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

Issues • Risk integration vs. isolation • Cart before the horse • Inconsistent oversight 2

Stellar Regulatory Performance Source: ML120400493 3

Flood of Known Safety Issues (GI-204 Reactors) Source: http://www.ucsusa.org/nuclear_power/reactor-map/embedded-flash-map.html 4

Another Drop in the Flood (CEUS Reactors) 5

Another Drop in the Flood (Action Matrix) 6

Flood is More Than One Drop 7

But NRC Only Sees a Drop NRC’s decision -making processes, such as this one from RG 1.174, are largely made without formally considering other known risks. 8

Connect-the-Dot? 9

Connect-the-Dot? 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? 10

Cart Before Horse The NRC mandated that walkdowns and assessments be performed BEFORE it clearly articulated its expectations and appropriate standards. 11

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

Cart Before Horse 02-29 02 29-2012: 2012: NRC NR 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 03-12 03 12-2012: 2012: NRC NR C man manda dated ted walkd alkdowns wns and and ree eeva valua luati tion ons of s of f flood looding ha ing haza zards ds 05 05-31 31-2012: 2012: NRC NR C en endo dorse sed d NEI flood NEI flooding ing walkd alkdown wn gu guidan idance ce 11 11-30 30-2012: 2012: NR NRC C issue issues fl s floo ooding ding ass assess essmen ment t gu guidan idance ce 01-04 01 04-2013: 2013: NRC NR 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 13

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 orkshop kshop. 14

Cart Before Horse Mor More than tw e than two o year ears s la later ter, , feder ederal al go gover ernment is nment is playing playing ca catc tch-up up. 15

Cart Before Horse Some Some unans unanswer ered questions: ed questions: 1) 1) Should Should dam f dam failur ailures es be be postulated co postula ted concur ncurrent wit ent with h hea heavy vy rainf ainfall, all, or should or should the the current “sunny day” practice continue? continue? 16

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 factor should actors s lik like e weight of eight of water af ter affecting str ecting structur uctures es be be considered, consider ed, or totall or totally y ignor ignored ed as as is is the cu the current pr ent practice? actice? 17

Cart Before Horse 18

Cart Before Horse Some Some unans unanswer ered questions: ed questions: 3) When 3) hen asse assessing ssing flooding flooding belo below design w design basis basis le levels, els, should manual should manual actions actions being being impair impaired ed by by flood w flood water be ter be considered, consider ed, or totall or totally y ignor ignored ed as as is is the cu the current pr ent practice? actice? 19

Cart Before Horse Had they Had they been completed been completed at t Fuku Fukushima shima Daiic Daiichi hi bef befor ore e Mar March 10, h 10, 2011, w 2011, would the ould the NRC-manda NR 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? 20

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. 21

Source: NRC slides 11/12/2013 (ML13311A268) 22

Source: NRC slides 11/12/2013 (ML13311A268) 23

Duck and Uncover 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 24

Issues • Risk integration vs. isolation • Cart before the horse • [redacted] oversight 25

Acronym List 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 26