December 29, 2016 

MEMORANDUM TO: Chairman Burns 

 Commissioner Svinicki 

 Commissioner Baran 

FROM: Michael R. Johnson /RA/ 

 Deputy Executive Director for Reactor 

 and Preparedness Programs 

 Office of the Executive Director for Operations 

 

SUBJECT: REQUEST FOR REVISION TO CERTAIN FUKUSHIMARELATED TASKINGS 

This memorandum requests Commission approval to close or revise four work item tracking 

system (WITS) tasks related to the lessons learned from the Fukushima Dai-Ichi event: WITS 

201200014, WITS 201200015, WITS 201200016, and WITS 201200017. These tasks were 

linked to Commission direction in the staff requirements memorandum (SRM) dated December 

15, 2011, associated with SECY-11-0137, “Prioritization of Recommended Actions To Be Taken 

in Response to Fukushima Lessons Learned,” dated October 3, 2011. In this SRM, the 

Commission directed the staff to consult with the Commission via notation vote papers before 

issuing any orders that would lead to a change in the design basis of licensed plants. 

This direction resulted in four taskings for the staff to provide notation vote papers associated 

with Near-Term Task Force Recommendations 2.1 and 2.3 related to seismic and flooding 

hazard reevaluations and walkdowns, respectively. These tasks specifically reference 

requesting Commission approval of orders to modify operating reactor licenses once staff has 

engaged stakeholders and established the requisite technical basis and acceptance criteria. All 

four tasks are due March 12, 2017. 

This approach to the tasking for Recommendations 2.1 and 2.3 was developed in early 2012 at 

the time the requests for information under Title 10 of the Code of Federal Regulations, 

Section 50.54(f) (referred to as the 10 CFR 50.54(f) letter) were being proposed. At the time, 

the staff envisioned that changes to numerous plants’ licensing bases through orders might be 

necessary. The staff has completed multiple actions in response to the Fukushima Dai-Ichi 

event, as reported to the Commission during the staff’s periodic updates (e.g., SECY-16-0043, 

“Ninth 6-Month Status Update on Response to Lessons Learned from Japan’s March 11, 2011, 

Great Tōhoku Earthquake and Subsequent Tsunami,” dated April 22, 2016 (Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML16054A255), as well 

as monthly status updates provided by memorandum). As the staff has completed actions and 

CONTACT: Lauren K. Gibson, NRR/JLD 

 (301) 415-1056

PLEASE RESPOND BY:

January 17, 2017

COMSECY-16-0030
The Commissioners - 2 - 

received Commission approval for alternate approaches to completing the hazard reevaluations, 

the staff has determined that it is appropriate to adjust these four broad-scope tasks. Additional 

detail on each of these tasks is presented below. 

WITS 201200016 and 201200017 

These tasks relate to the seismic and flooding walkdowns included in Recommendation 2.3. 

As discussed in SECY-16-0043, the operating reactor fleet completed the plant walkdowns 

(except for those portions of the seismic walkdowns that were not accessible at power) and 

submitted their walkdown reports by November 2012. The U.S. Nuclear Regulatory 

Commission (NRC) staff completed staff assessments of the walkdown reports by July 2014. 

The NRC staff assessments determined that the plant walkdowns consistently followed the 

intent of the NRC-endorsed guidance, thereby verifying that the walkdowns met the objectives 

of the 10 CFR 50.54(f) letter. Subsequently, all seismic walkdowns of inaccessible items were 

completed. The NRC staff documented the reviews of the inaccessible walkdown items in a 

staff memorandum dated September 25, 2015 (ADAMS Accession No. ML15268A477). All 

actions to address Recommendation 2.3 are complete, and this recommendation is closed. 

Therefore, there is no need for notation vote papers requesting Commission approval of orders 

related to Recommendation 2.3, as tracked in these tasks. 

The staff requests that the Commission approve closure of WITS 201200016 and 201200017. 

WITS 201200015 

This task relates to the reevaluation of flooding hazards at operating reactor sites, as described 

in Recommendation 2.1. In COMSECY-15-0019, “Closure Plan for the Reevaluation of 

Flooding Hazards for Operating Nuclear Power Plants,” dated June 30, 2015, the staff 

presented its “Mitigating Strategies and Flooding Hazard Reevaluation Action Plan” for 

Commission approval. This plan provides for the development of focused evaluations and 

integrated assessments of plant response to the reevaluated flooding hazard (Phase 1) and a 

subsequent NRC regulatory evaluation (Phase 2) to assess the need for additional regulatory 

actions. 

Phase 1 will be complete by the end of 2018, by which time licensees are expected to submit all 

focused evaluations and integrated assessments, as applicable. As part of Phase 2, if a plantspecific backfit evaluation is initiated, the staff will use the established processes for imposing 

additional requirements on licensees, as described in Management Directive 8.4, “Management 

of Facility-Specific Backfitting and Information Collection.” The Commission approved this 

action plan in its staff requirements memorandum to COMSECY-15-0019 dated July 28, 2015, 

and the staff is implementing the action plan. Consistent with Commission direction in 

SRM-SECY-11-0137, the staff would consult with the Commission via notation vote papers 

before issuing any orders that would lead to a change in the design basis of licensed plants. 

Therefore, the staff requests that the Commission approve an extension of WITS 20120015 to 

December 16, 2019, to enable the staff to complete Phase 2 for all affected facilities and submit 

any necessary notation vote papers. 
The Commissioners - 3 - 

WITS 201200014 

This task relates to the reevaluation of seismic hazards at operating reactor sites, as described 

in Recommendation 2.1. The staff has completed its assessment and closed the seismicrelated aspects of Recommendation 2.1 for 20 sites as of November 30, 2016. The reevaluated 

seismic hazard for these sites was either bounded by the site’s current design bases or the site 

had a limited high frequency exceedance. In addition, the staff has completed its assessment of 

the reevaluated seismic hazard for all sites. 

On October 27, 2015, the NRC staff issued a letter providing its final determination of which 

licensees for which Recommendation 2.1 remains open will need to perform a seismic 

probabilistic risk assessment (SPRA) (ADAMS Accession No. ML15194A015). This letter 

established a staggered submittal schedule for these assessments. There are currently 20 sites 

that will perform an SPRA. The first SPRAs are due to the NRC in March 2017 and all SPRAs 

will be received by December 2019. The remaining 32 sites will perform limited-scope 

evaluations—that is, a high frequency evaluation, low frequency evaluation, spent fuel pool 

evaluation, or a combination thereof. 

While the staff did not specifically submit a seismic action plan to the Commission for approval 

as it did for flooding, it expects to take an analogous approach and follow established processes 

to impose any necessary additional requirements. As with the flooding reevaluation, consistent 

with Commission direction in SRM-SECY-11-0137, the staff would consult with the Commission 

via notation vote papers before issuing any orders that would lead to a change in the design 

basis of licensed plants. 

Therefore, the staff requests that the Commission approve an extension of WITS 20120014 to 

December 14, 2020, to enable the staff to complete reviews of SPRAs for all affected facilities 

and submit any necessary notation vote papers. 

Based on the justifications provided above, the staff requests that the Commission approve the 

closure of WITS 201200016 and WITS 201200017, as well as the requested schedule 

adjustments for WITS 201200014 and WITS 201200015. 

SECY, please track. 

cc: SECY 

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The Commissioners - 3 - 

WITS 201200014 

This task relates to the reevaluation of seismic hazards at operating reactor sites, as described 

in Recommendation 2.1. The staff has completed its assessment and closed the seismicrelated aspects of Recommendation 2.1 for 20 sites as of November 30, 2016. The reevaluated 

seismic hazard for these sites was either bounded by the site’s current design bases or the site 

had a limited high frequency exceedance. In addition, the staff has completed its assessment of 

the reevaluated seismic hazard for all sites. 

On October 27, 2015, the NRC staff issued a letter providing its final determination of which 

licensees for which Recommendation 2.1 remains open will need to perform a seismic 

probabilistic risk assessment (SPRA) (ADAMS Accession No. ML15194A015). This letter 

established a staggered submittal schedule for these assessments. There are currently 20 sites 

that will perform an SPRA. The first SPRAs are due to the NRC in March 2017 and all SPRAs 

will be received by December 2019. The remaining 32 sites will perform limited-scope 

evaluations—that is, a high frequency evaluation, low frequency evaluation, spent fuel pool 

evaluation, or a combination thereof. 

While the staff did not specifically submit a seismic action plan to the Commission for approval 

as it did for flooding, it expects to take an analogous approach and follow established processes 

to impose any necessary additional requirements. As with the flooding reevaluation, consistent 

with Commission direction in SRM-SECY-11-0137, the staff would consult with the Commission 

via notation vote papers before issuing any orders that would lead to a change in the design 

basis of licensed plants. 

Therefore, the staff requests that the Commission approve an extension of WITS 20120014 to 

December 14, 2020, to enable the staff to complete reviews of SPRAs for all affected facilities 

and submit any necessary notation vote papers. 

Based on the justifications provided above, the staff requests that the Commission approve the 

closure of WITS 201200016 and WITS 201200017, as well as the requested schedule 

adjustments for WITS 201200014 and WITS 201200015. 

SECY, please track. 

cc: SECY 

 OGC 

 OCA 

 OPA 

 CFO 

DISTRIBUTION: 

RidsNrrMailCenter Resource RidsEdoMailCenter Resource RidsNrrJld 

RidsSecyMailCenter Resource RidsNrrOd TClark, OEDO 

ADAMS Accession Number: ML16259A232 EDO-004 *by e-mail 

OFFICE NRR/JLD/JHMB/PM QTE* NRR/JLD/JHMB/BC (A) NRR/JLD/D(A) 

NAME LKGibson Jay Doughtery GBowman MFranovich 

DATE 10/ 4 /2016 10/ 4 /2016 10/ 17 /2016 12/2/2016 

OFFICE OGC (NLO) * NRR/D EDO 

NAME SClark WDean (BMcDermott for) MJohnson 

DATE 11/21/2016 12/9/2016 12/ 29 /2016 

OFFICIAL RECORD COPY