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NRDC's petitions to the NRC in response to the Near-Term Task Force's 90 Day Report on the Lessons from Fukushima

In July 2011 the NRDC Nuclear Program submitted to the Nuclear Regulatory Commission (NRC) twelve 10 CFR 2.206 petitions for immediate agency action and six 10 CFR 2.802 petitions for rulemaking that track the nuclear safety recommendations in the NRC Task Force's recently-released 90 day report on the lessons from the Fukushima Daiichi disaster. The 10 CFR 2.206 petitions ask the Commission to directly issue orders to nuclear power plant license holders on specific reactor safety upgrades. And the 10 CFR 2.802 rulemaking petitions request the NRC to commence a public process to alter specific rules that govern the nuclear industry's safety requirements.

Prior to our petitions, the New York Times recently discussed the NRC's Near Term Task Force Review and also provided an explanation of the different processes that we have invoked.

Here are brief descriptions of the specific petitions we filed.

    10 CFR 2.206 Petitions

  • nuc_11081201a.pdf 2.1 Order licensees to reevaluate the seismic and flooding hazards at their sites against current NRC requirements and guidance, and if necessary, update the design basis and SSCs important to safety to protect against the updated hazards.[p.30]
  • nuc_11081201b.pdf 2.3 Order licensees to perform seismic and flood protection walkdowns to identify and address plant-specific vulnerabilities and verify the adequacy of monitoring and maintenance for protection features such as watertight barriers and seals in the interim period until longer term actions are completed to update the design basis for external events. [p.30]
  • nuc_11081201c.pdf 4.2 Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design-basis external events and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.[p.39]
  • nuc_11081201d.pdf 5.1 Order licensees to include a reliable hardened vent in BWR Mark I and Mark II containments. [p.41]
  • nuc_11081201e.pdf 7.1 Order licensees to provide sufficient safety-related instrumentation, able to withstand design-basis natural phenomena, to monitor key spent fuel pool parameters (i.e., water level, temperature, and area radiation levels) from the control room.[p.46]
  • nuc_11081201f.pdf 7.2 Order licensees to provide safety-related ac electrical power for the spent fuel pool makeup system.[p.46]
  • nuc_11081201g.pdf 7.3 Order licensees to revise their technical specifications to address requirements to have one train of onsite emergency electrical power operable for spent fuel pool makeup and spent fuel pool instrumentation when there is irradiated fuel in the spent fuel pool, regardless of the operational mode of the reactor. [p.46]
  • nuc_11081201h.pdf 7.4 Order licensees to have an installed seismically qualified means to spray water into the spent fuel pools, including an easily accessible connection to supply the water (e.g., using a portable pump or pumper truck) at grade outside the building.[p.46]
  • nuc_11081201i.pdf 8.1 Order licensees to modify the EOP technical guidelines (required by Supplement 1, “Requirements for Emergency Response Capability,” to NUREG-0737, issued January 1983 (GL 82-33), to (1) include EOPs, SAMGs, and EDMGs in an integrated manner, (2) specify clear command and control strategies for their implementation, and (3) stipulate appropriate qualification and training for those who make decisions during emergencies.[p. 49]
  • nuc_11081201j.pdf 8.3 Order licensees to modify each plant’s technical specifications to conform to the above changes.[p.50]
  • nuc_11081201k.pdf 9.3 Order licensees to do the following until rulemaking is complete:

    • Determine and implement the required staff to fill all necessary positions for responding to a multiunit event.
    • Add guidance to the emergency plan that documents how to perform a multiunit dose assessment (including releases from spent fuel pools) using the licensee's site-specific dose assessment software and approach.
    • Conduct periodic training and exercises for multiunit and prolonged SBO scenarios. Practice (simulate) the identification and acquisition of offsite resources, to the extent possible.
    • Ensure that EP equipment and facilities are sufficient for dealing with multiunit and prolonged SBO scenarios.
    • Provide a means to power communications equipment needed to communicate onsite (e.g., radios for response teams and between facilities) and offsite (e.g., cellular telephones, satellite telephones) during a prolonged SBO.
    • Maintain ERDS capability throughout the accident.[p.57]
  • nuc_11081201l.pdf 9.4 Order licensees to complete the ERDS modernization initiative by June 2012 to ensure multiunit site monitoring capability.[p.57]

    10 CFR 2.802 Rulemaking Petitions
  • nuc_11081201m.pdf 2.2 Petition for Rulemaking to require licensees to confirm seismic hazards every 10 years and address any new and significant information
  • nuc_11081201n.pdf 4.1 Petition for Rulemaking to revise 10 CFR §50.63
  • nuc_11081201o.pdf 7.75 Petition for Rulemaking to require licensees to improve spent nuclear fuel pool safety
  • nuc_11081201p.pdf 8.4 Petition for Rulemaking to require realistic training on Severe Accident Mitigation Guidelines
  • nuc_11081201q.pdf 9.1 Petition for Rulemaking to require emergency preparedness (EP) for multiunit events
  • nuc_11081201r.pdf 9.2 Petition for Rulemaking to require emergency preparedness (EP) enhancements for prolonged station blackouts
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