRC staff carefully considers each request on a plant-specific basis, and the NRC would only approve a relaxation request if a licensee provides good justification and demonstrates that safety would be maintained if the request were approved.
Even with the limited number of relaxation requests approved by the NRC, the industry is well on its way to appropriately implementing all post-Fukushima safety enhancements.
10 thoughts on “Considering Plant Circumstances for Post-Fukushima Requirements”
Simply – “Lessons Learned” purpose is to increase safety of nuclear reactors under the purview of the NRC, and be proactive in identifying potential problems and fixing them before they become problems. If I’m wrong, please inform me, these are safety and regulatory related tasks, correct? Lessons of Fukushima should be like a Preventive Maintenance program on steroids, correct?
Are Human Reliability/Factors programs a part of Post Fukushima requirements?
Why is it the stated position of the NRC not to require adherence to details involving specifications and safety requirements which could prevent serious problems, to include a cascading of events resulting in catastrophic multiple system failures of a nuclear reactor?
Case in point, quote – “The NRC expects that recipients will review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems. However, suggestions contained in this information notice are not NRC requirements; therefore, no specific action or written response is required.” Are over 200 loose parts banging around inside a reactor pressure vessel, to include damaging components, not a sufficient reason to issue a finding regarding the failure to adhere to technical specifications; or issuing a requirement to insure this failure doesn’t reoccur?
A lack of attention to detail, and a failure to enforce regulatory requirements, has been a previous problem for reactor operators and the NRC. This case (There are other cases such as Davis-Besse, which was a more serious problem involving a lack of attention to detail.) involves TVA’s Sequoyah Unit 1, reference IN 2016-02. The loose parts were known to be a problem in the Sequoyah Unit 1 Reactor Pressure vessel since its’ last refueling in 2013. Then, there was the lack of controls and management oversight regarding the most simple of tasks, wearing cold weather suits and various protocols of protecting an open reactor pressure vessel (RPV) during refueling. The cold weather suits were dropped into the RPV during refueling.
The intentional ignoring of crucial design requirements and improvements, failing to pay attention to detail involving simple but important tasks and requirements, subsequently allowing a reactor to operate without attention to detail, inadequate safety features and designs, external and internal to the reactor, are exactly what resulted in the cascading catastrophic failures of the nuclear reactors at Fukushima-Daiichi, Japan.
Accident investigations involving various complex engineering systems requiring human interactions reveal that in most cases catastrophic failures occur as a result of multiple small failures cascading over time into a catastrophic failure. The earthquake and Tsunami was the trigger which put into motion the final act of a building disaster.
The psychological detachment from reality and situational complacency, or delusion that “it can never happen to me (this includes a facility or organization),” is as much of a problem as a series of cascading system failures. Human Reliability/Factors are often elements overlooked and are either the trigger for the disaster or a part of the reason for multiple system failures. Human Reliability/Factors failures regarding attention to technical/safety details and failing to enforce safety and technical requirements at nuclear facilities doesn’t appear to be a lesson learned from Fukushima. What say you NRC?
Alrighty scott, expect it by september!
Once a vendor submits a “low-pressure… redundant passive cooling” reactor design, the NRC will review its ability to meet the relevant requirements. More information on the NRC’s advanced reactor activities is available on the agency website:
What is the NRC’s position on low pressure reactors with redundant passive cooling systems? Why not just require reactors to be absolutely fail safe? Its possible to engineer such systems… in fact its quite simple!
Such activity is a matter of public record. Go look them up for yourself.
I earlier posted on another NRC Blog on “Writing Rules on Lessons Learned from Fukushima,” and commended what staff did and are doing is a great job in trying to implement safety on Tier 1 and Tier 2 issues, while their senior management is tap dancing around the Commission who have their own priorities (and not write into rules some of the implemented EAs) – can you blame them? But licensees trying to take advantage of the staff playing cozy here trying to seek reliefs has to be put in some context. It is like the staff, with their hands tied behind the back are participating in a b__tt kicking contest. However a little bit of explanation that, the NRC provided to the commenters, to this blog, is perfectly in order that, with respect to EAs which are enforcement actions (which are just that); but the leeway given here is for only for request for Information or about reactors that are defueled and permanently shut down. It is perfectly in order and per 10 CFR 50.54(f)* any how!
You cannot convince Nay Sayers all the time, always !
* they ought to read these Regulations and educate themselves.
Generally, U.S. nuclear power plants have provided appropriate information and analysis to support the Fukushima-related requests. If the licensee has not provided that information and analysis, the NRC has asked for more information. In three cases, the request was either denied or the licensee withdrew it after discussions with the NRC – those plants met the required deadlines and actions. In another case, the NRC approved an extension, but not for the full amount that the licensee requested. The NRC will not approve and has not approved a request that does not meet our standards.
Ditto the two comments listed above.
I think it would be great if you listed the numbers of requests denied and/or the enforcements that resulted. That would go a long way toward showing the public that the NRC is not too cozy with those they “regulate,” which after all is one of the most important lessons learned from Fukushima.
I guess I’d just suggest, since Fukushima, this industry needs the NRC’s voice and directions to be strongly empowered. The balance in regulations here have been undermined for so long by industry, our Regulator voice needs to still grow and be empowered.
And then there’s the waste…….
Great work, NRC, yet if your going to be truly legit in this industry, your voice needs to be louder and have some bite with it.
NRC, of all the licensee requests for extending due dates, moving back deadlines, or otherwise failing to met commitments as originally promised, how many of those requests have you denied? And what were the consequences to the licensee? Take even the past 5 or 10 years for example? My read is that the NRC rarely says no to anything nuclear power plant owners ask. I believe those owners enjoy gifts from the NRC Santa Claus year round whether they have been naughty or nice! (:-)
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