Appendix A: Regulatory Authority Responses to
Phase 1 Information Request
Summaries of Actions Taken and Questionnaire Responses
Regarding Human and Organisational Factors Addressed bythese Actions

APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

Table of contents

CANADA ................................................................................................................................................... 5
CZECH REPUBLIC ................................................................................................................................... 35
FRANCE ................................................................................................................................................... 37
JAPAN ...................................................................................................................................................... 67
KOREA ..................................................................................................................................................... 99
SPAIN .................................................................................................................................................... 110
SWEDEN................................................................................................................................................ 149
UNITED STATES .................................................................................................................................. 159

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTCANADA
Response to Phase 1 Information Request
provided by Canadian Nuclear Safety Commission

1 Introduction
On March 11, 2011, a 9.0 magnitude earthquake struck off the coast of Japan and generated alarge tsunami that struck the Fukushima Daiichi Nuclear Power Plant. When the earthquake
occurred, three units at Daiichi were fully operational and were automatically shut down as per
design. The emergency diesel generators started automatically supplying power to all essential
electrical equipment including the pumps necessary to keep the fuel cool. When the tsunami
struck Daiichi Nuclear Power Plant, the water disabled the emergency generators and flooded
the electrical switchgear causing essential electrical equipment to stop functioning. Insufficientfuel cooling led to the meltdown of three or the six reactors and subsequently, the release ofradioactive material into nearby regions and the sea.
In response to the Fukushima accident, the Canadian Nuclear Safety Commission (CNSC)
requested Class I nuclear facilities to re-examine safety cases of their nuclear power plants. On
March 30, 2011, the Fukushima Task Force (FTF) was established to review licensees’ responses
regarding safety case review and to provide recommendations for essential regulatory, licensing,or procedural improvements. Additionally, on August 5, 2011, the CNSC executive management
committee determined that in light of lessons learned from Fukushima, CNSCs response to the
Fukushima accident should be reviewed by an External Advisory Committee (EAC). The EAC wasformed and consisted of members who were neither former CNSC employees, nor from thenuclear community, but who had backgrounds in forensic investigation, technology, andgovernance. EAC members were asked to review CNSCs immediate response to Fukushima, its
interactions, connections, and communications with other federal and international agencies,
and the interactions with the Canadian nuclear sector. The EAC determined that the CNSCs
actions following the Fukushima crisis were appropriate in that the CNSC immediately activatedits emergency operations centre and established effective communications with both local andinternational stakeholders, and with the general public.
On September 30, 2011, the FTF submitted its initial report complete with findings andrecommendations. The report contained 13 recommendations to further enhance safety with
an emphasis on these four categories:•

Strengthening reactor defence-in-depth;•

Enhancing emergency response and preparedness in Canada;•

Improving regulatory framework and processes; and•Enhancing international collaboration

In order to the implement the FTF recommendations, the CNSC developed a draft Action
Plan. The plan was subjected to three public consultations and two independent reviews. The
public consultations are outlined below.
•

October 28, 2011: Round one of consultations regarding the Task Force Report and theaccompanying CNSC Management Response;

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST•

December 21, 2011: Round two of consultations on the draft CNSC Staff Action Plan on
the CNSC Fukushima Task Force Recommendations and the comments received during
round one; and•March 2, 2012: Round three of consultations on the CNSC Staff Action Plan on the CNSC
Fukushima Task Force Recommendations and comments received during round two.

The independent reviews of the Action Plan were completed by the International Atomic
Energy Agency (IAEA) Integrated Regulatory Review Service (IRRS) and the same EAC that
reviewed the CNSCs’ initial response to the Fukushima event. The IRRS established that the
CNSC response to Fukushima was strong and complete and that Canada had an “effective andpragmatic framework” established to implement the Fukushima lessons learned. The EAC
provided nine recommendations that were incorporated into the final CNSC Integrated Action
Plan: On the Lessons Learned from the Fukushima Daiichi Nuclear Accident (August 2013). The
sixth recommendation is that the CNSC should, “Examine the area of human and organizational
performance (HOP) to achieve a more complete understanding of the lessons learned from the
Fukushima crisis.” The CNSC recognizes that HOP is essential in all design, procedural, andanalysis activities and as such, will examine HOP in beyond-design-basis scenarios and accident
management. HOP considerations have been integrated into relevant action items and closure
criteria. The final CNSC Action Plan incorporated public feedback and independent review
recommendations and included short-, medium, and long-term timelines for the actions asshown in Table 1.
The 13 FTF recommendations and subsequent actions are discussed in the sections
following the table and each action with HOP closure criteria is identified. Note that the action
items in this document are summarized and for more detail, refer to the CNSC integrated Action
Plan: On the Lessons Learned from the Fukushima Daiichi Nuclear Accident (August 2013). Additionally,answers to the questionnaire regarding specific Human an Organizational Factors that havebeen addressed by these actions can be found in Section 3.

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Table 1 CNSC Fukushima Action Plan Implementation Timeline
Implementation timeline
Task Force Recommendations

Short term

Medium termLong term(Dec 2012)(Dec 2013)(Dec 2015)

√

√

√

Strengthening Reactor Defence-in-depth
1. Verify Robustness of nuclear power plant designs
2. Assessment of Site-Specific External Hazards√

3. Enhance Modelling Capabilities√

Enhancing Emergency Response
4. Assess Emergency Plans (Onsite)√

5. Update Emergency Facilities and Equipment√√

6. Offsite Emergency Plans and Programs
Improving the Regulatory Framework and Processes
7. Class I Nuclear Facilities Regulations Amendments√

8. Radiation Protection Regulations Amendments√

9. Update Regulatory Document Framework√

10. Amend Power Reactor Operating Licences (PROLs)√

11. Implementation of Periodic Safety Reviews (PSRs)√√

Enhancing International Cooperation
12. Enhance Collaboration with CANDU Owner Countries√

13. Enhance International Cooperation√

2 Canadian Nuclear Safety Commission Fukushima Lessons Learned Action Items
This section provides a summary of the FTF recommendations and associated actions andidentifies if actions have HOP closure criteria. If actions have HOP closure criteria, these aredescribed.

2.1 Strengthening Reactor Defence in Depth
In its report, the FTF confirmed that all Canadian nuclear power plants are safe and that there
are multiple layers of defence built into the plants. These defences ensure that the public will
not be impacted from credible external events. Additionally, the design provides protection
against external events that are unlikely to occur. Even though the nuclear power plants’
defences are robust, the FTF made recommendations that plants should “strengthen each layerof defence built into Canadian nuclear power plants and licensing philosophy.” The CNSC
developed the following recommendations and actions to ensure that Canadian nuclear power
plants would have stronger layers of defense.

Recommendation 1 – Verify the Robustness of Nuclear Power Plant Designs
Action A.1.1 Licensees should submit to CNSC bleed/condenser relief capacity confidence
evidence. This action does not have HOP closure criteria expectations.
•

Action Item A.1.1.1 Submit an updated evaluation showing that bleed condenser/
degasser relief valves have sufficient capacity; andPOST-FUKUSHIMA ACTION IMPLEMENTATION AT NUCLEAR INSTALLATIONS: HUMAN AND ORGANISATIONAL FACTORS LESSONS LEARNT, NEA No. 7578, © OECD 2023

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST•

Action Item A.1.1.2 If additional relief capacity is required, develop plan/schedule for
confirmatory testing of installation.

Action A.1.2 Licensees should re-examine capability of shield tank/calandria vault relief todischarge steam in severe accident. This action does not have HOP closure criteria expectations.
•

Action Item A.1.2.1 Re-assess the capability of shield/tank calandria vault relief;•

Action Item A.1.2.2 If relief capacity is insufficient, asses benefits available from
adequate relief capacity and determine practicability of providing additional relief; and•Action Item A.1.2.3 If additional relief is beneficial and practicable, develop plan/schedule.

Action A.1.3 Licensees should evaluate ways to prevent failure of containment systems andunfiltered release of radioactive materials in beyond-design-basis accidents. This action has
HOP closure criteria expectations.
•

Action Item A.1.3.1 Evaluate adequacy of current means of protecting containment
integrity and preventing uncontrolled release; and•Action Item A.1.3.2 If current means are inadequate, develop plan/schedule forenhancements.

HOP Closure Criteria for Action Items A.1.3.1 and A.1.3.2•

Any system modifications should apply applicable Human Factors Engineering (HFE)
processes including function and task analysis, verification and validations, andconsideration of operating experience; and•If applicable, training needs analysis and procedural updates should be completed.

Action A.1.4 Licensees should install/complete installation of Passive Autocatalytic
Recombiners (PARs). This action does not have HOP closure criteria expectations.
•

Action Item A.1.4.1 Develop plan/schedule for installation as soon as possible.

Action A.1.5 If Irradiated Fuel Bays drain after a beyond-design-basis accident, need forhydrogen mitigation should be evaluated. This action does not have HOP closure criteria
expectations.
•

Action Item A.1.5.1 Evaluate potential for draining of Irradiated Fuel Bays (IFBs) and needfor hydrogen mitigation.

Action A.1.6 Licensees should evaluate the structural response of the IFB at temperatures
exceeding design limits. This action has HOP closure criteria expectations.
•

Action Item A.1.6.1 Evaluate structural response of IFB structure to exceeding
temperatures and assess maximum credible leak rate; and•Action Item A.1.6.2 If necessary, develop plan/schedule for mitigating measures for IFB.

HOP Closure Criteria for Action Items A.1.6•

The plan/schedule should include consideration of human actions in proposed
mitigating measures; and•A training needs analysis should be completed to ensure required human actions aredefined in training requirements for proposed mitigating measures.

Action A.1.7 Licensees should evaluate means to provide coolant make-up to the primary heattransport system, steam generators, moderator, shield tank/calandria vault, spent fuel pools,
and dousing tank. This action has HOP closure criteria expectations.
•8

Action Item A.1.7.1 Develop plan/schedule for optimization or additional coolant makeup provisions.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTHOP Closure Criteria for Action Item A.1.7•

Any system modifications should apply applicable HFE processes including function andtask analysis, verification and validations, and consideration of operating experience;and•If applicable, complete training needs analysis and update procedures (e.g. emergency
operating procedures and SAMGs).

Action A.1.8 Licensees should show that all equipment and instrumentation necessary forsevere accident management and executing the Serious Accident Management Guide (SAMG)
will perform as necessary. This action has HOP closure criteria expectations.
•

Action Item A.1.8.1 Develop plan/schedule for assessing and upgrading (whereappropriate) equipment/instrumentation.

HOP Closure Criteria for Action A.1.8•

Human Factors analyses should be used to contribute to requirements specifications for
upgrades/procurements;•

Any system modifications should apply applicable HFE processes including function andtask analysis, verification and validations, and consideration of operating experience;and•If applicable, complete training needs analysis to ensure that any human actions
required for operation or maintenance of equipment/instrumentation is defined in the
training requirements.

Action A.1.9 Licensees should evaluate habitability of control facilities following a severe
accident. This action has HOP closure criteria expectations.
•

Action Item A.1.9.1 Develop plan/schedule if upgrades are identified.

HOP Closure Criteria for Action A.1.9•

Human factors analysis using operating experience and lessons learned to support
personnel working in control facilities for extended period of time. Analysis should
include:–Thermal conditions;–

Requirements for, and impact of, wearing Personal Protective Equipment (PPE);–

Need for general and task lighting; and–Interactions of special lighting systems with panel displays.

•

Human Factors analyses should be used to specify requirements to support personnel
working in control facilities for extended periods of times;•

Design and implementation of upgrades should include HFE program, including
stakeholder and task analysis, and verification and validation activities; and•Complete training needs analysis to ensure that any human actions required for
operation or maintenance of equipment/instrumentation is defined in the training
requirements.

Action A.1.10 Licensees should explore options for extending availability of power for key
instrumentation and control to target eight hours of continued power without external support.
This action has HOP closure criteria expectations.
•

Action Item A.1.10.1 Evaluate requirements and capabilities for electric power for key
instrumentation/control; and•Action Item A.1.10.2 Develop plan/schedule if upgrades are identified.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTHOP Closure Criteria for Action A.1.10•

Design and implementation of upgrades should include HFE program, including
operating experience and lessons learned, stakeholder and task analysis, andverification and validation activities; and•Complete training needs analysis to ensure any required human actions involving
operations or maintenance of upgraded equipment, and to update procedures, as
required.

Action A.1.11 Licensees should obtain emergency equipment and other resources. This action
has HOP closure criteria expectations.
•

Action A.1.11.1 Develop plan/schedule for procuring equipment.

HOP Closure Criteria for Action A.1.11•

Complete training needs analysis for operation and maintenance of equipment; and•Human Factors analysis for use of equipment/instrumentation in severe accident
scenarios.

Recommendation 2 – Assessment of Site-Specific External Hazards
Action A.2.1 Licensees should complete review of the basis for external events against modern
state-of-the-art practices for evaluating external event magnitudes and relevant design capacity
for these events. This action has no HOP closure criteria expectations.
•

Action Item A.2.1.1 Re-evaluate site-specific events to which plant may be susceptible;
and•Action Item A.2.1.2 Develop plan/schedule for corrective actions.

HOP Closure Criteria for Action A.2.1•

No specific HOP closure criteria are identified.

Action A.2.2 Licensees should complete implementation of RD-310, Safety Analysis for Nuclear
Power Plants.
•

Action Item 2.2.1 No new requirement as already being implemented.

HOP Closure Criteria for Action A.2.2•

No specific HOP closure criteria are identified.

Recommendation 3 – Enhance Modelling Capabilities
Action A.3.1 Licensees should review/update/develop SAMGs at each station and include multiunit and IFB events in SAMGs and validate and refine SAMGs to reflect Fukushima lessons
learned. This action has HOP closure criteria expectations.
•

Action Item A.3.1.1 Develop plan/schedule for SAMGs that are not developed, finalized,
or fully implemented;•

Action Item A.3.1.2 Multi-unit plants to develop plan/schedule for inclusion of multiunit events;•

Action Item A.3.1.3 Develop plan/schedule for inclusion of multi-unit events in SAMGs;
and•Action Item A.3.1.4 Use table-top exercises/drills to demonstrate effectiveness of
SAMGs.

HOP Closure Criteria for Action A.3.1•

10

Expectations related to human and organizational performance were evaluated anddetermined to be embedded in the implementing and validating SAMGs work and this is
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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

covered in Action Item 3.1.4. Any identified human and organizational performanceissues will be followed up accordingly.
Action A.3.2 Licensees should develop improved modelling of multi-unit plans in severe
accident conditions, or show assumptions of current models are adequate. This action does nothave HOP closure criteria expectations.
•

Action Item A.3.2.1 Evaluate adequacy of current modelling of severe accidents in multiunit stations; and•Action Item A.3.2.1 Develop plan/schedule for improved modelling.

2.2 Enhancing Emergency Response
The FTF determined that Canadian emergency response and preparedness both on- and off-site
are appropriate. However, the FTF had a number of recommendations for improvements forinteractions with provincial and federal emergency planning authorities, and identified areasof improvement for other jurisdictions (e.g. provincial, federal, etc.). Action items developed toenhance emergency response are listed below.

Recommendation 4 – Assess Emergency Plans (Onsite)
Action A.4.1 Licensees should evaluate adequacy of existing emergency plans and programsand ensure minimum complement requirements to ensure their emergency responseorganizations are capable of responding to multi-unit accidents or severe natural disasters. Thisaction has HOP closure criteria expectations.
•

Action Item A.4.1.1 Evaluate adequacy of existing emergency plans/programs; and•Action Item A.4.1.2 Develop plan/schedule to address gaps.

HOP Closure Criteria for Action A.4.1•

Consideration should be given to whether or not the performance of human actions isachievable during multi-unit events and severe external events under the current
Emergency Response Organization (ERO);•

Examine how on-site staff would manage a prolonged response with delayed support orstaff changeovers; and•Validate the number of qualified staff that would be required for the ERO during a multiunit or severe accident event.

Action A.4.2 Licensees should review drills and exercise programs to ensure these are suitably
challenging for emergency response units. This action has HOP closure criteria expectations.
•

Action Item A.4.2.1 Develop plan/schedule for enhancements to exercise programs.

HOP Closure Criteria for Action A.4.2•

Identify and address any relevant elements of Human Factors under accident conditions;and•Minimum number of qualified staff specified in the license should be used in drills.

Recommendation 5 – Update Emergency Facilities and Equipment
Action A.5.1 Licensees should review adequacy of backup power for emergency facilities andequipment and ensure requirements and limitations are documented in applicable emergency
plans/procedures. This action has HOP closure criteria expectations.
•

Action Item A.5.1.1 Evaluate adequacy of backup power for emergency facilities andequipment; and•Action Item A.5.1.2 Develop a plan and schedule for addressing any gaps.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTHOP Closure Criteria for Action A.5.1•

Any system modifications should apply HFE processes including consideration ofoperating experience, function analysis, verification and validation.

Action A.5.2 Licensees should formalize any arrangements or agreements for external support
and these should be included in emergency plans and procedures. This action has HOP closure
criteria expectations.
•

Action Item A.5.2.1 Identify external support and resources that may be required during
an emergency;•

Action Item A.5.2.2 Identify external agreements that have been formalized anddocumented; and•Action Item A.5.2.3 Confirm formalization of any undocumented arrangements.

HOP Closure Criteria for Action A.5.2•

Factors such as personnel availability and qualifications, substitution of personnel, anddelegation of authority should be considered regarding impacts on human performance.

Action A.5.3 Licensees should install automated real-time station boundary radiation
monitoring systems with backup power sources and communication systems. This action has
HOP closure criteria expectations.
•

Action Item A.5.3.1 Develop a plan/schedule for completion of installation.

HOP Closure Criteria for Action A.5.3•

Provisions made for identification and consideration of any relevant elements of HF
involved in development and deployment of modelling tool.

Action A.5.4 Licensees should develop source term estimation capability including dosemodelling tools. This action does not have HOP closure criteria expectations.
•

Action A.5.4.1 Provide source term and dose-modelling tools specific to each nuclear power
plant.

Recommendation 6 – Offsite Emergency Plans and Programs
Action A.6.1 CNSC will meet with federal and provincial planning authorities to ensure
understanding of recommendations and findings. This action does not have HOP closure criteria
expectations.
•

Action Item A.6.1.1 CNSC staff will participate in provincial- and federal-led activities
and initiate adequate CNSC regulatory framework or oversight measures to address
recommendations.

2.3 Improving Regulatory Framework and Processes
The FTF reviewed the CNSC regulatory framework and processes and concluded that theregulatory framework is strong and complete. The FTF did find that there were areas for
improvement in the regulatory framework, supporting documents, and to the licensing basis toensure stronger oversight of existing and future programs. Action items developed to guide
regulatory and process improvements are listed below.

Recommendation 7 – Class I Nuclear Facilities Regulations Amendments
Action A.7.1 The CNSC will initiate a project to amend Class I Nuclear Facilities Regulations torequire submissions of municipal/provincial offsite emergency plans along with evidence
showing how licensees are meeting the requirements of the plans. This action does not have
HOP closure criteria expectations.

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Action Item A.7.1.1 The CNSC will prepare proposed amendments to the Class I Nuclear
Facilities Regulations and submit to Commission for approval; and•Action Item A.7.1.2 The CNSC will review results of consultation and prepare final
amendment to the Class I Nuclear Facilities Regulations and propose them to theCommission for enactment.

Recommendation 8 – Radiation Protection Regulations Amendments
Action A.8.1 The CNSC will initiate a project to amend Radiation Protection Regulations to further
clarify emergency does limits for workers and to develop criteria for when workers can return
to work. This action does not have HOP closure criteria expectations.
•

Action Item A.8.1.1 The CNSC will prepare and consult on a discussion paper on potential
amendments to the Radiation Protection Regulations including proposed changes toemergency provisions in the regulations;•

Action Item A.8.1.2 The CNSC will prepare proposed amendments to the Radiation Protection
Regulations and submit them to the Commission for approval to proceed; and•Action Item A.8.1.3 The CNSC will review results of consultation and prepare amendments
to the Radiation Protection Regulations and propose them to the Commission for enactment.

Recommendation 9 – Update Regulatory Document Framework
Action A.9.1 The CNSC will initiate projects to change pertinent regulatory documents toinclude Task Force findings for existing and new nuclear power plants. This action does nothave HOP closure criteria expectations.
•

Action Item A.9.1.1 The CNSC will adapt the proposed GD-310, Guidance on Safety Analysis
for Nuclear Power Plants, prior to publication to address the findings of the CNSC Task
Force review findings;•

Action Item A.9.1.2 The CNSC will revise RD-337, Requirements and Guidance for Design of
New NPPs Radiation Protection Regulations and after public consultations, present changes
to the Commission; and•Action Item A.9.1.3 The CNSC will amend specific regulatory documents and following
public consultations, submit for approval to publish changes. For a full list of regulatory
documents to be amended, see CNSC Integrated Action Plan: On the Lessons Learned from the
Fukushima Daiichi Nuclear Accident (August, 2013) document.

Action A.9.2 The CNSC will initiate a project to develop an accident management regulatory
document. This action does not have HOP closure criteria expectations.
•

Action Item A.9.2.1 The CNSC will prepare a draft document and after public
consultations, will submit it to the Commission for approval and publication.

Action A.9.3 The CNSC will initiate a project to develop an emergency management regulatory
document. This action does not have HOP closure criteria expectations.
•

Action Item A.9.3.1 The CNSC will prepare a draft document and after public
consultations, will submit it to the Commission for approval and publication.

Action A.9.4 The CNSC will support review of Canadian Standards Association (CSA) Standards
to take into account lesson from the Fukushima Daiichi nuclear accident through participation
in CSA Nuclear Strategic Committee (NSCC). This action does not have HOP closure criteria
expectations.
•

Action Item A.9.4.1 The CNSC will ask CSA to identify issue to be addressed in next
Standards review cycle and provide a plan for how to address needs.

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Recommendation 10 – Amend Power Reactor Operating Licenses (PROLs)
Action A.10.1 CNSC will require licensees to have accident and severe accident management
programs and public communications. This action does not have HOP closure criteria
expectations.
•

Action Item A.10.1.1 A Commission Member Document (CMD) will be produced
requesting approval of new power reactor operating licence conditions; and•Action Item A.10.1.2 Amendments to existing power reactor operator licences will be
included.

Action A.10.2 The CNSC will continue to develop RD/GD-99.3, Public Information and Disclosureand submit the document to the Commission for approval. This action does not have HOP
closure criteria expectations.
•

Action Item A.10.2.1 CNSC will submit updated draft to Commission for approval to
publish; and•Action Item A.10.2.2 Amendments to existing power reactor operator licences will beconsistent with those in Action Item A.10.1.

Recommendation 11 – Implementation of Periodic Safety Reviews
Action A.11.1 The CNSC will consider developing periodic safety review process regulatory
framework. This action does not have HOP closure criteria expectations.
•

Action Item A.11.1.1 CMD seeking endorsement to proceed with regulatory
requirements for conducting period safety review by licensees; and•Action Item A.11.1.2 Amendments to PROLs to be completed by December 31, 2015 or as
per direction from the Commission.

2.4 Enhancing International Collaboration
The CNSC Task Force recommended greater collaboration with international regulators andcolleagues. As per the Task Force recommendation, the CNSC is collaborating more closely with
Senior Regulators of countries that own and run CANDU reactors. This collaboration will provide
opportunities for the CNSC to build consensus on proposed initiatives. Action items developed
to enhance international collaboration are listed below.

Recommendation 12 – Enhance Collaboration with CANDU Owner Countries
Action A.12.1 The CNSC to begin talks with CANDU senior regulators to define any areas wheremutual support can be provided during an emergency. This action does not have HOP closure
criteria expectations.
•

Action Item A.12.1.1 The CNSC (collaborating with IAEA and CANDU senior regulators)
to propose a meeting in April 2012 in Vienna, Austria to develop common platform forharmonization of future improvements arising from lessons learned from independent
safety reviews.

Recommendation 13 – Enhance International Cooperation
Action A.13.1 In collaboration with industry and government, the CNSC is to prepare a national
report on lessons learned from the Fukushima Daiichi accident for peer review by contracting
parties and to participate in the 2nd Extraordinary Meeting of the Convention on Nuclear Safety.
This action does not have HOP closure criteria expectations.
•14

Action Item A.13.1.1 Prepare a national report on lessons learned from the Fukushima
Daiichi nuclear accident, consistent with requirements established by contracting
parties at the Fifth Review Meeting in April 2011.

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3. Questionnaire Responses
This questionnaire was designed to gather more detailed information regarding specific HOF
factors that were addressed by action items specific to each country.
1.

MITIGATION STRATEGIES (i.e. strategies for maintaining or restoring core cooling,
containment, and spent fuel pool cooling capabilities)

In general, CANDU reactors have a large inventory of water available for passive cooling in thesecondary cooling system, the primary cooling system, the moderator and the calandria
vault/shield tank. Additionally, a prolonged loss of cooling in severe conditions for the spent
fuel pools may lead to fuel bundles damage. The spent fuel pools at most nuclear power plants
were not designed to accommodate boiling in the pool. Therefore, a loss of cooling may lead tothe structural design temperature being reached. Above this temperature, there is an increasing
risk of structural cracking which could lead to leakage from the bay. For the aim of preventionof beyond design basis accidents (BDBAs) and mitigation of severe accidents, adding further
defence-in-depth in terms of make-up provisions resulted in improvements in most key areas.
The following Fukushima Action Items (FAIs) were actioned on licensees to assess andensure that adequate capabilities to provide and restore core cooling, containment, and spent
fuel pool cooling are available. They are:•

FAI 1.5.1

Hydrogen mitigation for irradiated fuel bay;•

FAI 1.6.2

Plan for mitigating measures for IFB; and•FAI 1.7.1

Evaluation of make-up.

These actions were implemented to improve the prevention of BDBAs and mitigation ofsevere accidents. Modifications to the make-up systems makes them capable of delaying coremelt for an extended period, and providing water makeup to containment and the spent fuelpools would reduce the likelihood and consequences of severe core damage and fuel melt in the
spent fuel pools. In turn, this would prevent large releases of radioactive materials.
These strategies and modifications require key operator actions for effective mitigation anddelay of accident progressing to severe core damage. Therefore, the training of these operators
had to be appropriately modified to take these modifications into account.
a)Development of New Mitigation Strategies

New computational aids
During the course of a severe accident, it may become necessary for personnel to access the
IFBs to implement strategies to control IFB conditions. In this scenario, elevated gamma dose
rates are expected to be encountered as result of decreased IFB water levels. In advance of
deploying personnel to implement SAMG strategies, it is necessary to be able to estimate thedose that will be accumulated as a result of performing field actions near the IFBs. To support
this evaluation, a correlation between gamma dose rate and IFB water level was recommended.
This led to the development of new computational aids for Gamma Dose Rate as a Function of IFB
Water Level.
EME modification and Implementation to enhance make-up cooling provisions
As part of FAI 1.11.1: Procurement of emergency equipment, it was required that licensees should
procure, as quickly as possible, emergency equipment and other resources that could be either
stored onsite or offsite and brought onsite to mitigate a severe accident. The plan and schedule
for procurement was to consider elements of HOP under accident conditions. More specifically,
the licensee’s procurement plan and schedule was to consider the following:•

Temporary supplies of electrical power and water.

•

Portable diesel emergency generators and portable diesel driven pumps.

•

Provisions for fueling of this equipment.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST•

Storage of emergency equipment should consider common cause failure (such as
flooding, etc.).

•

Plant design modifications to facilitate the necessary connections for temporary suppliesof electrical power and water (i.e. power cables, hoses, manifolds etc.). Cable and hoseconnections should meet usability requirements (e.g. quick disconnects where needed)and should not be subject to common cause failure.

•

Development of procedures for deployment of offsite mitigating equipment.

•

Consideration should be given to conducting a training needs analysis for the operationand maintenance of the equipment.

•

Programs for maintenance, testing and training, as required.

•

Human Factors analysis for the use of equipment and instrumentation in severe accident
scenarios.

Licensees have completed this action and the action item is closed.
b)Modification of Current Mitigation Strategies

During a severe accident, hydrogen is produced within containment through several
mechanisms. Along with hydrogen, the production of other gases can lead to an internalpressure greater than the design pressure of the containment structure. Higher than designedfor pressures can challenge the structure and may also lead to an uncontrolled release of fission
products to the environment. Various systems are available to maintain the integrity of thecontainment during accident scenarios. These include, but are not limited to, hydrogen igniters,
Passive Auto-catalytic Re-combiners (PARs), dousing systems, local air coolers, and Emergency
Containment Filtered Ventilation (ECFV) systems. The ECFV System and PARs have been
installed at Point Lepreau Generating Station. As it is manually activated, it does not require an
external source of power, and is used to relieve containment pressure for the conditions that
could be present in a severe accident. The CNSC required other nuclear power plants to install
PARs as quickly as possible (see FAI 1.5.1). The installations of PARs were modifications toexisting mitigation strategies for hydrogen in multi-unit stations.
c)

Assessment and/or integration of the whole set of mitigation strategies (e.g. Extended
Damage Mitigation Guidelines, FLEX Guidelines, Severe Accident Guidelines, Emergency
Operating Guidelines, etc.).

A review and update of SAMG documentation was recommended by the CNSC. It was
ascertained during CNSC task force review that CANDU Owners Group (COG) SAMG documents
developed for severe accidents remained fundamentally valid after a review of the in-vessel
retention strategy. CNSC recommended that the framework be modified to present a clearer
understanding of In-Vessel Retention (IVR), with some changes recommended, including
specific revisions to SAMG documentation.
Licensees of multi-unit nuclear power plants were asked to develop improved modelling ofmulti-unit plants in severe accident conditions or demonstrate that the current simple
modelling assumptions are adequate (see FAI 3.2.1.: Evaluation of modelling of multi-unit plants insevere accidents). This assessment had to consider elements of HOP under accident conditions.
However, expectations related to HOP were evaluated and found not to be applicable to this FAI,
which is concerned only with adequacy of computer code modelling, not code application. HOP
is important in the application phase of the results but is beyond the scope of that FAI.
A plan and schedule for the development of improved modelling of severe accidents in
multi-unit plants - including any necessary experimental support - was to be developed as partof FAI 3.2.2: Plan for improved modelling of severe accidents in multi-unit plants and was to consider
elements of HOP. However, the same conclusion reached for FAI 3.2.1 applies here: no HOPrelated elements were found to be directly linked to FAI 3.2.2.
Licensees have completed this action and the action item is closed.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTd)

Addition of new procedures/guidelines for newly installed systems or components or
new mobile equipment for improving mitigation capabilities

The following actions were raised by the CNSC with regards to the updating of the SAMG
program.
•

FAI 3.1.2 - Expansion of SAMGs to include multi-unit eventsThe licensees were to provide plans and schedules for the inclusion of multi-unit events in
SAMGs. The plan and schedule were to address the following:•

Supplement existing SAM procedures and guidelines to cater to multi-unit events; and•Identify the needs for supporting severe accident analyses.

Expectations related to HOP were evaluated and determined to be embedded in the work ofvalidating and implementing SAMGs. FAI 3.1.4 includes validation and demonstration ofeffectiveness of SAMGs. Any HOP issues identified during the validation activities will befollowed-up as appropriate.
•

FAI 3.1.3 - Expansion SAMGs to include irradiated fuel bay events.

The licensees were required to provide plans and schedules for the inclusion of IFB events instation operating documentation where appropriate. The plans and schedules were to consider
the following:••

Builds upon the existing SAM procedures and guidelines to cater to events affecting the
IFB.

•

Identify necessary mitigation measures such as water makeup to the IFB to cope with
events triggered by extreme external hazards for example, BDE or tornados.

•

Develop a set of drills to cover these events and undertake a validation assessment toconfirm that operator actions are possible for IFB events.

•

Identify the need for supporting severe accident analyses for IFB events.

FAI 3.1.4 – Validation of SAMGs

The licensees were required to demonstrate the effectiveness of SAMGs via table-top exercisesand drills, taking into account the effects of severe accident conditions on equipment
survivability, instrument readings, human-machine interface, and human and organizational
performance (HOP). This includes:•

Clarify responsibilities and organizational interfaces;•

Develop a set of drills to cover representative accidents, including multi-unit events and
IFB events;•

Undertake a validation assessment to confirm that operator actions are possible
for these accidents to account for:–Ease of access;–Presence of debris;–

Fires, flooding; and–Sufficient number of qualified staff.

•

Undertake integrated exercises to demonstrate effectiveness of SAM interfaces with the
emergency response organization and with other stakeholders;•Consider the extended SAMG mission time to account for the possibility of
prolonged time required to restore power, initiate and complete necessary actions
due to multi-unit damage and/or large-scale disturbances from outside or at the grid;•

Consider necessary countermeasures for extreme events where portable equipment andexternal supports are required to mitigate accident consequences and formalize thesecountermeasures in SAMGs; andPOST-FUKUSHIMA ACTION IMPLEMENTATION AT NUCLEAR INSTALLATIONS: HUMAN AND ORGANISATIONAL FACTORS LESSONS LEARNT, NEA No. 7578, © OECD 2023

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST•

Ensure drills and exercises to demonstrate effectiveness of SAMG for multi-unit and forspent fuel bay events are consistent with the plans and schedules as per FAIs 3.1.2, 3.1.3
and 4.2.1.

Licensees have completed this action and the action item is closed.
e)Changes, if any, in strategy design, implementation, use and adherence•f)Other actions related to mitigation strategies
•

g)

N/A

N/A

For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

All Canadian nuclear power plants and Class I nuclear facilities have a SAMG program inplace and they all are in compliance with REGDOC 2.3.2 Accident Management (September 2013).
There have been numerous table top exercises, review of the SAMG program and inspections
already conducted by the CNSC, as well as observations of drills and exercises.
Expectations related to human and organizational performance (HOP) were evaluated by
CNSC and determined to be embedded in the work of validating and implementing SAMGs. FAI
3.1.4 includes validation and demonstration of the effectiveness of SAMGs.
Licensees have completed related assessments. Validations, audits, inspections, training,
drills, exercises will continue to be the subject of regulatory oversight as opportunities for
improvement arise.

2.

OTHER PROCEDURES AND GUIDELINES (to manage other elements of event or emergency
response not directly supporting the implementation of mitigation strategies)a)

Modification of procedures and guidelines

Licensees were required to complete an evaluation of their existing emergency plans withrespect to multi-unit accidents and severe external events. Once the analysis was complete,licensees were to submit their plans/schedules for closing any gaps in existing emergency
plans/procedures.
b)

Changes, if any, in procedure design, implementation, use and adherence
N/Ac)

Other changes or additions to procedures and guidelines

Licensees were to develop emergency mitigating equipment guidelines for operating andmaintaining
emergency
mitigating
equipment.
SAMGs
were
also
to
be
developed/finalized/implemented and were to include multi-unit events and Irradiated Fuelbays. SAMGs have been submitted to the CNSC.
d)

For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

All nuclear power plants have developed and submitted their SAMGs. The CNSC continues its
review and approval of submitted SAMGs. Licensees have completed BDBA/SAMG drills (2013)and drills will be an ongoing activity (scheduled for 2019 and 2020) and lessons learned fromexercises will be used to update SAMGs (see question number 1 responses for more detailregarding SAMGs).

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTExisting emergency plans/procedures were analyzed to identify any gaps. Licensees haveupdated their emergency plans and drills have been completed using the updated
plans/procedures. Licensees also developed emergency mitigating equipment guidelines toensure emergency mitigating equipment can be operated and maintained. Validations, audits,
inspections, training, drills, and exercises will continue to receive regulatory oversight asopportunities for improvement arise (see question number nine responses for more detailregarding emergency plans/procedures).
The analysis of emergency plans was to consider the following human factors items:

3.

•

Number of qualified staff;•

Human factors analysis and changes to existing emergency plans and procedures toaccommodate the additional burden and complexity of the emergency response whennormally available resources are no longer available;–

Considerations should be given to command structure; and–New plans and procedures to enable response to events with limited resources andinfrastructure and possible loss or limitation of licensee staff available to respond.

STAFFING
Post-Fukushima, CNSC licensees were expected, as part of their exercise plans, to demonstrate
the effectiveness of SAMGs by confirming that operator actions are possible, accounting for a
sufficient number of qualified staff. Beyond previously established requirements for licensees
to maintain a Minimum Staff Complement (MSC), licensees were not required to assess MSC
requirements for BDBD or severe accident scenarios. However, on the basis of FAI closure
criteria, licensees are expected to have access to a sufficient number of qualified staff whether
those personnel are already onsite or are offsite with defined reporting requirements and/orinterfaces. However, it should be noted that “SAMGs may require sufficient qualified personnel
that are not part of the normal minimum staff complement.
Lessons learned:
The expectation for licensees to document, within Emergency Mitigating Equipment Guidelines(EMEG) and SAMGs, the minimum number of staff required to execute EMEGs and SAMGs could
be strengthened.
a)Assessment of staffing needs (numbers and roles).

Beyond previously established requirements for licensees to maintain a MSC, licensees were
not required to assess MSC requirements for BDBD or severe accident scenarios. However, on
the basis of FAI closure criteria, licensees are expected to have access to a sufficient number ofqualified staff whether those personnel are already onsite or are offsite with defined reporting
requirements and/or interfaces (“Also, current licensee emergency plans depend on the ability
to augment response from staff not on duty as well as from external resources; The review must
address how the licensee would manage their on-site response if site access was impaired.
Areas such as staff availability or delayed augmentation, as well as off-site responder
availability or delay must be considered” - from FAI Closure Criteria Expectation 4.1.1,
Version 2). According to section 5.2 of REGDOC 2.3.2, with respect to procedure verification, “anassessment should be undertaken to confirm that operator actions that are specified in
Emergency Operating Procedures (EOP) and SAMGs are possible, accounting for ease of access,possible radiation fields, presence of debris, fires or flooding, low light levels, use of PPE, andstaffing levels”. As well, “the licensee should establish qualification, training, deployment, andstaffing numbers for the various organizational groups involved in accident management”. In
accordance with the section 6.1 of REGDOC 2.3.2, with respect to the Integrated AccidentManagement Program (IAMP) the effectiveness of the IAMP should be periodically reviewed andcover: “review of responsibility allocation, staffing, personnel qualification, training needs, andperformance”. Subsequently, “SAM may require sufficient qualified personnel that are not partof the normal minimum staff complement” (see section 5.3 of REGDOC 2.3.2).

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTb)

Changes in plans and measures to augment on-site staffing levels
N/Ac)

Other actions related to staffing

Further guidance was provided to licensees with respect to the requirement for MSC for the ERO
and the presence of fixed real-time radiological detection and monitoring. In conjunction
FAI 5.3.1, licensees were expected to provide a plan and schedule to install automated real-timestation boundary radiation monitoring systems with appropriate backup power andcommunications systems. Accordingly, “members of mobile offsite survey teams need not be
accounted for as part of the minimum complement for facilities equipped with real-time fixedradiological detection and monitoring capabilities, if the licensee makes provisions for
immediate mobilization of offsite survey teams upon activation of the ERO” (see section 2.2.1 of
REGDOC 2.10.1).
With respect to personnel resources and emergency response plan provisions, section 2.2.4
of REGDOC 2.10.1, requires that: licensees “cooperate with and assist offsite organizations with
their response activities to address offsite impacts; provide expertise and resources (personnel,
emergency response equipment, and material) in support of offsite authorities during an
emergency; and define the quantity of available resources within their ER plan”.
With respect to staffing and expectations related to the plan and schedule for an improved
exercise plan (FAI 4.2.1), “exercises should only make use of the minimum number of qualified
staff specified in the licence, for their assigned roles”.
d)

For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

As part of the FAI Closure Criteria Expectations licensees were required to provide a timeline
and a plan as to how each FAI was going to be addressed according to a pre-determined scheduleestablished by the CNSC and communicated to the licensees via the CANDU Industry
Integration Team (CIIT).

4.

ORGANIZATIONAL STRUCTURES, COMMUNICATION, DECISION MAKING AUTHORITIES, AND
SAFETY CULTURE
a)Changes, if any, in the command & control organizations for accident management,
including single and multiple source term response, if applicable.

For command structure, see section 2.2.1 of REGDOC 2.10.1 for clarity with respect to therequirement to:•

Establish an emergency response organization (ERO) with a command structure that isclearly defined and integrated; and•Expectations related to the “indication of an effective ERO is the demonstration of clear
command and control over the emergency response. It should be clearly understood who
is in charge and with whom final decisions and authorities lie”.

For offsite Interfaces and Support, see section 2.2.4 of REGDOC 2.10.1
For organizational interfaces and expectations related to lines of authority and decision
making, see section 4.3.3 of REGDOC 2.3.2
For communication interfaces, see section 4.3.4 of REGDOC 2.3.2
Section 2.2.1 of REGDOC 2.10.1 details the requirements for Emergency Response
Organization and Staffing which strengthens the licensing basis in relation to the maintenanceof minimum staff complement. Prior to the events of Fukushima licensees were required tomaintain a sufficient number of qualified staff in accordance with section 12(b) of the General
Nuclear Safety and Control Regulations (GNSCR) and associated guidance detailed in G-323,

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

which is referenced in the Licence Conditions Handbook (LCH). Following the events ofFukushima, REGDOC 2.10.1 was modified and as such now requires licensees to define andmaintain the MSC for the ERO. This represents a substantial improvement in relation toorganizational defence in depth as the requirement to formalize the MSC for the ERO wasestablished in REGDOC 2.10.1 which was not present in G-306.
Prompted by the events of Fukushima, and based on the results of a third party assessmentof its response and engagement during the Ontario Power Generation’s Exercise Intrepid, the
CNSC decided to improve the capability of the CNSC Nuclear Emergency Response Plan (e-Doc# 3845178), the CNSC emergency operation centre, and communication capabilities (e-Doc #4899372).
b)

Others changes to organization structures, coordination protocols, and guidance fordecision making and communications (both internal and external). (Note:
Communications equipment is addressed separately in topical area 6).

Information will be added when it becomes available.
c)

Changes, if any, in the requirements or guidelines for promoting healthy safety culture.

To further strengthen existing requirements for licensees to understand and foster a healthsafety culture, the CNSC requested that amendments be made to the Class I Regulations toinclude provisions for safety culture and human performance. The regulatory amendments
were approved in October 2017 and are available at: www.gazette.gc.ca/rp-pr/p2/2017/2017-1004/html/sor-dors199-eng.phpd)

For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

As part of the FAI Closure Criteria Expectations licensees were required to provide a timeline
and a plan as to how each FAI was going to be addressed according to a pre-determined scheduleestablished by the CNSC and communicated to the licensees via the CIIT.
REGDOC 2.3.2 in consideration of the requirements for an Integrated Accident Management
Program, provides expectations in relation to lessons learned and training as follows:•5.

It is necessary to review and evaluate the effectiveness of the IAMP periodically to ensure
it reflects modern requirements, reflects lessons from drills and exercises, incorporates
knowledge gained from any new information and experimental data, and includes any
changes in personnel, reactor equipment and instrumentation conditions, and training
needs. The review should cover all the aspects of the preparation, development,
implementation, and documentation of the IAMP, including:–

Check of the interface between the IAMP and the emergency preparedness program;and–Review of responsibility allocation, staffing, personnel qualification, training needs,
and performance.

PERSONNEL QUALIFICATIONS AND TRAININGIn Canada, several regulatory requirements and expectations with respect to training andqualifications were placed on licensees following the events of Fukushima. To this end,
licensees were required to strengthen the interfaces within their communities by collaboratingwith responding offsite agencies and educating them on radiation protection. As well, forreactor facilities with a thermal capacity greater than 10 MW, licensees were required to provide
initial and re-qualification training to all emergency response organizations in accordance withthe positions to which they have been assigned.
In tandem with the licensees change management program and the Fukushima Closure
Criteria expectations, licensees were expected to evaluate personnel training needs and develop
appropriate qualifications for the deployment of emergency mitigating equipment, and in theuse of EMEGs and SAMGs. Opportunities for specific lessons learned with respect to training

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

should be available, as licensees are expected to conduct self-assessments with respect toemergency preparedness and response.
There were no specific changes made to the CNSC’s personnel certification requirementswith respect to accident management and emergency response.
a)Changes in job qualification requirements to address the need for new technical and nontechnical (e.g. for managing the unexpected, stress management) knowledge andabilities.
N/Ab)

Changes in training program content to address new knowledge and ability needs.

To enhance emergency preparedness and response capabilities of communities surrounding
nuclear facilities in Canada, licensees are expected to comply with the requirements related totraining and qualification, which is detailed in Section 2.3.1 of REGDOC 2.10.1, Nuclear
Emergency Preparedness and Response, as follows:•

In accordance with training and qualification, collaborate with responding offsite
agencies to educate them on radiation protection.

Additional requirements for licensees of reactor facilities with a thermal capacity greaterthan 10 MW have been implemented. These licensees shall:•

Develop and submit emergency drill and exercise schedules annually to the CNSC;•

Train and qualify all EROs in accordance with the positions to which they have been
assigned; educational materials are required to be available for any person who would
be responding to the emergency on behalf of an offsite authority, not just the first
responders; and•Establish requirements for frequency of re-qualification training for all ERO positions.

For licensees, as part of the change management process, the purchase, installation, andcommissioning of emergency mitigating equipment and modifications to existing systems,
structures and components, requires (based on licensees’ existing procedures) that training
needs analyses be conducted in alignment with the requirements of REGDOC 2.2.2, Personnel
Training (December 2016) and the Fukushima Action Items Closure Criteria and Expectations (January2013). As a result, several new qualifications were developed to ensure that licensee personnel
have the requisite knowledge, skills, and capabilities to execute tasks related to the deploymentof emergency mitigating equipment, or equipment associated with monitoring of
instrumentation used in severe accident conditions.
c)Changes in training program structure (e.g. instruction/assessment methods or
frequency).
N/Ad)

Other changes to personnel qualifications or training.

Based on Section 5.4 of REGDOC 2.3.2, licensees are expected to:22•

Provide training “to the operating personnel and responsible organizations to ensure
their competency in using the instructions and actions specified in EOPs and EMEGs, andtheir knowledge of the information required to identify events and accidents that are
beyond the design basis and of the guidelines specified in SAMGs; and•Training should be commensurate with each person’s role in the case of an accident,
enabling them to:–understand their roles and responsibilities in accident management–

learn about accident phenomena and processes–

become familiar with the activities to be carried out–

enhance their ability to perform in stressful conditions

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST–e)verify the effectiveness and improve the clarity of procedures and guidelines

For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

As part of the FAI Closure Criteria Expectations, licensees were required to provide a timeline
and a plan as to how each FAI was going to be addressed according to a pre-determined scheduleestablished by the CNSC and communicated to the licensees via the CIIT.
Opportunities for lessons learned relevant to training should be available from licensees
based on the requirement to conduct drills and integrated exercises. Accordingly, REGDOC
2.10.1 provides expectations regarding lessons learned and self-assessment as follows:•

Self-assessment reports should contain the following information:–

success and failures of exercise drills;–

lessons learned;–

areas for improvement;–

corrective action plans; and–As well, REGDOC 2.3.2 in consideration of the requirements for an Integrated
Accident Management Program provides expectations in relation to lessons learned
and training.

It is necessary to review and evaluate the effectiveness of the IAMP periodically to ensure it
reflects modern requirements, reflects lessons from drills and exercises, incorporates
knowledge gained from any new information and experimental data, and includes any changes
in personnel, reactor equipment and instrumentation conditions, and training needs.

6.

PLANT
INSTRUMENTATION,
COMMUNICATIONS EQUIPMENTa)

CONTROLS,HUMAN-SYSTEMINTERFACES,

AND

Addition or modifications to plant instrumentation and control to improve the usability
or availability of information to plant staff and their ability to take control actions (e.g.
spent fuel pool instrumentation, containment venting).

The following FAIs were actioned on licensees and took into considerations plant
instrumentation, controls, human-system interfaces, and communications equipment. They
are as follows:•

As part of FAI 1.8.1-Survivability assessments for equipment and instrumentation for severe
accident management, it what required that the licensee’s plans for equipment
survivability assessment would consider the following:–

Assessment should provide reasonable assurance that sufficient equipment andinstrumentation will be available to facilitate operator actions;–

A list of equipment required for severe accidents, together with corresponding
survivability time frames during accident progression, and survivability assessment
methodology;–

Ability of the listed equipment and instrumentation
temperature/high radiation during severe accidents;–

Upgrading requirements (relocation/shielding) for the equipment that is required forthe severe accidents. (e. g., connection nozzles location at much higher elevation
than the maximum anticipated flood level);–

Human Factors analysis should be used to contribute to requirements specification
for upgrades or procurements;

towithstand

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high

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST–HFE needs to be included in the design of instrumentation and equipment to include
its use in severe accident situations and how the equipment is maintained; and–Conduct, where applicable, a training needs analysis to ensure that any required
human action involving the operation or maintenance of the equipment or
instrumentation is defined in the training requirements.

As part of FAI 1.9.1- Habitability of control facilities, it was required that the licensee would
conduct an evaluation of the habitability of control facilities under conditions arising frombeyond-design-basis and severe accidents and, where applicable, provide a detailed plan andschedule for control facilities upgrades. Most importantly for the HOP aspect, CNSC staff
requested the plan and schedule for identified upgrades to consider the following:•

Strengthening radiation shielding and protection against airborne radioactivity incontrol facilities, as required, ensuring that individual dose targets will not be exceeded;•

Describe measures that should be taken to protect the occupants of the control facilities
against hazards that could hinder the emergency response capabilities of operators, toinclude:•–Means of detecting hazards;–

Means for isolating control facilities and enhancing the exclusive ventilation and air
conditioning systems for control facilities; and–Measures for ensuring sufficient leak tightness of control facilities.

Analysis of human factors considerations, including operating experience and lessons
learned, to support personnel working in the control facilities for extended periods
during beyond design basis and severe accident scenarios, to include:–

Thermal environments;–

The need for and impact of wearing PPE;–The need for general and task lighting; and–Interactions of special lighting systems with panel displays.

•

Human Factors analyses should be used to specify requirements to support personnel
working in the control facilities for extended periods during beyond design basis andsevere accident scenarios;•

The design and implementation of upgrades should include a HFE program, which
includes stakeholder analysis, task analysis, and verification and validation activities.

•

A training needs analyses to ensure that any required human actions involving operationor maintenance of the upgraded control facilities is defined in the training requirements.

As part of FAI 1.10.1-Evaluation of electric power requirements for key Instrumentation and Control(I&C), it was required that the licensees should investigate means of extending the availabilityof power for key I&C needed in accident management actions following a loss of all AC power.
This assessment was to consider elements of HOP under accident conditions.
Most importantly for HOP, the licensee’s evaluation of electric power requirements for key
I&C and capabilities was to consider the following:24•

A systematic process should be developed to identify key instrumentation & control
equipment that require power to operate and needed for prolonged accident
management;•

The selection basis should be documented for correctness, completeness andtraceability;•

The electrical power consumption of the I&C equipment should be identified according
to the targeted timeframe per individual equipment;

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST•The licensees should demonstrate a continuity of electrical power to critical equipment
exists during the BDBA event until such time as normal power sources are restored. This
assessment should reflect the existing battery supplies, appropriate bridging strategies
and portable generators;•

Upgrades, if any, should take into consideration other non-essential loads not affectedby load shedding that may impact the capacity of the batteries;•

Load shedding strategies should be developed for disconnecting loads not required for
prolonged accident management. For those loads that cannot be disconnected, theirloads should be considered in the sizing calculation; and•A training needs analyses to ensure that any required human actions involving operationor maintenance of the upgraded I&C equipment is defined in the training requirements.

Following FAI 1.10.1: Evaluation of electric power requirements for key I&C, a plan and schedule
for deployment of identified upgrades from FAI 1.10.1 was to be produced. This is reflected in
FAI 1.10.2: Plan for upgrades to electric power for key I&C. More specifically, the licensee’s evaluationof electric power requirements for key I&C and capabilities was to consider the following:b)•

The plan for the design and implementation of upgrades should include a HFE program,which includes use of operating experience and lessons learned, stakeholder analysis,
task analysis and verification and validation activities;•

The plan should include provision for training needs analysis and updates to proceduresshould be carried out, where applicable; and•The load shedding schemes should be described.

Addition or modifications to plant communications capabilities (onsite/internal
communications and communication with off-site individuals/organizations).
N/Ac)

Other changes to plant or equipment human-system interfaces to improve humanperformance reliability.
N/Ad)

For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).
•

Most of the FAI implying HOF elements for Plant Instrumentation, Controls, HumanSystem Interfaces, and Communications Equipment had target completion deadlines
ranging from 2012 to 2014. These actions and HOF closure criteria can be found in a moredetailed fashion in Fukushima Action Items Closure Criteria and Expectations; and•Licensees have completed related assessments. Most of the FA is have been closed. Somemay have other actions which will continue to be the subject of regulatory oversight asopportunities for improvement arises.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST7.

PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS
Licensees were to provide a reasonable level of confidence that the means (e.g. equipment andinstrumentation) necessary for severe accident management and essential to the execution of
SAMGs will perform its function in the severe accident environment for the duration for which
it is needed. This assessment should consider elements of HOF under accident conditions.
A detailed plan and schedule for performing assessments of equipment andinstrumentation survivability, and a plan and schedule for equipment upgrades whereappropriate, were to be developed based on the assessment.
a)Provision of additional portable plant equipment or hand tools to support reliable humanperformance

FAI 1.11.1 (Procurement of emergency equipment) was issued to licensees. The CNSC expects
the licensee’s procurement plan and schedule to consider the following:b)•

Temporary supplies of electrical power and water;•

Portable diesel emergency generators and portable diesel driven pumps;•

Provisions for fueling of this equipment;•

Storage of emergency equipment should consider common cause failure (such as
flooding, etc.);•

Plant design modifications to facilitate the necessary connections for temporary suppliesof electrical power and water (i.e. power cables, hoses, manifolds etc.). Cable and hoseconnections should meet usability requirements (e.g. quick disconnects where needed)and should not be subject to common cause failure;•

Development of procedures for deployment of offsite mitigating equipment.

•

Consideration should be given to conducting a training needs analysis for the operationand maintenance of the equipment;•

Programs for maintenance, testing and training, as required; and•Human Factors analysis for the use of equipment and instrumentation in severe accident
scenarios.

Design of portable plant equipment or hand tools to support reliable human performance(e.g. plug and play pipe connections, portable and installed equipment painted with somespecific colour, equipment needed during a station blackout identified with fluorescentlabels).

While this was not clearly stated in the expectations of FAIs related to emergency equipment,
HOF were part of considerations and required in the design of portable plant equipment or handtools to support reliable human performance. For example, in FAI 1.11.1: Procurement ofemergency equipment states as one of the expectations as: “Plant design modifications to facilitate thenecessary connections for temporary supplies of electrical power and water (i.e. power cables, hoses,
manifolds etc.), cable and hose connections should meet usability requirements (e.g. quick disconnects
where needed) and should not be subject to common cause failure.”c)Provision of additional protective gear or modifications to protective gear to support
reliable human performance.
N/Ad)

Modifications to work environments to support reliable human performance (e.g.
emergency lighting, flood protection)

The requirement for upgrading requirements (relocation/shielding) for equipment that isrequired for severe accidents (e.g. connection nozzles location at much higher elevation thanthe maximum anticipated flood level) was part of regulatory actions on licensees.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTe)Others changes to plant equipment/environments to support reliable performance of
mitigation actions

The licensee was to conduct an evaluation of the habitability of control facilities underconditions arising from beyond design basis and severe accidents and, where applicable, was toprovide a detailed plan and schedule for control facilities upgrades (FAI 1.9.1 - Habitability ofcontrol facilities). The following were to be considered:•

Control facilities should include areas that are required for access and egress during
accident conditions including the provision of access routes that provide suitable
protection from external and internal radiological hazards;•

HVAC requirements for the control facilities will be maintained during a prolonged
Station Blackout condition; and•Identify internal and external events that could pose a direct threat to continued
operations of control facilities.

f)

For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

The expectations of the regulator towards the licensees were:8.

•

Human Factors analysis was to be used to contribute to requirements specification for
upgrades or procurements.

•

Human Factors engineering needs to be included in the design of instrumentation andequipment to include its use in severe accident situations and how the equipment ismaintained.

•

Conduct, where applicable, a training needs analysis to ensure that any required humanaction involving the operation or maintenance of the equipment or instrumentation isdefined in the training requirements.

WORK PLANNING, TECHNICAL SUPPORT, AND EMERGENCY RESPONSE FACILITIESa)Design and implementation of new or modified on-site facilities

On-site storage facilities (Quonsets) were built for storing EME and other equipment andsupplies. One licensee relocated the Site Management Centre to a new location still withinproperty boundaries. The new Site Management Centre had permanent back-up power forcommunications, IT, lighting, and heat. Licensees were required to submit plans and schedules
for completion of design and implementation of new or modified on-site facilitiesb)

Design and implementation of new or modified off-site facilities

Two licensees have built Emergency Management Centre on off-site properties
If licensees had existing Emergency Operations Centres (EOC), reviews were completed to
identify any gaps regarding capability (e.g. back-up power), and if licensees did not already have
EOC, new centres were built. Two licensees built Emergency Management Centre on off-site
properties but in close proximity to nuclear power plants. Additionally, licensees were required
to ensure that new and existing EOCs had sufficient back-up power (e.g. access to transportable
generators and/or installation of permanent generators) in the event of a power outage.
Licensees were required to submit plans and schedules for completion of design andimplementation of new or modified off-site facilities.
c)Changes to other facilities not previously addressed

N/Ad)

For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

9.

•

Human Factors analysis for the use of back-up power equipment for new or modified
facilities•

Personnel training on how to use and maintain back-up power generators and other EME
for new or modified facilities•

During exercises, personnel use and maintain the EME used at new facilities•

Personnel training on any new procedures required for any of the new equipment
installed in any new or existing facilities

EMERGENCY RESPONSE PLANSa)

Changes in emergency response plans or implementation methods

Licensees were required to complete an evaluation of their existing emergency responseplans/procedures and provide to the CNSC any plans and schedules for closing any identified
gaps. Additionally, licensees were to incorporate BDBE and BDBA into their emergency plans.
Licensees completed their emergency response plans analyses and updated plans/procedures
accordingly. Emergency response plans and procedures are continually updated uponcompletion of any drill or exercises based on lessons learned.
b)Changes in the drills or exercises of the emergency response plan

Licensees were required to develop drills and exercises that included:•

Multiple unit event accidents;•

Failure of response component (emergency command centers become unavailable, etc.);•

Exercises should only make use of minimum number of qualified staff specified in thelicence, for their assigned roles;•

Severe weather scenarios;•

Loss of electrical grid scenarios; and•Large scale/multi-jurisdictional exercise to test all response groups simultaneously.

Licensees, along with federal, provincial, and municipal agencies, have completed drills totest emergency response plans under a variety of conditions. Lessons learned from the various
exercises have been integrated into the emergency response plans.
c)Others changes to emergency response plans

Although the CNSC has no regulatory control over federal or provincial agencies, the CNSC
worked very closely with various government agencies to upgrade emergency response plans.
As a result, Health Canada updated the Federal Nuclear Emergency Plan in 2013 and released it
in 2014. The Province of Ontario updated and released the Provincial Nuclear Emergency
Response Plan in 2017. This update was partially motivated and informed by the lessons learned
from Fukushima and the CNSC post-Fukushima Action Plan recommendations. The Province of
New Brunswick has committed to address gaps in governance, severe accident management,
and training and exercises in their response plans.
d)

For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

The expectations of the regulator towards the licensees were to identify any relevant elementsof human factors under accident conditions.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

10. EXTENDED (LONGER TERM) RESPONSE
The expectations related to extended or longer term response was addressed throughFukushima Action Items. For example, licensees were expected to conduct, an “analysis ofhuman factors considerations, including operating experience and lessons learned, to support
personnel working in the control facilities for extended periods during beyond design basis andsevere accident scenarios, to include:•

Thermal environments;•

The need for and impact of wearing PPE•

The need for general and task lighting•

Interactions of special lighting systems with panel displays

As well, “human Factors analyses should be used to specify requirements to support
personnel working in the control facilities for extended periods during beyond design basis andsevere accident scenarios”
Though expectations were provided, upon reviewing licensees’ submission in relation to
Habitability, CNSC staff deemed them inadequate to address all the concerns related to ensuringthat provisions in support of human performance are planned for.
Lesson Learned:
The Fukushima Action Item Closure Criteria Expectations for Habitability needed to be more
explicit in relation to non-radiological hazards and the expectations related to addressing thephysiological needs of plant personnel who would be tasked with responding in the unlikely
event of a BDBA or severe accident. The Technical Assessment on Habitability (e-Doc # 4300050)
conducted by CNSC staff raised several questions with respect to habitability that were notaddressed by licensees and were not raised as part of the Fukushima Action Item Closure
Criteria Expectations. Specifically, clarity around what constituted an extended period wassought by CNSC staff, as follows:•a)“A clear definition of what is meant by an “extended period” should be provided by thelicensee (e.g. 72 hours as described in REGDOC 2.10.1 [1]) as a bounding condition to
support its analysis in enabling emergency responders to fulfill operational, mitigation
and recovery objectives. Support provisions to maintain human habitability for an“extended period” e.g. food, water, sanitary facilities, sleeping/rest areas are notaddressed and should be analyzed as appropriate”.

Additions or modifications to plans or capabilities to address on-site staff physiologicalneeds (e.g. food, water, sleep, hygiene) over the duration of time required to achieve asafe/stable plant state.

Not explicitly communicated to licensees as part of the Fukushima Action Items Closure Criteria
Expectations, however was addressed as part of CNSC staff request for additional information.
b)

Additions or modifications to plans or capabilities to address on-site staff psychologicalneeds (e.g. fatigue/stress management, contact with families) over the duration of timerequired to achieve a safe/stable plant state.

This was addressed as part of specific FAI in response to CNSC questions raised following theTechnical Assessment on Habitability (e-Doc # 4300050).
c)

Additions or modifications to plans or capabilities to relieve/augment on-site staff (e.g.
communication, transportation, site access).

Licensees were required to evaluate and revise their emergency plans in regard to multi-unit
accidents and severe external events. A plan and schedule to address any gaps identified in theevaluation of FAI 4.1.1 (FAI 4.1.2) was to be completed. The plan included the following:•

The need for any additional HF analysis and validation in determining the number ofqualified staff required; andPOST-FUKUSHIMA ACTION IMPLEMENTATION AT NUCLEAR INSTALLATIONS: HUMAN AND ORGANISATIONAL FACTORS LESSONS LEARNT, NEA No. 7578, © OECD 2023

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST•

The schedule to revise the emergency plans as applicable.

This activity was to include an assessment of their minimum complement requirements toensure their emergency response organizations will be capable of responding effectively tomulti-unit accidents or to severe natural disasters. This assessment was to consider elementsof HOP under accident conditions (FAI 4.1.1 - Evaluation of existing emergency Plans andPrograms).
For multi-unit events, the review was to include details on how the ERO and associatedcommand/control structure would be adapted to multi-unit emergencies. Licensees were toconfirm that the ERO can address a multi-unit accident with respect to adequate ERO structure
and the maintenance of Command and control integration of 2 or more separate reactor units.
The review was to include details on how links between the ERO, engineering groups, SAMG
plans and procedures and other Beyond Design Basis Event (BDBE) criteria should be included.
As part of FAI 5.2.1: Identification of external support and resources required during emergency, it
was required that licensees should formalize all arrangements and agreements for external
support and should document these in the applicable emergency plans and procedures. Morespecifically:•

Licensees should provide a list of all the potential external organizations that have been
identified that may be required during an emergency;•

Licensees should include a reference table listing each organization with details ofwhom, purpose, brief summary of resources, etc. that is being considered. This referencetable may be broken down into types of organizations, such as provincial, local
emergency services, local security services, mutual aid, resources and supplies, nuclear
power plant agreements, international agreements; and•The factors that impact on human performance should be considered.

Following FAI 5.2.1: Identification of external support and resources required during emergency, andaccording to FAI5.2.2: Identification of external support and resources agreements, it was required thatlicensees should formalize all arrangements and agreements for external support and should
document these in the applicable emergency plans and procedures. This assessment was toconsider elements of HOP under accident conditions. More specifically, the following was to beconsidered:•

Licensees should provide a list that will be provided to all the external organizations thathave been identified that require a formal agreement or arrangement;•

Licensees should provide a reference table listing each agreement, with whom, purpose,
duration, etc. (more criteria may be required to be referenced) Note the information
contained in these agreements may include confidential or proprietary information, so
details may not be readily available; and•This reference table may be broken down into types of organizations, such as provincial,
local emergency services, local security services, mutual aid, resources and supplies,
nuclear power plant agreements, international agreements.

While licensees have implemented most of the requirements and expectations of the FAIs
on the extended response plans, they will continue to be the subject of regulatory oversight asopportunities for improvement arise.
d)Other additions or modifications to extended response plans.

Automated gamma boundary monitoring system is used to provide a real time measurement of
release, or absence thereof, of radioactive material at the boundary of a nuclear plant zone toprovide immediate environmental radiation information. Licensees were required to develop apermanent real time gamma boundary monitoring system to provide on and off site authorities
prompt environmental gamma radiation measurements. The measurements from this system
will enable off site authorities to be able to calculate an estimate of the amount of radioactive
material that may be released to the environment and the dose consequences to the public andenvironment. The automated real time gamma monitoring stations was to be suitably designed

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

for extreme weather conditions, reliability and equipped with appropriate back up power andcommunications links (FAI 5.3.1 - Plan and Schedule for real-time boundary monitoring).
Licensees were required to develop a system to estimate the magnitude of radiologicalinventory in containment prior to a release, in order to provide earliest possible information to
offsite authorities. The tool was to be capable of modeling the radioisotope inventory frommajor accidents, including design basis and beyond design accidents.
If source term calculations/modelling were not practical/available, licensees were todemonstrate that conservative protective measures are in place by offsite authorities toevacuate the public near the facility (FAI 5.4.1 Development of source term estimation
capability).
e)

For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

The licensees were to make provisions for the identification and consideration of any otherrelevant elements of HF involved in the development and deployment of the modelling tool forthe offsite response. The suggested modifications have been considered and implemented.
Further regulatory oversight will be ongoing as opportunities for improvement arise.

References
Canadian Nuclear Safety Commission, Action Plan Exercise Unified Response, E-DOC 4899372,
December 17, 2015 (no link available)
Canadian Nuclear Safety Commission, Assessment of the IAEA Director General Report of the
Fukushima Daiichi Accident, February 2016. http://nuclearsafety.gc.ca/eng/resources/
fukushima/cnsc-assessment-of-the-iaea.cfm
Canadian Nuclear Safety Commission, Directorate of Safety Management Technical Assessment– Subject: Review of COG Habitability Methodology from a Human and Organizational
Perspective – Review of OPG Request for Closure DNGS, FAI 1.9.1 Habitability of Control
Facilities, E-DOCS #4300050. May 7, 2014 (no link available).
Canadian Nuclear Safety Commission Fukushima Task Force Report, October 2011.
http://publications.gc.ca/site/eng/9.695082/publication.html
Canadian Nuclear Safety Commission, GD-310, Guidance on Safety Analysis for Nuclear Power
Plants, March 2012. http://publications.gc.ca/site/eng/418394/publication.html
Canadian Nuclear Safety Commission, Integrated Action Plan On the Lessons Learned from the
Fukushima Daiichi Nuclear Accident, August 2013. http://nuclearsafety.gc.ca/eng/
resources/publications/reports/action-plan-fukushima/index.cfm
Canadian Nuclear Safety Commission, Management Response to CNSC Fukushima Task ForceRecommendations, October 2011. http://publications.gc.ca/site/eng/407064/publication.html
Canadian Nuclear Safety Commission, Nuclear Emergency Response Plan – Master Plan, E-DOCS#3845178. Link to this document can be found here http://nuclearsafety.gc.ca/eng/resources/
emergency-management-and-safety/index.cfm
Canadian Nuclear Safety Commission, RD/GD-99.3, Public Information and Disclosure, March
2012. http://nuclearsafety.gc.ca/eng/acts-and-regulations/regulatory-documents/history/rd_99-3.cfm
Canadian Nuclear Safety Commission, Regulatory Document RD-310, Safety Analysis for
Nuclear Power Plant, February 2008. http://nuclearsafety.gc.ca/eng/acts-and-regulations/
regulatory-documents/published/html/rd310/

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTCanadian Nuclear Safety Commission, RD-337, Design of New Nuclear Power Plants, 2008.
http://nuclearsafety.gc.ca/eng/acts-and-regulations/regulatorydocuments/published/html/rd337/
Canadian Nuclear Safety Commission, REGDOC – 2.2.2, Personnel Training, Version 2, December
2016.
http://www.nuclearsafety.gc.ca/eng/acts-and-regulations/regulatory-documents/
published/html/regdoc2-2-2-v2/index.cfm
Canadian Nuclear Safety Commission, REGDOC 2.3.2, Accident Management (September 2015).
http://www.nuclearsafety.gc.ca/eng/acts-and-regulations/regulatorydocuments/history/regdoc2-3-2.cfm
Canadian Nuclear Safety Commission, REGDOC 2.10.1, Nuclear Emergency Preparedness andResponse (February 2016). http://www.nuclearsafety.gc.ca/eng/acts-and-regulations/
regulatory-documents/history/regdoc2-10-1.cfm
Canadian Nuclear Safety Commission, Regulatory Guide G-306, Severe Accident Management
Programs for Nuclear Reactors, May 2006. Link to this document can be found here
http://nuclearsafety.gc.ca/eng/acts-and-regulations/regulatory-documents/index.cfm
Canadian Nuclear Safety Commission, Regulatory Guide G-323, Ensuring the Presence ofSufficient Qualified Staff at Class I Nuclear Facilities – Minimum Staff Complement, July2007). Link to this document can be found here http://nuclearsafety.gc.ca/eng/acts-andregulations/regulatory-documents/index.cfm
Canadian Nuclear Safety Commission, Fukushima Safety Improvements Implementation for
Nuclear Power Plants: Fukushima Action Items Closure Criteria and Expectations, January
2013 (no link available).
Canadian Nuclear Safety Commission, Licence Conditions Handbook. July 2010 (no link
available).
Government of Canada, General Nuclear Safety and Control Regulations. http://laws.justice.gc.ca/
eng/regulations/sor-2000-202/page-1.html
Report of the External Advisory Committee: Examining the Response of the Canadian Nuclear
Safety Commission to the 2011 Japanese Nuclear Event, April 12, 2012.
http://publications.gc.ca/site/eng/420701/publication.html

Acronyms

32

BDBA

Beyond Design Basis Accidents

CANDU

Canadian Deuterium Uranium

CIIT

CANDU Industry Integration Team

CMD

Commission Member Document

CNSC

Canadian Nuclear Safety Commission

COG

CANDU Owners Group

CSA

Canadian Standards Association

DNGS

Darlington Nuclear Generating Station

EAC

External Advisory Committee

ECFV

Emergency Containment Filtered Ventilation

EMEG

Emergency Mitigating Equipment Guideline

EOP

Emergency Operating Procedure

ER

Emergency Response

ERO

Emergency Response Organization

FAI

Fukushima Action Item

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTFTFFukushima Task Force

HFE

Human Factors Engineering

HOF

Human and Organizational Factors

HOP

Human and Organizational Performance

I&C

Instrumentation and Control

IAEA

International Atomic Energy Agency

IAMP

Integrated Accident Management Program

IFB

Irradiated Fuel Bay

IRRSInternational Regulatory Review Service

IVR

In-Vessel Retention

MSC

Minimum Shift Complement

NSCC

Nuclear Strategic Steering Committee

PAR

Passive Autocatalytic Recombiners

PPE

Personal Protective Equipment

PROL

Power Reactor Operating Licences

PSR

Periodic Safety Review

SAM

Serious Accident Management

SAMG

Serious Accident Management Guide

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTCZECH REPUBLIC
Response to Phase 1 Information Request
provided by State Office of Nuclear Safety

The Phase 1 request for overviews of Post-Fukushima requirements and guidelines wascompleted prior to the Czech Republic joining this WGHOF task. As a result, there is no overview
document available for the Czech Republic.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTFRANCE
Response to Phase 1 Information Request
provided by Autorité de Sûreté Nucléaire

An update at the end of 2020 of the French case

1. Summary of Actions
The summary of actions and response to questionnaire has been prepared by the French
Nuclear Safety Authority (ASN, Autorité de Sûreté Nucléaire) with the support of its technicalsupport organization (TSO), the Institute of radioprotection and nuclear safety (IRSN, Institut deRadioprotection et de Sûreté Nucléaire).
Some information was extracted from the December 2020 ASN report “Closure report of theaction plan of the French nuclear safety authority (ASN) – Follow-up to the French nuclear power
plant stress tests” and December 2017 ASN report “Update of the action plan of the French
nuclear safety authority (ASN) – Follow-up to the French nuclear power plant stress tests”. These
reports are publicly available on the ENSREG website (see references). When necessary, otherreferences are mentioned and an update has been made with current information available inearly 2021.

1.1. Organization and actors in France and Europe
First of all, although the responses to the questionnaire address and focus on the French case,some requirements which were agreed on within the European framework are presented.

1.1.1. General organization of nuclear industry and oversight in France
In France, the French regulator of nuclear safety and radiation protection (Autorité de Sûreté
Nucléaire (ASN 1)) is in charge of prescribing corrective actions to operators and control theirimplementation on the nuclear power plants, on the manufacturing plants, the fuel-cycle
plants, and research reactors.
It is supported by the technical support organization (TSO), the Institut de Radioprotection
et de Sûreté Nucléaire (IRSN 2) that conducts assessment to determine if technical, human andorganizational measures implemented or to be implemented are robust and efficient to address
the nuclear safety and radiation protection requirements.
The recommendations of the most critical safety assessments of IRSN are debated within
the expert advisory committee in charge of nuclear power production (Groupe Permanentd’Experts réacteur (GPR 3)) which provides complementary recommendations for the nuclear
safety authority to establish the regulatory requirements to nuclear operators.
The three main French nuclear operators are: Electricité de France (EDF) that operates 56
nuclear power reactors (since closure of Fessenheim reactors in 2021) and will operate a newreactor (EPR), AREVA (called ORANO since 2018 for the fuel cycle and waste processing plants)
1 www.asn.fr.
2 www.irsn.fr.
3 http://www.french-nuclear-safety.fr/ASN/Technical-support/The-Advisory-Committees
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that manufactured reactors (Framatome activity is now within EDF group in EDVANCE), andCommissariat à l’Energie Atomique (CEA) that conducts research on nuclear research reactors.
There a few other nuclear operators, which are research centers. Totally, there are 124 basic
nuclear installations (BNI) in 2020.

1.1.2. The European regulatory framework
In Europe, nuclear safety regulation is a national responsibility. The national frameworks fornuclear safety regulation comply with European Directive.
The European Commission (EC) set-up the European Nuclear Safety Regulators Group(ENSREG) that involves all European regulators and advises the EC.
The Western European Nuclear Regulators’ Association (WENRA) is a subgroup of
regulators that produces reference documents to enhance harmonization within EU. It was
initiated by French regulator (ASN).

1.2. EU “stress tests” and action plan follow-up
After Fukushima accident, the 24 and 25 March 2011, the European Council requested “stresstests” to be developed by ENSREG, the European Commission and WENRA.
On 26 April 2012, one year after the Fukushima Daiichi nuclear power plant accident, a jointstatement by ENSREG and the European Commission concluded the stress tests conducted on
the European nuclear power plants. This statement emphasized the need to implement an
overall action plan to ensure that these stress tests would be followed by safety improvement
measures implemented in a consistent manner in each country.
The ENSREG global action plan required the nuclear safety regulator of each member
country to publish a national action plan by the end of 2012. In December 2012, ASN, the French
nuclear safety authority, published the action plan for France in response to therecommendations of the 2012 European Peer Review of Stress Tests and the 2nd Extraordinary
Meeting of the Convention on Nuclear Safety (CNS) in 2012. The national action plans thenunderwent a peer review which concluded with a seminar organized by ENSREG in Brussels, in
April 2013.
For France, the seminar summary report in particular emphasized the comprehensive
nature of the action plan presented, the importance that ASN attaches to the transparency ofthe stress tests process, the ambitious nature of the content and the implementation times forthe measures to improve safety in the nuclear power plants decided on in the wake of the
Fukushima Daiichi Nuclear Power Plant accident, and the consideration given to organizationaland human factors, including conditions regarding the use of subcontractors.
Following the seminar organized by ENSREG in the spring of 2013, the decision was taken to
produce a report, two years later, on the implementation of the measures carried out in eachcountry, on the occasion of a new seminar organized by ENSREG in 2015. For France, this update
mainly concerned the progress of the measures initiated for the various prescriptions issued by
the safety regulator.
Following this 2nd seminar, the decision was taken to adopt a simplified European levelpeer review process. It consists in updating the initial action plan and publishing it on the
ENSREG site, no later than at the end of 2017. The ASN report has been published in December
2017 “Update of the action plan of the French nuclear safety authority (ASN) – Follow-up to the
French nuclear power plant stress tests”. Then, a final report was issued by ASN in December
2020 “Closure report of the action plan of the French nuclear safety authority, Follow-up to the
French nuclear power plant stress tests”.

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1.3. “Stress tests” and post-Fukushima action plan for France
1.3.1. Complementary safety assessments after Fukushima and “Hardened safety core”
On 23 march 2011, the French prime minister requested the stress tests to be conducted. ASN
issued a number of resolutions on 5 May 2011 asking the licensees of major nuclear facilities to
conduct theses stress tests. They were carried out on the basis of specifications which wereconsistent with the ENSREG specifications developed for the European stress tests.
In France, the stress tests are called “Complementary safety assessments” (Evaluation
complémentaire de sûreté (ECS)). Their purpose is to challenge nuclear power plant design
assumptions to more extreme natural hazards threats. It is a complementary approach to theusual safety demonstration approach required for the license of design and operation, in thesense that it should address beyond design basis scenarios. Those beyond design basis scenarios
could lead to cliff-edge effects to some critical equipment and safety function (especially loss ofcooling and electricity) and would then lead to severe accident and radiological release in theenvironment.
All nuclear operators (mainly EDF, AREVA, CEA) prepared safety case reports for September
2011 describing the new provisions they intended to implement. This was performed withavailable information in spring 2011 and prior to receiving the final conclusions of public
hearings and investigations in Japan.
With this request and in this context, the “hardened safety core” approach was defined to
avoid, despite the impact of a severe natural disaster, the loss of the most critical safety systems
and functions of the defense-in-depth of the reactor in case of loss of water cooling function(heat-sink) and electrical supply, the occurrence of a severe accident and important radiologicalreleases in the environment. The “hardened safety core” is made of equipment, human andorganizational means which goals are to ensure for a long period the critical safety functions.
The results of these stress tests were presented to the Advisory Committees for Reactors
and for Laboratories and Plants which met on 8, 9, 10 November 2011, and ASN issued a position
statement on them, on 3 January 2012. This position was itself examined under the European
stress tests which were completed in April 2012.
The regulatory authority (ASN) issued the “first round” of post-Fukushima prescriptions the
26 June 2012.
ASN requested nuclear operators to enforce a set of new technical and organizational
measures, robust enough to resist to extreme events. For a nuclear reactor, it means that theminimum set of scenarios should consider losses of water cooling function (heat-sink) andelectricity caused by extreme natural hazards beyond former design assumptions. For the
French nuclear power plant operator (EDF), ASN required to set up:•

firstly,–•a hardened safety core of material and organizational provisions aimed at:–a) preventing an accident with fuel melt, or limit its progression;–b) limiting large-scale radioactive releases;–c) enabling the licensee to perform its emergency management duties.

–

a local emergency center allowing emergency management of the nuclear site as awhole in the event of an extreme external hazard,–

a nuclear rapid intervention force (FARN) which, using mobile means external to thesite, can intervene on a nuclear site in a pre-accident or accident situation.

and secondly,–

a set of corrective actions or improvements (notably the acquisition of additional
communication and radiological protection means, the implementation of

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additional instrumentation, extensive consideration of internal and external hazard
risks, improvements to the management of emergency situations),–

studies of modifications and additional means enabling ASN to issue a position
statement on future safety options.

As requested, EDF proposed new details on the objectives, assumptions and criteria for thedesign of the "hardened safety core” by June 2012 that were challenged by an expert assessmentof IRSN that was conducted in 2012 and debated within the advisory group in December 2012.
ASN notes that to date EDF has met its undertakings and all the regulatory deadlines thathave reached term. Nevertheless, ASN has supplemented its requests with a set of resolutions
dated 21 January 2014 aiming to clarify certain design provisions of the hardened safety core.
Since then, EDF delivered several answers to the requests and is presenting in a continuous
process from 2013 to date the new provisions on hardened safety core, especially theirengineering criteria and design assumptions.

1.3.2. The post-Fukushima action plan and its implementation on nuclear power plants
These additional prescriptions led to the examination of several dossiers, with a view to theirreview by the ASN Advisory committees, from 2015 to 2020, in order to look in detail at thevarious studies carried out by EDF and enable ASN to issue a position statement on them.
Generally speaking, ASN requests are part of a continuous process to improve safety withregard to the targets set for the 3rd generation reactors (EPR) and aim in addition to be able tocope with situations far beyond those normally considered for this type of installation.
These requests are issued in application of the defense-in-depth approach and as suchconcern measures to prevent and mitigate the consequences of an accident, based on both
additional fixed means and external mobile means planned for all the installations on a site
beyond their initial design basis.
In response to the ASN prescriptions, EDF implemented provisions that contribute to theimprovement of:40•

the protection against internal or external aggression, in particular reinforcement ofprotection against flooding;•the means of electrical power supply: installation of additional electrical power supply(backup diesel-generators), increase of the autonomy of the batteries used in the eventof complete loss of electrical power supply;•

the provisions to prevent accidents with core melt: e.g. installation of high temperature
reactor coolant pump seals capable to withstand loss of cooling for an extended periodof time, emergency water make-up in the reactor coolant system when it is open,
installation of standardized pipe connections for mobile equipment (particularly for the
FARN);•

the provisions to prevent the uncovery of fuel assemblies in the pool: e.g. provisions toprevent accidental rapid draining of the spent fuel pools, reinforcement of the spent fuelpool instrumentation;•

the management of accidents with core melt: e.g. redundant instrumentation for
detecting reactor vessel melt-through and hydrogen in the containment;•

the emergency management: reinforcement of the seismic resistance and flood
resistance of the emergency management premises, strengthening of the teampreparation in the event of an earthquake, measures to cope with site isolation in theevent of flooding, reinforcement of the communication means, multiple unit plant
emergency organization, coordination with neighbouring industrial operators in theevent of an emergency;•

the means of intervention on sites through the implementation of the nuclear rapid
action force (FARN): capacity for simultaneous intervention on all reactors of an accident
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site in less than 24 hours. The FARN provides water, compressed air and electricity
supply with its own mobile equipment.
ASN's requests are also part of a process of continuous improvement in safety with regard
to the objectives set for third-generation reactors, and are aimed, in addition, at coping withextreme events (earthquakes, floods, etc.), far beyond those retained during the design of the
facilities currently in operation.
Given the nature of the work required, it is necessary for the operator to carry out studies
for the design, construction and installation of new equipment, which requires, on the one
hand, deadlines and, on the other hand, planning for their optimal installation on each of thenuclear power plants.
Thus, the "hardened safety core" will be commissioned as part of the safety improvements
related to the continued operation of 900 MWe and 1,300 MWe reactors beyond 40 years and
1,450 MWe reactors beyond 30 years.

2. Response to the OECD/NEA/WGHOF Questionnaire
Summary of mitigation capabilities and human and organizational factors prescriptions
The OECD/NEA/WGHOF questionnaire addresses mainly the mitigation capabilities especiallyfrom human and organizational factors (HOF) standpoint.
With respect to the scope of the questionnaire to mitigation capabilities, ASN requested EDF
to take all necessary provisions to ensure the operational character of the organization andcrisis means in case of a site accident involving several reactors. Several modifications andchanges were requested upon the crisis organization (plans, communication), fixed andportable equipment and buildings to host the crisis center, severe accident means andstrategies.
With respect to the scope on Human and Organizational factors (HOF), ASN requested
operators to identify the human actions required to be performed and ensure they can be
performed despite the extreme conditions with adequate minimum staffing. In addition, it
requested that the actors that should perform those actions should be trained to extreme
situations context and stressful conditions. They should receive psychological support, as wellin relationship with their family.
Additionally, all the new equipment design, especially the “hardened safety core” that
require the performance of a human action have to comply with a design process that is usercentered and integrates human factors design approach.
Some of the requirements may originate from consensus within European peer reviews
performed within ENSREG in 2013 and convention on nuclear safety (CNS) in 2012.
From the HOF standpoint on mitigation capabilities, ASN made a key requirement toaddress the challenge of “operability” of the “hardened safety core” (see appendix for the whole
ECS1).
The ASN prescription ECS1-IV specifies:
IV. The licensee shall take all necessary steps to ensure that the emergency organization
and resources are operational in the event of an accident affecting all or some of the facilities
on a given site.
The licensee shall therefore include these steps in the hardened safety core defined in I. of
this requirement and, in accordance with II of this requirement, shall issue requirements
concerning:•

the emergency situation management premises, so that they offer greater resistance tohazards and remain accessible and habitable at all times and during long-duration
emergencies, including in the event of radioactive releases. These premises shall enable

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the emergency teams to diagnose the status of the facilities and control the resources of
the hardened safety core;•

the availability and operability of the mobile means vital for emergency management;•

the means of communication essential to emergency management, in particularcomprising the means of alerting and informing the emergency teams and the publicauthorities and, should this prove necessary, the arrangements for alerting the
population if the off-site emergency plan is triggered in reflex phase by delegation fromthe Prefect 4; the availability of parameters used to diagnose the status of the facility, as
well as meteorological and environmental measurements (radiological and chemical,
inside and outside the emergency situation management premises) enabling theradiological impact on the workers and general public to be evaluated and predicted;•

the active dosimetry resources, radiation protection measuring instruments andindividual and collective protective means. These resources shall be available insufficient quantity by 31 December 2012.

EDF has commissioned new emergency premises at the Flamanville site, which are robust
to withstand extreme hazards. EDF has taken into account the lessons learned to optimize thedesign of the emergency premises at the other sites.
1.

MITIGATION STRATEGIES (i.e. strategies for maintaining or restoring core cooling,
containment, and spent fuel pool cooling capabilities)a)

Development of new mitigation strategies
ENSREG Peer Review: The incorporation of the WENRA reference levels related to severe
accident management (SAM) into their national legal frameworks, and ensure theirimplementation in the installations as soon as possible. This would include:•

Hydrogen mitigation in the containment - Demonstration of the feasibility andimplementation of mitigation measures to prevent massive explosions in case of severe
accidents.

•

Hydrogen monitoring system - Installation of qualified monitoring of the hydrogenconcentration in order to avoid dangerous actions when concentrations that allow an
explosion exist.

•

Reliable depressurization of the reactor coolant system – Hardware provisions with
sufficient capacity and reliability to allow reactor coolant system depressurization toprevent high-pressure melt ejection and early containment failure, as well as to allow
injection of coolant from low pressure sources.

•

Containment overpressure protection - Containment venting via the filters designed forsevere accident conditions.

•

Molten corium stabilization - Analysis and selection of feasible strategies andimplementation of provisions against containment degradation by molten corium.

Following publication of the TSN Act in 2006 and its application decrees, ASN completely
revised the general technical regulations applicable to BNIs.
The order of 7 February 2012 setting the general rules for basic nuclear installations takes
up the WENRA reference levels that come under this level of regulatory text. This order also
provides a foundation for several of the requirements expressed by ASN further to the stresstests. This order was supplemented by several ASN statutory resolutions or guides published inorder to continue implementation of the WENRA reference levels.
Concerning the implementation of the reference levels on site, in particular thoseconcerning severe accidents:

4 In French Préfet.

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all the reactors in operation are equipped, since the end of 2007, with hydrogen passive
autocatalytic recombiners (PAR) intended to prevent global hydrogen detonation in thereactor containment;•

all the reactors in operation are equipped with a redundant instrumentation dedicatedto severe accident management, able to detect reactor vessel melt-through and thepresence of hydrogen in the containment;•

the prevention of high pressure meltdown sequences is based on voluntary opening of
the pressurizer safety relief valve tandems. A system was installed to allow valve
opening, even in the case of total loss of power supply;•

all the reactors in operation are equipped with the venting-filtration U5 system to limit
the pressure in the reactor containment in the event of an accident;•

on the Flamanville 3 EPR, the CHRS (Containment Heat Removal System), included at thedesign stage, allows the residual power removal from the containment as well as thecorium cooling.

Progress: completed.
Multiple accident
Peer Review: The enhancement of the capability for addressing accidents occurring
simultaneously on all plants of the site. Examples include assuring preparedness and sufficient
supplies, adding mobile devices and fire trucks and increasing the number of trained andqualified staff.
Analysis of the management of multiple accidents affecting all or some of the reactors of agiven site simultaneously has called into question the previously implemented material andorganizational provisions.
ASN prescriptions on new mitigation strategies mainly deal with strategies to mitigate a site
accident involving several reactors.
ASN prescription n° ECS–1: Definition of the structures and components of the "hardened
safety core", including the emergency management premises. Defining the requirements
applicable to this hardened safety core.
The licensee shall take all necessary steps to ensure that the emergency organization andresources are operational in the event of an accident affecting all or some of the facilities on
a given site.
The emergency centers forming part of the hardened safety core shall be built on each site;the material resources of the hardened safety core are installed on each reactor.
In this context ASN has issued prescriptions ECS–32 and ECS–36.II.
ASN prescription n° ECS–32: Multiple plant unit emergency organization
Before 31 December 2012, the licensee shall reinforce its material and organizational
measures to take account of accident situations simultaneously affecting all or some of the
facilities on the site.
Progress: Action completed. The modified on-site emergency plan (PUI) baseline has been
deployed on all EDF sites since 15 November 2012. It takes into account accident situations
simultaneously affecting several facilities on a given site.
This modified baseline PUI has been applied by all the sites since 13 November 2014. It more
specifically takes account of deployment of the FARN’s human and equipment capacity forintervention on a 6-unit site and the local emergency resources.
ASN prescription n° ECS–36: The nuclear rapid intervention force (FARN)

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTECS–36.II: On 31 December 2012, this organization will be deployable for intervention on areactor on the site. The FARN must be suitably sized to intervene simultaneously on all thereactors of the site by the end of 2014.
The licensee shall integrate into the accident operations procedures and the severe accident
management documents, including the severe accident management guidelines inparticular, the new provisions for handling the extreme situations studied in the stress tests
and affecting several reactors on the same site, for all operating states, as well as the fuelstorage buildings.
The FARN has the human and equipment resources to act simultaneously on all the reactors
on the same site.
Progress: completed.
b)

Modification of current mitigation strategies
Improvement in safety at shutdown and in the different reactor states
During the stress tests, ASN analyzed situations with loss of heat sink and loss of electrical
power supplies to the reactors, going beyond the situations considered in the current
baseline requirements. It considered all the states of reactors and fuel storage pools, andscenarios which firstly have a lasting effect on all the reactors on a site and secondly could
be caused by an earthquake or external flooding, including of a level higher than thatconsidered in the current baseline requirements. For each of these situations, the times
before the fuel becomes exposed in the event of loss of the cooling systems and the electricalsupplies have been evaluated.
ASN prescription n° ECS–16.II: Emergency water supply resources and emergency water
make-up in the reactor coolant system
Before 31 December 2012, the licensee shall present ASN with the modifications it intends
to make for the installation, before 31 December 2013 unless specifically justified, of systems
to ensure the injection of borated water into the reactor core in the event of total loss of site
electrical power supplies when the reactor primary coolant system is open.
Before 30 June 2013, the licensee shall propose final requirements to ASN for theseprovisions and shall indicate whether or not they are part of the hardened safety core.
EDF initially made provisions on each reactor to allow the injection of borated water by
connecting mobile means to tappings installed for that purpose (completion at end of 2015,
in a first phase), a function that will be ensured in a second phase by fixed equipment of thehardened safety core.
ASN asks to integrate into the accident operations procedures and the severe accident
management documents - including the severe accident management guidelines inparticular - the new provisions for handling the extreme situations studied in the stresstests and affecting several reactors on the same site, for all operating states, as well as thefuel storage buildings.
Progress: EDF has responded to this request.
EDF presented the modifications (new shafts, basins or tanks depending on the site), as wellas their requirements, to provide new means to ensure cooling of the reactor and the fuelpool.
The elements relating to the operational management of these equipment items were
examined by ASN prior to the implementation of the modifications to permit the injectionof borated water and within the framework of the requests for modification of emergency
management, also submitted to ASN.
EDF implemented modifications on 900 MWe reactors to manage situations when the
primary coolant system is open. This is a mobile pump powered by the generator set
installed in response to the ECS–18.III prescription. On the P4, P'4 and N4 type reactors, EDF
has justified that the existing means make it possible to inject borated water into the

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primary coolant system in these situations.
c)

Assessment and/or integration of the whole set of mitigation strategies (e.g. Extended Damage
Mitigation Guidelines, FLEX Guidelines, Severe Accident Guidelines, Emergency Operating
Guidelines, etc.).
See c)d)

Addition of new procedures/guidelines for newly installed systems or components or new
mobile equipment for improving mitigation capabilities
Enhancement and extension of the scope of the severe accident management guides (SAMG)
to all reactor states
CNS (Convention Nuclear Safety of ENSREG): Performing or planning an evaluation of theguidance that is to be used by the operator to manage emergency situations resulting fromsevere accidents caused by extreme natural phenomena at nuclear power plants, including forlow power and shutdown states. These documents include emergency operating procedures toprevent core damage, severe accident management guidelines to prevent containment failure,and extensive damage mitigation guidelines to address accidents that result in fires or
explosions that affect a large portion of a nuclear power plant.
Recommendation specific to France resulting from the peer review of 2012: The French
SAMGs however, do not cover accidents in the SFP, and do not include multi-unit events.
Shutdown states are currently only implemented for the 900 MWe series, their implementation
for the other series of the French reactor fleet is foreseen.
The reactors in operation have severe accident management guides (SAMGs), which aredesigned to provide assistance to emergency teams in order to ensure the best possible
containment of radioactive products. Indeed, when the emergency teams apply the SAMG, thepriority is no longer the prevention of core melt but that of the containment. In these guides,
possible actions to reduce the consequences of a severe accident are described.
The different work carried out in the context of stress tests took into account scenarios that
had not been considered in the past. Their conclusions are taken into account for the revisionsof the documents relating to the management of severe accidents. In particular, these
documents cover, for all reactors, reactor shutdown states.
Progress: completed
Peer review: In conjunction with the recommendation 2.4 (see ENSREG Peer review, ASN, 2020),
the enhancement of SAMGs taking into account additional scenarios, including, a significantly
damaged infrastructure, including the disruption of plant level, corporate-level and nationallevel communication, long-duration accidents (several days) and accidents affecting multiple
units and nearby industrial facilities at the same time. Following the stress tests, ASN has issued
the following prescription.
ECS–14.II: Coordination with neighboring industrial operators in the event of an emergency
II. No later than 30 September 2012, the licensee shall take all steps, for example by meansof agreements or detection and alert systems, to ensure that it is rapidly informed of any
event liable to constitute an off-site hazard for its facilities, in order to protect its staff
against these hazards and to ensure that emergency management is coordinated with theneighboring operators.
EDF has defined alert systems for all of its sites in order to better coordinate with neighboring
operators.
Progress: completed
Management of severe accidents induced by a severe external event
Peer review: The systematic review of SAM provisions focusing on the availability andappropriate operation of plant equipment in the relevant circumstances, taking account of

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accident initiating events, in particular extreme external hazards and the potential harshworking environment.
ASN has instructed EDF (ECS–35.I&II, see 3.a) to check that the emergency management
actions planned for in extreme situations studied for the stress tests are effectively achievable.
Prescription ECS–35.I&II calls for ensuring the feasibility of emergency management actions in
extreme situations. It also instructed EDF (ECS–14.I) to take into consideration the industrial
risks induced in extreme situations by nearby risk-prone facilities.
ECS–14.I: Integration of industrial risks in extreme situations.
I. No later than 31 December 2013, the licensee shall supplement its ongoing studies with
the inclusion of the risk arising from activities taking place near its facilities, in the extreme
situations studied by the stress tests and in conjunction with neighboring licensees
responsible for these activities (nuclear facilities, installations classified on environmental
protection grounds or other facilities liable to constitute a hazard). By that deadline, thelicensee shall propose any modifications to be made to its facilities or their operatingprocedures as a result of this analysis.
EDF has carried out, for all sites, studies to determine the risks induced by potential hazards
due to the industrial environment on a nuclear power plant site and the possible
modifications to be made. EDF indicates that the studies to verify the robustness of thehardened safety core functions take this risk into account.
Progress: completed
Validation of the severe accident management guides (SAMG)
Peer Review: The validation of the enhanced SAMGs.
The various documents relative to severe accident management are validated following theusual processes established by ASN and the licensees, including an independent technicalanalysis by IRSN.
Progress: completede)Changes, if any, in strategy design, implementation, use and adherence
No specific prescriptions.

f)Others actions related to mitigation strategiesg)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections, training,
drills, exercises).

2.

OTHER PROCEDURES AND GUIDELINES (to manage other elements of event or emergency
response not directly supporting the implementation of mitigation strategies)

No specific prescriptions.

46h)Modification of procedures and guidelinesi)

Changes, if any, in procedure design, implementation, use and adherencej)

Other changes or additions to procedures and guidelinesk)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).

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3.

STAFFINGa)

Assessment of staffing needs (numbers and roles).
ASN prescription: n° ECS - 35.I and II: feasibility of emergency management actions in extreme
situations
I. No later than 31 December 2012, the licensee shall define the human actions required for
management of the extreme situations studied in the stress tests. It shall check that theseactions can effectively be carried out given the intervention conditions likely to be encounteredin such scenarios. It shall for instance take account of the relief of the emergency teams and thelogistics necessary for the interventions. It shall specify any material or organizational
adaptations envisaged. On the deadline date, the licensee shall transmit a summary of theresults of this work and the envisaged measures. On 30 June 2012, the licensee shall send ASN
an interim report.
II. Before 31 December 2012, the licensee shall send ASN a list of the necessary emergency
management skills, specifying whether these skills could be provided by outside contractors.
The licensee shall provide proof that its organization ensures the availability of the necessary
skills in an emergency situation, including if outside contractors are used.
Progress:
EDF has defined the human actions required and their competences needed for the
management of extreme situations studied in the stress tests, as well as the measures to havespecialized teams capable of intervening on the sites.
EDF has transmitted the human actions required for management of the extreme situations
studied in the stress tests, along with the measures planned to ensure the availability of
specialized teams capable of intervening on the sites. EDF presented ASN with a methodology
for determining the personnel numbers permanently present on a nuclear site to deal with anextreme situation. It conducted several tests on full-scale control room simulators with
operations teams.
IRSN completed in 2016 an assessment of the methodology presented by EDF to determine theminimum staff to deal with an extreme situation and focused its examination on theassumptions used especially on the worst case scenarios, the definition of roles andresponsibilities related to workload to perform all actions and according to specific work
conditions for some actions and the method to verify the robustness of staffing. The
recommendations aim at enhancing organizational robustness to known scenarios andorganizational resilience to all type of situations.
New operations procedures are under development in coherence with new hardened safety coreequipment strategies and will be tested in the future with overall team performance of humanactions in the plant. Human factors and risk analysis of work conditions in case of severe
external threat are analyzed for each priority action of the operation procedures. Investigations
have shown workload issues of the operation team, especially the supervisor function that has
to prioritize, control, and anticipate, and the head of team that have to support, control andinform the national team for crisis management.
On this basis, ASN issued a position statement in 2017 with several prescriptions.

b)

Changes in plans and measures to augment on-site staffing levelsc)Other actions related to staffingd)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections, training,
drills, exercises).

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4.

ORGANIZATIONAL STRUCTURES, COMMUNICATION, DECISION MAKING AUTHORITIES, AND
SAFETY CULTURE
a)Changes, if any, in the command & control organizations for accident management,
including single and multiple source term response, if applicable.

No specific prescriptions.
b)

Others changes to organization structures, coordination protocols, and guidance fordecision making and communications (both internal and external). (Note:
Communications equipment is addressed separately in topical area 6).

Main changes to organization structures: subcontracting
The order setting the general rules relative to basic nuclear installations, called the "BNI" order,
was signed on 7 February 2012. The provisions of this order cover the organization andresponsibilities of the BNI licensees in particular. Several articles in the "BNI" order cover
subcontracting:•

The licensee must have the necessary in-house technical competence to oversee theactivities that directly concern the safety of the installation.

•

The licensee must establish and implement a policy that gives priority to nuclear safety
and protection of the environment, disseminate this policy and ascertain that it is
known, understood and applied by all the personnel required to implement it, including
outside contractors’ personnel.

•

The activities important for nuclear safety and radiation protection of the environment,
their technical controls, the verifications and assessments are carried out by persons
with the necessary skills and qualifications. The licensee ascertains that the outsidecontractors take the necessary training measures to maintain these skills andqualifications and, where necessary, to develop them.

•

The licensee takes all necessary measures to enable outside contractors to detect thedeviations that concern them and report them to the licensee without delay.

•

The licensee monitors the outside contractors.

•

Monitoring of performance of activities important for protection by an outside contractor
must be ensured by the licensee, who may not subcontract this task. This being said, inparticular cases the licensee can be assisted in the monitoring, on condition that it
retains the skills necessary to maintain control of said monitoring (article 2.2.3).

The regulatory provisions relative to subcontracting were supplemented by the decree of 28
June 2016 relative to the modification, final shutdown and decommissioning of basic nuclear
installations and to subcontracting. This decree lays down the following provisions:48•

The basic nuclear installation licensee can use outside contractors on condition that it
retains the capacity to control these activities and the operation of its installation.

•

To guarantee the control of activities that are important for the protection of theinterests mentioned in the Environment Code, the licensee keeps the number ofsubcontracting levels as low as possible. When the licensee entrusts services or works
important for the protection of the abovementioned interests to an outside contractor
within the perimeter of its facility which is either in operation or undergoing
decommissioning, they may be performed by second-tier subcontractors at the lowest.

•

The licensee cannot entrust to an outside contractor the operational responsibility andoversight of a basic nuclear installation, including with regard to the handling ofaccidents, incidents and deviations, and emergency situation preparedness andmanagement.

•

The licensee monitors the activities important for protection of the abovementioned
interests when they are performed by outside contractors. The licensee puts in place a

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system for transmitting information received from the outside contractors, particularly
for the purpose of experience feedback.
•

When these provisions cannot be adhered to in the case of an unforeseeable event
affecting the conditions of performance of the activity or necessitating one-off
operations, the licensee can authorize the outside contractor to use a third-tier
subcontractor The licensee informs ASN beforehand, indicating the reasons for thisdecision.

•

When the licensee is considering using an outside contractor to perform activities
important for the protection of the abovementioned interests, it evaluates the bids taking
into account criteria that give priority to the protection of these interests. The licensee
ascertains beforehand that the companies it is considering using have the technicalcapability to carry out the work in question and control the associated risks.

Main changes to organization structures: support to the personnel on site
Peer review: Rescue teams and adequate equipment to be quickly brought on site in order toprovide support to local operators in case of a severe situation.
CNS: Upgrading regional, off-site and on-site emergency response centers.
Following the stress tests, ASN has set prescription ECS–36 to reinforce the emergency
organization.
ASN prescription on the nuclear rapid intervention force (FARN – ECS–36.I).
I. Before 30 June 2012, the licensee shall present ASN with the measures it intends to take inorder to provide specialized teams capable of relieving the shift crews and deploying emergency
response resources in less than 24 hours, with operations starting on the site within 12 hours
following their mobilization. This system may be common to several of the licensee’s nuclear
sites.
These teams shall be sized so that they can respond on all the reactors of the site and havemeasuring instruments that can be deployed as of their arrival. The licensee shall specify theorganization and sizing of these teams, in particular:•

the activation criteria,•

the tasks incumbent upon the teams,•

the material and human resources at their disposal,•

the personal protective equipment,•

the system put into place to ensure the maintenance of these material resources andtheir permanent operability and availability;•

the training of their staff and the skills currency process.

EDF has set up a nuclear rapid intervention force (FARN) with equipment and humanmeans at its disposal.
The FARN is a national organization capable of rapidly providing equipment and humanassistance to a site in an accident situation or to one or more sites in difficulty simultaneously.
This organization must notably allow the relief of the teams present on the site if it
impossible for the normally planned relief teams to fulfil this function or to get to the accidentstricken site.
All the installations have been modified to be able to connect the mobile emergency meanstransported by the FARN.
The activation of the FARN is decided at the national level on the basis of the analysis of thesituation. The FARN is made up of a headquarters and four regional centers located at thenuclear power plants of Bugey, Civaux, Dampierre and Paluel.
The FARN's mission is to:
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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST•

intervene after 24 hours, in continuity and in relief of the operating shift teams which
will have assumed the emergency actions of the site concerned, whose accessinfrastructures may be partially destroyed act autonomously for several days (which
implies logistic support capacities in the field of food and accommodation in particular);•

deploy heavy means of protection or intervention, unique for EDF's nuclear fleet, withina few days;•

ensure permanent liaison with the EDF’s upper management, the management andteams of the nuclear power plant and the local public authorities in order to manage andcoordinate interventions;•prepare the sustainability of its actions beyond the first days of autonomy in the eventof a long-term emergency.

The four regional centers have on-call intervention teams of 14 people covering the various
areas (processes, intervention, logistics). These teams are made up of dedicated EDF personnel,
prepared for emergency situations, in particular through training (annual training volume of
33,000 hours) and as well regular training and role-playing. The FARN uses methods ofadaptation to situations from the military world and civil security intervention units to be able
to act in a wrecked environment and take stress into account.
The FARN has specialist teams capable of intervening in the areas of operational control,
maintenance and logistics on a site in an accident situation.
The FARN's activities can be broken down into short-term (less than 3 days) or long-term(more than 3 days – see long term §10 of questionnaire) activities.
The short-term activities have the following aims:•

bring operational control skills onto the site to back up or relieve the shift team;•bring in additional material resources, connect them up and put them into service within
24 hours;•

ensure radiological monitoring of the environment;•

bring to the site, in situations lasting more than 24 hours, the necessary logistics forcorrect operation of the resupplied functions.

The FARN has transport and handling equipment, redundant telecommunication means
and equipment for water and electricity supply (pumps, compressors, generators...) to intervene
simultaneously on all the reactors on a same site. The equipment is stored in specific premisesin each center. Each team is able to treat 2 reactors and can bring the necessary equipment todo so. The FARN has the human and equipment resources to intervene simultaneously on all
the reactors on a same site (up to six reactors). Locations of potential rear bases are identified
near the nuclear power plants.
At the end of 2020, 45 exercises were carried out on nuclear sites, each time involving abouta hundred actors. FARN has also been involved in two real situations resulting from extreme
climatic hazards and it brought:•

support to teams of technicians to reconstitute the power grid on the island of SaintMartin after hurricane IRMA, with the installation of a life base for a month and a half;•

support for EDF Hydraulique teams in the Tina, Roya and Vésubie valleys for three weeks
to clear the hydraulic structures.

Progress: completedc)Changes, if any, in the requirements or guidelines for promoting healthy safety culture.
No specific prescriptions.

d)50

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining

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relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections, training,
drills, exercises).
See above.

5.

PERSONNEL QUALIFICATIONS AND TRAININGa)

Changes in job qualification requirements to address the need for new technical and nontechnical (e.g. for managing the unexpected, stress management) knowledge and abilities.

b)

Changes in training program content to address new knowledge and ability needsc)Changes in training program structure (e.g. instruction/assessment methods or frequency).

d)

Other changes to personnel qualifications or training.

e)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections, training,
drills, exercises).
Severe accident management training
Peer Review: Regular and realistic SAM training exercises aimed at training staff. Training
exercises should include the use of equipment and the consideration of multi-unit accidents
and long-duration events. The use of the existing nuclear power plant simulators is considered
as being a useful tool but needs to be enhanced to cover all possible accident scenarios.
French regulations and the EDF on-site emergency plans (PUI) provide for regular andappropriate training of the personnel intervening on site, and the performance of several
exercises on each nuclear power plant each year. Thus, each section of the site's PUI(radiological and toxic safety, climatic and similar hazards safety, etc.) must undergo an overall
exercise every 3 years. The number of exercises per year and per site is determined according
to the number of emergency team members, as each team member must attend one PUI
exercise per year. Implementation of the new material and organizational provisions will beaccompanied by specific training actions to ensure their effectiveness.
The PUI plan takes into account accident situations affecting several installations on thesame site at the same time. The implementation of this PUI plan has been accompanied by
specific training for personnel.
Following the stress tests, ASN has issued prescriptions ECS–10 and ECS–35.III
ASN prescription n° ECS–1: Definition of the structures and components of the "hardened
safety core", including the emergency management premises. Defining the requirements
applicable to this hardened safety core.
Comments: The organizational means and equipment necessary for emergency
management and included in the "hardened safety core" are identified in the on-site
emergency plans of the sites, along with their storage locations and deployment procedures.
They are tested regularly and training in their use is provided during exercises.
ASN prescription n° ECS–10: Reinforcement of team preparation in the event of anearthquake
Before 30 June 2012, the licensee shall send ASN a training program for the operating teams
to enhance their level of preparedness for earthquake situations. This program shall inparticular include regular in-situation training exercises. This program shall have been
followed by the reactor operating personnel in charge of the seismic instrumentation rackand of the associated operating measures no later than 31 December 2012. The other site
operating teams shall receive information by 31 December 2012 and shall have followed theentire program no later than 31 December 2013.
All operating teams have undergone a training program to reinforce their level of
preparedness for earthquake situations. This training is carried out every 3 years.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTASN prescription n° ECS–35.III: Severe accident management training
III. Before 30 September 2013, the licensee shall provide the personnel concerned with thetraining and preparation needed to enable them to respond to particularly stressful accident
situations. It shall ensure that the outside contractors liable to intervene in management of
the emergency adopt similar requirements concerning the preparedness and training of
their own staff.
Progress:
EDF has updated its training system for the persons mobilized under the on-site emergency
plan. EDF developed a training plan for the FARN (nuclear rapid intervention force) personal.
No EDF subcontractors intervene in nuclear power plant emergency situations.
EDF is undertaking research and development into the emergency situation preparednessof operators and emergency and crisis management teams in order to modify its internal
training if necessary. Furthermore, EDF is drawing lessons from the training of the FARN
(nuclear rapid intervention force).
IRSN conducted a safety assessment completed in 2018 on the training and preparation to
manage extreme and stressful situation for the FARN teams. The examination dealt with
the identifications of relevant competencies, the adequacy of training and preparation(exercises, drill) provisions to the goals, and the assessment of the efficiency of theprovisions. Specific issues have been addressed such as the stressors in working situations,the mapping of competencies, the physical capabilities training, the ethical considerations
for decision-making, the appropriation of tactical decision-making methods of fire brigades
as well as their stress management practices, the debriefing techniques, the conduct of
exercises with interfaces between operation, FARN and crisis teams. In addition, trainings
in degraded situations aims at learning how to develop resilience practices.

6.

PLANT
INSTRUMENTATION,
COMMUNICATIONS EQUIPMENTe)

CONTROLS,HUMAN-SYSTEMINTERFACES,

AND

Addition or modifications to plant instrumentation and control to improve the usability oravailability of information to plant staff and their ability to take control actions (e.g. spent
fuel pool instrumentation, containment venting).

Seismic instrumentation
Peer Review: The installation of seismic monitoring systems with related procedures andtraining.
Recommendation specific to France resulting from the 2012 peer review: The seismic
instrumentation could be improved to a state of the art concept. It is also recommended toconsider an upgrade of the corresponding safety rule RFS 1.3.b (1984)
The operating conditions of the seismic instrumentation installed on the sites were
specifically verified by ASN during the targeted inspections conducted in 2011. The findings led
ASN to set prescriptions ECS–8 obliging the seismic instrumentation to be brought into
conformity with the recommendations of RFS I.3.b (ref: Basic safety rule I.3.b 08/06/1984
concerning seismic instrumentation).
ASN prescription n° ECS–8: Conformity of seismic instrumentation with RFS 1.3.b
ASN prescription on the suitability of the instrumentation used in France for measuring theseismic hazard.
Before 30 June 2013, the licensee shall carry out a study to compare the seismic
instrumentation currently used in France with that used internationally. This study shallenable the licensee to determine whether the instrumentation used in France is still suitable
for measuring the seismic hazard or whether it needs to be replaced, in the light of the mostrecent scientific knowledge.

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By the same deadline, the licensee will present the conclusions drawn from the study andwill, as necessary, propose an appropriate plan of action along with time-lines.
Progress: The EDF studies have been transmitted. ASN considers that the technology usedenables these equipment items to fulfil their assigned safety function satisfactorily.
Revision of RFS I.3.b: In view of the files submitted by EDF, the work done to restore
conformity of the nonconforming instrumentation and the fact that the safety function ofthis measurement is a simple threshold measurement, ASN (2020) considers that updatingof the basic safety rule relative to the seismic instrumentation is not necessary.
Instrumentation and measuring
Peer Review: The enhancement of instrumentation and monitoring. Examples include separate
instrumentation and/or power sources to enable monitoring of essential parameters under any
circumstances for accident management and the ability to measure specific importantparameters based on passive and simple principles.
Recommendation specific to France resulting from the 2012 peer review: Further
qualification to Severe Accident environmental conditions and against external hazards; andensuring electrical power supply (Spent fuel pools instrumentation will be included into thehardened safety core). […] In case of loss of the electrical power supplies for the operating
Nuclear Power Plants, the instrumentation that detects entry into the Severe Accident situation
is no longer available in the control room. […] For the operating nuclear power plants in theevent of an earthquake, the availability of the instrumentation useful in SA situations is notguaranteed because it is not earthquake classified. These should therefore also be integrated
into the hardened safety core. […]During the stress tests, complementary studies were conducted to examine the robustnessof the instrumentation & control necessary for diagnosis and guidance of the operating teamduring electrical power failure. The conclusions of this work led ASN to set prescriptions ECS–
19 and ECS–20.
ASN prescription n° ECS –19: Redundancy of instrumentation for detecting reactor vessel
melt-through and hydrogen in containment
I. As early as possible, given the constraints of cross-fleet deployment, and in any casebefore 31 December 2017, the licensee shall install redundant means in the reactor pit todetect vessel melt-through as well as in the containment to detect the presence of hydrogen.
Instrumentation in the control room shall indicate corium melt-through of the vessel.
State of progress: deadline of 31/12/2016 for Implementation of redundant means for the 13
sites and 31/12/2017 was the Deadline for the implementation of redundant means for 6
sites.
II. Before 31 December 2013, the licensee shall propose final requirements to ASN for theseprovisions and shall indicate whether or not they are part of the hardened safety core.
EDF has defined the requirements associated with its redundant instrumentation. EDF has
set up these instrumentations for all of its 19 sites. EDF considers that this equipment does
not belong to the hardened safety core.
ASN prescription n° ECS–18.I: Increased battery life and n° ECS–18 II: Ultimate backup diesel
generator sets
Peer Review: The enhancement of the DC power supply. Examples include improving thebattery discharge time by upgrading the existing battery, changing/diversifying battery type(increasing resistance to common mode failures), providing spare/replacement batteries,
implementing well-prepared load shedding/staggering strategies, performing real load
testing and on-line monitoring of the status of the batteries and preparing dedicatedrecharging options (e. g. using portable generators).
Recommendation specific to France resulting from the 2012 peer review: The reviewers
recommend ASN to also consider the benefits of recharging the batteries before their
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complete depletion in case of a total Station Black Out (total loss of electrical power supplies)in addition to the foreseen battery capacity increase.
Electric batteries provide and guarantee continuity of the electrical supply to certain key
equipment items in the event of loss of the off-site electrical power supplies and when theemergency generator sets are not operating. The protection, capacity and life of thesebatteries were specifically studied within the framework of the stress tests. ASN has set
prescription ECS–18.I
ECS–18.I: Increased battery life
I. Before 30 June 2012, the licensee shall present ASN with the modifications it intends tomake before 31 December 2014 in order to significantly increase the operating life of thebatteries used in the event of loss of the off-site and on-site electrical power supplies
The operating life of the batteries has been increased from 1 hour to 2 hours. These batteries
can be recharged by the ultimate diesel generator (DUS).
Progress: completed
Main and emergency control rooms
Peer Review: The enhancement of the main control room (MCR), the emergency control room
(ECR) and emergency control center (ECC) to ensure continued operability and adequate
habitability conditions in the event of a station black-out (SBO) and in the event of the loss of
DC (this also applies to Topic 3 recommendations).
Total loss of electrical power supplies (loss of the off-site sources and the on-site diesel
generators), also called station black-out (SBO), is a situation that leads to the loss of the
dynamic containment ensured by the ventilation systems, and particularly the main control
room ventilation function and this ventilation’s filtration via iodine trap.
ASN has issued prescription ECS–18.III. Prescription ECS–18.III requires the installation of
emergency power supplies. These allow the supply of the necessary reactor control system fromthe control room, the lighting in the control room, and the ventilation-filtration system.
Progress: completed
ECS–18.III: Installation of provisional emergency electrical power supplies pending
installation of the means required by prescription ECS–18.II
In the meantime, and no later than 30 June 2013, the licensee shall install a temporary
system on each reactor for supplying:•

the I&C (Instrumentation and Control system) necessary in the event of loss of the offsite and on-site electrical power supplies,•

the control room lighting.

The licensee installed a backup diesel generator on each reactor within the required timeframe. Finally, each site can have mobile means provided by the nuclear rapid intervention
force (FARN), including diesel generators.
Progress: completed
The improvement of the robustness of the spent fuel pool (SFP)Peer Review: Examples include reassessment/upgrading SFP structural integrity, installation ofqualified and power-independent monitoring, provisions for redundant and diverse sources ofadditional coolant resistant to external hazards (with procedures and drills), design of pools thatprevents drainage, the use of racks made of borated steel to enable cooling with fresh(unborated) water without having to worry about possible recriticality, redundant andindependent SFP cooling systems, provision for additional heat exchangers (e. g. submerged in
the SFP), an external connection for refilling of the SFP (to reduce the need for an approach
linked to high doses in the event of the water falling to a very low level) and the possibility ofventing steam in a case of boiling in the SFP.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTCNS: Installing additional equipment and instrumentation in spent fuel pools to ensurecooling can be maintained or restored in all circumstances, or performing additional technicalevaluations to determine if additional equipment and instrumentation are needed
The stress tests included an in-depth examination of the consequences of a major natural
hazard on the systems that evacuate the residual heat from the fuel stored in pools, on the
integrity of the pools in the fuel building or the reactor building and the systems connected tothem, and the risks of storage rack deformation and falling loads.
The conclusions of the analyses have led ASN to issue prescriptions ECS–16.I, ECS–18.II, ECS–
20, ECS– 21, ECS–22, ECS–23 and ECS–25. Prescriptions ECS–16.I and ECS–18.II impose theimplementation of makeup means for the pool, powered by complementary electrical supply
means. Prescription ECS–20 requires the implementation of reinforced instrumentation of thecondition of the spent fuel pool.
ASN prescription n° ECS–20: Reinforcement of pool condition instrumentation
I. Before 30 June 2012, the licensee shall present ASN with the modifications to be made, formeasuring both the condition of the fuel storage pool (temperature and water level in the
spent fuel pool) and the radiological atmosphere in the fuel building hall.
II. Pending their implementation: By 31 December 2012 at the latest, the licensee shallprovide its national emergency organization with charts indicating the times to reachboiling point in the event of total loss of cooling, according to the residual power of the fuelstored in the spent fuel pool;
No later than 31 December 2013, the licensee shall ensure that level measurement in theevent of total loss of electrical power supplies is available.
The fuel pools are equipped with instrumentation for measuring the water level: this
instrumentation is now electrically backed up. It is also currently reinforced to ensure its
resistance to earthquakes and damaged environmental conditions.
The fuel pools have temperature sensors: the temperature measurements are only used toensure initiation of incidental or accidental procedures. Abacuses are used to evaluate theonset of boiling and can compensate for the absence of temperature measurement indeteriorated conditions. The fuel pools have activity measuring chains in the hall of the fuelbuilding that are used in particular in case of fuel handling. For other accidental situations,these measurements are not used because the actions of the operators (water makeup) are
carried out from premises located outside the pool hall or the fuel building.
Progress: completed
ASN Prescription n° ECS–25: Reinforcement of the provisions for managing a transfer tube
leak or in the compartment drainage pipes
I. Before 31 December 2012, the licensee shall submit to ASN a study of the possible changes
to equipment or operating conditions in order to prevent uncovering of the assemblies
during handling, as the result of a break in the transfer tube between the pools in the reactor
and fuel buildings or in the compartment drainage pipes.
II. Before 31 December 2012, the licensee shall present ASN with the possible changes toequipment or operating conditions to be made before 30 June 2013, in order to prevent the
rapid loss of water inventory above the stored fuel assemblies, as a result of a break in thetransfer tube between the pools in the reactor and fuel buildings or in the compartment
drainage pipes.
EDF carried out a seismic resistance study as well as modification studies to prevent
uncovering of the fuel assembly during handling in the event of a break in the transfer tube
or in the compartment drainage pipes.
EDF has taken organizational measures (by modifying the administrative lock-out
conditions for valves to guarantee their positions) in order to prevent exposure of the fuelassembly in the event of a break in the compartment drainage pipes.
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Progress: completed

ECS–7: Measures to cope with site isolation in the event of flooding (Cruas, Tricastin sites)
Before 31 December 2012, the licensee shall demonstrate to ASN that it has implemented
an organization and resources able to deal with site isolation in the event of flooding.
These measures serve to overcome the lack of resources and provide for the monitoring ofcertain meteorological and hydrological parameters, among other things. The use of special
operating rules is decided on the basis of predetermined meteorological or hydrologicalcriteria (monitoring of river levels or sea level) to allow the safe shutdown of the reactors.
EDF has implemented an organization and resources able to deal with site isolation in theevent of flooding.
Progress: completed
Advanced warning of deteriorating weather
Peer Review: The implementation of advanced warning systems for deteriorating weather, as
well as the provision of appropriate procedures to be followed by operators when warnings are
made.
The licensee has taken operational measures to protect the sites from extreme
meteorological conditions (flooding, extreme heat, extreme cold, low water, etc.) more
specifically including alert systems in the event of a foreseeable hazard (high temperatures,riverside or coastal flooding, possibly combined with extremely high winds, rainfall) andagreements with outside organizations such as Météo France and the Prefecture.
ASN checked that these systems were operational during the targeted inspections carriedout in 2011. The conclusions of these inspections led ASN to issue prescription ECS–7 for theCruas and Tricastin sites.
f)Addition or modifications to plant communications capabilities (onsite/internal
communications and communication with off-site individuals/organizations).

Peer Review: The improvement of communication systems, both internal and external,
including transfer of severe accident related plant parameters and radiological data to all
emergency and technical support center and regulatory premises.
CNS: Improving their radiation monitoring and communications capabilities and enhancing
public communications, such as via dedicated public websites.
Following the stress tests, ASN has issued prescription ECS–30
Improvement in communication
The improvement in means of communication has been demanded by ASN in the short term
and is the subject of the following prescriptions.
ASN prescription n° ECS–1: Defining the structures and components of the "hardened safetycore", including the emergency management premises. Defining the requirements
applicable to this hardened safety core.
Comments: The communication means vital for emergency management are included inthe "hardened safety core". They include more specifically the means of alerting andinforming the emergency team members of operator at national level and the publicauthorities. If necessary, the licensee can activate the means used to alert the populations
if the off-site emergency plan (PPI) is triggered in the reflex response phase by delegationfrom the prefect.
State of progress: The additional means of communication have been procured.
ASN prescription n° ECS–30: Reinforcement of the means of communication

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II. No later than 30 June 2012, the licensee sets up independent communication resources
allowing direct contact between the site and the national emergency organization definedin the interministerial directive of 7 April 2005.
State of progress: Means of communication implemented as at 30/06/2012.
In addition, EDF has a redundant and secure communication system, in addition to theadditional satellite telephone resources that were deployed on the sites in 2012 to enable alink in an extreme case in redundancy of the resources already deployed.
g)Other changes to plant or equipment human-system interfaces to improve humanperformance reliabilityh)For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).

7.

PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS

a)

Provision of additional portable plant equipment or hand tools to support reliable humanperformanceb)

Design of portable plant equipment or hand tools to support reliable human performance (e.g.
plug and play pipe connections, portable and installed equipment painted with some specificcolor, equipment needed during a station blackout identified with fluorescent labels)c)Provision of additional protective gear or modifications to protective gear to support reliable
human performance
Radiation protection
Peer Review: The provision for radiation protection of operators and all other staff involved in
the SAM and emergency arrangements.
CNS: Improving their radiation monitoring and communications capabilities and enhancing
public communications, such as via dedicated public websites.
French regulations require the licensee to make provisions for the protection of personspresent in the establishment in the event of an emergency, in particular adapted collective andindividual protective equipment, operational dosimetry means, and radiation protection
measuring means available in sufficient quantity for all persons present in the establishment.
French regulations require the licensee to have at its disposal, in the nuclear installation orin its vicinity, in particular mobile means enabling it to take samples and measurements insideor outside the establishment under all circumstances, especially in the event of an incident or
accident. These points are subject to verification during ASN inspections.
Exercises involving simulated media pressure are organized every year to test the
information capacities of the various players (Préfets, safety authorities, licensees at the local
and national levels…).
Among the technical and organizational provisions of the hardened safety core, and pursuant
to the ASN prescription, the licensee has integrated the provisions necessary to ensure theavailability of the active dosimetry equipment, the measuring instruments for radiation
protection and the personal and collective protective equipment. Furthermore, the verificationof the feasibility of the human actions prescribed by ASN has taken into account the radiation
protection of the persons involved. Lastly, the licensee has checked that it is possible to monitor
and manage the facilities after radioactive releases while taking into account the radiation
protection of the persons involved.
ASN prescription n° ECS–1: Defining the structures and components of the "hardened safetycore", including the emergency management premises. Defining the requirements
applicable to this hardened safety core.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTThe licensee shall take all the measures necessary to ensure the availability of the active
dosimetry equipment, the measuring instruments for radiation protection and the personaland collective protective equipment.
Progress: These items of equipment have been procured by the sites. These points havebeen verified in the course of ASN inspections.

ASN prescription n° ECS–31: Modifications to ensure facility management further to releases
Before 31 December 2012, the licensee shall send ASN a file presenting the planned
modifications on its site to ensure that, in the event of release of dangerous substances or
opening of the U5 venting-filtration system, operation and monitoring of all the facilities on thesite are guaranteed until a long-term safe state is reached; the corresponding deployment
schedule shall also be provided. EDF has implemented measures to mitigate the release ofradioactive substances in accident situations:•a provision to anticipate, in a situation of total loss of electrical power supply, the closingof high priority containment isolation valves;•the installation of alkalizing baskets in the buildings of the 1300 MWe and N4 typereactors to limit the source term released (basic pH of the sumps) in accident situations.
This modification, which limits gaseous iodine releases, has a favorable effect on theradiological environment of the control room and on the accessibility of the site;•

for 1300 MWe and N4 type reactors, the electrical back-up for the filtration of the space
between the two walls of the reactor containment.

EDF has also implemented an electrical back-up for the filtration of the air entering thecontrol room.
d)Modifications to work environments to support reliable human performance (e.g. emergency
lighting, flood protection)e)Others changes to plant equipment/environments to support reliable performance of mitigation
actionsf)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections, training,
drills, exercises).
Mobile equipment
Peer Review: The provision of mobile pumps, power supplies and air compressors withprepared quick connections, procedures, and staff training with drills. Mobile devices areintended to enable the use of existing safety equipment, enable direct feeding of the primary or
secondary side, allow extended use of instrumentation and operation of controls, allow effective
fire-fighting, and ensure continued emergency lighting. The equipment should be stored inlocations that are safe and secure even in the event of general devastation caused by events
significantly beyond the design basis.
ASN has set the following prescriptions with respect to these mobile material provisions.
ASN prescription n° ECS–1: Defining the structures and components of the "hardened safetycore", including the emergency management premises. Defining the requirements
applicable to this hardened safety core.
The emergency procedures, which incorporate the new measures identified in the stresstests, provide for the use of mobile equipment situated either on or off the site, and whose
availability and operability must be guaranteed. ASN has set prescription ECS–30.
French regulations require the licensee to ensure the availability and operability of themobile means required for emergency management. This is verified during inspections.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

In addition, all the installations have been modified to enable the connection of the mobile
emergency means transported by the FARN.
ASN prescription n° ECS–30: Storage of mobile means
III. No later than 30 June 2013, the licensee shall store its mobile resources necessary for
emergency management in appropriate premises or zones able to withstand the SSE andflooding in the event of the flood safety margin level being reached.
This measure, implemented by EDF, is checked as part of the ASN inspections.
Progress: completed.

8.

WORK PLANNING, TECHNICAL SUPPORT, AND EMERGENCY RESPONSE FACILITIESa)Design and implementation of new or modified on-site facilities

Main and emergency control rooms
Peer Review: The provision of an on-site emergency center protected against severe natural
hazards and radioactive releases, allowing operators to stay onsite to manage a severe accident.
CNS: Upgrading regional, off-site and on-site emergency response centers.
The emergency premises for the reactors in service were designed without regulatory
requirements relative to resistance to hazards.
Total loss of electrical power supplies (loss of the off-site sources and the on-site diesel
generators), also called station black-out (SBO), is a situation taken into account in the severe
accident management guidelines. This situation leads to the loss of the dynamic containment
ensured by the ventilation systems, and particularly the main control room ventilation function
and this ventilation’s filtration via iodine trap. Permanent habitability of the control room isguaranteed, unless the reactor containment U5 venting system filter is opened. Habitability canbe temporarily compromised if the U5 system is used, or if there are large releases of toxic
substances from outside the site. In this respect, the licensee has planned to reinforce theelectrical back-up of control room ventilation and filtration by an ultimate backup diesel
generator (GUS). Pending implementation of this modification, the Nuclear Rapid Response
Force (FARN, will deploy means to ensure the electrical back-up of these equipment items forthe damaged reactor.
The emergency rooms (security block – BDS, emergency equipment stores, etc.) were
designed without specific regulatory requirements concerning flooding and earthquakes. The
BDS is temporarily uninhabitable after opening the U5 system filter.
ASN has therefore set the following prescriptions which make it mandatory to include theemergency situation management premises in the "hardened safety core", and for them to behighly resistant to hazards and to remain accessible and habitable at all times and during longduration emergencies, including in the event of radioactive releases. Pending the installation of
new emergency premises that meet these requirements, ASN has instructed the licensee toguarantee the design of the existing emergency premises against the seismic and flooding levelsof the current baseline safety requirements.
ASN has therefore set the prescriptions ECS–30.I and ECS–1.IV to improve the resistance tohazards of crisis management premises for them to remain accessible and habitable duringlong-duration emergencies, including in the event of radioactive releases.
ASN prescription n° ECS–1: Defining the structures and components of the "hardened safetycore", including the emergency management premises. Defining the requirements applicable tothis hardened safety core.
The emergency management rooms, the availability of parameters used to diagnose thestatus of the facility, the communication means necessary for emergency management, and themeteorological and environmental measurements are included in the hardened safety core.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

As part of hardened safety core implementation, EDF is building a local emergency
management center on each site that withstands the hardened safety core situations (the first
local emergency management center will be built for the commissioning of the EPR). In theinterim, the existing emergency management premises have undergone seismic reinforcement

ASN prescription n° ECS–30: Designing the emergency premises to withstand earthquakes andflooding
I. The licensee shall ensure that the emergency situation management premises can withstandflooding in the event of the flood safety margin level being reached. Before 30 June 2012, it shallpresent ASN the conclusions of this verification and any modifications considered necessary.
Before 30 June 2013, it shall perform any necessary reinforcement work.
The licensee checks that the emergency management premises can withstand the safe
shutdown earthquake (SSE). Before 30 June 2012, it shall present ASN the conclusions of thisverification and any modifications considered necessary. Before [Date variable according to thesites, see below], it shall perform any necessary works.
•

EDF has carried out, for all the sites requiring it, the necessary modifications andadjustments to the emergency premises to enable them to withstand the flood safetymargin level and the safe shutdown earthquake.

II. No later than 30 June 2012, the licensee shall set up independent communication
resources allowing direct contact between the site and the national emergency organization
defined in the interministerial directive of 7 April 2005.
III. No later than 30 June 2013, the licensee shall store its mobile resources necessary for
emergency management in appropriate premises or zones able to withstand the SSE andflooding in the event of the flood safety margin level being reached.

ASN prescription ECS–31: Modifications to ensure facility management further to releases
Before 31 December 2012, the licensee shall send ASN a file presenting the planned
modifications on its site to ensure that, in the event of release of dangerous substances or
opening of the U5 venting-filtration system, operation and monitoring of all the facilities on thesite are guaranteed until a long-term safe state is reached; the corresponding deployment
schedule shall also be provided.
EDF has implemented measures to mitigate the release of radioactive substances in accident
situations:•a provision to anticipate, in a situation of total loss of electrical power supply, the closingof high priority containment isolation valves;•the installation of alkalizing baskets in the buildings of the 1300 MWe and N4 typereactors to limit the source term released (basic pH of the sumps) in accident situations.
This modification, which limits gaseous iodine releases, has a favorable effect on theradiological environment of the control room and on the accessibility of the site;•

for 1300 MWe and N4 type reactors, the electrical back-up for the filtration of the space
between the two walls of the reactor containment.

EDF has also implemented an electrical back-up for the filtration of the air entering thecontrol room.

60b)

Design and implementation of new or modified off-site facilitiesc)Changes to other facilities not previously addressedd)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST9.

EMERGENCY RESPONSE PLANSa)

Changes in emergency response plans or implementation methods

Summary of the main changes since 2014:•

France has put in place a new national response plan for major nuclear or radiologicalaccidents whose regional application (with regard to the defense and safety zones andthe local countries administration (France administrative territory is divided in ahundred departments) is currently in progress.

•

Baseline emergency requirements integrating the lessons learned from the FukushimaDaiichi Nuclear Power Plant accident have been deployed on all the French nuclear
power plants; they introduce changes in emergency situation preparedness zones interms of both geographical coverage and response actions. The off-site emergency plan
(PPI) zones for the nuclear power plants shall be extended from 10 to 20 km and the PPIs
introduce an immediate evacuation measure over a radius of 5 km.

•

ASN maintains its high level of international involvement at both European level andbeyond. ASN actively participates, for example, in the reflections conducted by theEuropean radiation protection and nuclear safety authorities in order to harmonize
population protection measures on either side of national frontiers and participates
actively in involving the civil protection authorities and more generally the government
authorities in their application.

b)

Changes in the drills or exercises of the emergency response plan

Severe accident simulation exercises
Peer Review: Exercises aimed at checking the adequacy of SAM procedures and organizational
measures, including extended aspects such as the need for corporate and nation level
coordinated arrangements and long-duration events
The crisis organization of the EDF nuclear fleet is designed to take into account emergency
situations, in particular to avoid any radioactive release into the environment or to limit themas much as possible. It is based on two levels:•the local level at each site under the direction of the nuclear power plant director or his
representative. It is structured into teams that cover the four main areas required to
manage emergency (expertise, decision, action, communication);•

the National Emergency Organization (ONC), which supports the local level withspecialists from EDF's corporate services. The emergency organization of the EDF nuclear
fleet is equipped with human and material means that can be called upon 24 hours a day
and 7 days a week by a nuclear power plant.

Public authorities (the Government, ASN and technical experts) and licensees in radiologicalemergencies intervene in their respective fields of competence relating to assessment, decisionmaking, action and communication, for which regular audioconferences are organized.
Exchanges lead to decisions and orientations relating to the safety of the installation and theprotection of the population. Similarly, relations between the communication units and the
spokespersons of the emergency centers ensure consistency in the information provided to the
public and the media.
In particular, exercises make it possible to train the people likely to be involved and to
implement the various aspects of the emergency organization, as well as the procedures
provided for in the various plans and reference systems (national plan, Government reference
systems, emergency plans and municipal safeguard plans).
The organizational means and equipment necessary for emergency management are
identified in the on-site emergency plans of the sites, along with their storage locations anddeployment procedures. They are tested regularly and training in their use are provided during
exercises.
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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTThe French regulations provide for the conducting of accident simulation exercises,
including severe accident, at regular intervals. Each nuclear power plant carries out several
exercises each year, including one in which the on-site emergency plan is deployed. In addition,
each nuclear power plant carries out a national-scale exercise at intervals not to exceed 5 years.
French regulations require the licensee to ensure the operational nature of the organizationand emergency means in the event of an accident affecting all or part of the installations on thesame site. These various points are verified during ASN inspections.
This context has led ASN to set the following prescription.
ASN prescription n° ECS–1: Defining the structures and components of the "hardened safetycore", including the emergency management premises. Defining the requirements applicable tothis hardened safety core.
The organizational means and equipment necessary for emergency management andincluded in the "hardened safety core" are identified in the on-site emergency plans of the sites,
along with their storage locations and deployment procedures. They are tested regularly andtraining in their use must be provided during exercises. These points are verified during ASN
inspections.

62c)Others changes to emergency response plansd)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

10. EXTENDED (LONGER TERM) RESPONSEa)

Additions or modifications to plans or capabilities to address on-site staff physiologicalneeds (e.g. food, water, sleep, hygiene) over the duration of time required to achieve asafe/stable plant state.

b)

Additions or modifications to plans or capabilities to address on-site staff psychologicalneeds (e.g. fatigue/stress management, contact with families) over the duration of timerequired to achieve a safe/stable plant state.

c)Additions or modifications to plans or capabilities to relieve/augment on-site staff (e.g.
communication, transportation, site access).

d)Other additions or modifications to extended response planse)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).

Operational and preparatory actions for increasing autonomy of sites and resupply
Peer Review: Implementation of operational or preparatory actions with respect to theavailability of operational consumables. Examples include, ensuring the supply of consumables
such as fuel, lubrication oil, and water and ensuring adequate equipment, procedures,
surveillance, drills and arrangements for the resupply from off-site are in place.
The actions to be implemented further to a large-scale event are of a material andorganizational nature. Aspects considered include the autonomy of the sites in all
circumstances - especially further to an event leading to site isolation - the bringing in of outside
resources, and personnel training.
These aspects were verified during targeted inspections carried out in 2011. In the course of
these inspections ASN identified deviations that led to specific requests (the inspection followup letters can be consulted on the ASN website: http://www.french-nuclear-safety.fr/). These
aspects are subject to ASN inspections. In addition, the FARN has set up an organization andmeans to supply the sites with consumables, including in cases where access conditions
deteriorate. ASN also issued the following prescriptions and requests.
ASN prescription on the reliability of the on-site stocks of fuel and oil.
ASN asks to improve the reliability of the on-site stocks of fuel and oil, as well as theirresupply in all circumstances, such as to ensure an autonomy of at least 15 days for all thereactors of a site.
Progress: This subject undergoes verification as part of ASN normal inspection activities.
The FARN has set up an organizational structure and means for supplying consumables tosites where access conditions have been impaired.

Objectives of the long-term activities of the FARN (ECS–36)
The long-term activities assigned to the FARN should cover:•

deploying major equipment resources (protection of the environment, waterproduction, radiation protection means, etc.);•

preparing for continuation of these actions beyond the first days of autonomy in theevent of a long-duration emergency (including logistic resupply);•

mitigating the environmental impact of discharges, particularly by seeking to restore
containment and treat the radioactive effluents;•

setting up a rear base allowing long-term management of the accident.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTAPPENDIX – HARDENED SAFETY CORE
ASN prescription n° ECS - 1: Defining the structures and components of the "hardened safetycore", including the emergency management premises. Defining the requirements applicable tothis hardened safety core, based on diversified structures and components.
•

64

I. Before 30 June 2012, the licensee shall propose to ASN a hardened safety core of robustmaterial and organisational measures designed, for the extreme situations studied in the
stress tests, to:–prevent an accident with fuel melt, or limit its progression,–

limit large-scale radioactive releases,–

enable the licensee to perform its emergency management duties.

•

II. Within this same time-frame, the licensee shall submit to ASN the requirements
applicable to this hardened safety core. In order to define these requirements, thelicensee adopts significant fixed margins in relation to the requirements applicable on 1
January 2012. The systems, structures and components (SSC) which are included in thesemeasures shall be maintained in a functional state, in particular for the extreme
situations studied in the stress tests. These SSC shall be protected against the internaland external hazards induced by these extreme situations, for example: falling loads,
impacts from other components and structures, fires, explosions.

•III. For this hardened safety core, the licensee installs SSC that are independent anddiversified in relation to the existing SSC, in order to limit common mode risks. If
applicable, the licensee shall justify the use of undiversified or existing SSC.

•

IV. The licensee shall take all necessary steps to ensure that the emergency organisation
and resources are operational in the event of an accident affecting all or some of the
facilities on a given site. To this end, the licensee includes these steps in the hardened
safety core defined in § I. of this prescription and, in accordance with II of thisprescription, more specifically sets requirements concerning:–

the emergency situation management premises, so that they offer considerable
resistance to hazards and remain accessible and habitable at all times and duringlong-duration emergencies, including in the event of radioactive releases. These
premises shall enable the emergency teams to diagnose the status of the facilities
and control the resources of the hardened safety core,–

the availability and operability of the mobile means vital for emergency
management,–

the means of communication essential to emergency management, in particularcomprising the means of alerting and informing the emergency teams and the publicauthorities and, should this prove necessary, the arrangements for alerting the
population if the off-site emergency plan is triggered in reflex phase by delegationfrom the Prefect,–

the availability of parameters used to diagnose the status of the facility, as well as
meteorological and environmental measurements (radiological and chemical, insideand outside the emergency situation management premises) enabling theradiological impact on the workers and general public to be evaluated and predicted,–

the active dosimetry resources, radiation protection measuring instruments andindividual and collective protective means. These means shall be available insufficient quantity by 31 December 2012.

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3. References
3.1. Key public reports
French reports
ASN (2020), Closure report of the action plan of the French nuclear safety authority, Follow-up
to the French nuclear power plant stress tests, http://www.ensreg.eu/document/nationalfinal-report-france-2020
ASN (2017), Follow-up to the French nuclear power plant stress tests, update of the action planoftheFrenchnuclearsafetyauthority,
reportofDecember
2017,
http://www.ensreg.eu/sites/default/files/attachments/update_of_the_action_plan_of_the_fr
ench_nuclear_safety_authority.pdf
ASN (2012), Complementary safety assessments follow-up to the French nuclear power plantstress tests, http://www.french-nuclear-safety.fr/publications/2012/national-plan-ASN-122012/files/assets/common/downloads/publication.pdf
ASN letter to EDF further to the meeting of the Advisory Committee for reactors in November
2011: CODEP-DCN-2012-020754 of 26 June 2012.

European reports
ENSREG (2012), Post-Fukushima accident, Peer review report on stress tests performed on
European nuclear power plants, v12i – 2012 04 25 http://www.ensreg.eu/sites/default/files/
EU%20Stress%20Test%20Peer%20Review%20Final%20Report_0.pdf
ENSREG (2012) Stress tests and Peer Review Process, Joint statement of ENSREG and theEuropean Commission, 2012/04/26 , http://www.ensreg.eu/sites/default/files/EC%20ENSREG%20Joint%20Statement%2026%20April%202012%20-Final%20to%20publish.pdf
ENSREG (2011), Declaration of ENSREG, stress test specifications, http://www.ensreg.eu/sites/
default/files/EU%20Stress%20tests%20specifications_1.pdf

3.2. Public web pages
French website
http://www.french-nuclear-safety.fr/Information/News-releases/European-stress-tests-ASNpublishes-its-national-action-plan

European website
http://www.ensreg.eu/EU-Stress-Tests
http://www.ensreg.eu/news/final-ensreg-report-regarding-stress-tests-european-nuclearpower-plants-now-available
http://www.ensreg.eu/EU-Stress-Tests/EU-level-Reports
http://www.ensreg.eu/EU-Stress-Tests/Background-and-Specifications
http://www.ensreg.eu/EU-Stress-Tests/Country-Specific-Reports
http://www.ensreg.eu/EU-Stress-Tests/Country-Specific-Reports/EU-Member-States
http://www.ensreg.eu/EU-Stress-Tests/Country-Specific-Reports/EU-Neighbouring-Countries

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTJAPAN
Response to Phase 1 Information Request
provided by Japan Nuclear Regulatory Authority[1] Background on Response of Japan to the Questionnaire
Chapter 1 outlines the major post-Fukushima measures taken including the legal amendments,
and Chapter 2 outlines the technical competence (organizational structure, education, training,etc.) required to prevent and mitigate severe accidents including those caused by extreme
external events.

Chapter 1 Outline of Major Post-Fukushima Measures including Legal Amendments
1.1 Major Legal amendments
Regarding the root causes of the accident of the Fukushima Daiichi Nuclear Power Station (NPS),
which occurred on March 11, 2011, the National Diet of Japan Fukushima Nuclear Accident
Independent Investigation Commission (NAIIC), the governmental Investigation Committee on
the Accident at the Fukushima Nuclear Power Stations of Tokyo Electric Power Company andthe Fukushima Daiichi accident report by the IAEA Director General pointed out, for example,
as follows:•

Lack of independence of safety regulation•

The “regulatory capture” of Japan’s nuclear industry•

Before the accident, there was a basic assumption in Japan that the design of nuclear
power plants and the safety measures that had been put in place were sufficiently robust
to withstand external events of low probability and high consequences.

•

The measures against severe accidents had not been subject to regulation before the
Fukushima accident and the licensees had not prepared adequately against severe
accidents.

•

There had been no legal framework to retroactively apply new standards to existing
nuclear power plants, and efforts to always pursue a high level of safety had not beenmade.

In light of these points, the Atomic Energy Basic Act was partially amended in June 2012.
•“To protect people's lives, health and property, and to contribute to environmental
conservation and the security in Japan” has been added to the objectives of the Act.

•“To take into account the established international standards" has been stipulated.

Also, the Act for Establishment of the Nuclear Regulation Authority (NRA) was enacted, andthe NRA was established as a new regulation authority. Through this process, "safety
regulation" was separated from "promotion" of utilization of nuclear energy, and the NRA has
been independently in charge of nuclear safety regulation from a neutral and impartial position
based on technical knowledge and expertise. Also, the responsibilities for nuclear safety

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

regulation, nuclear security, safeguards for nuclear non-proliferation, radiation monitoring andregulation of radioisotopes, etc. have been integrated into the NRA.
The Act on the Regulation of Nuclear Source Materials, Nuclear Fuel Materials and Reactors(hereinafter referred to as the Reactor Regulation Act) was partially amended, making severe
accidents subject to regulation, and a system was established to back-fit the new NRA
Ordinance on Standards for the Location, Structure, and Equipment of Commercial Power
Reactors and that on Technical Standards for Commercial Power Reactor Facilities (hereinafterreferred to as the new regulatory requirements) to the existing nuclear power plants. The
following are the major amendments to the Reactor Regulation Act:••

Clarification and addition of the objectives of the Act–“To protect people's lives, health, and property, and to contribute to environmental
conservation and the security in Japan”–“To postulate an occurrence of a large-scale natural disaster, a terrorist attack andother criminal acts”

Shift to safety regulation taking into account severe accidents as well–•

Responsibilities of the licensees–•

It has been stipulated that the measures against severe accidents are included in theactions to be taken by the licensees for ensuring safety, and it is mandatory for the
licensees to conduct the periodic assessments of safety improvement of their nuclear
facilities, to notify the results to the NRA and to make them available to the public.

It has been stipulated that the licensees are responsible for taking actions needed to
improve safety, taking into account the state-of-the art knowledge.

Shift to the regulation reflecting the stat-of-the art knowledge even in the existing
nuclear facilities–

A "back-fitting system" has been introduced which makes it also mandatory for the
nuclear facilities that had already been licensed to conform to the latest regulatory
requirements.

1.2 Basic Policy for Measures against Severe Accidents and Terrorism

68•

The new regulatory requirements require measures for mitigation of the consequencesof severe accidents, in addition to those for prevention of severe accidents.

•

Since "to postulate an occurrence of terrorism" is added to the objectives of the Act, themeasures against a large aircraft crash due to terrorism are also required.
–

The measures shall be based on defense-in-depth of “prevention of core damage,”“prevention of containment failure,” “controlled release by filtered venting” and“suppression of radioactive material dispersal.”–

Considering the responses using mobile alternative equipment as primary measures,the reliability is further enhanced with its combined use with permanent alternativeequipment.

–

Enhancement of the protective measures for SFP–

Enhancement of robustness of emergency response facility–

Enhancement of reliability and robustness of communication system for emergency
response facility, and enhancement of reliability and robustness of instrumentation
systems for SFP and others (enhancement of command communication andinstrumentation)–

Since it is essential that the system functions properly by the combination ofequipment (hardware) and human actions (software), it is required to implement the

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

emergency procedures and manuals, measures for securing human resources in caseof emergency, training and drills, and so forth. (refer to Chapter 2).
–

As for the measures against intentional aircraft crash and others, diversity in thelocation of mobile equipment and their interconnections are required. Installation ofa so-called “specialized safety facility” is also required as a backup measure forreliability enhancement.

1.3 Outline of New Regulatory Requirements•

Measures against loss of safety functions due to common cause failures, those forprevention of a severe accident, and those for mitigation of its consequences

Prevent loss of safetyfunctions due to common
cause failures (prevention ofsevere accidents)

Strengthen measures against largescale natural disasters

Strictly postulate occurrences and consequences ofearthquake and tsunami
Introduce measures against tsunami inundation
Postulate also occurrences and consequences of
volcanic eruption, tornado and forest fire

Enhance robustness against fires,internal flooding and loss of power,etc.

Enhanced and thorough measures against fires
Introduce measures against internal flooding
Enhance the reliability of offsite power supply
Implement redundant onsite power sources andswitchgears/switchboards in diverse locations
Strengthen systems for monitoring, communication,
etc.

Install equipment andprocedures, etc. to prevent a
severe accident and thosecapable of dealing with it,
should it occur.
Take measures against
terrorism such as intentional
aircraft crash

Prevent core damage

Strengthen measures to shut down the reactor
Strengthen measures to depressurize the reactor
Strengthen measures to inject water into the reactor
and to remove heatStrengthen measures to inject water into the spent
fuel pool

Maintain containment integrity, etc.
of the primary containment vessel(Prevent the primary containment
vessel failure)

Strengthen measures to prevent containment vessel
failureIntroduce measures to prevent hydrogen explosion in
the reactor building, etc.

Suppress radioactive material
dispersal

Introduce measures to suppress radioactive material
dispersal

Ensure supporting functions for
emergency response, etc.

Implement emergency response center

Ensure measures in case that theStore the power supply vehicles, etc. at a location 100
supporting facilities surrounding the m away from the reactor.
reactor building are damaged.
Install dedicated facilities (specialized safety facility)
for further reliability enhancement.

•

Assuming a large-scale natural disaster or an intentional large airplane crash and otherforms of terrorism, so-called “extended damage mitigation measures” are also required
to cope with large-scale damage.

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Chapter 2 Outline of Technical Competence (organizational structure, education,
training, etc.) Required to Prevent and Mitigate Severe Accidents including Those
Caused by Extreme External Events
The Reactor Regulation Act was partially amended in June 2012 and the requirements wereadded for the technical competence needed to take measures for prevention and mitigation ofsevere accidents.
Subsequently the NRA Ordinance Concerning the Installation and Operation of Commercial
Power Reactors (hereinafter referred to as the Commercial Reactors Ordinance) was also
partially amended in June 2012 and the following actions to be taken were added.
•

To establish a plan required to perform activities for securing safety (hereinafter referred
to as “safety management activities”) for power reactor facilities•

To secure staff personnel required to perform the safety management activities for
power reactor facilities (hereinafter referred to as “accident responders”)•

To perform periodically education and training for the accident responders at least oncea year•To provide the power supply vehicles, fire engines, fire hoses and other materials andequipment required to perform the safety management activities for power reactor
facilities•

To establish items regarding the measures listed below needed to perform the safety
management activities for power reactor facilities and to make the accident responders
follow these items–

Prevention of severe core damage–

Prevention of primary containment vessel failure–

Prevention of damage to the fuel assemblies stored in the spent fuel pool–

Prevention of damage to the fuel assemblies during reactor shutdown•

To implement a system needed to perform the safety management activities other thanthose mentioned above for power reactor facilities•

To evaluate periodically the actions mentioned above and to take necessary actions
based on the evaluation results

Also, it was added to take the following actions listed below also in the event of large-scale
damage (extended damage mitigation measures).

70•

To establish a plan needed to perform the safety management activities for powerreactor facilities•

To secure staff personnel needed to perform the safety management activities for powerreactor facilities•

To perform periodically education and training once a year or more for accident
responders•

To provide the power supply vehicles, fire engines, fire hoses and other materials andequipment needed to perform the safety management activities for power reactor
facilities•

To establish items regarding the measures listed below needed to perform the safety
management activities for power reactor facilities and to make the personnel follow
these items–

Firefighting activities in the event of a large-scale fire–

Mitigation of severe core damage

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST–

Mitigation of primary containment vessel failure–

Securing the water level of the spent fuel pool, and mitigation of severe damage offuel assemblies•

To install a system needed to perform the safety management activities other than thosementioned above for power reactor facilities•

To evaluate periodically the above-mentioned actions and to take necessary actions
based on the evaluation results

It was newly added to stipulate the following matters in the licensee’s operational safety
programs.
•

Matters regarding actions to be taken in an emergency•

Matters regarding the implementation of a system to perform the activities for safety
management of the facility in the event of a severe accident•

Matters regarding the implementation of a system to perform the activities for safety
management for the facility in the event of a large-scale damage (a system to take theextended damage mitigation measures)

Subsequently, the NRA newly established the review guide, etc. concerning the abovementioned technical competence in June 2013.
The Commercial Reactors Ordinance requires that the quality assurance (QA) program inaccordance with the licensee's Operational Safety Programs shall include above mentioned
requirements and that the licensee shall perform the PDCA (plan-do-check-act) cycle andcontinuously improve the QA program.

Current Status of Conformity Review
As shown in the table below, as of August 31, 2018, the NRA has completed the conformity
review to the new regulatory requirements for 9 units, which have already restarted, and also
granted permission for alternation of reactor installation as part of the conformity review for 5
units. Beside these 14 units, 13 units are undergoing their conformity review

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Permission for change in reactor installation

Restarted on

Company/Reactor unit

72

Filed onApproved on

Hokkaido Electric Power Company
Tomari 1
Tomari 2
Tomari 3

2013.7.8
2013.7.8
2013.7.8

Not yetNot yetNot yetNot yetNot yetNot yetThe Kansai Electric Power Company
Mihama 3
Takahama 1
Takahama 2
Takahama 3
Takahama 4
Ohi 3
Ohi 4

2015.3.17
2015.3.17
2015.3.17
2013.7.8
2013.7.8
2013.7.8
2013.7.8

2016.10.5
2016.4.20
2016.4.20
2015.2.12
2015.2.12
2017.5.24
2017.5.24

Not yetNot yetNot yet2016.1.29
2016.2.26
2018.3.14
2018.5.9

Shikoku Electric Power Company
Ikata unit 3

2013.7.8

2015.7.15

2016.8.12

Kyushu Electric Power Company
Sendai 1
Sendai 2
Genkai 3
Genkai 4

2013.7.8
2013.7.8
2013.7.12
2013.7.12

2014.9.10
2014.9.10
2017.1.18
2017.1.18

2015.8.11
2015.10.15
2018.3.23
2018.6.16

Tohoku Electric Power Company
Higashidori 1
Onagawa 2

2014.6.10
2013.12.27

Not yetNot yetNot yetNot yetTokyo Electric Power Company Holdings
Kashiwazaki-Kariwa 6
Kashiwazaki-Kariwa 7

2013.9.27
2013.9.27

2017.12.27
2017.12.27

Not yetNot yetChubu Electric Power Company
Hamaoka 3
Hamaoka 4

2015.6.16
2015.1.26

Not yetNot yetNot yetNot yetHokuriku Electric Power Company
Shika 2

2014.8.12

Not yetNot yetThe Chugoku Electric Power Company
Shimane 2
Shimane 3

2013.12.25
2018.8.10

Not yetNot yetNot yetNot yetThe Japan Atomic Power Company
Tokai Daini
Tsuruga 2

2014.5.20
2015.11.5

Not yetNot yetNot yetNot yetElectric Power Development Co., Ltd. (JPOWER) Oma

2014.12.16

Not yetNot yet

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST[2] Response of Japan to the Questionnaire
1. Mitigation Strategies (i.e. strategies for maintaining or restoring capabilities forcore cooling, containment and spent fuel pool cooling)
Requirements (NRA Ordinances)
To consider the lessons learned from the accident of the Fukushima Daiichi Nuclear Power
Station, the NRA partially revised the Commercial Reactors Ordinance, and decided to ask thelicensees for response in the following (1) and (2) for the actions for mitigating the consequencesof large-scale damage and a severe accident.

(1) Taking the actions listed in the following is required as a system to perform the activities forsafety management of power reactor facilities in the event of a severe accident, etc. (Article 85)
5.

7.

Establish internal regulations regarding the following matters in order to maintainthe integrity of nuclear power reactor facilities in the event of severe accidents to beobserved by emergency personnel.
1)Matters related to measures for preventing severe damage to cores in the eventof severe accidents.

2)

Matters related to measures for preventing damage to reactor containments inthe event of severe accidents.

3)

Matters related to measures for preventing severe damage to fuel assemblies
stored in spent fuel interim storage equipment in the event of severe accidents.

4)

Matters related to measures for preventing severe damage to fuel assemblies
during reactor shut-down in the event of severe accidents.

Regularly evaluate each measure mentioned above and take necessary measures in
response to the evaluation results.

(2) Taking actions listed in the following as a system to perform the activities for safety
management for power reactor facilities in the event of large-scale damage (Article 86.)
5.

7.

Establish internal regulations regarding the following matters in order to maintainthe integrity of nuclear power reactor facilities in the event of large-scale damage tobe observed by the personnel.
1)Matters related to fire-fighting in the event of large-scale damage.

2)

Matters related to measures for mitigating severe damage to cores in the eventof large-scale damage.

3)

Matters related to measures for preventing severe damage to reactor
containments in the event of large-scale damage.

4)

Matters related to measures for maintaining the necessary water level in interim
storage tanks of spent fuel and for preventing severe damage to fuel assemblies
in the event of large-scale damage.

5)

Matters related to measures for reducing the release of radioactive substancesin the event of large-scale damage.

Regularly evaluate each measure mentioned above and take necessary measures in
response to the evaluation results.

Review Standard (NRA Regulatory Guides)
Regarding the licensees’ technical competence needed to perform the actions for preventionof a severe accident and its escalation, the new review standards for commercial power
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reactor licensees’ technical capability needed to perform the actions for prevention of a severe
accident and its escalation have been established. The review standards have asked thelicensees in response to the following (1) and (2).

(1) Easy changeover
1.0 General
1)

Severe accident coping facilities
1]

Switchover Readiness
Licensee's engagement shall demonstrate that application switchover procedures
shall have been developed for the non-severe accident dedicated systems to be
used to manage a severe accident.

(2) Specific requirements
1.1 Procedures, etc. to bring the power reactor sub-critical without SCRAM or the emergency
shutdown
Procedures to bring the reactor sub-critical and to maintain the integrity of the reactor
coolant pressure boundary and the containment vessel shall be developed assuming that
SCRAM or the emergency shutdown might not function as designed under the anticipatedtransient conditions or even after a SCRAM failure to prevent severe core damage.
1)

The assumption of "SCRAM or the emergency shutdown might not function as
designed" represents the postulated situation that the change of reactor parameterssuggests a failure of the emergency shutdown.

2)

Those procedures shall be as follows or bring equal or better effects than following
procedures do.
1]

BWR/PWR commona)To manually shutdown the reactor in case SCRAM or the emergency shutdown
might not function as designed.

2]

BWR

a)

To manually stop the reactor coolant recirculation pumps to control reactor core
reactivity when they do not automatically stop in case SCRAM might not function
as designedb)

To pre-establish the actuation criteria of Standby Liquid Control System (SLCS)
having sufficient reactivity control capacityc)

To actuate SLCS if unstable core power oscillation is detected in case SCRAM might
not function as designed

3]

PWR

a)

To manually actuate Auxiliary Feedwater (AFW) pumps to reduce reactor power if
the AFW pumps do not automatically start or manually trip the main turbine if it
does not automatically stop in case the emergency shutdown might not function as
designedb)

To manually inject a sufficient amount of boric-acid solution into the reactor byusing the chemical volume control system or emergency core cooling system incase the emergency shutdown might not function as designed

1.2 Procedures, etc. to cool the reactor core at high pressure
Procedures to cool the reactor core at high pressure shall be developed to prevent a severe
core damage assuming that any core cooling functions of the Design Base Accident (DBA)
facilities are lost.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

1)Those procedures shall be as follows or bring equal or better effects than following
procedures do.
1]

The measures listed below or better shall be implemented to enable Reactor Core
Isolation Cooling system (RCIC) or Isolation Condenser, those which are dedicated to
BWRs, or the turbine-driven AFW pumps, which is dedicated to PWRs, assuming aloss of total AC power supply and a loss of stationary DC power supply (hereinafterreferred to as “station blackout"). Hereinafter RCIC, IC and the turbine-driven AFW
pumps are collectively called RCIC, etc.
a) Portable SA equipmenti) To prepare portable SA equipment (portable batteries or nitrogen gas
cylinders) as well as its operation procedures, etc. to control the local valves
for actuation and continuous operation of RCIC, etc. for sufficient period until
the reactor depressurization is completed and the low pressure core coolingsystems are ready to operate.
b) Local actionsi) To prepare local action procedures, etc. to manually control the local valves for
actuation and continuous operation of RCIC, etc. for sufficient period until thereactor depressurization is completed and the low pressure core coolingsystems are ready to operate.
c) Monitoring and controli) To prepare procedures, measurement devices, equipment, etc. to project areactor water level (for BWRs and PWRs) and Steam Generator (SG) water level(for PWRs)ii) To prepare procedures, sensing devices and equipment, etc. to grasp theoperating conditions of equipment important to safety, such as RCIC, etc.
iii) To prepare procedures, equipment, etc. to control the reactor water level or SG
water level2]

Restorationa) Reactor coolant inventory shall be made up (allowing coolant circulation) at highpressure. By supplying power the core cooling equipment shall be actuated andcontinuously operated for sufficient period (for BWRs).
b) By supplying power to the motor-driven AFW pumps, they shall be actuated andcontinuously operated for sufficient period (for PWRs).

3]

Suppression of progress of a severe accident, etc.
a) To prepare procedures, etc. to inject water into the reactor core through SLCS or
the Control Rod Drive Mechanisms (CRDs), etc. in order to suppress progress ofa severe accident, etc. (for BWRs)

1.3 Procedures, etc. to de-pressurize the reactor coolant pressure boundaries
Procedures to de-pressurize the reactor to prevent a severe core damage and a containment
vessel failure shall be developed assuming that any reactor de-pressurization functions of
the DBA facilities are lost under the high pressure reactor condition.
1)

Those procedures shall be as follows or bring equal or better effects than following
procedures do.
1]

Portable SA coping equipmenta) To prepare de-pressurization procedures, etc. to actuate reactor vessel depressurization valves (safety relief valves for BWRs and main steam pressure

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

relief valves or pressurizer pressure relief valves for PWRs) assuming a loss ofstationary DC power supply.
b) To prepare portable compressors or nitrogen gas cylinders to actuate pneumatic
de-pressurization valves if they are used for de-pressurization of reactor coolant
pressure boundaries.
c) To clearly specify the environmental conditions under which the depressurization valves are operable
2]

Restorationa) To prepare restoration procedures, etc. to utilize the alternative power supply
systems for actuation of the de-pressurization valves assuming a loss ofstationary DC power supply.
3] Steam Generator Tube Rupture (SGTR)a) To isolate the damaged SG in the event of SGTR. To prepare procedures, etc. toactuate the pressurizer pressure relief valves assuming an isolation failure of
the damaged SG by SGTR (For PWRs).

4]

Interface-System LOCA (ISLOCA)a) To isolate the damaged section of the reactor coolant pressure boundaries in theevent of ISLOCA. To prepare procedures, etc. to actuate above mentioned depressurization valves assuming an isolation failure of the damaged section of
the reactor coolant pressure boundaries by ISLOCA.

1.4 Procedures, etc. to cool the reactor core at low pressure
Procedures to cool the reactor core at low pressure shall be developed to prevent a severe
core damage and a containment vessel failure assuming that any core cooling functions of
the DBA facilities are lost.
1)

Those procedures shall be as follows or bring equal or better effects than following
procedures do.
1]

Core cooling at a low pressurea) To prepare procedures, etc. to transport, connect and operate the portable SA
coping equipment.

2]

Restorationa) By connecting the alternative AC power supply system to the DBA facilities, theyshall be actuated and continuously operated for sufficient period.

1.5 Procedures, etc. to transport heat to the Ultimate Heat Sink (UHS)
Procedures to transfer heat to UHS to prevent a severe core damage and a containment
vessel shall be developed assuming a loss of UHS system function of the DBA facilities.
1)

Those procedures shall be as follows or bring equal or better effects than following
procedures do.
1]

Prevention of core damagea) Assuming a loss of UHS due to a loss of the sea water intake function at the site,
on-site alternative heat exchanger trucks shall be connectable to the heattransfer systems and operable as alternative UHS within the time allowed by the
suppression pool that could work as a heat sink of core cooling for a while as for
BWRs. In addition, loss of all the residual heat removal systems (RHRs) shall betaken into account.
As for PWRs, heat transfer to alternative UHS shall be established through thesecondary side of the core cooling system by means of the turbine-driven AFW
pumps and main steam relief valves.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

1.6 Procedures, etc. to cool the Primary Containment Vessel (PCV)
1.

Procedures to reduce the containment vessel temperature and pressure shall be
developed to prevent a severe core damage assuming that any containment cooling
functions of the DBA facilities are lost.

2.

Procedures to reduce the containment vessel temperature, pressure and radioactivity
shall be developed to prevent a containment vessel failure assuming an occurrence of asevere core damage.
1)

Those procedures shall be as follows or bring equal or better effects than following
procedures do.
1]

Prevention of severe core damagea) To prepare procedure, etc. needed to reduce the internal pressure andtemperature of the PCV to prevent severe core damage, using the alternative
water injection equipment for the containment spray assuming that any
containment cooling functions of the DBA facilities are lost.

2]

Prevention of PCV damagea) To prepare procedure, etc. needed to reduce the pressure, temperature andconcentration of radioactive material inside the PCV using the alternative water
injection facility for the containment spray to prevent PCV damage in the eventof serious core damage

1.7 Procedures, etc. to prevent containment overpressure failure
Procedures to reduce the containment vessel temperature and pressure shall be developed
to prevent a containment vessel failure assuming an occurrence of a severe core damage.
1)

Those procedures shall be as follows or bring equal or better effects than following
procedures do.
1]

Prevention of containment overpressure failurea) To prepare procedure, etc. needed to reduce the pressure and temperatureinside the PCV using the containment pressure relief device or the containment
coolant recirculation unit assuming an occurrence of a severe core damage.

2]

Prevention of adverse effectsa) To prepare procedure, etc. as necessary, for preventing PCV damage due tonegative pressure using the PCV relief device

3]

Local manual manipulation, etc.
a) Isolation valves of the PCV pressure relief device shall be manually manipulated
without difficulty.
b) Radiation protection measures such as radiation shielding and distance shall beavailable for local manual manipulation of the isolation valves of the PCV
pressure relief device even when the core has been seriously damaged.
c) Manipulation equipment for the isolation valves shall be available near the valve
installation in anticipation of loss of driving force for the valves.

4]

Radiation protection at restoration worka) Radiation protection measures such as radiation shielding shall be taken at
restoration work for the filters, etc. with high dose after their use in thecontainment pressure relief device.

1.8 Procedures, etc. to cool the molten core fallen on the PCV bottom
Procedures to cool the molten core fallen on the PCV bottom shall be developed to preventa containment vessel failure assuming an occurrence of a severe core damage.

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1)Those procedures shall be as follows or bring equal or better effects than following
procedures do. It is noted that molten core cooling aims at suppressing the MoltenCore-Concrete-Interaction (MCCI) and retaining the molten core not to interact withthe containment vessel boundary.
1]

Molten core cooling fallen on the bottom of the PCVa) To prepare procedure, etc. needed to prevent PCV damage using the equipment
to inject water to the containment bottom.

2]

Delaying and prevention of molten core falling toward the bottom of the PCVa) To prepare procedure, etc. needed to delay or prevent molten core falling fromthe Reactor Pressure Vessel (RPV) to the bottom of the PCV by means of water
injection, etc. into RPV.

1.9 Procedures, etc. to prevent PCV failure due to a hydrogen explosion inside the PCVProcedures to prevent a PCV failure due to a hydrogen explosion inside the PCV (hereinafterreferred to as hydrogen explosion) shall be developed assuming an occurrence of a severe
core damage.
1)

Those procedures shall be as follows or bring equal or better effects than following
procedures do.
1]BWRa) To prepare procedure, etc. needed to prevent hydrogen explosion by
maintaining the PCV inert

2]

PWR (as needed)a) To prepare procedure, etc. needed to prevent hydrogen explosion by using theequipment to control hydrogen concentration in the PCV

3]

Common to BWR and PWRa) AC or DC power shall be available from the alternative AC power supply system
to the equipment to prevent hydrogen explosion damage if it would need powerat the time of use.
b) To prepare procedure, etc. needed to prevent hydrogen explosion caused byhydrogen and oxygen generation through high-temperature water-zirconium
reaction and water radiolysis assuming an occurrence of a severe core damage.

1.10 Procedures, etc. to prevent hydrogen explosion damage to the reactor buildings
Procedures to prevent hydrogen explosion damage to the reactor buildings including
buildings retaining gaseous radioactive materials leaked from the PCV shall be developed
assuming an occurrence of a severe core damage.
1)

Those procedures shall be as follows or bring equal or better effects than following
procedures do.
a) To prepare procedures, etc. to prevent hydrogen explosion damage by usinghydrogen concentration control equipment or hydrogen discharge equipment.
b) AC or DC power shall be available from the alternative AC power supply system
to the equipment to prevent hydrogen damage if it would need power at thetime of use.

1.11 Procedures, etc. to remove heat from the spent fuel storages
1.

78

Procedures to remove heat from, provide radiation shielding against and prevent
criticality of nuclear fuels and spent fuels in the spent fuel storages (hereinafter referred
to as stored fuels) shall be developed assuming that any cooling and injection functions
for the spent fuel storages are lost and that water level of the storages decreases due towater leakage and so forth.
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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

2.

Procedures to mitigate damage progression of the stored fuels and prevent criticality inthe storages shall be developed assuming that water level of the storages extremely
decreases due to large water leakage and so forth.
1)"Water level of the storage decreases" mentioned in 1. is the result of Postulated
accidents 1 and 2, which are specified in "The Regulatory Guide of the NRA Ordinanceon Standards for the Location, Structure, and Equipment of Commercial Power
Reactors."
Postulated accident 1: An accident in which the water temperature within a spent fuelstorage pool rises due to the loss of cooling function or water injection function of the
spent fuel storage pool and the water level lowers due to evaporation.
Postulated accident 2: An accident in which the small loss of water due to the siphonicphenomenon lowers the water level of the spent fuel storage pool.

2)

The procedures described in 1. shall be as follows or bring equal or better effects thanfollowing procedures do.
a) To prepare procedures, etc. needed to remove heat from, provide radiation
shielding against and prevent criticality of the stored fuels by using thealternative water injection equipment in the event of Postulated accident 1 or 2.

3)

The procedures described in 2. shall be as follows or bring equal or better effects thanfollowing procedures do.
a) To prepare procedures, etc. needed to mitigate damage progression of the stored
fuels and to prevent criticality in the storage by using the spray system in casethat water level of the storage should not be sufficiently maintained.
b) To prepare procedures, etc. needed to reduce radioactive materials release to
the environment as much as possible in case that the stored fuels should bedamaged.

4)

As a part of the procedures described in 1. and 2., spent fuel storage monitoring
systems shall be as follows.
a) The spent fuel storage monitoring systems shall cover all the possible ranges ofwater level of the storage, temperature of the fuel storage coolant and air dose
rate in the storage during a severe accident.

Implementation
These matters have been specified in the licensees’ operational safety programs and have been
followed by licensee (Article 43-3-24 of the Commercial Reactors Ordinance, Article 92 of theCommercial Reactor Establishment Permit Ordinance)

2. Other Procedures and Guidelines (These are not to support directly the implementation of
mitigation strategy, but are to manage the other factors of events or emergency response)

Requirements (NRA Ordinances)
In the Commercial Reactors Ordinance amended based the lessons learned from the accidentof Fukushima Daiichi NPS, the NRA has decided to require the licensees in response to thefollowing (1) and (2) as measures other than those for mitigating the consequences of largescale damage and a severe accident.

(1) To take actions listed in the following as a system to perform the activities for safety
management of nuclear power reactor facilities in the event of a severe accident, etc. (Article85.)

6. Develop a system for carrying out other necessary activities for maintaining the integrityof nuclear power reactor facilities in the event of severe accidents.

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7. Regularly evaluate each measure mentioned above and take necessary measures in
response to the evaluation results.

(2) The actions listed in the following are needed as preparation of a system to perform theactivities for safety management of nuclear power reactor facilities in the event of largescale damage. (Development of a system to respond to extensive damage (Article 86)

6. Develop a system for carrying out other necessary activities for maintaining the integrityof nuclear power reactor facilities in the event of large-scale damage.
7. Regularly evaluate each measure mentioned above and take necessary measures in
response to the evaluation results.

Review Standard (NRA Regulatory Guides)
Regarding the licensees’ technical competence necessary to perform the actions required forprevention of a severe accident and its escalation, in the review standards related to theamended NRA Ordinance on Technical Capability for Commercial Power Reactor Facilities forcommercial power reactor licensees’ technical competence, the NRA has also decided to require
the licensees in response to the following (1) to (3) as measures other than those for mitigating
the consequences of large-scale damage and a severe accident.

(1) Restoration (requirements for recovery work)
1.0 General
2) Restoration (requirements for recovery work)
1] Spares and equipment needed for replacement work
Licensee shall engage that spares as well as equipment needed for replacement work
including construction equipment and lighting shall be secured for the important safety
facilities.
2] Storages
Licensee shall engage that storage facilities shall be secured to store the abovementioned spares and equipment taking account of extreme external event conditions
and geographical divergence.
3] Accessibility
Licensee shall engage that access routes shall be secured for the restoration work.
(2) Preparation of procedures
1.0 General
4) Procedures, training and organizational structure
Licensee's engagement shall demonstrate following three requirements for the licensee
to cope with a severe accident in an appropriate flexible manner.
1] Procedures shall be developeda) To organize types of needed information, their collection methods and criteria in orderto obtain the conditions of the power reactor facilities and to make a reasonable
judgment on measures to be performed against a severe accident, etc. under a limited
time, assuming a loss of all AC power supply systems and normal DC power supply
systems, multiple failures of the components or instrumentation of safety systems, or
simultaneously damaged multiple unitsb) To clarify beforehand the criteria of the most urgent and crucial actions etc. in orderto prevent serious core damage and primary containment vessel damage

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTc) To have the policy shown appropriately, giving due priority to nuclear safety rather
than asset protection (equipment, etc.)d) To appropriately establish procedures for licensees and supporting organizations toperform specific measures against a severe accident, etc. depending on the developmentof the accident. And, to clarify the procedures’ structures when the procedures can bedivided into several types depending on the development of the accident and to clarify
the transfer criteria between each proceduree) To specify the measurable parameters in the procedures, such as the water level,pressure and temperature, etc., to be verified as the criteria for the implementation of
specific measures against a severe accident, etc. Moreover, to organize the parameter
behavior prediction, items to be evaluated for their impact, parameters to be monitored,
etc. in the procedures during the implementation of the measures against a severe
accident, etc.
f) To prepare procedures to be able to perform proactive response, etc. (for example,
reactor shutdown and cooling operation in the event of a large tsunami alert) at the timeof confirming a precursory event.
g) To have actions listed in 1) to 3) in the following established regarding protection ofoperators in the reactor control room and in the emergency control room in the event of
toxic gas generation, personnel required to address a severe accident, etc. in theemergency response facility and personnel who perform especially important actions
for coping with a severe accident, etc. (hereinafter referred to as the "operation andresponse personnel") (the actions are the connection of portable equipment foraddressing a severe accident, etc. [limited to equipment to supply water or power fromthe outside of the reactor building] provided outdoors to permanent equipment)–

To prepare procedures and a system for keeping the toxic gas concentration that theoperation and response personnel are inhaling below the criteria for protection fromtoxic gas–

To perform the operational measures for deployment and wearing of protective
equipment to the personnel to perform initial response among operators in thereactor control room and in the emergency control room and personnel to give
instructions required to cope with a severe accident, etc. in the emergency response
facility in order to respond to an unexpected generation of toxic gas–

To inform the operators and accident responders about the generation of toxic gas
from operators in the reactor control room and the emergency control room using
the communication system(3) Specific requirements
1.12 Procedures, etc. to suppress off-site dispersion of radioactive materials
Procedures to suppress off-site dispersion of radioactive materials shall be developed
assuming an occurrence of a severe core damage following a PCV failure or an occurrenceof a severe spent fuel damage in the spent fuel storage.
1)

Those procedures shall be as follows or bring equal or better effects than following
procedures do.
a) To prepare procedures, etc. needed to suppress off-site dispersion by using water
spray facilities at site.
b) To prepare procedures, etc. needed to suppress radioactive material dispersion tothe ocean.

1.13 Procedures, etc. to supply large amount of water enough to stabilize a severe accident, etc.
Procedures to secure and supply large amount of water enough to stabilize a severe
accident, etc. separately from water source needed for DBA stabilization shall be developed.
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1)Those procedures shall be as follows or bring equal or better effects than following
procedures do.
a) To prepare procedures, etc. to supply large amount of water enough to stabilize apostulated severe accident, etc.
b) To secure two or more alternative fresh water sources such as water pools, dams
and water reservoirsc) To make use of the sea as a fresh water sourced) To secure water transfer routes from each water sourcee) To prepare hoses and pumps to transfer water from alternative water sourcesf) To prepare procedures, etc. to switch to another water source not to interrupt watersupply1.14 Procedures, etc. to secure power sources
Procedures to secure power sources needed to prevent a severe core damage, a PCV failure,a severe spent fuel damage in the spent fuel storages and a severe fuel damage in the RPV
in the outage shall be developed assuming an occurrence of a severe accident due to thestation blackout.
1)

Those procedures shall be as follows or bring equal or better effects than following
procedures do.
1]

To secure electric power required to prevent severe core damage, etc.
a) To prepare procedures, etc. needed to secure electric power supplied by using
alternative power supply source.
b) Portable, alternative AC-power supply systems shall be connectable to the reactor
unit and available with adequate time allowance within 24 hours, for which the inhouse DC power supply system is able to supply electric power.
c) At a multi-unit site, electric power supply systems shall be inter-connectable
among the units. Spare power cables, etc. shall be prepared in case the laid cables,
etc. should not be usable at the time of use.
d) In-house electric facilities (motor control center, power center and metal-clad
switchgear) shall not lose their functions due to a common cause, and at least one
train of them shall maintain its functionability and accessibility.

1.16 Procedures, etc. to maintain the Main Control Room (MCR) habitability
Procedures to maintain the MCR habitability shall be developed to secure operators'
occupancy in the MCR assuming an occurrence of a severe accident.
1)Those procedures shall be as follows (implementation of radiation shielding andventilation system in the MCR, accident management such as use of gas masks andoxygen tanks, etc.) or bring equal or better effects than following procedures do.
a) To prepare procedures, etc. needed to maintain the MCR habitability byimplementation of radiation shielding, etc.
b) To prepare procedures, equipment, etc. for the alternative AC-power system toconnect and supply power to the MCR ventilation system, lighting and so forth.

Implementation
These matters have been specified in the licensees’ operational safety programs and have been
followed by the licensee. (Article 43-3-24 of the Commercial Reactors Ordinance, Article 92 of
the Commercial Reactor Establishment Permit Ordinance)

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

3. Staffing

Requirements (NRA Ordinances)
The NRA decided to require licensees to respond to the following (1) and (2) regarding thestaffing during large-scale damage and a severe accident, in the amended Commercial
Reactors Ordinance based on the lessons learned from the accident of the Fukushima Daiichi
Nuclear Power Station.

(1) To take the actions listed in the following for staffing of the system to perform the activities

for safety management for the power reactor facilities in the event of a severe accident, etc.
(Article 85).
2. Deploy personnel necessary for maintaining the integrity of nuclear power reactor
facilities in the event of severe accidents (hereinafter called “emergency personnel”).
7. Regularly evaluate each measure mentioned above and take necessary measures in
response to the evaluation results.

(2) To take the measures listed in the following for staffing of the system which performs theactivities for safety management of the nuclear power reactor facilities in the event of largescale damage (Article 86).

2. Deploy personnel necessary for maintaining the integrity of nuclear power reactor
facilities in the event of large-scale damage.
7. Regularly evaluate each measure mentioned above and take necessary measures in
response to the evaluation results.

Implementation
For the adequacy of the staffing mentioned above, the Commercial Reactor Establishment
Permit Ordinance newly established requires appropriate actions for each event (Article 37, etc.),
and the adequacy is verified by the license review.
For staffing of the Nuclear Regulation Agency, it was decided in March 2014 to dissolve theJapan Nuclear Energy Safety Organization, which was an external supporting organization, andto move work for the following (1) and (2) of which the Organization had been in charge to theTechnical Platform Group newly established in the NRA.

(1) Matters regarding technical studies and research among the regulation of the fabricating

business, storage business, reprocessing business, waste disposal business related tonuclear energy and nuclear reactors and other work for ensuring the safety of thesebusinesses(2) Matters regarding technical studies and research among the regulation concerning the useof nuclear source materials and nuclear fuel materials and other work for ensuring thesafety of that use

4. Organizational Structure, Communication, Authority for Making Decisions and Safety
CultureRequirements (NRA Ordinances)
The NRA decided to require the licensees to respond to the following (1) and (2) as theorganizational system, etc. during large-scale damage and a severe accident, in theCommercial Reactors Ordinance amended based on the lessons learned from the accident of
the Fukushima Daiichi NPS.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST(1) To take the actions listed in the following regarding organization, etc. of the system, etc. toperform the activities for safety management of the nuclear power reactor facilities in theevent of a severe accident, etc. (Article 85).

6. Develop a system for carrying out other necessary activities for maintaining the integrityof nuclear power reactor facilities in the event of severe accidents.
7. Regularly evaluate each measure mentioned above and take necessary measures in
response to the evaluation results.

(2) To take the actions listed in the following regarding organization, etc. of the system, etc. toperform the activities for safety management of the nuclear power reactor facilities in theevent of large-scale damage (Article 86).

6. Develop a system for carrying out other necessary activities for maintaining the integrityof nuclear power reactor facilities in the event of large-scale damage.
7. Regularly evaluate each measure mentioned above and take necessary measures in
response to the evaluation results.

Review Standard (NRA Regulatory Guides)
Regarding the licensees’ technical competence necessary to perform the actions required forprevention of a severe accident and its escalation, in the review standards related to theamended NRA Ordinance on Technical Capability for Commercial Power Reactor Facilities forcommercial power reactor licensees’ technical competence, the NRA has also decided to require
the licensees in response to the following (1) and (2) as the organizational system, etc. during
large-scale damage and a severe accident.

(1) To have prepared needed system appropriately to be able to flexibly and adequately copewith a severe accident, etc.

1.0 General
4) Procedures, training and organizational structure
Licensee's engagement shall demonstrate following three requirements for the licensee tocope with a severe accident in an appropriate flexible manner.
3] Organizational structure shall be established aiming for following requirements:a) By allocating roles and responsible managers of the SA coping organization and its
supporting organizations respectively, the organizational structure shall be able toperform the effective measures against a severe accident.
b) The SA coping organization shall be composed of licensee's operators and so forth.
c) The SA coping organization shall be able to cope with simultaneous severe accident
occurrence at all the units at the site.
d) The supporting organizations shall include technical support organizations thatwould give technical advices to the SA coping organization and operational support
organizations that would create an environment in which the SA coping
organization could concentrate the measure against a severe accident.
e) The SA coping organization and its supporting organizations shall be established in
the situation where the measures against a severe accident, etc. are needed.
Moreover, smooth call-out system shall be developed and improved by periodicallyconducting communication exercise based on the communication systempredetermined so that the system could work even during nights and holidays.
f) Functions of the SA coping organization and the supporting organizations shall beclearly defined, respectively. Each team of those organizations shall be definitively
given its function. Responsible managers shall be allocated in the teams,
respectively.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTg) The chain of command shall be clarified in licensee's organization. The order ofacting commanders shall be pre-determined for an absence of the commander.
h) Facilities and equipment needed for the above-mentioned organizational structure
shall be well-prepared so that it could effectively perform its activities.
i) The supporting organizations shall prepare a communication system to notice andprovide the condition of the reactor units and the implementation status of themeasures to on- and off-site organizations.
j) A supporting organizational structure that utilizes the off-site supports shall beestablished.
k) Another organizational structure shall be established that could consider
appropriate responses in preparation for the necessity for mid- and-long-term
response to a severe accident, etc.

(2) To have the policy shown appropriately, giving due priority to nuclear safety rather thanasset protection (equipment, etc.) when preparing procedures

4) Procedures, training and organizational structure
Licensee's engagement shall demonstrate following three requirements for the licensee tocope with a severe accident in an appropriate flexible manner.
1] Procedures shall be developedc) To have the policy shown appropriately, giving due priority to nuclear safety rather
than asset protection (equipment, etc.)

Implementation
These matters have been specified in the licensees’ operational safety programs and followedby licensee. (Article 43-3-24 of the Commercial Reactors Ordinance, Article 92 of the Commercial
Reactor Establishment Permit Ordinance).

Requirements (Reactor Regulation Act)As a nuclear emergency response, the following (1) to (4) are specified in the amended Nuclear
Emergency Act.

(1) The government is responsible for taking appropriate actions for nuclear disasterprevention (Paragraph 2 of Article 4).

(2) When recognizing an occurrence of a nuclear emergency, the NRA must report the needed
information on the situation immediately to the Prime Minister and submit the proposed
public notice and directions (Article 15).

(3) The Prime Minister establishes the Nuclear Emergency Response Headquarters and the

Chairman of the NRA is to be deputy chief of the Nuclear Emergency Response Headquarters(Article 16 and Article 17).

(4) The directions of the general manager of the Nuclear Emergency Response Headquarters(Article 20) does not cover the matters regarding the contents of the judgment for ensuringsafety of nuclear facilities solely based on engineering and expert knowledge regarding
works belonging to the NRA.

Organizational Structure of Regulatory
As a system of the NRA, the NRA Ordinance for Organization of the NRA was newly established,
and as a system of the NRA in the event of a severe accident, etc., the divisions for dealing with

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

nuclear accidents or hazards to humans related to nuclear facilities, failures of nuclear facilities,
preparation of facilities and equipment, or materials and equipment for prevention of a disasterdue to a nuclear accident were established.
While the new regulatory standards have been put in place and the safety review as aprerequisite for resuming operations has been in progress, in order to further increase the safetylevel by review and enhancement of regulations concerning the inspection system for ensuringsafety during the operation phase and concerning radioisotopes, to consider the results of theIntegrated Regulatory Review Service (IRRS) of the IAEA, the Reactor Regulation Act was partiallyamended in April 2017, and the NRA has newly introduced a mechanism to enable the Authority
to always check the licensees’ safety-preserving activities and a system, etc. for conducting thechecks. The amendment concerned will be enforced in spring of 2020.

5. Personnel Qualification and Training

Requirements (NRA Ordinances)
The NRA decided to require the licensees to respond to the following (1) and (2) as the
personnel qualification and training to perform the required activities during large-scale
damage and a severe accident, in the amended Commercial Reactors Ordinance based on thelessons learned from the accident of the Fukushima Daiichi NPS.

(1) To take the actions listed in the following as the qualification and training of personnel toperform the required activities for safety management of the power reactor facilities in theevent of a severe accident, etc. (Article 85).

3. Regularly provide education and conduct training for emergency personnel at least oncea year.
7. Regularly evaluate each measure mentioned above and take necessary measures in
response to the evaluation results.

(2) To take the actions listed in the following as preparation of a system to perform the safety
management activities for power reactor facilities in the event of large-scale damage (Article86)

3. Regularly provide education and conduct training at least once a year for personnel
responsible for maintaining the integrity of nuclear power reactor facilities in the eventof large-scale damage.
7. Regularly evaluate each measure mentioned above and take necessary measures in
response to the evaluation results.

Review Standard (NRA Regulatory Guides)
Regarding the licensees’ technical competence necessary to perform the actions required forprevention of a severe accident and its escalation, in the review standards related to theamended NRA Ordinance on Technical Capability for Commercial Power Reactor Facilities forcommercial power reactor licensees’ technical competence, the NRA has also decided to require
the licensees in response to the following procedures for the qualification and training of
personnel to perform the required activities in the event of large-scale damage and a severe
accident.
1.0 General
4) Procedures, training and organizational structure
Licensee's engagement shall demonstrate following three requirements for the licensee tocope with a severe accident in an appropriate flexible manner.
2] Training shall be conducted86

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTA) To provide the education and training regarding the measures against a severe
accident, etc. so as to be able to improve knowledge on the behavior of the powerreactor facilities in the event of a severe accident, etc., based on the fact that themeasures against a severe accident, etc. needed a wide range of the measuresdepending on the situation of the power reactor facilities
B) To periodically provide education contributing to the improvement of a knowledge
base according to roles of personnel to perform measures against a severe accident,
etc. and to plan exercises, etc. to confirm the effectiveness comprehensively, etc. of
the implementation organization and its supporting organizationsC) To familiarize with the power reactor facilities and spare articles, etc. by obtaining
hands-on experience with part replacement, etc., performing maintenance andinspection activity on a routine basis
D) To conduct emergency response exercises assuming conditions under high radiation,night and adverse weather, etc.
E)

To prepare information and manuals on the equipment, and materials, etc. to be used
for an accident through routine maintenance activities, etc. in order to enable them
to be utilized immediately, and to perform exercises for responding to an accident
using them

Implementation
These matters have been specified in the licensees’ operational safety programs and followedby licensee. (Article 43-3-24 of the Commercial Reactors Ordinance, Article 92 of the Commercial
Reactor Establishment Permit Ordinance)

Requirements (Reactor Regulation Act)As a nuclear emergency response, the following (1) to (3) are specified in the amended Nuclear
Emergency Act.

(1) The Prime Minister seek the opinions of the NRA before the development of the program on
an emergency exercise (Article 13).

(2) The licensees report the results of their emergency exercises to the NRA and make asummary thereof available to the public (Paragraph 2 of Article 13).

(3) When recognizing that the results of the emergency exercise reported are not sufficientenough to prevent a nuclear disaster or its escalation at the site concerned, the NRA candirect the licensees concerned to improve the method of the emergency exercise and to takethe other needed actions after seeking the Prime Minister's opinion. Furthermore, the Basic
Disaster Management Plan specifies that the NRA evaluate the reports on the results of thelicensees’ emergency exercises. Based on these, the Nuclear Regulation Agency annuallysummarizes the evaluation of the reports on the emergency exercise results of the licensees
in the debriefing session of emergency drills to be held in public and reports the summaryof the reports and evaluation to the NRA.

Review Standard
And, the Guide for Emergency Preparedness and Response (hereafter “the EPR Guide”) describesthat emergency preparedness personnel are needed to become skilled at their work, always
assuming that various kinds of nuclear emergencies will occur and that it is important to
conduct education and training on the nuclear emergency measures in order to smoothly andeffectively conduct the nuclear emergency measure.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

6. Instrumentation, Control, Human System Interface, and Communication Equipment ofPower Stations

Requirements
The NRA decided to require the licensees to respond to the following (1) to (4) regarding
instrumentation, etc. to be used during large-scale damage and a severe accident in theCommercial Reactor Establishment Permit Ordinance and its interpretation.

(1) To provide the equipment to obtain the effective information to estimate the parameter

concerned when it has become difficult to measure the parameters to be monitored for
addressing a severe accident, etc., due to a failure of instrumentation (including those foran emergency) (Article 58.)

(2) To provide the equipment to communicate with the locations inside and outside of thepower reactor facilities concerned, needed for communication in the event of a severe
accident, etc. (Article 62.)

(3) To provide the equipment to communicate with the locations inside and outside of theonsite emergency response center concerned, needed for communication to be able to takeappropriate actions to cope with a severe accident, etc. even in the event of the severe
accident, etc. (Article 61.)

(4) To provide the communication equipment in the emergency control room for a specificsevere accident, etc. and to enable communication between the emergency control room of
this Specialized Safety Facility, the reactor control room and the emergency response facility(Article 42.)

◆ Review Standard

Regarding the licensees’ technical competence necessary to perform the actions required forprevention of a severe accident and its escalation, in the review standards related to theamended NRA Ordinance on Technical Capability for Commercial Power Reactor Facilities forcommercial power reactor licensees’ technical competence, the NRA has also decided to require
the licensees in response to the following (1) to (3) on the instrumentation to be used during
large-scale damage and a severe accident.

(1) Procedures, etc. for instrumentation during an accident
1.15 Procedures, etc. to secure instrumentation during a severe accident
Procedures to grasp effective parameters needed to monitor for Severe AccidentManagement shall be developed assuming that those parameters are not available due to
instrumentation failure including the safety-related caused by a severe accident.
1)Those procedures shall be as follows or bring equal or better effects than following
procedures do. It is noted that "parameters needed to monitor for Severe AccidentManagement" represent conditions of the power reactor facility that shall be grasped
by the licensee for the successful implementation of the core damage prevention
measures as well as the PCV failure prevention measures.
a)

The monitoring capability (the measurable highest temperatures, etc.) under the
beyond-design-basis conditions of the power reactor facility shall be
determined.

b)

The conditions of power reactor facilities when they exceed the monitoring
capability (the measurable highest temperatures, etc.) shall be estimated.
i) Temperature, pressure and water level in the reactor pressure vessel shall be
estimated.
ii) The amount of water injected into the RPV and the PCV shall be estimated.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTiii) As for parameters to be used for such condition estimation, the priority orderamong the parameters shall be defined according to their certainty.
c)

The PCV parameters such as temperature, pressure, water level, hydrogenconcentration, and the radiation dose rate shall be measured or monitored andrecorded necessary for Severe Accident Management.

d)Procedures, etc. (battery testers, unit conversion tables, etc.) needed to measureor monitor the important parameters during a loss of DC power shall be
prepared(2) Procedures, etc. for monitoring and measurement, etc.
1.17 Procedures, etc. for radioactive release monitoring and weather monitoring
1.

Procedures to monitor, measure and record radioactivity concentration released fromthe power reactor facility and radiation dose at the-site and in the surrounding areas(including the ocean) assuming an occurrence of a severe accident.

2.

Procedures to monitor, measure and record wind direction, wind velocity and theother weather conditions at the site assuming an occurrence of a severe accident.
1)Those procedures described in 1. shall be as follows or bring equal or better effects
than following procedures do.
a)

To prepare procedures, etc. needed for monitoring, measuring and recording theconcentration of radioactive material released from the power reactor facility
and the radiation dose at the site and in the surrounding areas (including theocean) by use of the monitoring facilities, etc.

b)

To enable for the alternative AC power supply system to supply power to thestationary monitoring facilities.

c)

As for off-site monitoring, to establish an appropriate collaboration structurewith other organizations.

2)

Background effect shall be reduced by avoiding radioactive contamination on themonitoring systems from the surrounding area after an accident(3) Procedures, etc. for communication
1.19 Procedures, etc. to communicate with on and off-sites organizations
Procedures to communicate with on and off-sites organizations necessary assuming an
occurrence of a severe accident.
1)Those procedures shall be as follows or bring equal or better effects than following
procedures do.
a)

The communication systems shall be powered by the alternative power supply
systems (including spare power supply systems and batteries).

b)

Procedures, etc. needed to share the important parameters including themeasured with the right person in the right place

Implementation
These matters have been specified in the licensees’ operational safety programs and followedby licensee. (Article 43-3-24 of the Commercial Reactors Ordinance, Article 92 of the Commercial
Reactor Establishment Permit Ordinance)

Requirements
The following (1) to (3) for preparation of equipment are specified in the EPR Guide.
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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST(1) The required physical resources shall be prepared to appropriately perform the nuclear
emergency measures.

(2) To be specific, the equipment and components to measure radiation quantity during

various phases, a system to analyze a wide range of radiation effects from various kindsof data and to contribute to the judgment of evacuation, etc., and infrastructure, etc. toshare promptly and precisely the information on the situation or actions among local
residents, organizations concerned and licensees shall be prepared since radiation
effects are not necessarily immediately apparent.

(3) In preparing this equipment, components, etc., the robustness against natural disasters,such as an earthquake, shall be taken into consideration.

7. Portable Components and Tools, Protection Suits, and Work Environment

Requirements
The NRA decided to require the licensees to respond to the following (1) to (4) regarding theportable components, etc. to be used during large-scale damage and a severe accident in theCommercial Reactor Establishment Permit Ordinance.
(1) The following matters for the portable equipment for coping with a severe accident, etc.
(Article 43.)ｏ For the equipment connected to the stationary equipment:

To have unified the standard of the connections and take other appropriate actions so thatthe portable equipment can be easily and infallibly connected to the stationary equipment
concerned and can be mutually used for two or more systems or power reactor facilities

To provide connections for portable equipment for addressing a severe accident, etc.
(limited to those to supply water or electric power from outside a reactor building) at
multiple different locations to prevent those connections from being unavailable due to acommon causeｏ To select installation locations where it is unlikely that the radiation dose will be high, toinstall shielding at the installation locations and to take other appropriate actions
ｏ To store the portable equipment for addressing a severe accident, etc. in a storage locationdifferent from that of stationary equipment, taking into consideration the impact due tolarge-scale damage, equipment layout and other conditions
ｏ To take appropriate actions to be able to secure roads and pathways in a factory, etc. totransport portable equipment for addressing a severe accident, etc. or to ascertain thedamage situation of other equipment in the event of an assumed severe accident, etc.
ｏ To take appropriate actions so that the required functions of the roads and pathways would
not be simultaneously compromised due to a common cause(2) To provide equipment needed to enable operators to remain in the reactor control room,
even in the event of serious core damage regarding the protective equipment and work
environment in the reactor control room (Article 59). The equipment shall meet thefollowing requirements in view of the Commercial Reactor Establishment Permit Ordinance.
ｏ To secure habitability, assuming an accident sequence that successfully recovers from an
accident with the severest consequences from the viewpoint of radiation exposure tooperators in the reactor control room among containment failure modes90

It can be taken into consideration that operators wear masks. However, in that case, asystem for the provision shall be prepared.



A system for replacement of personnel can be taken into consideration. However, in thatcase, a system for the provision shall be prepared.
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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTAs for the criteria, operators’ effective dose shall not exceed 100 mSv for 7 days.

ｏ Under the situation where the outside of the reactor control room has been contaminatedwith radioactive material, an area for monitoring and changing working clothes shall be
provided to prevent the contamination from being brought into the reactor control room.
(3) Regarding the emergency response facility, to have taken appropriate action for remaining
the personnel giving needed directions and to be able to accommodate the needed numberof personnel even in order to cope with a severe accident in the event of the severe accident,
etc. (Article 61.) These matters shall meet the following requirements in view of theCommercial Reactor Establishment Permit Ordinance.
ｏ To secure the habitability when the assumed amount of released radioactive material isequivalent to that of the accident of the Fukushima Daiichi NPS of the Tokyo Electric PowerCo.
The Accident responders shall not need to wear masks in the emergency response facility,
excluding the case that take special protective actions when a radioactive plume is passing.

A system for replacement of personnel, taking stable iodine and temporary equipment, etc.
can be taken into consideration. However, in that case, a system for the provision shall be
prepared.



As for the criteria, Accident responders’ effective dose shall not exceed 100 mSv for 7 days.

ｏ Under the situation where the outside of the emergency response facility has been
contaminated with radioactive material, an area for monitoring and changing working
clothes shall be provided to prevent the contamination from being brought into theemergency response facility.
ｏ The emergency response facility shall have the number of personnel needed at least to
perform the measures for reducing the dispersal of radioactive material to the outside of
the site due to primary containment vessel damage, etc.
(4) When the measures for the emergency control room to prevent containment damage using
the equipment for addressing the severe accident does not function effectively, to meet thefollowing requirements assuming that a severe accident is addressed in the emergency
control room, moving from the reactor control room, (Article 42.) These matters shall meetthe following requirements in view of the Commercial Reactor Establishment Permit
Ordinance.
ｏ To secure the habitability when the assumed amount of released radioactive material isequivalent to that of the accident of the Fukushima Daiichi NPS of the Tokyo Electric PowerCo.


It can be taken into consideration that operators wear masks. However, in that case, asystem for the provision shall be prepared.



A system for replacement of personnel can be taken into consideration. However, in thatcase, a system for the provision shall be prepared.



As for the criteria, operators’ effective dose shall not exceed 100 mSv for 7 days.

Review Standard
Regarding the licensees’ technical competence necessary to perform the actions required forprevention of a severe accident and its escalation, in the review standards related to theamended NRA Ordinance on Technical Capability for Commercial Power Reactor Facilities forcommercial power reactor licensees’ technical competence, the NRA has also decided to require
the licensees in response to the following for the portable components, etc. to be used during
large-scale damage and a severe accident.

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2.1 Mobile facilities
As for establishment of organizational structures to cope with the large-scale damage on the
power reactor facility caused by natural disaster or terrorism including intentional airplanecrash, procedures, etc. shall address following five activities. Moreover, the systems andmaterials and equipment for performing activities according to those procedures shall beappropriately prepared, or demonstrated by the licensee's preparation policy.
I)

Firefighting activity for a large-scale fire caused by the large-scale damage.

II) Mitigation activity for a severe core damage caused by the large-scale damage.
III) Mitigation activity for a PCV failure caused by the large-scale damage.
IV) Activity for securing water level of the spent fuel storages and mitigating a severe stored
fuel damage caused by the large-scale damage.
V) Suppression activity for a radioactive material release caused by the large-scale damage.

Implementation
These matters have been specified in the licensees’ operational safety programs and followedby licensee. (Article 43-3-24 of the Commercial Reactors Ordinance, Article 92 of the Commercial
Reactor Establishment Permit Ordinance)

8. Work Plan, Technical Support, and Emergency Response Facility

Requirements
The NRA decided to require the licensees to provide a facility with functions listed in thefollowing (1) to (43) (The Specialized Safety Facilities) as the emergency response facility forlarge-scale damage and a severe accident in the Commercial Reactor Establishment Permit
Ordinance (Article 42.)

(1) The functions to cope with a severe accident, etc. due to an intentional large airplanecrash to the reactor building and other terrorism shall not be compromised.

(2) The equipment for prevention of containment vessel damage shall be provided.
(3) The Specialized Safety Facilities shall must be able to be used until support from outside

the power reactor facilities can be received after an occurrence of an intentional large
airplane crash to the reactor building or other forms of terrorism.

The actual results of safety review of the Specialized Safety Facilities (Examination meetings
on the specialized safety facilities of Takahama Units 1 and 2 (3 and 4) of the Kansai ElectricPower Co., Inc., were held at 9 times in total) were flowing;
(1)

92

・

It was confirmed that the necessary separation distance (100 m or more, for example) was
ensured between the reactor auxiliary or other important buildings*1 and the Specialized
Safety Facilities to prevent a simultaneous failure of any of those buildings and theSpecialized Safety Facilities.

・It was confirmed that the Specialized Safety Facilities were accommodated in a robustbuilding to prevent damage by an intentional crash of a large airplane. Moreover, it was
confirmed that, for the assumable major and other accidents to be considered in thedesign, a crash of a large airplane, which is a severe event among various credible events,
was considered as a representative one. Moreover, it was also confirmed that the

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

following matters were performed appropriately according to the Specialized Safety
Facilities Review Guide*2 and the Aircraft Collision Impact Assessment Guide*3.
1.

Determination of characteristics of a large airplaneFollowing the Specialized Safety Facilities Review Guide, the model, entry path, entry
rate, and fuel capacity of the aircraft assumed to crash were confirmed.

2.

Determination of the collision point and the scope of the impact assessment of a large
airplane crash into the specific facilities *4



The way of thinking to use the physical impedance, including the mountain topography(bunker system), underground installation, and distributed arrangement, which areconsidered as effective measures to prevent a simultaneous or continuous failure due
to an intentional crash of a large airplane into the reactor’s auxiliary or other importantbuildings, was confirmed.

3.

Determination of the design policy based on the impact assessment of a large airplanecrash into the specialized safety facilitiesIt was confirmed that a large airplane crash does not impair the functions of theevaluation items (buildings, equipment, and other components).

*1 Primary containment facility and reactor auxiliary building, which corresponds to the"reactor building" of Article 42 of the Commercial Reactor Establishment Permit Ordinance*2 Review Guide for Responding Facilities for Specific Major and Other Accidents Related
to Commercial Power Reactors*3 Review Guide for the Aircraft Collision Impact Assessment Related to Commercial Power
Reactors*4 This means structural and functional evaluations for a large airplane crash specified in
the Aircraft Collision Impact Assessment Guide.
(2)
・Concerning the design policy related to the equipment provided with the required
functions to prevent a primary containment vessel failure, the equipment has thefunctions of the following 1) to 8) and the emergency control room (i.e. secondary
control room) is to be provided. The system was judged to conform to Item 2, Article
42.

1.

Depressurization-operation function of the reactor coolant pressure boundary(reactor-depressurization equipment)

2.

Cooling function of the molten core in the reactor (low-pressure water injection
equipment)

3.

Cooling function of the molten core fallen to the lower plenum of the primarycontainment vessel (water injection equipment to the primary containment vessel
lower plenum)

4.

Functions of cooling, depressurization, and radiological material reduction functionsin the primary containment vessel (water injection equipment for containment spray)

5.

Function to prevent an over-pressurization failure of the primary containment vessel(filter venting)6.

Function to prevent a failure of the primary containment vessel due to a hydrogen
explosion (hydrogen-concentration control device)

7.

Support function (power system, instrumentation, and communication equipment)

8.

Related functions of the abovementioned equipment (depressurization valve, piping,and other components)

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST(3)・

It was confirmed that the design of fuel and other materials to be stored in the Specialized
Safety Facilities are considered to be of sufficient quantity to maintain the functions of theSpecialized Safety Facilities (at least for 7 days) with reference to the Specialized Safety
Facilities Review Guide.

The emergency response facility is newly required to have the functions listed in the following(1) to (4) (Article 61.)

(1) To take appropriately the action such that the person giving needed directions to cope witha severe accident, etc. can remain there(2) To provide the appropriately equipment such that information needed can be obtained togive needed directions to cope with a severe accident, etc.

(3) To provide with the needed equipment to communicate with the locations forcommunication between inside and outside of the power reactor facility(4) To be able to accommodate the number of personnel needed to cope with a severe accident,
etc.

Review Standard
Regarding the licensees’ technical competence necessary to perform the actions required forprevention of a severe accident and its escalation, in the review standards related to theamended NRA Ordinance on Technical Capability for Commercial Power Reactor Facilities forlicensees’ technical competence, the NRA has also decided to require the licensees in responseto the following (1) to (2) for work plans during large-scale damage and a severe accident.
1.0 General3) Supports
Licensee shall engage that severe accident management activities shall be maintainedby pre-established means (equipment, spares, diesel fuel, etc.) on site for at least 7 days
after an occurrence of the accident.
Licensee shall engage that the external support plan shall be developed based on
consultation and agreement with organizations concerned.
Licensee shall engage that the external support by use of pre-established off-sitemeans (severe accident coping facilities, spares, diesel fuel, etc.) can be enjoyed within
6 days after an occurrence of the accident.
2.
Requirements for large-scale damage caused by natural disaster or terrorism
including intentional large airplane crash
2.2

Organizational structure to maintain Specialized Safety Facilities functions

Licensee's engagement shall demonstrate that organizational structure to maintain
Specialized Safety Facilities functions shall be established.
2)

The organizational structure shall be established to maintain the Specialized Safety
Facilities functions, which shall be served until the external supports are available (forexample, at least 7 days).

The actual results of safety review of the Specialized Safety Facilities (Examination meetings
on the specialized safety facilities of Takahama Units 1 and 2 (3 and 4) of the Kansai ElectricPower Co., Inc., were held at 9 times in total) were flowing;ｏ

94

Concerning the design policy related to the equipment provided with the required
functions to prevent a primary containment vessel failure, the equipment has the

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

functions of the following 1) to 8) and the emergency control room (i.e. secondary controlroom) is to be provided. The system was judged to conform to Item 2, Article 42.
ｏMoreover, the policy to prepare the system, procedure, and other matters, which are
related to the necessary operation to maintain the functions, was judged to conform to
the technical capability standard 2.2.
1)

Depressurization-operation function of the reactor coolant pressure boundary(reactor-depressurization equipment)

2)

Cooling function of the molten core in the reactor (low-pressure water injection
equipment)

3)

Cooling function of the molten core fallen to the lower plenum of the primarycontainment vessel (water injection equipment to the primary containment vessel
lower plenum)

4)

Functions of cooling, depressurization, and radiological material reduction functionsin the primary containment vessel (water injection equipment for containment spray)

5)

Function to prevent an over-pressurization failure of the primary containment vessel(filter venting)6)

Function to prevent a failure of the primary containment vessel due to a hydrogen
explosion (hydrogen-concentration control device)

7)

Support function (power system, instrumentation, and communication equipment)

8)

Related functions of the abovementioned equipment (depressurization valve, piping,and other components)

1.18 Procedures, etc. to maintain the Emergency Response Center (ERC) habitability
Assuming an occurrence of a severe accident, procedures to maintain the ERC habitability
shall be developed to secure personnel occupancy in the ERC that enables the personnel togive necessary instruction, communicate with on and off sites organizations and call for
emergency response teams who consists of personnel enough to cope with the accident.
1) Those procedures shall be as or bring equal or better effects than following proceduresdo.
a) To prepare procedures, etc. needed to maintain the ERC habitability byimplementation of radiation shielding, etc.
b) To enable the ERC to be powered from the alternative AC-power systems.
c) To supply equipment and devices (dosimeters and gas masks, etc.) for sufficientradiation controls to the ERC personneld) To prepare documents needed for the equipment and for the consideration of Severe
Accident Management.
e) To stock drinking water, food, etc. for ERC personnel for at least one week without
support from the outside

Implementation
These matters have been specified in the licensees’ operational safety programs and followedby licensee. (Article 43-3-24 of the Commercial Reactors Ordinance, Article 92 of the Commercial
Reactor Establishment Permit Ordinance)

Requirements (Reactor Regulation Act)As a nuclear emergency response, following (1) and (2) are specified in the amended Nuclear
Emergency Act.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST(1) The Prime Minister shall designate an “off-site center” to serve as a base for emergency

response measures and measures for restoration from nuclear emergency for each nuclear
site, and the Prime Minister shall seek the NRA’s opinions when designating it or changing
the designation. (Article 12.)(2) An off-site center is specified in the (EPR guide) as follows.


The off-site center is should be located in the area to consider PAZ and UPZ, to beprovided with required radiation protection measures, be able to coordinate closelywith local public organizations, etc. and to provide with ways and means to secure analternative facility and double-tracking of the communication channel and a systemfor prompt start-up of the off-site center for maintaining its functions even in the eventof a serious situation. Moreover, at the off-site center, it is should to control disasterrelated materials, to maintain communication equipment, etc. from normal times andto promote the close liaison and coordination by the periodical liaison meeting of
persons involved in emergency preparedness, including the Senior Specialists for
Nuclear Emergency Preparedness and emergency drills. When the government
designates an off-site center for establishment, it is should for the government todesignate the off-site center based on local circumstances, seeking the opinions of local
public organizations, etc.

In addition to the off-site center, licensees should designate beforehand their local
activity bases at appropriate locations in the vicinity of nuclear facilities, according to
the characteristics of those facilities, where materials, equipment, and personnel
needed for accident response can be relayed, and they should be able to use their local
activity bases, as needed.

9. Emergency Preparedness Plan / 10. Extended (Long Term) Response

Requirements
As an emergency response (including a long-term response), responses listed in the following(1) to (6) have been performed.

(1) The NRA is required to establish the EPR Guide about the expert and technical matters to

support scientific and objective judgment when licensees, the Government and local publicorganizations, etc. establish their plans for nuclear emergency preparedness and implement
them (Article 6-2 of the Nuclear Emergency Act.)(2) The basic plan for emergency preparedness established by the Government, regional plansfor emergency preparedness established by local public organizations and licensees’ plansfor emergency preparedness established by licensees have been in review based on the EPR
Guide.

(3) The EPR Guide classifies the emergency situation at the initial response phase into threeclassifications: the alert situation, the facility site emergency situation, and the generalemergency depending on facility conditions, to consider the concept of the framework ofprotective actions established by the IAEA, etc. The guide also clarifies the roles to be playedby the licensee, the government and local public organizations in each classification. As thecriteria for licensees to judge whether the situation corresponds to these emergency
situation classifications or not, licensees set up the Emergency Action Level (EAL) based on
conditions of equipment in each layer constituting defense-in-depth in nuclear facilities,
conditions of the radioactive material containment function, and the conditions of nuclear
facilities, such as an occurrence of an external event, etc. The operational intervention level(OIL) represented, in principle, by the measurable values, such as air dose rate andconcentration of radioactive material in environmental samples, is established as thecriteria to judge whether emergency protective actions are to be implemented based on
observable indicators.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST(4) As in the EPR Guide, it should be taken the focused measures (zone where such measures

are taken is called “Strategic Region for Nuclear Emergency Actions”) specific to a nuclear
emergency in order to efficiently perform the protective actions against radiation exposure
to residents in a short period of time, assuming an occurrence of an abnormal event
beforehand and appointing the zones where the effects can reach based on thecharacteristics, etc. of the facilities, and that rough standards for the Precautionary Action
Zone (PAZ) and the Urgent Protective Action Planning Zone (UPZ) have been established.

(5) It is required to prepare and amend the licensee emergency action plan for each nuclear site
to take the measures for prevention of a nuclear disaster, emergency response measures,
post-emergency measures and measures for restoration from the disaster at each nuclear
site (Article 7 of the Nuclear Emergency Act.)(6) The directions for the licensee, emergency action plan, require that matters regarding the

preparation of disaster prevention materials in addition to matters regarding the formationof an organization for nuclear emergency preparedness, duties of its manager (nuclear
emergency preparedness manager), substitutes and personnel, and the implementation of
education for personnel in the licensee emergency action plan, and make it mandatory toestablish the following matters regarding the preparation and operation of a base andmaterials for power reactor facilities, reprocessing facilities and test and research reactors(10 MW or more) facilities.


Matters regarding emergency response facility

Matters regarding nuclear site emergency support base

Matters regarding nuclear facility emergency response center

Matters regarding communication equipment for transferring information at anuclear siteMatters regarding the preparation of emergency power supplies, etc.



Matters regarding the preparation of emergency communication andteleconference system for information communication between the Prime
Minister’s official residence, the NRA and each base of licensees.

In addition, the Nuclear Emergency Act makes it mandatory for licensees to notify the NRAof preparation and modification of the licensee emergency action plan, appointment anddismissal of a nuclear emergency preparedness manager and a deputy manager, and changes
to disaster prevention materials.

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KOREAResponse to Phase 1 Information Request
provided by Korea Institute of Nuclear Safety

1. Korea Summary of Actions taken to improve mitigations capability following the
Fukushima Daiichi Accident
Due to an earthquake and tsunami beyond expectation, a severe accident occurred at multiple
units at the Fukushima nuclear site in Japan, causing severe damage to the nuclear site andadjacent infrastructure. Many lessons are learned from the nuclear accident with regard to
emergency response and post-accident management. Considering that situation, a safety
inspection led by the regulatory body was conducted to prepare a plan to improve domestic
emergency response and the emergency medical service system. The areas inspected were:•Emergency preparedness plan related to procedures and organization, including
Emergency Action Level (EAL),•

Emergency response facilities and equipment,•

System operating status for protecting residents in case of emergency,•

Emergency medical system,•

Exercises to test emergency response capabilities, and•Response system to simultaneous emergencies at multi-units on the same site.

As a result, it was verified that emergency response and the emergency medical system
based on existing design and accident concept are appropriate. However, action items to
respond to a natural disaster beyond the design basis and simultaneous emergencies at multiple
units were identified as follows:•

Securing additional thyroid blocking agent for protecting residents near a nuclear power
plant,•

Amending the radiological emergency plan to include such events as the simultaneously
issuing an emergency alert at multiple units,•

Securing additional equipment in preparation for an event where in the emergency is
prolonged,•

Expanding equipment of emergency medical treatment organizations,•

Reinforcing radiation emergency exercise,•Devising a means for securing necessary information in case of a prolonged loss ofelectrical power,•

Securing countermeasures for protecting maintenance workers,•

Improving emergency response facilities,•

Amending the information disclosure procedure in the event of a radiation emergency,

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST•

Evaluating protective measures for residents who live beyond the emergency plan area,
and•Reinforcing the performance of emergency alarm equipment.

The Licensee of Korea, KHNP (Korea Hydro & Nuclear Power), which is the operator of
nuclear power plants, the research reactor, the nuclear cycle facility operator, and KIRAMS(Korea Institute of Radiological and Medical Sciences) which is the emergency medical
institution, prepared and have implemented a detailed action plan with regard to emergency
response and medical service at the request of the regulatory body in May 2011.
•

Amending the radiological emergency plan to include such events as the simultaneous
declaring of an emergency at multiple units
The radiological emergency organizations were structured to cope with a radiologicalemergency at a single-unit. Now, the radiological emergency organizations are
restructured based on three scenarios: first, a radiological emergency at single unit,
second, simultaneous emergencies at two units on the same site, and third,
simultaneous emergencies at all units on the same site, and the revision of theradiological emergency plan to incorporate the plan for establishing a radiation
emergency organization based on three scenarios has been already completed in
December 2011.
In the revised radiological emergency plan, the magnitude of tsunami is added to thecriteria for declaring an emergency with respect to a natural disaster. In addition, therevised radiological emergency plan defines the target time for emergency response:issuing a radiation emergency alert within 15 minutes after detection, initiating radiation
emergency organizations within one hour after the declaration of a radiation emergency
and putting the emergency organizations into operation within two hours.

•

Securing additional equipment to prepare for a prolonged emergency
Before the Fukushima Daiichi Accident, pursuant to the radiological emergency plan, the
KHNP kept approximately 350 units of seven different types of radiation (radioactivity)
instruments including high-level beta-gamma dose rate meters, 8 600 pieces of radiation
production equipment including protective clothing, 166 000 tablets (130g) of thyroid
protection medicine. In response to a prolonged emergency like the nuclear accident inFukushima, the KHNP has additionally secured 440 units of radiation (radioactivity)
instruments and 20 000 radiation protection gears to increase inventory 200% of theprevious level.

•

Increasing the equipment of emergency medical treatment institutions
To effectively respond to a sudden increase in patients due to a radiological disaster,Seoul National University Hospital and 22 others designated for radiological emergency
medical service have been continuously provided with medical facilities, equipment andmedical products. As of now 740 000 tablets of thyroid protection medicine are secured.

•

Reinforcing radiation emergency exercise
Under the recommendation of the NSSC (Nuclear Safety and Security), the KHNP has
conducted an unannounced radiation emergency exercise at each nuclear power site
once a year. Unannounced means the personnel participating in the exercise must not
be advised in advance, of the exact date, time and scenario of the exercise. Therefore, it
is believed that the unannounced exercise contributes to strengthening emergency
response capabilities of radiological emergency staff. Furthermore, research was
conducted to develop exercise scenarios based on earthquake and tsunami. The newly
developed scenarios have already been applied in the unified emergency exercise•

Devising a means for securing necessary information in case of a prolonged loss ofelectrical power
The power supply to emergency response facilities as well as the main computer isessential for acquisition of key plant parameters in case of a prolonged loss of power.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTThe EDG (Emergency Diesel Generator) together with the UPS (Uninterruptible Power
Supply) is secured to prepare for the loss of power to emergency response facilities,
however the UPS alone is not sufficient in case of a long-term loss of power. To resolve
the issue, the licensee completed additional deployment of mobile power generating
equipment to ensure continued power supply to the main computer in 2015.
The Fukushima Daiichi Accident showed that when massive earthquake and tsunami cause
prolonged on- and off-site power outage, flooding and damages in facilities, Environmental
Radiation Monitoring System (ERMS) installed in on-site EPZ (Emergency Planning Zone) mightexperience unrecoverable damage. To prepare for such case, mobile environmental radiation
monitoring facility (seven instrumentation equipment and one operating server) was adopted
to ensure the environmental monitoring in case of emergency.
•

Improving emergency response facilities
A plan to improve the habitability and scale of emergency response facilities including
Technical Support Center (TSC) and Operation Support Center (OSC) and to prevent
inundation of emergency facilities due to a large tsunami is continuously in progress byimproving TSC and OSC.

•

Securing countermeasures for protecting emergency workers
The standard Procedure for Protecting Emergency Workers, which describes proceduresfor input of emergency workers for accident prevention and emergency measures, wasdeveloped in August 2011. This is a procedure that standardizes the decision andapproval of emergency work to avoid confusion of radiation protection during a radiation
emergency. It will enable emergency workers to perform emergency work promptly.
Since contract workers are also important in a radiological emergency, they aremandated to take the same training for radiation emergency preparedness as KHNP
employees do and to participate in the emergency preparedness exercise.

•Amending the information disclosure procedure in the event of a radiological emergency
With respect to improvement of the national radiation disaster management systemafter the nuclear accident in Fukushima, the operator had a discussion with the NSSC
and the KINS regarding dealing with the media. Based on that, the government manualfor crisis management and the operator's radiation emergency plan was revised to raise
the transparency and promptness of disclosing the information to be provided to themedia, the public and residents near nuclear plants by specifying the details of
information (list of information released real time, information on radiologicalcontamination, and the protection of residents).

•

Evaluating protective measures for residents who live beyond an emergency planningzone
Pursuant to the APPRE, the emergency planning zone for a nuclear installation can be
defined as an area within the radius of eight to 10 km from a nuclear installation. A
research to identify items to protect residents who live beyond an emergency planningzone based on lessons learned from the Fukushima Daiichi Accident was completed. In
this research, the dispersal pattern and distance of radioactive materials and theirimpact on residents beyond an emergency panning zone was able to be evaluated taking
into consideration environmental conditions around a nuclear power plant such as winddirection and speed to identify necessary measures to protect local residents.

•

Reinforcing the performance of emergency notifying system
The operator has established an emergency alerting system (Amplifier and Speaker) forthe local residents who live within the radius of 2 km from the outside boundary of a
nuclear power plant and with the expansion of EPZ, the radius of emergency alerting
system was also expanded to the maximum radius of 5 Km in December 2015. The
integrity of the system has been maintained via self-inspection and joint inspection
attended by the local and central governments. The joint inspection has been conductedto check the status of sound and the operation of the system on a quarterly basis. As aneed to improve the emergency notifying system rises after the nuclear accident in

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Fukushima, an emergency power source for alerting system and wirelesscommunications system were secured in preparation of power loss caused byearthquake and tsunami.
The KHNP identified the below action items additionally in consideration of lessons learned
from the Fukushima Daiichi Accident and prepared a detailed action plan.
•

Improving a cooperation system with relevant organizations
The KHNP strives to establish a close cooperation with relevant organizations, and basedon which, respond to an accident promptly and prevent the expansion of an accident incase of a radiation emergency or disaster. One example is the Agreement on Prompt
Response and Cooperation in Case of a Nuclear Emergency that KHNP and National
Emergency Management Agency (NEMA, currently fire-fighting division of Ministry of
Public Safety and Security) signed in September 2011. It deals with helicopter support in
the event of a radiological accident and an emergency medical airlift. According theagreement, in the event of a radiation disaster accident, NEMA (currently fire-fighting
division of Ministry of Public Safety and Security) will allow National 119 Rescue Services
to provide a helicopter for rescues, patient transfers, and transporting experts while the
KHNP provides nuclear facility experts and radiation protection equipment to NEMA
(currently fire-fighting division of Ministry of Public Safety and Security).
In addition, with the expansion and redefinition of EPZ, the role of local metropolitan
government has increased. Hence, Kori Headquarters (HQ) made an agreement with
relevant organizations in the city of Busan and its region over metropolitan based
cooperation agreement for nuclear safety and emergency preparedness related work on
August 12, 2015. Hanbit HQ signed the consultative agreement in the southwestern
metropolitan area with the city of Gwangju and regions of Jeonnam and Jeonbuk toprovide manpower, resource and technical support in case of radiation release accident.

•

Operating an assessment program for public protective actions
The APPRE requires the nuclear operator to assess the estimated dose to residents andtake protective measures in case of a radiation emergency. To this end, the KHNP has
developed and operated KHNP Radiological Emergency Dose Assessment Program (KREDAP). The reliability of the program has been secured through emergency
preparedness drills at a nuclear power plant.
In the past, real-time meteorological data was not considered to calculate the estimateddose to public in the system, which undermined data accuracy. Therefore, KHNP
developed Smart Radiological Emergency Dose Assessment Program (S-REDAP) thatenables real-time meteorological and environmental radiation data to assess the impact
on residents and has applied it to nuclear power plants. The system was configured bycomparing calculated estimates with environmental radiation monitoring data and thenevaluating the difference repeatedly to arrive at the most accurate expected exposure
dose.

The regulatory body has reinforced a radiological/radioactive environment monitoring
system across the country to ensure prompt and effective protective measures for residents,
and completed the revision of laws and systems to adopt the concepts of the precautionary
action zone (PAZ) and the urgent protective action planning zone (UPZ) instead of the EPZ.
•

Environment Monitoring
As part of post-Fukushima actions, KINS has also increased regional radioactive
monitoring station from 12 to 15, and Integrated Environmental Radiation Monitoring
Networks (IER-Net) from 71 to 134 so as to strengthen the capability for early detectionof radiation (radioactivity) abnormalcy following nuclear accidents at home and abroad.

•

Reforming EPZ
For more prompt and effective protection of public in case of radiological emergency, therevision of the radiological emergency planning zone was completed to divide theexisting single EPZ into the precautionary action zone (PAZ) and the urgent protective

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST

action planning zone (UPZ). Relevant laws were revised in 2014 and currently Radiation
emergency plan is in revising process to be in compliance with the expansion of EPZ to
20-30 km and subdivided EPZ.

2. Post-Fukushima Action
After the Fukushima Daiichi Accident on March 11, 2011, KHNP identified short- and long-term
action items for safety improvement to assure safety against natural disasters such as
earthquakes and tsunami, and severe accidents that exceed the design basis as is the case with
the Fukushima Daiichi Accident. KHNP enhanced its preventive and mitigatory capabilities
against the early stage of natural disasters by: 1) investigating and researching the maximum
potential earthquakes for nuclear sites and sea water levels; 2) improving seismic function of
nuclear installations; 3) installing waterproof doors and discharge pumps; and 4) enhancing
cooling sea water intake capability. KHNP also strengthened its safety functions and accident
management capabilities by: 1) improving reliability of electric power system, core cooling
function, and spent fuel pool cooling function; 2) securing cooling water sources, fire fighting
water sources, and integrity of containment building; 3) mitigating the release of effluent
radioactive material to the environment; and 4) building up capabilities to respond to fire,
management of severe accidents, and extensive damage. In addition, KHNP enhanced
emergency preparedness and radiation emergency medical system by 1) securing additional
inventory of potassium iodide tablets for residents in vicinity of nuclear power plants; 2)
procuring emergency equipment to prepare for a prolonged emergency; and 3) reinforcing
emergency notifying system.
After the Fukushima Daiichi Accident, the Korean government formed a safety inspection
team consisting of experts from relevant fields and from KINS and carried out a safety
inspection for domestic nuclear installations including operating nuclear power plants,
research reactors, nuclear fuel cycle facilities, and radiological emergency medical centers fromMarch 21 to April 30, 2011. The safety inspection was conducted for six areas: safety of structure
and components against earthquakes and tsunami; safety of electric power, cooling and fire
protection systems against flooding; emergency preparedness system; nuclear power plants inoperation for long period of time and new nuclear power plants; research reactors/nuclear fuelcycle facilities; and radiological emergency medical center.
As a result of the safety inspection, the inspection team identified a total of 50 action items
for safety improvement and required them to be implemented; 46 from KHNP, one from Korea
Institute of Radiological and Medical Sciences (KIRAMS) and three from Korea Atomic Energy
Research Institute. Together with the 10 additional items identified by KHNP from its selfassessment in February 2012, the inspection team finalized 60 action items for safety
improvement and has selected and reviewed items that need to be addressed by each year. For
each nuclear power plant unit, the regulatory body has received reports of minor changes orapproved operation change and also carried out technical review to verify safety of actions for
improvement suggested by the licensee. Periodic inspection and other field activities are also
being used as a way to confirm the adequacy of corrective measures for each nuclear power
plant unit. In addition, the result of each item’s corrective action is confirmed when the licensee
completes the corrective actions and its self-inspection process.



Major Post-Fukushima Actions
Immediate ResponseSpecial Safety Inspections on nuclear power plants: 50 Items (2011)
Independent Regulatory Body

Establishment of NSSC (2011)

Safety Review

Stress Test for Operating nuclear power plants (Wolsong unit 1 & Kori unit 1)

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Improvement of Emergency Preparedness
Extending EPZ: 8~10 km 20~30 km

Rulemaking of Severe Accident
Implementation of DEC

Implementation of 50 Action Items for Safety Enhancement50 Action Items (May 2011~)
Earthquake and SSCs integrity (5 items): Automatic Seismic Trip System, Seismic
Upgrade of Safe Shutdown & Maintenance System (0.2g 0.3g), etc.
Seismic/storm surge and SSCs integrity (4): Seawall extension for Kori Unit 1&2, Water
proof gate/door installation, etc.
Safety function security (11): Installment of emergency mobile generator and pumps,
rechargeable battery, etc.
Severe Accident Response (6): Installment of PAR, CFVS, external cooling water
injection loop, etc.
Emergency Response (11): Radiation protection of workers at/adjacent plant, etc.
Safety of Long-operated nuclear power plants, research facilities, and so onThree Additional Action Items (April 2014~)
Establishment of emergency response team, emergency response facility, etc.

Current Status of Implementations
42 Short to Mid-term Action Items out of 53 items have been implemented and the rest
11 Long-term Action Items will be accomplished referencing insights from the stress
test, etc. by 2020

As of the end of 2017, regarding 69 items on four nuclear power plant sites, the safety review
through Q&A process on 69 items including reports on minor changes, approval on operation
change, etc. is in progress and the review on 117 items regarding licensing were completed. The
status of safety review for each nuclear power plant site is shown as follows

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Figure. Status of Review on Post-Fukushima Items as of end of 2017

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3. Responses to Questionnaire on Post-Fukushima Actions to Improve Mitigation
Capabilities for Extreme External Events and Severe Accidents
1)

MITIGATION STRATEGIES (i.e. strategies for maintaining or restoring core cooling,
containment, and spent fuel pool cooling capabilities)
Regulatory Requirement;The accident management strategies shall satisfy the following criteria:i.

The essential safety functions that are maintained and recovered for accident
management shall be defined and shall include various actions in considerationof personnel factors; andii.

The system shall include the technical grounds of the accident management
strategies, the methods of preparing manuals and guidelines, and plans for repair
and maintenance.

The accident management performance system shall satisfy the following criteria:i.

The organs and personnel required for accident management shall be secured
and the related responsibilities and authority for implementing the management
strategies shall be assigned as and when required;

ii.

Command and control systems shall be developed to implement the accident
management strategies;iii.

The normal operation of the equipment required for implementing the accident
management strategies shall be monitored and adequate actions shall be takenin the event of any malfunction;iv.

The system shall also include information concerning the functional integrationof the accident management strategies; andv.

It shall also consider information concerning multiple units when other nuclear
reactor facilities are located at the relevant site.

Licensee Action Plan;


Plan to set up of MACST (Multi-barrier Accident Coping STrategy)Conformity of safety and development of improvements by the evaluation of
emergency responses and preparedness




106

Scheduled to complete until the year of 2019 through the stress test for theoperating nuclear power plant.

Prepared document of accident management plan until the year of 2019 reflecting theresults of the stress test

Development of a systematic accident management and strengthen of theemergency facilities and equipment in case of a severe accident occurred at
multiple units.

Including safety issues of accident mitigation strategy, implementation plan,
guidelines and procedures, and education and training for the case of design basis
accident (DBA), beyond design basis accident (B-DBA), and severe accidents.

Prepared new procedures and guidelines for newly installed systemDeveloping the newly or improved installed system such as Passive Autocatalytic
Recombiner (PAR), Containment Filtered Venting System, mobile power generation
car, etc.

Developing guidelines and procedures for interface between EOP, SAMG, and
MACST.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUEST2)OTHER PROCEDURES AND GUIDELINES (to manage other elements of event or emergency
response not directly supporting the implementation of mitigation strategies)
Regulatory Requirement;
N/A
Licensee Action Plan;
Prepared new procedures and guidelines for newly installed system



3)



Developing the newly or improved installed system such as Passive Autocatalytic
Recombiner (PAR), Containment Filtered Venting System, mobile power generation
car, and other portable equipment, etc.

Developing guidelines and procedures for interface between EOP, SAMG, and
MACST.

STAFFING
Regulatory Requirement;
N/A
Licensee Action Plan;

Evaluation of the appropriateness for staffing level in the situation of severe accidents
through the stress testConcerned staffing issue comprehensively during the safety review on the accident
management plan by regulatory body4)

The accident management plan will be developed by reflecting the results of thestress test.

ORGANIZATIONAL STRUCTURES, COMMUNICATION, DECISION MAKING AUTHORITIES,AND SAFETY CULTURE
Regulatory Requirement;
N/A
Licensee Action Plan;

5)

Newly organized on and off site for responding severe accidentSAFE-T (Severe Accident Fast Response Expert Team); Off-site organization forsupporting technical issues in the situation of severe accident (dispatched within 6
hrs to the accident site)STAG (Severe Accident Technical Advisor Group); Off-site organization to provide
specialized technical advice for accident mitigation and plant recovery (Organized
in CRI (Central Research Institute) of KHNP)Emergency Response Expert Center; On-site organization for managing plantresources, portable and mobile equipment/facilities, and surveillance of plantstatus, etc.

PERSONNEL QUALIFICATIONS AND TRAINING
Regulatory Requirement;The education/training plan developed to maintain the validity of the accident
management plans shall satisfy the following criteria:

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTi.

Education corresponding to the relevant responsibilities and authority shall be
provided periodically for the members of the accident management
organizations.

ii.

raining shall be performed every two years or less to enable verification of thevalidity of the accident management strategies and implementation systems.

Licensee Action Plan;
Reinforcing education and training for severe accidents after the Fukushima Daiichi
Accident6)

Plan to improve simulator for operator training and qualification to simulate
various situations of severe accidents.

Conducted an unannounced radiation emergency exercise at each nuclear powersite once a year under the recommendation of the NSSC

PLANT INSTRUMENTATION, CONTROLS,COMMUNICATIONS EQUIPMENT

HUMAN-SYSTEMINTERFACES,

AND

Regulatory Requirement;
N/A
Licensee Action Plan;
N/A

7)

PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS
Regulatory Requirement;
N/A
Licensee Action Plan;
Improving emergency response facilities



Securing additional equipment to prepare for a prolonged emergency





8)

A plan to improve the habitability and scale of emergency response facilities
including Technical Support Center (TSC) and Operation Support Center (OSC) andto prevent inundation of emergency facilities due to a large tsunami.

Additionally, secured 440 units of radiation (radioactivity) instruments and 20,000
radiation protection gears to increase inventory 200% of the previous level.

WORK PLANNING, TECHNICAL SUPPORT, AND EMERGENCY RESPONSE FACILITIESRegulatory Requirement;
N/A
Licensee Action Plan;
N/A

9)

EMERGENCY RESPONSE PLANS
Regulatory Requirement;
N/A

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Licensee Action Plan;
Determined action items to respond to a natural disaster beyond the design basis andsimultaneous emergencies at multiple units as follows;

Securing additional thyroid blocking agent for protecting residents near a nuclear
power plant,

Amending the radiological emergency plan to include such events as thesimultaneously issuing an emergency alert at multiple units,Securing additional equipment in preparation for an event where in the emergency
is prolonged,

Expanding equipment of emergency medical treatment organizations



Reinforcing radiation emergency exercise

Amending the information disclosure procedure in the event of a radiation
emergency

Reforming emergency planning zone (EPZ)

Divide the existing single emergency planning zone (EPZ) into the precautionary
action zone (PAZ) and the urgent protective action planning zone (UPZ).



Currently Radiation emergency plan is in revising process to be in compliance withthe expansion of EPZ to 20-30 km and subdivided EPZ.

10) EXTENDED (LONG TERM RESPONSE)
Regulatory Requirement;
N/A
Licensee Action Plan;
N/A

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTSPAINResponse to Phase 1 Information Request
provided by Consejo de Seguridad Nuclear

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Improvement plans after Fukushima-Daiichi, HOF lessons learned

WGHOF
TASK ON HOF LESSONS LEARNEDIMPROVEMENT PLANS AFTER FUKUSHIMA-DAIICHI(Phase 1)

Consejo de Seguridad Nuclear
Spain

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Improvement plans after Fukushima-Daiichi, HOF lessons learned

CONTENTS
1. Summary of Actions Taken
2. Questionnaire

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Improvement plans after Fukushima-Daiichi, HOF lessons learned

CONTENTS
1. Summary of Actions Taken
2. Questionnaire

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NPPs in operation*

Other nuclear installations

1. Garoña

BWR, MK-I (1971) 466 MWe

1. Ascó (2 reactors)

Vandellós I NNP
deferred dismantling

Fuel manufacturing(Juzbado)

W-PWR (1983-1985)
1,033 & 1,027 MWe

2. Vandellós II

José Cabrera NPP
under decommissioning

W-PWR (1987) 1,087 MWe

3. Cofrentes

Centralized storage for spent fuel

BWR, MK-III (1984) 1,092 MWe

4. Trillo

KWU-PWR (1988) 1,066 MWe

Low Level waste disposal(El Cabril)

5. Almaraz (2 reactors)
W-PWR (1983-1984)
1,049 & 1,445 MWe

1 fuel manufacturing plant
1 NPP under deferred dismantling
1 NPP under decommissioning

7 reactors in power operation (5 sites)*

1 Intermediate, Low and Very Low Level waste disposal facility
1 NPP (Garoña) in final shutdown situation

1 centralized storage for spent fuel and high level waste, (ATC), under licensing process

SPANISHSITUATION

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Improvement plans after Fukushima-Daiichi, HOF lessons learned
EUROPEAN UNIONEUROPEAN
Stress test
2011

Nuclear Safety Directive

NSD 2014/87
EURATOM
2014

FUKUSHIMA
11/03/2011

WENRA

Reviewed RL
after
Fukushima
2014

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NUCLEAR SAFETYCONVENTION

VDNS
2015

REGULATORYFRAMEWORK
ITC1 + ITC 3
ITC 2+ ITC 4(2011-2012)
ITC 5, ITC 6
NSD 2014/87
transposition
Royal D. on NS(Scheduled for 2018)
Harmonization
processCSN Instructions(Scheduled for 2018)

NPP

Stress test
2011

DesignModifications
2012-2017
FVCS
AEMC
PAR
EDMG
Mobile equipment

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Improvement plans after Fukushima-Daiichi, HOF lessons learned• Spanish NPP completed the European-stress tests (2011) and their peer
review processes (2012), including two on site technical visits.
• In accordance with ENSREG agreement of July 2012 for European stresstests, the CSN performed a National Action Plan, which was published in
December 2012 and has been subjected to an European Peer Review
process in 2013.
• Additionally to the stress tests scope, the CSN launched a parallel process
for improving the protection of plants against malicious acts that might leadto the loss of large areas of the installation and severely affect its safety or
the environment and public health.

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Improvement plans after Fukushima-Daiichi, HOF lessons learned• Improvements have been implemented according to a schedule thatcan be summarized as follows:—

Short Term: Analysis (2012)—

Medium Term: Implementation of improvements (2014)—

Long Term: Large modifications (2016) + 2017

• Improvements can be classified into:———Protective measures. Aimed at protecting SSCs against extreme natural
phenomena
Preventive measures. Aimed at avoiding core melt
Mitigation measures. Aimed at minimizing the impact on the people andthe environment

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Improvement plans after Fukushima-Daiichi, HOF lessons learned

2011

2012

ITC-2-PLLA
30/6/2011

ITC-4-PLLA
26/7/2012

ITC-1-ST
23/5/2011

2015

2014

2013

2016

2017

2018

ITC-5-ST+PLLA
9/4/2014

ITC-5-ST+PLLA
9/4/2014

ITC-3-ST
15/3/2012

ITC-6-ST
14/5/2015

PLABEN

Short term:
Analysis
Medium term:
Implementation of improvements
Long term:
Large modifications

Assess, improve and issue new revision of PLABEN

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Society and Government

Regulator

Corporation

Organization

Individuals

Technology

Production process

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1. REGULATORY RESPONSE AFTER FUKUSHIMAa) Commitment with Europeb) Regulatory requirements: ITC 1/3, ITC 2/4, ITC 5c) Design criteriad) CSN supervisione) CSN organization
2. SPANISH NUCLEAR POWER PLANTS RESPONSEa) Response to ITC 3 ITC 2/4b) Proceduresc) Analysesd) Main physical modifications in the Spanish NPPe) Radiation protection issuesf)Periodic informationwww.csn.es

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Improvement plans after Fukushima-Daiichi, HOF lessons learned

1. REGULATORY RESPONSE AFTER FUKUSHIMAa) Commitment with Europeb) Regulatory requirements: ITC 1/3, ITC 2/4, ITC 5c) Design criteriad) CSN supervisione) CSN organization
2. SPANISH NUCLEAR POWER PLANTS RESPONSEa) Response to ITC 3 ITC 2/4b) Proceduresc) Analysesd) Main physical modifications in the Spanish NPPe) Radiation protection issuesf)Periodic information

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Improvement plans after Fukushima-Daiichi, HOF lessons learneda) COMMITMENT WITH EUROPE STRESS TEST - NATIONAL REPORT - PEER REVIEW(May, 2011 - April, 2012)
 WENRA (Reference levels review under Fukushima events light)(May, 2012 - October, 2013)
CSN participation in working groups under RHWG (Reactor Harmonization
Working Group):o I4: Mutual assistanceo T1: Natural hazards
o T2: Containment in severe accidentso T3: Accident managementwww.csn.es

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Improvement plans after Fukushima-Daiichi, HOF lessons learnedb) REGULATORY REQUIREMENTS: ITC 1/3, ITC 2/4, ITC 5
 Regulatory requirements associated to the NPP operating licence (“Orders”)
 Specific for every NPP
 Post-Fukushima European stress tests: ITC 1 and ITC 3
 Large explosions or fires beyond design bases: ITC 2 and ITC 4
 Post-Fukushima European stress test and Large explosions or fires BDB: ITC 5
 Post Fukushima seismic characterisation of NPP sites: ITC 6

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 POST-FUKUSHIMA: ITC 1 AND ITC 3
 ITC 1: Stress test (lessons learnt from the Fukushima events)o May, 2011 to NPP
June, 2011 to Jose Cabrera and Juzbado

oo Closed interaction between CSN and licensees
 ITC 3: Specific requirements derived from the Stress tests conclusionso March, 2012o Extreme natural hazards, prolonged and total SBO, loss of UHS
o Accident management (reactor/containment and fuel pool storage)o Two types of requirements:i)Analysis and, depending on the results, modifications;ii)

Modifications

Short (2012), medium (2014) and long (2016) terms requirementsowww.csn.es

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Improvement plans after Fukushima-Daiichi, HOF lessons learned

 LARGE EXPLOSIONS OR FIRES BEYOND DESIGN BASES: ITC 2 AND ITC 4
In a separate but totally coordinated process, the CSN has fulfilled a program aimed at protecting the plants against other severe events that might be
induced by malicious acts and seriously impact the safety of the installation, the environment and public health.

 ITC 2: “Potential loss of big areas in the NPP”
oJuly, 2011oConfidentialityo

NEI 06-12, rev.2 “B.5.b phase 2&3 submittal guideline” as referenceoRequire analysis and modifications depending on the results, covering: Emergency management
 Large fires extinction
 Fuel damage mitigation (both in the reactor core and in spent fuel storage) Mitigation of radioactive releases

 ITC 4: “Potential loss of big areas in the NPP”
oJuly, 2012oSome additional requirements/clarifications not included previously in ITC 2

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Improvement plans after Fukushima-Daiichi, HOF lessons learned

 ITC 5: “Adapted” ITC
 In force for CNSMG (July, 2013)*
o Compilation of ITC 2/4 and 3 requirementso Adaptation of these previous orders to its new operational situationo Consistency between the two processes
o Relief of confidentiality requirementso Abolition of ITC 2/4 and 3* CNSMG has been in “permanently” shutdown operation since July 6th, 2013. Final shutdown since August 2017

 In force for the rest of the NPPs (April, 2014)
With a view to facilitating simultaneous and coordinated compliance with the two sets of requirements issued by the
CSN for the nuclear power plant licensees (those deriving from the stress tests and those arising as a result of the ITCs
issued by the CSN to improve the capacities of the plants to respond to severe events that might be induced bymalicious acts), in April 2014 the CSN issued a new “adapted” ITCs that brings together in a single document all thoserequirements that - given the terms foreseen for implementation – were still pending a solution by the licensees. It is
important to point out, however, that these ITCs do not incorporate any new requirements.

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Improvement plans after Fukushima-Daiichi, HOF lessons learned

 ITC 6: Seismic characterisation
 In force (May, 2015):
o Requiring the licensees to update seismic characterizations of the NPPs sites
according to the most advanced methodologies currently known (IAEA,
US-NRC,...).

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Improvement plans after Fukushima-Daiichi, HOF lessons learnedc) DESIGN EVALUATION CRITERIA FOR PLANT MODIFICATIONS CSN developed some criteria as a minimum to fulfil some ITC 2/4 and 3 requirements
 Applicable to physical design modifications
 Double purpose: Design (utility) and acceptance criteria (CSN) General application criteria:
 For new or pre-existing equipment/system, fixed or mobiles, considered in theanalysis Assuring robustness against postulated events (extreme natural hazards, prolonged
and total SBO, loss of UHS, events with loss of large areas) Requirements in terms of functionality, availability, “qualification”.....
 Specific criteria to design: On site alternative management centre (CAGE)
 Filtered containment venting systems (FCVS) Passive autocatalytic recombiners (PAR)www.csn.es

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Improvement plans after Fukushima-Daiichi, HOF lessons learned

 CSN SUPERVISION CSN developed a detailed guide to fulfil the supervision process Inspection and Evaluation specific program Several annual inspections to every NPP on ITC 2/4 and 3 requirements (different
inspection teams depending on the topic)
 Evaluation on some ITC 2/4 and 3 requirements
 CSN formal acceptance on some design modifications
 Final report of the whole supervision process to be presented in few months to the CSN(Commission) for approval.

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Improvement plans after Fukushima-Daiichi, HOF lessons learnede) CSN ORGANIZATION
 No changes in the normal organization of CSN
 Different departments affected Supervision process responsibilities defined in the guidewww.csn.es

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Improvement plans after Fukushima-Daiichi, HOF lessons learned

1. REGULATORY RESPONSE AFTER FUKUSHIMAa) Commitment with Europeb) Regulatory requirements: ITC 1/3, ITC 2/4, ITC 5c) Design criteriad) Follow-upe) CSN organization
2. SPANISH NUCLEAR POWER PLANTS RESPONSEa) Response to ITC 3 ITC 2/4b) Proceduresc) Analysesd) Main physical modifications in the Spanish NPPe) Radiation protection issuesf)120

Periodic information

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Improvement plans after Fukushima-Daiichi, HOF lessons learneda) RESPONSE TO ITC 3 ITC 2/4
 Specific response from every NPP
 Most of the NPP proposed changes to fulfil ITC 3 and ITC 2/4 requirements simultaneously Planning for accident management (organization, human resources, training, facilities)
 Procedures (EOPs – SAMG – EDMG)
 Physical Design Modifications
 Time frame: a few of authorized delays on some specific requirements . Not compromised
final dates

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Improvement plans after Fukushima-Daiichi, HOF lessons learnedb) PROCEDURES
 Westinghouse-PWR and General Electric-BWR: review of EPG-SAMG under OG (Owners
Group) reference
 KWU-PWR: Developing symptom based SAMG. Long term
 NPP developing EDMG (Extended Damage Management Guidelines): short/medium term
 Different models depending on the NPP design
 Mobil equipment
 Fuel damage prevention/mitigation
 Fire/explosion/security
 Radiological issues

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Improvement plans after Fukushima-Daiichi, HOF lessons learnedc) ADDITIONAL ANALYSIS In response to some CSN requirements (ITC 3 and 2/4)
 Short and medium term Implementation of improvements (modifications) identified in the analysis: medium andlong term Examples of some kind of analyses:
 Natural HazardsoSeismic margins in SC-I and non SC-Io

Potential and large internal floodingoHarmonization between scenarios of dam breaking considered under stress test
and considered under the dam emergency plansoCombination of another potential extreme natural hazards (extreme
temperatures, rain, snow...)

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Improvement plans after Fukushima-Daiichi, HOF lessons learned
 Planning for accident managemento

Human resources required to reinforce the NPP emergency organizationsoAccess routes towards the plant under extreme natural hazardsoMutual assistance (among Spanish NPP)oCommunication resources (on-site & external)

 Severe accidents

122oAlternatives to depressurize the RCS under total SBO and earthquakeo

Use of seismic FPS (Fire Protection System) to inject/spray water in the
RPV/Containment/SFPoHydrogen leaks to neighbour buildingsoSevere accidents in shutdown states

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Improvement plans after Fukushima-Daiichi, HOF lessons learned
 Severe accidents (cont.)oCritical instrumentation for severe accident managementoInstrumentation in containment under severe accident conditionsoClosure of containment under total SBO (whatever operational mode: normal
operation, but of course shutdown, refuelling outage)oContainment integrity under severe accident conditions

 Storage fuel pooloReinforcement of the instrumentation (temperature, level and radiation) under
severe accident scenario and total SBO

 Radiological protectionoAnalysis of additional radiological protection resources and equipmentoAnalysis of the resources needed to estimate radioactive emissions

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Improvement plans after Fukushima-Daiichi, HOF lessons learnedd) MAIN PHYSICAL DESIGN MODIFICATIONS IN THE SPANISH NPP Design criteria: Developed by CSN with NPP participation
 Emergency management: On site alternative emergency centre Specific design criteria (functionality, availability, “qualification”, radiological aspects)
 For potential loss of large areas in the NPP and for extreme natural hazards
 Main difficulty: seismic design base definition
 Not an alternative emergency control room Final date: long term (2016) Prevention/mitigation severe accident scenarios
 General and/or specific design criteria (functionality, availability, “qualification”)
 Reactor/containment/spent fuel pool
 Mobile/fixed, new or adapted, equipment to respond against postulated events(extreme natural hazards, prolonged and total SBO, loss of UHS, loss of large areas)

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 Examples of design modifications implemented in the Spanish NPPs:
 New (or up-graded in Cofrentes NPP) FCVS (Filtered Containment Venting Systems)
 H2 control: PAR (Passive Autocatalytic Recombiners) inside containment. Exceptions: Trillo NPP (italready has PAR) New mobile equipment and new procedures to inject/spray water into the
RPV/SG/Containment/SFP (motor driven pumps/connections/hoses).
 Minor modifications and new procedures to allow water injection to RPV/SG by using the preexisting turbine driven pumps without DC power (manually operated).
 Improvements in all PWR-Westinghouse RCP seals. Almaraz NPP still under discussion.
 New or upgrade instrumentation for critical parameters/new portable equipment and orprocedures to alternatively obtain critical values.

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 Examples of design modifications implemented in the Spanish NPPs: Supporting systems
 New mobile electrical power supply (mobile diesel generators for AC/batteries or
MDG+battery charger for DC/connections) for mobile/fixed equipment, including
instrumentation.
 New mobile fuel supply (tanker) for mobile/fixed equipment.
 New mobile lightening systems for exterior use.
 New alternate air supply (mobile or fixed/connections) for pneumatic equipment.
 New connections for alternate water supply (from different pre-existing tanks or water
reservoirs).

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e)Improvement plans after Fukushima-Daiichi, HOF lessons learned

RADIATION PROTECTION ISSUES

Reinforce the electrical supply to the main control room habitability systemReinforce the electrical power supply to essential radiological surveillance equipment

Containment filtered ventingExternal spray of the containment and another buildings with potential radiological risk

Confinement/treatment of the radioactive liquid waste

Development of radiological guidelines for severe conditions actuations

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PERIODIC INFORMATIONThe Spanish NPPs have been submitting periodically (every six months) a reportsummarizing the advance state of their activities related to the ITC 2/4 and ITC 3, as
required by CSN

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CONTENTS
1. Summary of Actions Taken
2. Questionnaire

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Acronyms:
ITC: Instrucción Técnica Complementaria (Complementary Technical Instruction of the CSN)
ITC-ST: CSN ITC issued with the conclusions of the Stress Tests (15/3/2012)
ITC-PLLA: CSN ITC related to the Potential Loss of Large Areas, after September 11th terrorist attack

Type of requirements included in the ITC-3-ST:
G, stands for “Generic requirement”
I, stands for “Improvement implementation requirement”
A, stands for “Additional Analysis requirement”

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1. MITIGATION STRATEGIES (i.e., strategies for maintaining or restoring core cooling, containment,
and spent fuel pool cooling capabilities)

QUESTIONNAIRE

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1. MITIGATION STRATEGIES (i.e., strategies for maintaining or restoring core cooling, containment,
and spent fuel pool cooling capabilities)
 W-PWR and GE-BWR: review of EPG-SAMG under Owners Group reference.
 KWU-PWR: Developing symptom based SAMG. Long term.
 NPP developing EDMG (Extended Damage Management Guidelines) : short/medium term
EMERGENCY

PLAN
Different models depending on the+NPP
design.
Emergency

Mobil equipment.

Response
Organization(ERO)

Fuel damage prevention/mitigation.
Fire/explosion/security.
Radiological issues• Provisions to recover supply from nearby hydroelectric facilities• Diversity of the grid and offsite power supply sources• Additional EDGs in some cases• EDGs autonomy 7 days

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1. MITIGATION STRATEGIES (i.e., strategies for maintaining or restoring core cooling, containment,
and spent fuel pool cooling capabilities)

Management ofincidents and accidents
Design features (DBA and DEC)
Normal operating procedures
Administrative controls

EMERGENCY
PLAN+ Emergency
Response
Organization(ERO)

For all operating reactors, post Fukushima measures have been implemented to improvesevere accident management.

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2. OTHER PROCEDURES AND GUIDELINES (to manage other elements of event or emergency response
not directly supporting the implementation of mitigation strategies)

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2. OTHER PROCEDURES AND GUIDELINES (to manage other elements of event or emergency response
not directly supporting the implementation of mitigation strategies)

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2. OTHER PROCEDURES AND GUIDELINES (to manage other elements of event or emergency response
not directly supporting the implementation of mitigation strategies)d:

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3. STAFFING

ESC (Emergency Support Centre), centralised at national level

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3. STAFFING

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4. ORGANIZATIONAL STRUCTURES, COMMUNICATION, DECISION MAKING AUTHORITIES, AND
SAFETY CULTURE

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4. ORGANIZATIONAL STRUCTURES, COMMUNICATION, DECISION MAKING AUTHORITIES, AND
SAFETY CULTURE

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5. PERSONNEL QUALIFICATIONS AND TRAININGQUESTIONNAIRE

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5. PERSONNEL QUALIFICATIONS AND TRAINING• Staff procedure training

ERO review
in moredemandingscenarios

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6. PLANT INSTRUMENTATION, CONTROLS, HUMAN-SYSTEM INTERFACES, AND COMMUNICATIONSEQUIPMENT

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6. PLANT INSTRUMENTATION, CONTROLS, HUMAN-SYSTEM INTERFACES, AND COMMUNICATIONSEQUIPMENT

PAR (Passive Autocatalytic Recombiners)

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6. PLANT INSTRUMENTATION, CONTROLS, HUMAN-SYSTEM INTERFACES, AND COMMUNICATIONSEQUIPMENT
Seismic margin increase
up to 0,3g (RLE) including
new SSCs (SBO equipment, SFP, etc),well above the expected
seismic risks

Drainage capability increase

Barriers and leak-tightness
reinforcement in criticallocations
QUESTIONNAIRE

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6. PLANT INSTRUMENTATION, CONTROLS, HUMAN-SYSTEM INTERFACES, AND COMMUNICATIONSEQUIPMENTTANK• Filtered Venting System in all NPPs
• H2 passive recombiners• External Containment spraying w/water cannons

CONTAINMENT SPRAY

H2 passive
recombiners

STEAM GENERATOR

Resistant and filteredventing to stack

HEAT
EXCHANGER

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6. PLANT INSTRUMENTATION, CONTROLS, HUMAN-SYSTEM INTERFACES, AND COMMUNICATIONSEQUIPMENTQUESTIONNAIRE

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6. PLANT INSTRUMENTATION, CONTROLS, HUMAN-SYSTEM INTERFACES, AND COMMUNICATIONSEQUIPMENT

Reinforced
Communications(satellite)

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7. PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS

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7. PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS

(

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7. PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS• Additional EDGs in some cases• EDGs autonomy 7 days
• Reinforce existing equipment and procedures to achieve 24h of autonomy and havecapabilities to withstand up to 72 h
• Address leaks through RCP seals• Alternative water injection to RCS and AFW (for PWRs) and RCIC (for BWRs). Use of
equipment and mobile pumps. Allow for manual actuationwww.csn.es

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NPPs RESPONSES

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7. PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS
Portable pumps
to inject water into
RPV and SFP fromdifferent sources

Equipment & Materials
Movement Vehicles

Easy connection
to the plantPortable DGs to supply
essential services

Portable
instrumentation& batteriesStored in safe
areas

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7. PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS

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7. PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS

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7. PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS

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7. PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS

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8. WORK PLANNING, TECHNICAL SUPPORT, AND EMERGENCY RESPONSE FACILITIESAEMC (Alternative Emergency Management Centre)

ESC (Emergency Support Centre), centralised at national level

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8. WORK PLANNING, TECHNICAL SUPPORT, AND EMERGENCY RESPONSE FACILITIESEmergency Management Center at each NPP

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8. WORK PLANNING, TECHNICAL SUPPORT, AND EMERGENCY RESPONSE FACILITIESCentralized Emergency
Support Center

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9. EMERGENCY RESPONSE PLANS

TSC (Technical Support Centre in the NPP)
SALEM (Emergency Centre in the CSN)

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9. EMERGENCY RESPONSE PLANS

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10. EXTENDED (LONGER TERM) RESPONSE

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10. EXTENDED (LONGER TERM) RESPONSE

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Complementary Technical Instructions (ITCs) relating to the potential loss of large areas of a NPP (events that might be
induced by malicious acts): ITC-2-PLLA and ITC-4-PLLAIn addition to all the topics and actions covered by the Stress Tests and the ENSREG Peer Reviews, and in a separate but totally
coordinated process, the CSN has fulfilled a programme aimed at protecting the plants against other severe events that might
be induced by malicious acts and seriously impact the safety of the installation, the environment and public health.
It is important to point out that the actions requested by the CSN were focused on the “mitigation” of the consequences ofthese extreme situations.
On July 1st 2011, the CSN issued a first set of ITCs, requesting the preparation, before the end of 2011, of the plant-specificanalysis to prepare the installations to cope with these situations, including the proposals for new material and/or humanresources. The ITCs required that consideration be given to the three main aspects of the problem within the scope of theanalysis: The capacity to fight major fires beyond the plant design basis
 The capacity to mitigate potential fuel damage (both in the reactor core and in the spent fuel storage facilities)
 Ways to limit or control radioactive emissions, in the form of liquid or gaseous releases
On July 27th 2012 the CSN issued additional ITCs incorporating some clarifications regarding the process, including the need to
draw up an implementation plan fully consistent with the one already prepared for the incorporation of the conclusions of theStress Tests.

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Emergency preparedness & response and post-accident management (off-site):

PLABEN

Very soon after the occurrence of the Fukushima accident, the need to review the provisions to cope with major nuclear
accidents became clear for most of the agencies involved in the Spanish Emergency System. An action plan was drafted inclose cooperation between the two main actors in this system, the Directorate General for Civil Defence and Emergencies andthe Nuclear Safety Council.
The main aspects of this plan were summarised in the Spanish National Report to the second extraordinary meeting of theConvention on Nuclear Safety. The plan included the in-depth, open review of the provisions set forth in the document, which
establishes the main provisions and criteria for Preparedness, Planning and Response to nuclear emergencies, the so-called
PLABEN (Basic Plan for Nuclear Emergencies). Eleven general issues were identified to be the main points, on which the review
work is being focused. These issues will be included in the new revision of the PLABEN, which is currently under elaborationand is being coordinated by the General Direction for Civil Protection and Emergencies (DGPCE, Ministry of the Interior) and isforeseen to be released throughout 2018.
1. Adequacy and provision of adequate resources to cope with major nuclear emergencies and other organisational issues:
In this area, the inclusion in the emergency organisation of all the resources provided by the Military Emergency Response
Unit (a military unit created in 2005 and especially trained to cope with major disasters) is one of the main aspects to beconsidered.
2. Reference levels for protective actions, for both the urgent and intermediate phases:
The reference levels included in the PLABEN currently in force will be reviewed and updated to the most recent international
criteria (i.e. IAEA BSS) and other lessons learnt from the Fukushima accident, especially the ones relating to management of
the intermediate phase.

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Emergency preparedness & response and post-accident management (off-site):

PLABEN(cont.)

3. Reference levels for emergency response personnel:
The reference levels for off-site and on-site intervening personnel will be harmonised (in the current PLABEN the approach is
not consistent with this principle). Moreover, the reference levels to be adopted should allow sufficient margin to allow theassigned personnel to carry out on-site activities that are deemed to be crucial to prevent or mitigate major releases.
4. Accident scenarios and their time scale:
Suitable changes should be considered in the allocation of resources and provisions to cope with long-lasting emergencies,
considering the possibility of the need for urgent response actions planning and preparedness level. Also, the coordination ofoff-site provisions with some relevant on-site actions involving the possibility of important releases (especially the opening of
the containment venting) will be addressed.
5. Emergency Planning Zone (EPZ) size:
The current provisions for the EPZ considered in the PLABEN include an Urgent Protective actions Zone (Zone 1) measuring 10
km. in radius and a Long-Term Protective actions Zone (Zone 2) with a radius of 30 km. It is necessary to reassess the size ofsuch zones, considering the experience of Fukushima, to determine the suitability of possible modifications, to allow for more
realistic planning and preparedness. The size of the Preferred Actuation Zone (currently 5 km) will also be included in thereassessment.

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Emergency preparedness & response and post-accident management (off-site):

PLABEN(cont.)

6. Decision making and implementation criteria for urgent and intermediate phase protective actions:
The implementation criteria for some urgent phase actions will be reviewed, taking into consideration some insights from the
Fukushima experience and new trends in emergency management:• In the case of evacuation, the suitability of implementing a staggered evacuation criterion should be considered. This
would involve a departure from the current PLABEN criterion (which establishes evacuation in the direction of the wind,
the so called preferred attention sector) to an evacuation zone based on distance, and staging the evacuation according toprioritising criteria.
• To limit the duration of on-site sheltering to a few days
• To analyse several options (i.e. centralised distribution vs. distribution in advance) to improve the effectiveness ofradiological prophylaxis.
In the case of relevant long-term protective actions (relocation, foodstuffs and water control), it is considered that theapplicable criteria must be reviewed and developed in further detail, considering the lessons learned from Fukushima and themost recent developments in these areas.
7. Warning and communication systems:
The existing warning system in Zone 1 should be reviewed to provide a balanced set of diverse and effective means to alert the
population, considered certain limiting scenarios. Also, the provisions available for communication to the public and the media
during the emergency will be revisited in order to ensure the ability to provide both reliable and timely information.

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Emergency preparedness & response and post-accident management (off-site):

PLABEN(cont.)

8. Public radiological screening facilities:
The current PLABEN establishes the provision of facilities (the so called Screening and Decontamination Facilities, ECD) towhich the evacuated people would be directed after evacuation and, once this screening and decontamination is completed,then the public would be directed to the Sheltering and Lodging Centres. The site of these ECD’s is not very far from the NPP,
as a result of which they might be contaminated during a major accident; furthermore, the size of the facilities is relatively
small, so the ability to screen a large number of people is limited. Consequently, in the light of the experience of Fukushima
this issue is going to be reassessed and the suitability of modifying the screening process determined, so that it may be carriedout directly in the Sheltering and Lodging Centres.
9. Strengthening the role of the municipalities during planning and response:
In order to reinforce this role, which has been shown to be essential, suitable changes in the organisational provisions of the
PLABEN will be defined.
10. Cooperation of the licensees with the off-site emergency plans:
To date, the cooperation of the licensees with the off-site emergency plans has taken place in an unstructured manner andonly on a voluntary basis. This situation must be changed to allow for the binding and clearly structured cooperation of thelicensees with the off-site emergency plans, both in preparedness, planning and response.

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Emergency preparedness & response and post-accident management (off-site):

PLABEN(cont.)

11. Transition from urgent to intermediate phase and from intermediate emergency phase to the existing exposure situation
The current PLABEN is mainly focused on the urgent phase. Very few provisions are included for the intermediate phase.
Moreover, the concept of the existing exposure situation is not included, due to the issuance date of the document. Moredetailed and clear provisions (both from the technical and organisational standpoint) will be included for the intermediatephase. Also, the concept and provisions for transition to the existing exposure situation, as set forth in the IAEA BSS (Basic
Safety Standards), will be established.
Additionally the CSN, the regulatory authority, which is responsible during nuclear emergencies for the coordination of
support and response activities relating to nuclear safety and radiological protection, has promoted the improvement of thefollowing additional aspects:
12. Improvements in environmental radiological surveillance during an emergency:
New mobile monitoring units have been acquired and the fixed surveillance network has been reinforced with portableequipment for power supply.
13. Improvements in the communications between the different emergency response centres (off-site, on-site, CSN).
In case the Virtual Private Network (VPN), which supports these communications, becomes unavailable during an emergency,
alternate means for communication have been provided:• Implementation of satellite technology and by feeding the communication equipment with diesel groups.
• Readiness of the means provided by the Spanish Military Emergency Response Unit (UME), which among other supplies
can provide alternative support for voice and data communications.

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Good practices identified during the implementation of the National Action Plan
The main good practices identified to date by both the CSN and the licensees of the plants have been as follows:146Adequate implementation of protocols, including periodic testing, for the quick and preferential recovery of off-site electrical feed.



Actions required (procedures and tests) for the safe shedding of Direct Current loads.



Actions required (procedures and tests) to allow for the remote manual use of relevant equipment in the event of loss of direct
current power.



Implementation of new equipment (fixed and portable) for extended SBO. This equipment is subject to a specific surveillance
program and is designed to be used under the general philosophy of “plug & play”.



As a result of the tracking of the international main pump seal improvement programmes, three out of the five Westinghouse PWR
groups currently existing in Spain have installed new seals in the main pumps. The CSN is assessing the need to require theinstallation of these improved seals in the remaining two groups.



Verification and, where appropriate, reinforcement of the seismic resistance capacity of equipment of importance for accident
management, up to a “seismic margin” of 0.3 g (PGA) equal for all the sites.



Implementation of a Fire Protection subsystem with seismic design.

Issuance of a new ITC requiring the licensees to update seismic characterizations of the NPPs sites according to the most advanced
methodologies currently known (IAEA, US-NRC,...).

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Good practices identified during the implementation of the National Action Plan
The main good practices identified to date by both the CSN and the licensees of the plants have been as follows (cont.):Issuance of a new requirement to the licensees to verify the analysis of dam rupture scenarios every ten years, considering the results
obtained from surveillance, auscultation and maintenance processes.

Implementation of additional measures (specific to each site) to increase protection against external flooding.

Implementation of the new Emergency Support Centre (ESC) at national level.

Implementation of the Alternative Emergency Management Centre (AEMC), the Passive Autocatalytic Recombiners (PAR) and theContainment Filtered Venting System at all the NPPs.

The CSN has promoted the implementation of an early warning system to the plants in case of extreme weather conditions, organized
together with the Meteorological State Agency.

Improvements to facilitate alternative site access in case of extreme environmental situations have been developed

The communication in case of emergency has been reinforced through the implementation of satellite technology and by electricallyfeeding the communication equipment with diesel groups.



Improvement of the capacity to handle large masses of contaminated liquids.



Development at all the plants of Radiation Protection Guidelines complementary to the SAMG.

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Challenges identified during the implementation of the National Action Plan
The main challenges identified by both the CSN and the plant licensees have been as follows: There is no reference standard for the design and implementation of this type of improvement. The CSN has drawn up a
generic document on evaluation criteria that is known to the licensees and is being applied by the CSN evaluators andinspectors. In specific cases, engineering judgement criteria have been applied.
 Emergency Response Organisation (ORE) capabilities analysis methodology: this was a novelty issue; the CSN has requested
the licensees to develop their own methodology, which was finally based on that developed in the USA by NEI (alreadymentioned in section 4.1.4).
 The performance of special tests contemplated in the NAcP, such as for example the testing at Westinghouse PWR plants of
the local manual operation (with loss of Direct Current power) of the steam generators relief valves and the auxiliary
feedwater turbine-driven pumps.
 Certain developments conditioned by the work performed at international level, such as for example the drawing up ofguidelines on severe accidents in shutdown conditions, which are closely related to projects initiated by owners groups in
the USA, or the implementation of new main pump seals at Westinghouse PWR plants.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTSWEDEN
Response to Phase 1 Information Request
provided by Swedish Radiation Safety Authority

Response to WGHOF Questionnaire Phase 1 – Post-Fukushima Actions to Improve
Mitigation Capabilities for Extreme External Events and Severe Accidents
Summary of Actions
The Swedish Radiation Safety Authority (SSM) was reviewing the existing regulations on
Emergency Preparedness at Certain Nuclear Facilities (SSMFS 2008:15), at the time of the Fukushima
event. The review took into account the early experiences of the emergency response from theevent. The revision was finalized when the new regulations The Swedish Radiation Safety
Authority’s Regulation on Emergency Preparedness at Nuclear Facilities (SSMFS 2014:2), wereadopted in June 2014 and entered into force on January 1, 2015. Measures to meet the increased
requirements are implemented at the nuclear power plants.
The Swedish Radiation Safety Authority has reviewed the nuclear power plant licensees’
documentation for severe accident management. In July 2017, SSM issued orders to the three
nuclear power plants’ licensees to review and update their own instructions and guidelines,
with reference to INTERNATIONAL ATOMIC ENERGY AGENCY, Safety Guide No. NS-G-2.15 “Severe
Accident Management Programmes for Nuclear Power Plants”, IAEA, Wien 2009 and WENRA Safety
Reference Level for existing reactors Issue LM, 2014-09-14, and to inform SSM regularly until 2020
about their revisions and their experiences from exercises and training within severe accident
management (SSM2016-602-3, SSM2016-602-5 and SSM2016-602-7).
The Swedish Radiation Safety Authority’s Regulations concerning Safety in Nuclear Facilities(SSMFS 2008:1) were revised to meet the COUNCIL DIRECTIVE 2014/87/EURATOM of 8 July 2014
amending Directive 2009/71/Euratom establishing a Community framework for the nuclear safety of
nuclear installations. The revision was finalized when the new regulations The Swedish Radiation
Safety Authority’s Regulation on Safety in Nuclear Facilities (SSMFS 2017:1) were adopted in June2017 and entered into force on August 1, 2017.
The Swedish Radiation Safety Authority (SSM) issued in December 2012 the “Swedish Action
Plan for Nuclear Power Plants” following the ENSREG stress tests. The Swedish national action has
been developed with the intention to manage plant weaknesses identified by the EU stress tests
as well as by other forums such as the second extraordinary meeting under the Convention on
Nuclear Safety. Follow-up meetings have been held on international level to review the
implementation progress of the specified actions. A status report was published in December
2017 (2017 Status Report – Swedish National Action Plan).
Strålsäkerhetsmyndigheten
Swedish Radiation Safety Authority
SE-171 16 Stockholm

Tel:+46 8 799 40 00

E-post: registrator@ssm.se

Solna strandväg 96

Fax:+46 8 799 40 10

Webb: stralsakerhetsmyndigheten.se

Links:
SSMFS 2008:1 (Consolidated version with revisions from 2017:1), https://www.stralsakerhets
myndigheten.se/contentassets/cd1f200b9d6b4363b6977d971b608816/ssmfs-20081POST-FUKUSHIMA ACTION IMPLEMENTATION AT NUCLEAR INSTALLATIONS: HUMAN AND ORGANISATIONAL FACTORS LESSONS LEARNT, NEA No. 7578, © OECD 2023

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stralsakerhetsmyndighetens-foreskrifter-och-allmanna-rad-om- sakerhet-i-karntekniskaanlaggningar-konsoliderad-version
SSMFS
2014:2(Consolidated
versionwithrevisions
from
SSMFS
2017:2)https://www.stralsakerhetsmyndigheten.se/contentassets/c9d5e45cc17b41e79c7fcc106073
1da0/ssmfs-20142-stralsakerhetsmyndighetens-foreskrifter-om-beredskap-vidkarntekniska-anlaggningar
SSM2016-602-3
https://www.stralsakerhetsmyndigheten.se/contentassets/f57d0aa913dc4682bab2629f4101
1100/forelaggande-avseende-rutiner-for-hantering-av-svara-haverier-vid-ringhals-1-2-3och-4.pdf
SSM2016-602-5
https://www.stralsakerhetsmyndigheten.se/contentassets/f57d0aa913dc4682bab2629f4101
1100/forelaggande-avseende-rutiner-for-hantering-av-svara-haverier-vid-oskarshamn3.pdf
SSM2016-602-7
https://www.stralsakerhetsmyndigheten.se/contentassets/f57d0aa913dc4682bab2629f4101
1100/forelaggande-avseende-rutiner-for-hantering-av-svara-haverier-vid-forsmark-1-2och-3.pdf
Swedish Action Plan for Nuclear Power Plants
https://www.stralsakerhetsmyndigheten.se/contentassets/d086f05078bf4fd0b0ed69c932fc
1a58/swedish-action-plan-response-to-ensregs-request-for-nuclear-power-plantsdecember-2012.pdf
2017 STATUS REPORT – SWEDISH NATIONAL ACTION PLAN
Response to ENSREG’s request within the European Stress Tests, December
http://ensreg.eu/sites/default/files/attachments/stress_test_nacp_sweden_2017.pdf

2017

IAEA Safety Guide No. NS-G-2.15
http://www-pub.iaea.org/MTCD/publications/PDF/Pub1376_web.pdf
WENRA - Safety Reference Levels for Existing Reactors
http://www.wenra.org/media/filer_public/2014/09/19/wenra_safety_reference_level_for_e
xisting_reactors_september_2014.pdf
COUNCIL DIRECTIVE 2014/87/EURATOM
https://publications.europa.eu/en/publication-detail/-/publication/14d69d3c-13cd-11e401aa75ed71a1/language-en

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1. MITIGATION STRATEGIES (i.e., strategies for maintaining or restoring core cooling,
containment, and spent fuel pool cooling capabilities)a) Development of new mitigation strategies.
The Regulation of the Swedish Radiation Safety Authority (SSMFS) has been revised in
SSMFS 2017:2 and includes the new requirement for licensees to address accidents andsevere accidents that simultaneously involve or affect several units.
b) Modification of current mitigation strategies
The regulations in SSMFS 2017:2 have been modified to include specific requirements one.g. symptom based EOPs, periodical review and regular updates of instructions, taking
account of experience from exercises and lessons learned from accidents.
SSM has issued orders to the licensees to update their mitigative strategies anddocumentation with reference to the recommendations from IAEA NS-G 2.15. Required
actions involve e.g. additional studies to expand the spectrum of credible challenges tofission product boundaries, evaluation of current plant criteria for transition frompreventive to mitigatory domains, improved documented guidance with descriptions ofboth positive and negative potential consequences of proposed SAM actions.
c) Assessment and/or integration of the whole set of mitigation strategies (e.g. Extended
Damage Mitigation Guidelines, FLEX Guidelines, Severe Accident Guidelines, Emergency
Operating Guidelines, etc.).

d) Addition of new procedures/guidelines for newly installed systems or components or
new mobile equipment for improving mitigation capabilitiese) Changes, if any, in strategy design, implementation, use and adherencef) Others actions related to mitigation strategies
Based on national action plan a diversified mean of suppling feed water to the SFP haveto be implemented.
g) For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).
SSMFS 2017:2 is in force since August 1, 2017.
SSM orders to the licensees to be implemented by 2020.

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2. OTHER PROCEDURES AND GUIDELINES (to manage other elements of event or
emergency response not directly supporting the implementation of mitigation
strategies)a) Modification of procedures and guidelinesb) Changes, if any, in procedure design, implementation, use and adherence
SSM has ordered the implementation of an additional permanent preventive injection
system, independent as far as reasonably practicable from the existing mitigation
system.
c) Other changes or additions to procedures and guidelinesd) For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

3. STAFFINGa) Assessment of staffing needs (numbers and roles).
SSM has issued orders to the licensees to evaluate the staffing needs of specialists within
the technical support function resulting from the update of their mitigative strategies anddocumentation, with reference to the recommendations from IAEA NS-G 2.15.
b) Changes in plans and measures to augment on-site staffing levelsc) Other actions related to staffingd) For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).
SSM orders to the licensees to be implemented by 2020.

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4. ORGANIZATIONAL STRUCTURES,AUTHORITIES, AND SAFETY CULTURE

COMMUNICATION,DECISION

MAKINGa) Changes, if any, in the command & control organizations for accident management,
including single and multiple source term response, if applicable.
Response organization (SSMFS 2014:2):
Person with the authority to classify and to declare an emergency should be available at
all times and should, on request, be able to arrive at the central control room within 15
minutes.
The management in the response organization should be in place in the Emergency
Control Center (ECC) within 2 hours of a declared emergency.
b) Others changes to organization structures, coordination protocols, and guidance fordecision making and communications (both internal and external).
Communications equipment is addressed separately in topical area 6).

(Note:

SSM has issued orders to the licensees to clarify responsibilities and authorities within
the SAM organisation at the time of transition from the preventive to the mitigatory
domain with reference to the recommendations found in e.g. IAEA NS-G 2.15.
c) Changes, if any, in the requirements or guidelines for promoting healthy safety
culture.

d) For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).
SSMFS 2014:2 is in force since January 1, 2015.
SSM orders to the licensees to be implemented by 2020.

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5. PERSONNEL QUALIFICATIONS AND TRAININGa) Changes in job qualification requirements to address the need for new technical andnon-technical (e.g. for managing the unexpected, stress management) knowledge andabilities.

b) Changes in training program content to address new knowledge and ability needs
SSM has issued orders to the licensees with requests for information on how theexperience from emergency training and exercises is implemented into the SAM
guidelines.
c) Changes in training program structure (e.g. instruction/assessment methods or
frequency).

d) Other changes to personnel qualifications or training.

e) For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).
SSM orders to the licensees to be implemented by 2020.

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6. PLANT INSTRUMENTATION, CONTROLS, HUMAN-SYSTEM INTERFACES, AND
COMMUNICATIONS EQUIPMENTa) Addition or modifications to plant instrumentation and control to improve the usability
or availability of information to plant staff and their ability to take control actions (e.g.
spent fuel pool instrumentation, containment venting).
Action T1.LA.3 seismic monitoring in SNAP (2017 STATUS REPORT – SWEDISH NATIONALACTION PLAN Response to ENSREG’s request within the European Stress Tests, December2017). Seismic monitoring systems are installed at all Swedish sites. The licensees havecompleted the requested review of the procedures and training program for seismic
monitoring and implemented the revised procedures and programs.
SNAP T1.LA.8 – Improved early warning notification. The licensees have completed therequested investigation of the need of improved early warning systems for deteriorating
weather, as well as the provision of appropriate procedures to be followed by operators
when warnings are made. The licensees have introduced instructions for the control room
staff to check the weather forecast with the Swedish Metrological and Hydrological
Institute (SMHI) once per shift. The instructions include a check regarding possible effects
of extreme weather conditions at the nuclear power plants and the consideration ofsuitable mitigating measures.
SNAP T1.LA.10- Develop standards to address qualified plant walk-downs
Completed for all nuclear power plants. Extensive efforts have been undertaken to manage
resistance to earthquakes and other external events. As part of this, a walk-down
methodology has been defined and documented, and walk-downs have been performed.
The licensees use thedeterministic method represented by SMA (Seismic Margin Assessment), based on
guidelines in the EPRI NP-6041 SL.
b) Addition or modifications to plant communications capabilities (onsite/internal
communications and communication with off-site individuals/organizations).
Means of communications (SSMFS 2014:2):
Independence of public communication systems.
Radio communication system for collaboration with first responders.
Audio and visual (video) communication system for communication between the ECC andthe Radiation Safety Authority.
c) Other changes to plant or equipment human-system interfaces to improve humanperformance reliabilityd) For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).
SSMFS 2014:2 is in force since January 1, 2015.

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7. PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTSa) Provision of additional portable plant equipment or hand tools to support reliable
human performanceb) Design of portable plant equipment or hand tools to support reliable humanperformance (e.g. plug and play pipe connections, portable and installed equipment
painted with some specific color, equipment needed during a station blackout identified
with fluorescent labels)c) Provision of additional protective gear or modifications to protective gear to support
reliable human performance
Equipment (SSMFS 2014:2):
Action plans shall exist on how personal protective equipment should be provided to beconstantly available to the response organization on-site.
d) Modifications to work environments to support reliable human performance (e.g.
emergency lighting, flood protection)
Power supply (SSMFS 2014:2):- The ECC must be equipped with priority reserve power for at least one week ofcontinuous operation without refuelling.
e) Others changes to plant equipment/environments to support reliable performance of
mitigation actionsf) For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).
SSMFS 2014:2 is in force since January 1, 2015.

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8. WORK PLANNING, TECHNICAL SUPPORT, AND EMERGENCY RESPONSE FACILITIESa) Design and implementation of new or modified on-site facilities
Planning (SSMFS 2014:2):- The response organization should be dimensioned and designed to handle asimultaneous radiological emergency at all reactors during long-lasting situations.
b) Design and implementation of new or modified off-site facilities
Premises (SSMFS 2014:2):
Establishment of an off-site Logistics Center. The Logistics Center aims to provide
conditions for the response organisation to prepare measures for actions on-site.
The licensee shall take the necessary steps to be able to receive equipment and othersupport from external organizations to the extent reasonably foreseeable.
c) Changes to other facilities not previously addressedd) For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).
SSMFS 2014:2 is in force since January 1, 2015.

9. EMERGENCY RESPONSE PLANSa) Changes in emergency response plans or implementation methods
Response plan (SSMFS 2014:2):
Extended requirements concerning the contents of the plan.
Coordination against plan for physical protection.
b) Changes in the drills or exercises of the emergency response planc) Others changes to emergency response plansd) For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).
SSMFS 2014:2 is in force since January 1, 2015.

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10. EXTENDED (LONGER TERM) RESPONSEa) Additions or modifications to plans or capabilities to address on-site staff physiologicalneeds (e.g. food, water, sleep, hygiene) over the duration of time required to achieve asafe/stable plant state.

b) Additions or modifications to plans or capabilities to address on-site staff
psychological needs (e.g. fatigue/stress management, contact with families) over theduration of time required to achieve a safe/stable plant state.

c) Additions or modifications to plans or capabilities to relieve/augment on-site staff (e.g.
communication, transportation, site access).

d) Other additions or modifications to extended response planse) For any changes that you described for this topical area, please state theirimplementation schedule (either required or estimated, as applicable) and list any
opportunities for gaining relevant HOF lessons-learnt (e.g. related assessments,
validations, audits, inspections, training, drills, exercises).

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTUNITED STATES
Response to Phase 1 Information Request
provided by Nuclear Regulatory Commission

PREFACEThe following summary and questionnaire responses were completed in March 2018 based on
information available at that time. The information used as the basis for the summary andresponses included, in part, proposed rule language for the Nuclear Regulatory Commission’s(NRC’s) Mitigation of Beyond-Design-Basis Events (MBDBE) rulemaking and associated draft
guidance. Subsequent to completion of this summary, the NRC issued the final MBDBE rule
which became effective on September 9, 2019. The final rule includes substantive changes fromthe proposed rule described in this summary. Notably, requirements pertaining to strategies
and guidelines, staffing, organizational structure, communications capabilities, training andqualification, drills and exercises, and an integrated response capability were either removed or
modified. These changes, and the rationale for making these changes, is described in Section IV
of Federal Register notice for the final rule (84 FR 39718, Aug. 9, 2019). The Federal Register noticeis also available in NRC’s Agency wide Documents Access and Management System (ADAMS) at
ML19059A140.
Request for Summary of U.S. Response: The summary should briefly describe the actions takenby the regulatory authority and actions taken by the nuclear industry in your country (e.g. nuclear
power plant licensees, industry organisations) and identify the key requirements and guidance
documents pertaining to these actions. The summary should provide an overview level perspectiveon the scope of actions taken, the objectives of these actions, and any important inter-relationships
among these actions or between these actions and the pre-existing requirements and guidelines. In
developing the summary, your objective should be to create a narrative context that can aid
understanding of responses to the second part of this information request (i.e., the questionnaire
identified as item 2 above). To that end, we recommend that you familiarize yourself with thequestionnaire prior to writing your summary. You will find that the questionnaire focuses on thehuman and organizational factors elements, implications, and considerations associated with thepost-Fukushima actions being implemented in your country. To help keep the summary concise,details concerning the HOF elements, implications, and considerations can be provided in yourresponses to the questionnaire. If you so choose, those responses may simply be referenced orsummarized in your summary narrative.
Please provide citations for, or links to, the requirements and guidelines referenced in yoursummary so that these documents can be compiled by our task group. Your summary and the
documents referenced in your summary will be made available in an on-line library. Documents
you should consider referencing in your summary include:•

Requirements (e.g. regulations, orders, or other immediately effective requirements)•

Recommendations (e.g. policy statements)•

Demands for information/assessments•

Consensus standards or other guidelines deemed acceptable for meeting the regulatory
requirements•

Recommended practices or other guidelines deemed acceptable for meeting theregulatory body’s policy

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References in your summary should be to the publicly available primary source document.
Where applicable (e.g. regulations, orders, demands for information/assessments) the summary
should include, or cite as a reference, the timetable for plant operators to achieve fullcompliance. For requirements or guidance that is not yet final, please cite the most recent
publicly available draft along with a projection of when a final version is expected to be issued.
When readily available, an English language version of the referenced documents is preferred,
but other language version may also be cited as a reference.

US Summary of Actions taken to improve mitigation capability following theaccident at Fukushima Dai-ichi
A. Fukushima Dai-ichi
On March 11, 2011, the Great East Japan Earthquake, rated a magnitude 9.0, occurred off thecoast of Honshu Island, resulting in the automatic shutdown of 11 nuclear power plants (nuclear
power plants) at four sites along the northeast coast of Japan, including three of six reactors at
the Fukushima Dai-ichi Nuclear Power Plant (the three remaining plants were in outages). The
earthquake caused a large tsunami that is estimated to have exceeded 14 meters in height at
the Fukushima Dai-ichi Nuclear Power Plant. The earthquake and tsunami produced
widespread devastation across northeastern Japan, significantly impacting the infrastructure
and industry in the northeastern coastal areas of Japan. The earthquake and tsunami disabled
the majority of the external and internal electrical power systems at the Fukushima Dai-ichi
Nuclear Power Plant, creating a significant challenge for operators in responding to the event.
In addition, the combination of severe events challenged the implementation of emergency
plans and procedures.

B. Near-Term Task ForceThe U.S. Nuclear Regulatory Commission (NRC) Chairman’s tasking memorandum, COMGBJ-110002, “NRC Actions Following the Events in Japan,” established a senior-level task force referred
to as the “Near-Term Task Force” (NTTF) to conduct a systematic and methodical review of the
NRC’s regulations and processes to determine if the agency should make safety improvements
in light of the events in Japan. On July 12, 2011, the NRC staff provided the report of the NTTF
(NTTF Report) to the Commission as an enclosure to SECY-11-0093, “Near-Term Report andRecommendations for Agency Actions Following the Events in Japan.” The NTTF concluded that
continued U.S. plant operation and NRC licensing activities present no imminent risk to publichealth and safety. While the NTTF also concluded that the current regulatory system has served
the NRC and the public well, it found that enhancements to safety and emergency preparedness
are warranted and made 12 general recommendations for Commission consideration. In
examining the Fukushima Dai-ichi event for insights for reactors in the United States, the NTTF
addressed protecting against accidents resulting from natural phenomena, mitigating theconsequences of such accidents, and ensuring emergency preparedness. The NTTF found that
the Commission’s longstanding defense-in-depth philosophy, supported and modified asnecessary by state-of-the-art probabilistic risk assessment techniques, should continue to serveas the primary organizing principle of its regulatory framework. The NTTF concluded that theapplication of the defense-in-depth philosophy could be strengthened by including explicit
requirements for beyond-design-basis events.

C. Implementation of the Near-Term Task Force Recommendations
In response to the NTTF Report, the Commission directed the NRC staff on August 19, 2011, in
Staff Requirements Memorandum (SRM)-SECY-11-0093, to engage with stakeholders to review
and assess the NTTF recommendations in a comprehensive and holistic manner and to provide
the Commission with fully-informed options and recommendations. The NRC staff provided theCommission with recommendations for near-term action in SECY-11-0124, “Recommended
Actions To Be Taken without Delay from the Near-Term Task Force Report,” dated September 9,

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2011. The suggested near-term actions addressed several NTTF recommendations, including
NTTF recommendations 4, 8, and 9.3. In SRM-SECY-11-0124, dated October 18, 2011, theCommission directed the NRC staff to, among other things: initiate a rulemaking to address
NTTF recommendation 4, station blackout (SBO) regulatory actions, as an advance notice ofproposed rulemaking (ANPR); designate the SBO rulemaking associated with NTTF
recommendation 4 as a high priority rulemaking; craft recommendations that continue torealize the strengths of a performance-based system as a guiding principle; and consider
approaches that are flexible and able to accommodate a diverse range of circumstances andconditions. The regulatory actions associated with NTTF recommendation 4 evolved
substantially from this early Commission direction, and included issuance of Order EA-12-049,“Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for BeyondDesign-Basis External Events” (Mitigation Strategies Order), that, as implemented, ultimately
addressed all of NTTF recommendation 4 as well as other recommendations.
In SECY-11-0137, “Prioritization of Recommended Actions To Be Taken in Response to
Fukushima Lessons Learned,” dated October 3, 2011, the NRC staff, based on its assessment of
the NTTF recommendations, proposed to the Commission a three-tiered prioritization for
implementing regulatory actions stemming from the NTTF recommendations. The Tier 1
recommendations were those actions having the greatest safety benefit that could be
implemented without unnecessary delay. The Tier 2 recommendations were those actions thatneeded further technical assessment or critical skill sets to implement, and the Tier 3
recommendations were longer-term actions that depended on the completion of a shorter-term
action or needed additional study to support a regulatory action. On December 15, 2011, theCommission approved the staff’s recommended prioritization in SRM-SECY-11-0137.
Several NTTF recommendations provided the initial regulatory impetus for rulemaking
activities that would later be consolidated under the Mitigation of Beyond-Design-Basis Events(MBDBE) rulemaking, discussed further in Section D. These recommendations include:•

NTTF recommendation 4: strengthen SBO mitigation capability at all operating and newreactors for design-basis and beyond-design-basis external events;•

NTTF recommendation 7: enhance spent fuel pool (SFP) makeup capability andinstrumentation for the SFP;•

NTTF recommendation 8: strengthen and integrate onsite emergency response
capabilities such as emergency operating procedures (EOPs), severe accident
management guidelines (SAMGs), and extensive damage mitigation guidelines (EDMGs);•

NTTF recommendation 9: require that facility emergency plans address staffing, dose
assessment capability, communications, training and exercises, and equipment andfacilities for prolonged SBO, multi-unit events, or both;•

NTTF recommendation 10: pursue additional emergency protection topics related tomulti-unit events and prolonged SBO, including command and control structure and thequalifications of decision makers; and•NTTF recommendation 11: pursue emergency management topics related to decision
making, radiation monitoring, and public education, including the ability to deliverequipment to the site with degraded offsite infrastructure.

In response to input received from stakeholders, the NRC accelerated the schedule originallyproposed in SECY-11-0137. On February 17, 2012, the NRC staff recommended in SECY-12-0025,“Proposed Orders and Requests for Information in Response to Lessons Learned From Japan’sMarch 11, 2011, Great Tōhoku Earthquake and Tsunami,” that the Commission issue orders andrequests for information.
To address Tier 1 NTTF recommendation 4, the NRC issued the Mitigation Strategies Orderon March 12, 2012, requiring all U.S. nuclear power plant licensees to have additional capability
to mitigate beyond-design-basis external events through the implementation of strategies andguidelines that enable them to cope without their permanently installed alternating current (ac)electrical power sources for an indefinite period of time. These strategies would provide
additional capability to maintain or restore reactor core and spent fuel cooling, as well as protect
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the reactor containment. This order also addressed: portions of NTTF recommendation 9 torequire that facility emergency plans address prolonged SBOs and multi-unit events; portionsof NTTF recommendation 10 to pursue additional emergency protection topics related to multiunit events and prolonged SBO; and portions of NTTF recommendation 11 to pursue emergency
procedure topics related to decision making, radiation monitoring, and public education.
To address Tier 1 NTTF recommendation 7, the NRC issued Order EA-12-051, “Order
Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation” (SFPI Order), on
March 12, 2012, requiring all U.S. nuclear power plant licensees to have a reliable indication of
the water level in associated SFPs.
To address Tier 1 NTTF recommendation 8, the NRC issued an ANPR on April 18, 2012 (77 FR
23161), to engage stakeholders in rulemaking activities associated with the methodology for the
integration of onsite emergency response processes, procedures, training and exercises.

D. Consolidation of Regulatory Efforts
While developing the rulemakings discussed in the previous section, the NRC staff recognizedthat efficiencies could be gained by consolidating the rulemaking efforts due to the interrelationships among the proposed changes. The NRC staff recommended to the Commissionthat rulemaking activities to address NTTF recommendations 4, 7, 8, 10.2, and 11.1, as well as
portions of NTTF recommendation 9, be consolidated in one effort that became the MBDBE
rulemaking. (See COMSECY-13-0002, “Consolidation of Japan Lessons Learned Near-Term Task
Force Recommendations 4 and 7 Regulatory Activities,” dated January 25, 2013;
COMSECY-13-0010, “Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan
Lessons Learned,” dated March 27, 2013; and SECY-14-0046, “Fifth 6-Month Status Update on
Response to Lessons Learned From Japan’s March 11, 2011, Great Tōhoku Earthquake andSubsequent Tsunami,” dated April 17, 2014.)
The NRC staff consequently provided a draft final version of the MBDBE rule to theCommission for consideration in SECY-16-0142. The draft final MBDBE rule combines the two
NRC activities for which documents have been published in the Federal Register - Onsite
Emergency Response Capabilities (RIN 3150-AJ11; NRC-2012-0031) and Station Blackout
Mitigation Strategies (RIN 3150-AJ08; NRC-2011-0299). The MBDBE rule identification number
and regulations.gov docket number are RIN 3150-AJ49 and NRC-2014-0240, respectively. These
consolidations were intended to:•

Align the regulatory framework with ongoing industry implementation efforts to
produce a more coherent and understandable regulatory framework. Given thecomplexity of these requirements and their associated implementation, the NRC
concluded that this was an important objective for the regulatory framework.

•

Reduce the potential for inconsistencies and complexities between the related
rulemaking actions that could occur if the efforts remained as separate rulemakings.

•

Facilitate better understanding of the requirements for both internal and external
stakeholders, and thereby lessen the impact on internal and external stakeholders who
would otherwise need to review and comment on multiple rulemakings while crossreferencing both proposed rules and sets of guidance documents.

E. Industry Response
In response to the Mitigating Strategies Order, the nuclear industry developed a strategy called“FLEX,” which is the foundation of its overall response. The FLEX approach adds equipment—such as pumps, generators, and battery chargers—in diverse locations throughout the plant site.
The equipment is commercial-grade with engineered specifications, with provisions forequipment testing and maintenance. The strategy is flexible in that it does not mandate
installation of permanent equipment. Instead, it specifies that the plant sites obtain, prepare,and maintain equipment that could be used to mitigate virtually any event. The equipment will
be able to connect to a variety of locations for injecting coolant and providing a continuous

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supply of electricity. The objective of FLEX is to ensure plant-specific capability to cope for anindefinite period through a combination of installed plant capacity, portable onsite equipment,
and offsite resources.
The FLEX strategy was informed by the industry’s response to the September 11, 2001,
terrorist attacks, in which additional equipment—such as portable generators, water pumps,
hoses, and batteries—were put in place to mitigate the effects of possible large fires andexplosions. The FLEX approach offers an additional layer of mitigation for events that are
beyond what a plant was originally designed to withstand. Multiple means of obtaining power
and water fulfill the key safety functions of reactor cooling, containment integrity, and SFP
cooling that would prevent damage to nuclear fuel and protect the public and the environment.
FLEX equipment ranges from diesel-driven pumps and electric generators to ventilationfans, hoses, fittings, cables, and communications gear. The new equipment will be stored atdiverse locations at the sites and protected to ensure that it can be used if other systems in a
facility’s multilayered safety strategy are compromised.
The U.S. nuclear power industry has also established two national response centers (one in
Memphis, Tennessee, and another in Phoenix, Arizona) for the purposes of extra equipment
storage and rapid deployment.
In response to the SFPI Order, all operating reactors are installing reliable level
instrumentation in their SFPs. During the accident at Fukushima, the plants lost the ability tocool the SFPs and plant operators could not determine how much water was in the pools. This
caused concern that if enough water boiled away or was otherwise lost, the spent fuel rods could
become uncovered as the water receded and potentially release significant amounts ofradiation. It was later learned that the spent fuel was always covered, but the information gap
diverted significant attention and extremely limited resources from more important tasks
during the accident. The SFP level instrumentation order would preclude that from happening.
Licensees were required to promptly start implementation of the first two orders andcomplete full implementation no later than two refueling outages after issuance of the orders
or by December 31, 2016, whichever came first. The majority of operating power reactor
licensees have achieved compliance with the two orders at present, with some adjusted
compliance dates being granted to account for plant-specific justifications such as theinstallation of hardened containment venting systems.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTQuestionnaire on Post-Fukushima Actions to Improve Mitigation Capabilities for
Extreme External Events and Severe Accidents
Instructions for Respondents:
The following questionnaire is to be answered by nuclear regulatory authorities as acomplement to your Summary of Actions (i.e. response to information request 1).
Objective: The objective of the questionnaire is to understand which actions described in your
Summary of Actions were intended, or are expected, to improve the ability of individuals andorganisations to respond to extreme external events or severe accidents. The information you
provide in response to the questionnaire will be used as background by the task group to
understand the operating experiences of licensees (operating companies) implementing thepost-Fukushima requirements and guidance. As described in the project overview, thecollection of such operating experience/lessons-learnt will be conducted in the next phase ofthis effort.
Main Topics: Each item in the questionnaire requests the regulatory authority to describe
actions taken in their country in one of 10 main topic areas. The main topic areas are thenumbered items of the questionnaire and are written in “UPPER CASE BOLD PRINT.” Together
the 10 main topic areas aim to cover the spectrum of topics where actions may have been
implemented to address the human and organizational challenges presented by extreme
external events and severe accidents.
Sub-topics: Each main topic area includes several sub-topics. These sub-topics are prompts orsuggestions for specific information to consider when developing a response. The subtopic
prompts are not intended to limit your response. Please describe any requirements, guidelines,
actions or other information you consider relevant to the topical area.
Response Format: Depending on the level of detail provided in your Summary of Actions, you
may choose to repeat or cite a portion of your summary as a response to the items of thequestionnaire below or provide additional details such as citing a specific portion of arequirement or guideline document. If the specific item addressed by the questionnaire is not a
subject of, or affected by, the actions in your country following the Fukushima accident, a “notapplicable” or similar response is acceptable.
Response Content: Your responses should describe any post-Fukushima actions that have beentaken or planned that are intended or expected to improve the ability of individuals andorganisations to respond to extreme external events or severe accidents.
Types of Agency/Industry Actions to Describe: Describe any actions by you, the regulatory
authority, and industry organizations in your country. Such actions may include but are notlimited to requirements, recommendations, demands for information or assessments,
guidelines, regulatory oversight. Please include a brief statement regarding the intent/objectiveof the action relative to supporting human and organizational performance.
Scope of Individual/Organizational Responses to Consider: The scope of individual andorganizational performance to consider when listing actions (as described above) should
include, but is not limited to, actions by: (1) control room operators, (2) equipment operators orother field personnel installing/operating equipment in the field, (3) personnel to prevent or
mitigate adverse effects of the environment (e.g. external flooding), (4) personnel in work
control centers, technical support centers, emergency operations facilities or like facilities, (5)personnel in emergency response organization or like organisations managing off-siteradiological responses, (7) personnel in off-site organizations (e.g. local police, fire, medical
personnel), (8) actions by senior officials with decision making authority for site responses
under conditions of extreme external events and severe accidents.
Time Period to Consider: The time period to be considered for the individual/organisational
actions (described above) should include the onset of the event through maintaining the plantin a safe/stable state, prior to the initiation of recovery actions.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTFor each of the following topical areas, describe: (1) any regulatory agency or industry
organization actions that have been taken, or are planned, that are intended or expected to
improve the ability of individuals and organisations to respond to extreme external eventsor severe accidents, the implementation schedules for the changes, and (3) any opportunities
to gain HOF lessons-learnt regarding these changes.
Responses to Questionnaire on Post-Fukushima Actions to Improve Mitigation Capabilities for
Extreme External Events and Severe Accidents

1.

MITIGATION STRATEGIES (i.e., strategies for maintaining or restoring core cooling,
containment, and spent fuel pool cooling capabilities)a)

Development of new mitigation strategies. On March 12, 2012, the NRC issued Order
EA-12-049, “Order Modifying Licenses With Regard to Requirements for Mitigation
Strategies for Beyond-Design-Basis External Events” (the Mitigation Strategies Order),requiring all U.S. nuclear power plant licensees to have additional capability to mitigate
beyond-design-basis external events through the implementation of strategies andguidelines that enable them to cope without their permanently installed alternating current(ac) electrical power sources for an indefinite period of time. These strategies would provide
additional capability to maintain or restore reactor core and spent fuel cooling, as well asprotect the reactor containment. Licensees were required to achieve compliance on aschedule determined by their refueling outage schedules, allowing them to take necessary
measurements, etc., to support planning during one outage in order to support planning forthe installation of any necessary modifications during the next outage. The Mitigation
Strategies Order included a backstop compliance date of December 31, 2016 for compliance.
Guidance for the Mitigation Strategies Order is provided in Japan Lessons-Learned
Directorate Interim Staff Guidance document (JLD-ISG-2012-01), “Compliance with Order
EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies
for Beyond-Design-Basis External Events,” which endorses an industry-developed guideline,
the Nuclear Energy Institute (NEI) document 12-06, “Diverse and Flexible Coping Strategies(FLEX) Implementation Guide.” Human and organizational factors lessons learned in theimplementation of the mitigation strategies by nuclear power plant licensees have been
incorporated into the guidance documents in revisions published since their initialissuance. Further lessons learned will be incorporated in the regulatory guides for the
MBDBE Rule when published.

b)

Modification of current mitigation strategies.
The Mitigation Strategies Order built upon operating experience and lessons learned fromthe implementation of mitigation strategies for the loss of a large area of the plant due tofires or explosion that were initially required by Order EA-02-026, “Order for Interim
Safeguards and Security Measures,” dated February 25, 2002, following the terrorist eventsof September 11, 2001. While the NRC did not require that the existing mitigation strategies
be modified under the Mitigation Strategies Order, that option was available for licensees asa potential method of achieving compliance.

c)Assessment and/or integration of the whole set of mitigation strategies (e.g. Extended
Damage Mitigation Guidelines, FLEX Guidelines, Severe Accident Guidelines, Emergency
Operating Guidelines, etc.).
Integration of the whole set of mitigation strategies is addressed in the draft final Mitigationof Beyond-Design-Basis events (MBDBE) rule, currently under consideration by theCommission. Each applicant or licensee subject to the draft final MBDBE rule would be
required to develop, implement, and maintain an integrated response capability that
includes Flex Support Guidelines (FSGs), reevaluated hazards strategies and guidelines oralternative approaches as applicable, Extensive Damage Mitigation Guidelines (EDMGs),sufficient staffing, communications capabilities, and a supporting organizational structurewith defined roles, responsibilities, and authorities for directing and performing thesestrategies, guidelines, and procedures. The MBDBE rule would require integration of thisPOST-FUKUSHIMA ACTION IMPLEMENTATION AT NUCLEAR INSTALLATIONS: HUMAN AND ORGANISATIONAL FACTORS LESSONS LEARNT, NEA No. 7578, © OECD 2023

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new capability with existing EOPs. The basis for this framework is explained in the following
discussion.
The requirements in Title 10 of the Code of Federal Regulations (CFR), §50.155(b)(1) for FSGs
makes generically applicable requirements previously imposed on licensees by the
Mitigation Strategies Order.
The nuclear industry developed EDMGs following the terrorist events of September 11, 2001,
in response to security advisories, orders, and license conditions issued by the NRC that
required licensees to develop and implement guidance and strategies intended to maintainor restore core cooling and containment and spent fuel pool (SFP) cooling capabilities under
the circumstances associated with the loss of large areas of the plant due to fire or explosion.
The EDMGs further extend the range of initiating events and plant damage states for which
strategies and guidelines are available for use by operators to include the loss of large areasof the plant and a subsequent impairment of the operability and functionality of structures,
systems, and components (SSCs) that are within that area. The Nuclear Energy Institute(NEI) 06-12, Revision 2 (the NRC-endorsed guidance for the requirements associated with
EDMGs), provides appropriate coordination of the EDMGs with the SAMGs through its
guidance that the EDMGs “must be interfaced with existing SAMGs so that potential
competing considerations associated with implementing these and other strategies areappropriately addressed.”
Based upon these considerations, the NTTF recommended that the NRC require licensees
to further integrate EOPs, SAMGs and EDMGs, including a clarification of transition points,
command and control, decision making, and rigorous training that includes conditions thatare as close to real accident conditions as feasible.
Based on the lessons learned from the Fukushima Dai-ichi event, the range of initiating
events and plant damage states for which strategies and guidelines are available for use by
operators was further extended through the development of mitigation strategies forbeyond-design-basis external events in response to the Mitigation Strategies Order. The
development and implementation of this set of strategies and guidelines was accomplishedgiving consideration to other Near-Term Task Force (NTTF) recommendations to the extent
practical. In order to provide better integration with the EOPs, the FSGs leave the designationof command and control and decision making functions within the EOPs or SAMGs, as
appropriate. Consistent with the recommendation in the NTTF Report, this rule requiresthat EDMGs and FSGs, including strategies and guidelines or alternative approaches, asapplicable, for reevaluated hazards, be integrated with EOPs. This maintains EOPs as thecentral element of a licensee’s initial response capability.
In establishing a requirement for an integrated response capability, the NRC considered thefact that these strategies, guidelines, and procedures were developed at separate times overa period of several decades and that the associated efforts have been focused on responding
to different types of initiating events and plant damage states. As a result, these strategies,
guidelines, and procedures may not properly reflect consideration of the interfaces (e.g.
procedure transitions), dependencies (e.g. reliance on common systems or resources) andinteractions (e.g. alignment of response strategies) among strategies, guidelines, andprocedures that may be used in combination, either consecutively or concurrently, tomitigate a design-basis or beyond-design-basis event.
Additionally, the NRC considered that these strategies, guidelines, and procedures are notused by a single licensee organizational unit but will often require coordination and transfer
of responsibilities among licensee organizational units. For example, in the event of the lossof the main control room, the EDMGs may be implemented, and therefore initiated anddirected by knowledgeable and available site personnel until coordination andaugmentation efforts enable transition to a more stable command and control structure.
The mitigation strategies for beyond-design-basis external events, though initiated by themain control room complement of licensed operators, may require coordination with andaugmentation by offsite organizations. Further, and as noted previously, there are potential
accident scenarios in which a licensee might employ strategies from more than one of thesestrategies, guidelines, and procedures during its response to an accident. One plausible
sequence is for operators to take initial action using the EOPs, supplement these actions

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with actions under the FSGs, and ultimately transition to actions under the SAMGs. Such an
accident progression engages and requires the coordination of multiple licensee
organizational units.
In light of the preceding considerations, the draft final MBDBE rule would require that the
mitigation strategies, guidelines, and procedures, staffing, and supporting organizational
structure be developed, implemented, and maintained such that they function as an“integrated” response capability. The intent of this integrated response capability
requirement is to ensure that applicants and licensees establish and maintain a functional
capability to produce a coordinated and logical response under a wide range of accident
conditions. The intent is not to require physical integration (e.g. organizations need not bemerged and strategies, guidelines, and procedures need not be combined), but rather torequire a functional integration of the elements of the response capability.
To achieve this functional integration, the NRC expects that applicants and licensees haveaddressed the interfaces, dependencies, and interactions among the elements of their
response capability. For example, functional integration of the strategies, guidelines, andprocedures would ensure that transition points are explicitly identified and conflicts
between strategies are eliminated to the extent practical. Functional integration of responseorganizations ensures that organizations working together to use these strategies,
guidelines, and procedures (e.g. to coordinate actions or provide support) have clearly
defined lines of communication among the organizations, as well as clearly defined
authorities and responsibilities relative to each other, such that there are no gaps orconflicts.
d)Addition of new procedures/guidelines for newly installed systems or components or new
mobile equipment for improving mitigation capabilities.
In parallel with activities on the Mitigation Strategies Order, the NRC issued a separate order
to licensees of Boiling-Water Reactors (BWRs) with General Electric (GE) Mark I and II
containments, NRC Order EA-12-050, “Order Modifying Licenses with Regard to Reliable
Hardened Containment Vents.” This order was subsequently withdrawn and replaced by
NRC Order EA-13-109, “Order Modifying Licenses with Regard to Reliable Hardened
Containment Vents Capable of Operation under Severe Accident Conditions.” Regulatory
guidance for NRC Order EA-13-109 is contained in JLD-ISG-2013-02, “Compliance with Order
EA-13-109, ‘Order Modifying Licenses with Regard to Reliable Hardened Containment Vents
Capable of Operation under Severe Accident Conditions,’” and the industry-developed
document NEI 13-02, “Industry Guidance for Compliance with Order EA-13-109.” Additional
regulatory guidance is contained in JLD-ISG-2015-01, “Compliance with Phase 2 of Order EA13-109, ‘Order Modifying Licenses with Regard to Reliable Hardened Containment Vents
Capable of Operation under Severe Accident Conditions.’” The NRC Order EA-13-109
required installation of new structures, systems and components for the removal of heatfrom GE Mark I and II containments for BWRs, and action that supports the implementationof the mitigation strategies requirement to maintain or restore containment capabilities.
The order required that those licensees subject to it develop, implement and maintainprocedures necessary for the safe operation of the hardened containment venting system
required by the order when normal and backup power is available and during an extended
loss of AC power. Similar to the compliance schedule for the Mitigation Strategies Order,
Order EA-13-109 has a rolling schedule based on licensee refueling outages with a backstop
compliance date of June 30, 2019.
Additionally, the NRC Order EA-12-051, “Order Modifying Licenses with Regard to Reliable
Spent Fuel Pool Indication,” required licensees to install instrumentation and to establish
and maintain procedures for the testing, calibration and use of that instrumentation.
Regulatory guidance for those procedures is contained in NEI 12-02, “Industry Guidance forCompliance with NRC Order EA-12-051, ‘To Modify Licenses with Regard to Reliable Spent
Fuel Pool Instrumentation,’” as endorsed by JLD-ISG-2012-03, “Compliance with Order EA12-051, Reliable Spent Fuel Pool Instrumentation.” The remainder of procedure/guideline
development for new systems, components and mobile equipment is under the guidance
for the Mitigation Strategies Order.

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APPENDIX A: REGULATORY AUTHORITY RESPONSES TO PHASE 1 INFORMATION REQUESTe)Changes, if any, in strategy design, implementation, use and adherence
No changes have been mandated for the strategy design, implementation, use or adherenceby the NRC. There is the potential for changes resulting from the MBDBE Rulemaking
currently before the Commission in draft final form under SECY-16-0142, most notably inthe proposed requirement for licensees to address the reevaluated flooding and seismic
hazards resulting from the NTTF Recommendation for reevaluation of those hazards. The
NRC issued a request for information under 10 CFR 50.54(f) in conjunction with the issuanceof the Mitigation Strategies Order; in response to this request, operating power reactor
licensees have submitted evaluations of what the flooding and seismic hazards, including
sufficient margin to account for the evaluation process, would have been if they were
submitting applications for early site permits or combined licenses for those sites underpresent day regulations and guidance. If implemented as proposed by the NRC staff, the
MBDBE Rule would require licensees to consider the new hazard information in their
mitigation strategies or otherwise address it.

f)Others actions related to mitigation strategies
All actions related to mitigation strategies are as described in the preceding responses.

g)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
The implementation schedule for the mitigation strategies requirements has been
completed for the majority of operating power reactors in the United States. The
implementation of the hardened containment venting systems was required based upon
the refueling outage schedules of individual plants with a backstop date of June 30, 2019.

2.

OTHER PROCEDURES AND GUIDELINES (to manage other elements of event or emergency
response not directly supporting the implementation of mitigation strategies)a)

Modification of procedures and guidelinesb)

Changes, if any, in procedure design, implementation, use and adherencec)Other changes or additions to procedures and guidelinesd)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
Separately from the development and implementation of the mitigation strategies under
the Mitigation Strategies Order, the US Nuclear Power Industry regularly responds to lessons
learned and operating experience. Specifically in response to the Fukushima Daiichi
Accident, operating power reactor licensees of the US NRC have modified their dose
assessment capability to be able to assess multiple source terms and have modified theirsevere accident management guidelines. Both of these actions were accomplished undervoluntary industry initiatives that the NRC monitors.

3.

STAFFINGa)

Assessment of staffing needs (numbers and roles).

b)

Changes in plans and measures to augment on-site staffing levelsc)Other actions related to staffing
On March 12, 2012, the NRC issued a request for information under 10 CFR 50.54(f) that
included the reevaluation of on-site levels necessary to respond to a site-wide multiple unit
emergency and to support the execution of the mitigation strategies under the Mitigating
Strategies Order. Licensees in the US have completed their evaluations of the former and

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are completing their evaluations of the latter in conjunction with their achievement ofcompliance with the Mitigation Strategies Order.
The draft final Mitigation of Beyond-Design-Basis Events (MBDBE) rule would require thatlicensees provide the staffing necessary for having an integrated response capability tosupport implementation of the strategies, guidelines, and alternative approaches it would
require. To be effective, staffing for an expanded response capability should include thetrained and qualified individuals who would be relied upon to analyze, recommend,
authorize, and implement the mitigation strategies. The staffing required of a licensee by
the draft final MBDBE rule is that staffing necessary to directly support the assessment andimplementation of the range of mitigation strategies developed, implemented, andmaintained by the license that are intended to maintain or restore the functions of corecooling, containment, and SFP cooling.
The recommended minimum positions and staffing levels for emergency plans were
initially provided in 1980 in NUREG-0654/FEMA-REP-1, “Criteria for Preparation and
Evaluation of Radiological Emergency Response Plans and Preparedness in Support of
Nuclear Power Plants,” Revision 1. In 2011, the NRC issued the “Enhancements to Emergency
Preparedness Regulations” final rule (Emergency Preparedness final rule) (76 FR 72560;
November 23, 2011) to amend, in part, Title 10 of the Code of Federal Regulations part 50,
appendix E, to address concerns about the assignment of tasks or responsibilities to on-shift
emergency response organization (ERO) personnel that would potentially overburden themand prevent the timely performance of their functions under the emergency plan. Licensees
must have enough on-shift staff to perform specified tasks in various functional areas of
emergency response 24 hours a day, 7 days a week. The draft final MBDBE rule addresses
the staffing requirements for the expanded response capabilities for on-shift response andthe ERO.
The draft final MBDBE rule would require adequate staffing to implement the strategies,
guidelines, and alternative approaches required by § 50.155(b) with the EOPs without
requiring further analysis to supplement analyses that were completed as a result of the
Mitigation Strategies Order or the Emergency Preparedness final rule. Staffing levels shouldbe established to ensure that if strategies are executed, completing them would not bedelayed due to the lack of qualified personnel. The draft final MBDBE rule contains drill andtraining requirements that provide assurance that the licensee staff are properly trained
and can demonstrate implementation of the mitigation strategies and guidelines. These
additional requirements also provide assurance that licensees maintain sufficient staffing
levels, because insufficient staffing levels would result in ineffective implementation of thestrategies.
d)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
The changes described in this topical area are contained in a draft final rule currently underconsideration by the Commission. The draft final rule proposes an implementation
schedule for operating power reactor licensees within two or three years of the effective
date of the rule depending on the reactor type. This is an estimated implementation
schedule.

4.

ORGANIZATIONAL STRUCTURES, COMMUNICATION, DECISION MAKING AUTHORITIES, AND
SAFETY CULTURE
a)Changes, if any, in the command & control organizations for accident management,
including single and multiple source term response, if applicable.

b)

Others changes to organization structures, coordination protocols, and guidance fordecision making and communications (both internal and external). (Note: Communications
equipment is addressed separately in topical area 6).

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The draft final Mitigation of Beyond-Design-Basis Events (MBDBE) rule currently before theCommission for consideration would require licensees to have a supporting organizational
structure with defined roles, responsibilities, and authorities for directing and performing
the strategies, guidelines, and alternative approaches required by § 50.155(b) of Title 10 of
the Code of Federal Regulations (CFR). The objective is to ensure that licensees address theorganizational implications of: 1) implementing the Flex Support Guidelines (FSGs); and 2)
integrating the FSGs, reevaluated hazard strategies and guidelines or alternative
approaches, and Extensive Damage Mitigation Guidelines (EDMGs) with the Emergency
Operating Procedures (EOPs) such that organizational units responsible for on-site accident
mitigation (e.g. main control room, emergency operations facility, and technical support
center staff) can support a coordinated implementation of these procedures and guidelines
under the challenging conditions presented by beyond-design-basis events.
Additional requirements exist in 10 CFR part 50, appendix E, section IV.A, “Organization,”for the inclusion within the licensee’s emergency plan of a description of the organization
for coping with radiological emergencies, including definition of authorities,
responsibilities, and duties of individuals assigned to the licensee’s emergency organizationand the means for notification of such individuals in the event of an emergency. These
requirements provide the command and control structure for use in the execution of theemergency plan. The current 10 CFR part 50, appendix E, sections IV.A.2. and IV.A.5., further
require that the emergency plan include: 1) a detailed description of the authorities,
responsibilities, and duties of the individual(s) who will take charge during an emergency;
2) plant staff emergency assignments; 3) authorities, responsibilities, and duties of an onsite
emergency coordinator who shall be in charge of the exchange of information with offsite
authorities responsible for coordinating and implementing offsite emergency measures;and 4) the identification, by position and function to be performed, of other employees ofthe licensee with special qualifications for coping with emergency conditions that may
arise.
The need for defined command and control structures and responsibilities for use inbeyond-design-basis conditions was recognized in the course of the development of theguidance and strategies for the former § 50.54(hh)(2), now § 50.155(b)(3). As stated in theindustry’s guidance document for that set of requirements, NEI 06-12, Revision 2,“[e]xperience with large scale incidents has shown that command and control execution
can be a key factor to mitigation success.” The guidance and strategies developed for thateffort include an EDMG for initial response to provide a bridge between normal operationalcommand and control and the command and control that is provided by the ERO in theevent that the normal command and control structure is disabled. The NRC considers thatthe actions taken in the development of the EDMGs for initial response for the guidance andstrategies for § 50.155(b)(3) continue to be adequate for compliance with the MBDBE rule for
EDMGs. The regulatory guidance for the draft final MBDBE rule, specifically draft final RG
1.226, which endorses industry guidance in NEI 12-06, specifies that the existing commandand control structure will be used for transition to the SAMGs.
All previous requirements did not specify a command and control structure for a multi-unit
event that includes the potential need for acquisition of offsite assistance to support onsite
event mitigation. Additionally, these requirements were not understood to require such a
response because they preceded the Fukushima Dai-ichi event and the regulatory actions
that stemmed from that event. As a practical matter, the current command and control
structures, including any changes that resulted from the implementation of the Mitigation
Strategies Order requirements, are sufficient to ensure that the functional objectives of the
MBDBE rule are achieved. The NRC requested stakeholder feedback on this issue in the
proposed rule (refer to section VI, “Specific Requests for Comments,” of the proposed rule
Federal Register notice). Based on that feedback, which suggested that the MBDBE rule should
contain its own command and control requirements, the NRC staff has concluded that it isappropriate to require command and control for the integrated response capability in thedraft final rule in order to address the additional area of command and control for multiunit events, including the need for the acquisition of offsite assistance.

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Changes, if any, in the requirements or guidelines for promoting healthy safety culture.
The NRC’s final Safety Culture Policy Statement (SCPS) was published on June 14, 2011. The
SCPS provides the NRC’s expectation that individuals and organizations performing
regulated activities establish and maintain a healthy safety culture that recognizes thesafety and security significance of their activities and the nature and complexity of theirorganizations and functions. Because safety and security are the primary pillars of the NRC’s
regulatory mission, consideration of both safety and security issues, commensurate with
their significance, is an underlying principle of the SCPS. SCPS was established as a resultof work already in progress when the Fukushima Daiichi accident took place and no changes
were necessary as a result of the accident.

d)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
The changes described in this topical area are contained in a draft final rule currently underconsideration by the Commission. The draft final rule proposes an implementation
schedule for operating power reactor licensees within two or three years of the effective
date of the rule depending on the reactor type. This is an estimated implementation
schedule.

5.

PERSONNEL QUALIFICATIONS AND TRAININGa)

Changes in job qualification requirements to address the need for new technical and nontechnical (e.g. for managing the unexpected, stress management) knowledge and abilities.

b)

Changes in training program content to address new knowledge and ability needsc)Changes in training program structure (e.g. instruction/assessment methods or frequency).

d)

Other changes to personnel qualifications or training.
The Mitigation Strategies Order specified that compliance with the order includes thenecessary training of personnel. This is addressed in the regulatory guidance for the
Mitigation Strategies Order in Nuclear Energy Institute (NEI) 12-06, Section 11.6. Compliancewith the training requirements of the Mitigation Strategies Order are as described previously
for the remainder of the elements of the order (see p. 6 of the narrative summary).
The mitigation of the effects of beyond-design-basis events using the strategies andguidelines is principally accomplished through manual actions rather than automated plant
responses. Additionally, the instructions provided for event mitigation may be largely
provided as high level strategies and guidelines rather than step-by-step procedures. The
use of strategies and guidelines supports the ability to adapt the mitigation measures to thespecific plant damage and operational conditions presented by the event. However, effective
use of this flexibility depends upon the knowledge and abilities of personnel to selectappropriate strategies or guidelines from a range of options and implement mitigation
measures using equipment or methods that may differ from those employed for normal
operation or design-basis event response. As a result, the NRC considers personnel training
and qualification necessary to ensure that individuals are capable of effectively performing
the roles and responsibilities established in the strategies and guidelines that are requiredby this rule.
The NRC acknowledges that licensee training programs, such as those required for licensed
operators under Title 10 of the Code of Federal Regulations (CFR) part 55, “Operators’ Licenses,”
the programs for plant personnel specified under § 50.120, “Training and qualification of
nuclear power plant personnel,” and the training for emergency response personnel
required by 10 CFR part 50, appendix E, section IV.F, “Training,” likely provide for theknowledge and abilities required for performing activities described in the strategies andguidelines that are required by this rule. Nevertheless, as noted previously, the strategies
and guidelines may use new methods or equipment that require knowledge and abilities
not currently addressed under existing training programs and, as a result, there may be gaps
in these training programs that must be addressed to support effective use of the strategies

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and guidelines. Accordingly, the draft final Mitigation of Beyond-Design-Basis Events(MBDBE) rule would further require that licensees provide for the training of personnel using
the systems approach to training (SAT) process as defined in § 55.4, except for elements
already covered under other NRC regulations. The SAT process, which is acceptable formeeting training requirements under 10 CFR part 55 and § 50.120, also is appropriate forlicensee identification and resolution of any current gaps or future modifications topersonnel training that may be necessary to provide for the training of personnel
performing activities described in the mitigation strategies and guidelines that are requiredby this final rule. The NRC recognizes that there are other training programs that are
currently acceptable for meeting other regulatory required training (e.g. 10 CFR part 50,
appendix E, section IV.F) that do not use the SAT process. In light of the existence of thesetraining programs, which have been found acceptable for more frequently occurring designbasis events, the NRC has determined that these training programs can meet the needs forcommon elements with beyond-design-basis event mitigation. Therefore, the NRC is not
requiring licensees to revise these training programs to use the SAT process to meet the
MBDBE rule requirements. Licensees would be required to use the SAT process for newly
identified training requirements supporting the effective use of the strategies andguidelines that are required by this rule.
By using the SAT process, licensees identify and train on any additional tasks that arenecessary to implement the strategies and guidelines for the mitigation of beyond-designbasis events as defined in this final rule. The additional tasks identified are incorporated
into the training program to ensure appropriate training is administered for each qualified
individual designated to implement the strategies and guidelines required by this rule.
e)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
The changes described in this topical area are contained in a draft final rule currently underconsideration by the Commission. The draft final rule proposes an implementation
schedule for operating power reactor licensees within two or three years of the effective
date of the rule depending on the reactor type. This is an estimated implementation
schedule. The general need for training of the operators under the Mitigating Strategies
Order has been implemented for the majority of operating power reactor licensees, althoughextended compliance dates have been established for some licensees to account for plantspecific circumstances such as the installation of hardened containment venting systems.

6.

PLANT
INSTRUMENTATION,
COMMUNICATIONS EQUIPMENTa)

CONTROLS,HUMAN-SYSTEMINTERFACES,

AND

Addition or modifications to plant instrumentation and control to improve the usability oravailability of information to plant staff and their ability to take control actions (e.g. spent
fuel pool instrumentation, containment venting).
While the Mitigation Strategies Order itself does not require the addition of or modification
to plant instrumentation and control, this issue is addressed in the guidance contained in
Nuclear Energy Institute (NEI) 12-06, Section 3.2.10, which states that:
Actions specified in plant procedures/guidance for loss of ac power are predicated on use of
instrumentation and controls powered by station batteries. In order to extend battery life, aminimum set of parameters necessary to support strategy implementation should be
defined. The parameters selected must be able to demonstrate the success of the strategies
at maintaining the key safety functions as well as indicate imminent or actual core damage
to facilitate a decision to manage the response to the event within the Emergency Operating
Procedures and FLEX Support Guidelines or within the SAMGs.
NEI 12-06 provides typical sets of parameters for instrumentation that would be needed andstates that a “plant-specific evaluation may identify additional parameters that are needed

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in order to support key actions identified in the plant procedures/guidance (e.g. isolation
condenser (IC) level), or to indicate imminent or actual core damage.”
In addition, on March 12, 2012 the NRC issued Order EA-12-051, “Order Modifying Licenses
with Regard to Reliable Spent Fuel Pool Indication,” requiring licensees to install
instrumentation for monitoring spent fuel pool levels. Regulatory guidance for this
instrumentation is contained in NEI 12-02, “Industry Guidance for Compliance with NRC
Order EA-12-051, ‘To Modify Licenses with Regard to Reliable Spent Fuel Pool
Instrumentation,’” as endorsed by JLD-ISG-2012-03, “Compliance with Order EA-12-051,
Reliable Spent Fuel Pool Instrumentation.” Most licensees refer to this instrumentation in
their mitigation strategies under the Mitigation Strategies Order. All operating licensees
have completed installation of this instrumentation.
In parallel with activities on the Mitigation Strategies Order, the NRC issued a separate order
to licensees of Boiling-Water Reactors (BWRs) with General Electric (GE) Mark I and II
containments, NRC Order EA-12-050, “Order Modifying Licenses with Regard to Reliable
Hardened Containment Vents.” This order was subsequently withdrawn and replaced by
NRC Order EA-13-109, “Order Modifying Licenses with Regard to Reliable Hardened
Containment Vents Capable of Operation under Severe Accident Conditions.” Regulatory
guidance for NRC Order EA-13-109 is contained in JLD-ISG-2013-02, “Compliance with Order
EA-13-109, ‘Order Modifying Licenses with Regard to Reliable Hardened Containment Vents
Capable of Operation under Severe Accident Conditions,’” and the industry-developed
document NEI 13-02, “Industry Guidance for Compliance with Order EA-13-109.” Additional
regulatory guidance is contained in JLD-ISG-2015-01, “Compliance with Phase 2 of Order EA13-109, ‘Order Modifying Licenses with Regard to Reliable Hardened Containment Vents
Capable of Operation under Severe Accident Conditions.’” The NRC Order EA-13-109
required a means to monitor the effluent discharge for radioactivity that may be released
from operation of the hardened containment venting system. Compliance with Order EA13-109 is required on a rolling basis keyed to licensee outage schedules with a backstop dateof June 30, 2019.
b)

Addition or modifications to plant communications capabilities (onsite/internal
communications and communication with off-site individuals/organizations).
The draft final Mitigation of Beyond-Design-Basis Events (MBDBE) rule would requirecommunication capabilities for events that result in loss of all ac power onsite, or potential
destruction of offsite communications infrastructure. Because of the destruction tocommunications capability that occurred during the Fukushima Dai-ichi event, the MBDBE
rule contains requirements for licensees to provide a capability to communicate with onsite
staff to support mitigation of the event, and to support offsite communications to gain any
additional support or to perform emergency preparedness functions. The communication
requirements support effective implementation of the mitigation strategies and guidelinesof Title 10 of the Code of Federal Regulations, section 50.155(b)(1) and were included as part ofthe implementation of the Mitigation Strategies Order. These requirements are relocated in
the final MBDBE rule to more clearly reflect the importance of communication to effective
implementation of the mitigation strategies and guidelines, and to better align with theprevious implementation of these requirements under the Mitigation Strategies Order.
In its letter issued on March 12, 2012, pursuant to § 50.54(f), the NRC requested information
associated with Near-Term Task Force recommendation 9.3 for emergency preparedness
communications. Specifically, the letter requested licensees submit an assessment of theircurrent communications systems and equipment used during a beyond-design-basis
natural event resulting in an extended loss of AC power to all units on site and impeding
access to the site. The § 50.54(f) letter cites § 50.47(b)(6) and 10 CFR part 50, appendix E,
section IV.E.9 as the applicable regulations that describe the licensee’s emergency plancommunications systems requirements. The communications systems used by licensees tomeet these regulations are the communications systems that were to be considered in therequested assessment. The intent of the communications assessment was to determine
what, if any, enhancements would be needed for onsite communications systems (e.g.
radios for response teams and between facilities) and offsite communications systems (e.g.

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cellular telephones and satellite telephones) used in support of required mitigative response
actions during a site-wide loss of all ac power to ensure continued availability.
Therefore, any communication capability enhancement made by a licensee in response to
the assessment did not need to meet the design capabilities for the communications system
required by 10 CFR part 50, appendix E or testing frequencies described for primary andbackup onsite and offsite communications systems. Any enhanced communications
system, equipment, or power supply implemented as a result of the § 50.54(f) assessment
was not necessary to meet the requirement to notify offsite emergency responseorganizations within 15 minutes of an emergency declaration or to meet the monthly
communications testing requirement for contiguous State/local governments within theplume exposure pathway emergency planning zone.
c)

Other changes to plant or equipment human-system interfaces to improve humanperformance reliability
NEI 12-06 Section 3.2.2, “Minimum Baseline Capabilities,” addresses the development andimplementation of procedures and administrative guidance regarding human performancereliability in order to meet the requirements of the Mitigation Strategies Order. The issues
addressed include:•

Identification of site-specific actions necessary to secure AC power to essential loads;•

Recognition of priority equipment early in the event and focusing adequate attention on
this equipment;•

Recognition of sources of potential reactor inventory loss and specified actions toprevent or limit significant loss;•

Identify the lighting and communications systems necessary for plant ingress and egress
and to plant areas required for deployment of FLEX strategies;•

Consideration of accessibility requirements at locations where operators will be required
to perform operator manual actions;

In addition, NEI 12-06, Section 12, “Off-Site Resources,” provides guidance for thesynchronization of off-site resources with the on-going event mitigation activities. Humanperformance reliability aspects include site procedures to address notification to mobilize
off-site resources early in the event and the use of specified, standard mechanical couplingsand electrical connections.
d)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
NEI 12-06, “Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,” provides
guidance with regard to developing mitigating strategies for beyond design basis external
events (BDBEEs). The NRC staff endorsed the guidance in NEI 12-06 as an acceptable method
for licensees to comply with the requirements of Order EA-12-049 to establish a capability
and strategies to mitigate the effects of a BDBEE. All operating nuclear power plant sites in
the US have completed implementation of the BDBEE mitigating strategies associated with
Order EA-12-049 and the NRC is in the process of completing compliance inspections.

7.

PORTABLE EQUIPMENT/TOOLS, PROTECTIVE GEAR, AND WORK ENVIRONMENTS
a.

Provision of additional portable plant equipment or hand tools to support reliable humanperformance
The NRC-endorsed guidance Nuclear Energy Institute (NEI) 12-06, Rev. 2, Section 1.1“Background,” includes tools, debris clearing equipment, temporary flood protection andother supporting equipment or tools as one of the key elements of the FLEX strategies. Plants
procured FLEX debris removal equipment based on the specific site characteristics anddeployment strategies.

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Design of portable plant equipment or hand tools to support reliable human performance(e.g. plug and play pipe connections, portable and installed equipment painted with somespecific color, equipment needed during a station blackout identified with fluorescentlabels)The NRC-endorsed guidance for the Mitigation Strategies Order, NEI 12-06, Revision 2,
Appendix E, Attachment 5, “Inherent FLEX Attributes That Enhance Human Reliability inthe Event of a Beyond Design Basis Event,” specifically addresses human reliability
enhancements associated with the FLEX strategies. The sub-section entitled, “Special
Equipment,” emphasizes that the number and type of specialized equipment is minimal.
This includes standardization of the control panels and operation procedures for portable
generators and portable FLEX pumps as well as the specification of clearly labeled gauges,
components and controls with similar ergonomics regardless of the size of the portablecomponent. In addition, FLEX equipment connections utilize standardized color coded
electrical connections and standardized mechanical couplings.

c.

Provision of additional protective gear or modifications to protective gear to support reliable
human performance
Under NEI 12-06, Revision 2, Appendix E, Attachment 5, FLEX mitigation strategies are basedon the criteria that there are no extraordinary tasks/subtasks which would require special
equipment/fitness capabilities beyond the use of normal personal protective equipment.
However, the impact of the stress and pressure associated with the beyond-design-basis
external event (BDBEE) is recognized and the FLEX validation plans include a qualitative
assessment of the time margin between when an action can be performed in ideal
conditions and when it must be performed under BDBEE conditions for successful FLEX
implementation.

d.

Modifications to work environments to support reliable human performance (e.g.
emergency lighting, flood protection)
Under NEI 12-06, Revision 2, Appendix E, Attachment 5, FLEX mitigation strategies aredeveloped with considerations for environmental factors such as inclement weather anddarkness. The environmental impact of darkness, wind and rain is addressed by personal
protective equipment, flashlights, portable powered lighting and lighting on the deployed
FLEX equipment. Lighting designated for fire emergencies (i.e., Title 10 of the Code of Federal
Regulations, Part 50, Appendix R) will remain functional where needed and human factor
aides such as labeling, color coding and placards are used to limit the impact of darkness.

e.

Others changes to plant equipment/environments to support reliable performance of
mitigation actions
The regulatory guidance for the Mitigation Strategies Order in NEI 12-06, Revision 2, Sections
3.2.1.9, “Personnel Accessibility,” 3.22, “Minimum Baseline Capabilities” and Appendix E,
Attachment 5, address the impact of personnel accessibility on the implementation ofoperator actions including environmental factors. Plant sites were evaluated for alternate
deployment routes for FLEX equipment to the designated staging areas. Where appropriate,
pre-staging of equipment was implemented to ensure personnel accessibility to FLEX
equipment in circumstances such as flooding. Heavy debris removal equipment was
positioned inside FLEX equipment storage buildings in such a way as to be accessible toclear the exit of the building for the portable equipment.

f.

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
The regulatory guidance for the Mitigation Strategies Order, NEI 12-06, “Diverse and Flexible
Coping Strategies (FLEX) Implementation Guide,” Rev. 2, provides guidance with regard todeveloping mitigating strategies for beyond design basis external events (BDBEEs). The NRC
staff endorsed the guidance in NEI 12-06 as an acceptable method for licensees to comply
with the requirements of Order EA-12-049 to establish a capability and strategies to mitigate
the effects of a BDBEE.

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WORK PLANNING, TECHNICAL SUPPORT, AND EMERGENCY RESPONSE FACILITIESa.

Design and implementation of new or modified on-site facilitiesb.

Design and implementation of new or modified off-site facilitiesc.

Changes to other facilities not previously addressed
The regulatory guidance for the MBDBE Rulemaking currently before the Commission would
endorse NEI 13-06, “Enhancements to Emergency Response Capabilities for Beyond Design
Basis Events and Severe Accidents,” which provides guidance on recommended actions withregard to emergency response facilities and equipment which include but are not limited to
the recommended actions listed below.
4.3 RECOMMENDED ACTIONS
4.3.1 Industry Performance Standard for EP Facilities and Equipment
Each licensee should implement the Emergency Preparedness (EP) facility andequipment enhancements identified in their communications and staffing assessments
provided to the NRC staff in accordance with the 50.54(f) letter.
For EP facility and equipment enhancements not addressed by the requirements or
guidance discussed above, the following approaches are recommended. NEI 13-06(Revision 0) September 2014
Determine applicable design and configuration control measures.
Items may be procured and installed under the commercial and site requirements
normally applied to EP facilities and equipment.
For multi-unit sites, ensure that sufficient quantities of radiation protection equipment
and supplies are, or can be made, available to support protracted operation of an
expanded Emergency Response Organization (ERO).
Programmatic controls should be developed to ensure the availability and reliability of
EP facilities and equipment, including the performance of periodic inventory checks,
functionality testing and maintenance.
Supporting contracts with vendors should be periodically verified.

d.

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
The draft final MBDBE rule proposes an implementation schedule for operating powerreactor licensees within two or three years of the effective date of the rule depending on thereactor type. This is an estimated implementation schedule.

EMERGENCY RESPONSE PLANS

9.

a.

Changes in emergency response plans or implementation methodsb.

Changes in the drills or exercises of the emergency response planc.

Others changes to emergency response plans
The regulatory guidance for the Mitigation of Beyond-Design-Basis Events (MBDBE)
Rulemaking currently before the Commission would endorse Nuclear Energy Institute (NEI)
13-06, “Enhancements to Emergency Response Capabilities for Beyond Design Basis Eventsand Severe Accidents,” which provides the following guidance on recommended industry
performance standards for beyond design bases event response drills:

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5.3.1 Industry Performance Standards for BDB Event Response Drills
Each licensee should demonstrate the capability for effective integrated use of theiraccident mitigation and management procedure and guideline sets. In particular, theability to transition between procedure and guideline sets, and select the best strategy
for preventing or mitigating fuel damage and limiting radiological releases, isdemonstrated. Complementary methods will be necessary to accomplish thisdemonstration since the procedures and guidelines implemented for a given scenario
are dependent upon the nature of the postulated initiating event, the plant
response/accident sequence, and the ability of responders to select and implement
mitigation/management strategies. The use of complementary methods will also
promote more effective use of resources (e.g. facilitates targeted drill objectives, avoids
excessive drill “down time” and durations, etc.), and minimize potential safety
challenges to personnel and equipment.
a)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
The draft final MBDBE Rule is currently before the Commission for consideration. It would
establish a compliance schedule of four years from the effective date of the rule, withsubsequent drills or exercises being required every eight years.

10. EXTENDED (LONGER TERM) RESPONSE
1)

Additions or modifications to plans or capabilities to address on-site staff physiologicalneeds (e.g. food, water, sleep, hygiene) over the duration of time required to achieve asafe/stable plant state.

2)

Additions or modifications to plans or capabilities to address on-site staff psychologicalneeds (e.g. fatigue/stress management, contact with families) over the duration of timerequired to achieve a safe/stable plant state.

3)

Additions or modifications to plans or capabilities to relieve/augment on-site staff (e.g.
communication, transportation, site access).

4)

Other additions or modifications to extended response plans

5)

For any changes that you described for this topical area, please state their implementation
schedule (either required or estimated, as applicable) and list any opportunities for gaining
relevant HOF lessons-learnt (e.g. related assessments, validations, audits, inspections,training, drills, exercises).
The regulatory guidance for the Mitigation of Beyond-Design-Basis Events Rulemaking
currently before the Commission would endorse NEI 13-06, “Enhancements to Emergency
Response Capabilities for Beyond Design Basis Events and Severe Accidents,” which
provides guidance on recommended actions for existing augmented staffing to respond toa multi-unit event. These actions include notification, training, and transportation routes
and options for response. The guidance does not specifically address physiological or
psychological needs for extended response.

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