Flooding Hazards January 6, 2014 David Lochbaum Director, Nuclear - - PowerPoint PPT Presentation

Flooding Hazards

January 6, 2014 David Lochbaum Director, Nuclear Safety Project Union of Concerned Scientists www.ucsusa.org

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Issues

• Risk integration vs. isolation
• Cart before the horse
• Inconsistent oversight

Stellar Regulatory Performance

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Source: ML120400493

Flood of Known Safety Issues

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Source: http://www.ucsusa.org/nuclear_power/reactor-map/embedded-flash-map.html

(GI-204 Reactors)

Another Drop in the Flood

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(CEUS Reactors)

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(Action Matrix)

Another Drop in the Flood

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Flood is More Than One Drop

But NRC Only Sees a Drop

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NRC’s decision-making processes, such as this one from RG 1.174, are largely made without formally considering other known risks.

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Connect-the-Dot?

Connect-the-Dot?

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If Reactors A and B each had flooding protection issues, NRC’s processes would treat each equally in terms of urgency, etc. But what if Reactor B also had seismic and fire issues and was in Action Matrix column 4 while Reactor A had no other issues and was in column 1?

Cart Before Horse

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The NRC mandated that walkdowns and assessments be performed BEFORE it clearly articulated its expectations and appropriate standards.

NRC accepted upstream dam failure issue in its generic issue program Fukushima Daiichi experienced earthquake and tsunami NRC began walkdowns per Temporary Inspection 2515/183 Near-Term Task Force issued report and recommends external flooding walkdowns 08 08-09 09-2010: 2010: 03 03-11 11-2011: 2011: 03 03-23 23-2011: 2011: 07 07-12 12-2011: 2011:

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Cart Before Horse

NR NRC C app pproved ed up upstr strea eam m da dam m failur ailure issue e issue as G as Gen eneric eric Issu Issue e 20 204 NR NRC C man manda dated ted walkd alkdowns wns and and ree eeva valua luati tion

• ns of

s of f flood looding ha ing haza zards ds NR NRC C en endo dorse sed d NEI flood NEI flooding ing walkd alkdown wn gu guidan idance ce NR NRC C issue issues fl s floo

• oding

ding ass assess essmen ment t gu guidan idance ce NR NRC C issue issues tsun s tsunami, su ami, surge ge, , se seic iche he ha haza zard d ass assess essmen ment t gu guidan idance ce 02 02-29 29-2012: 2012: 03 03-12 12-2012: 2012: 05 05-31 31-2012: 2012: 11 11-30 30-2012: 2012: 01 01-04 04-2013: 2013:

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Cart Before Horse

Mor More than 10 e than 10 months months AFTER AFTER the the walkdo alkdown wn dir directiv ective, e, NR NRC C hosted hosted a floodin a flooding g assessme assessment nt wor

• rkshop

kshop.

Cart Before Horse

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Mor More than tw e than two

• year

ears s la later ter, , feder ederal al go gover ernment is nment is playing playing ca catc tch-up up.

Cart Before Horse

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Cart Before Horse

Some Some unans unanswer ered questions: ed questions: 1) 1) Should Should dam f dam failur ailures es be be postula postulated co ted concur ncurrent wit ent with h hea heavy vy rainf ainfall, all, or should

• r should the

the current “sunny day” practice continue? continue?

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Cart Before Horse

Some Some unans unanswer ered questions: ed questions: 2) 2) When hen asse assessing ssing flooding flooding abo bove e design design basis basis le levels, els, should should factor actors s lik like e weight of eight of water af ter affecting str ecting structur uctures es be be consider considered, ed, or totall

• r totally

y ignor ignored ed as as is is the cu the current pr ent practice? actice?

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Cart Before Horse

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Cart Before Horse

Some Some unans unanswer ered questions: ed questions: 3) 3) When hen asse assessing ssing flooding flooding belo below design w design basis basis le levels, els, should should manual manual actions actions being being impair impaired ed by by flood w flood water be ter be consider considered, ed, or totall

• r totally

y ignor ignored ed as as is is the cu the current pr ent practice? actice?

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Cart Before Horse

Had they Had they been completed been completed at t Fuku Fukushima shima Daiic Daiichi hi bef befor

• re

e Mar March 10, h 10, 2011, w 2011, would the

• uld the

NR NRC-manda mandated ted flooding flooding walkdo alkdowns wns and and asse assessme ssments nts ha have pr e prevented the thr ented the three ee reactor melt eactor meltdo downs? wns?

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Cart Before Horse

Near Term Task Force recommendation 2.2:

Initiate rulemaking to require licensees to confirm seismic hazards and flooding hazards every 10 years and address any new and significant information. If necessary, update the design basis for SSCs important to protect against the updated hazards.

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Source: NRC slides 11/12/2013 (ML13311A268)

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Source: NRC slides 11/12/2013 (ML13311A268)

Duck and Uncover

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06/22/2010 – Secret confirmatory action letter for Oconee flood protection shortcoming 10/08/2010 – Public yellow finding for Fort Calhoun flood protection shortcoming 06/18/2013 – Public yellow finding for Point Beach flood protection shortcoming 08/28/2013 – Public yellow finding for Monticello flood protection problem

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Issues

• Risk integration vs. isolation
• Cart before the horse
• [redacted] oversight

Acronym List

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CEUS – Central and Eastern United States GI – Generic issue NEI – Nuclear Energy Institute NRC – Nuclear Regulatory Commission RG – Regulatory Guide SSC – Systems, structures, and components USGS – United States Geological Survey