Enclosure 2 

Summary of Closed Tier 2 and 3 Activities and Updates on Ongoing Work

In SECY-11-0137, “Prioritization of Recommended Actions to Be Taken in Response to 

Fukushima Lessons Learned,” dated October 3, 2011 (Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML11269A204), the U.S. Nuclear Regulatory 

Commission (NRC) staff prioritized the Near-Term Task Force (NTTF) recommendations. 

These recommendations were published in SECY-11-0093, “Near-Term Report and 

Recommendations for Agency Actions Following the Events in Japan,” dated July 12, 2011 

(ADAMS Accession No. ML11186A950), and are grouped into three tiers. 

In 2015, the NRC staff re-evaluated its plans to resolve the Tier 2 and Tier 3 recommendations 

in light of the safety benefit that will be achieved through the Tier 1 recommendations and 

insights gained from related Commission decisions. The NRC staff provided its 

recommendations to the Commission in SECY-15-0137, “Proposed Plans for Resolving Open 

Fukushima Tier 2 and 3 Recommendations” (ADAMS Accession No. ML15254A006), on 

October 29, 2015, with updated plans and closeout recommendations for some of the Tier 2 

and 3 items. This enclosure provides the current status of the Tier 2 and Tier 3 items. 

The NRC staff sorted the resolution plans for the Tier 2 and 3 recommendations into the 

following three groups: 

(1) Recommendations that should be closed now. 

(2) Recommendations that the NRC staff’s initial assessment has concluded should be 

closed, but for which stakeholder interaction is warranted before finalizing the NRC 

staff’s assessment. 

(3) Recommendations for which the NRC staff has not yet completed its assessment, 

stakeholder interactions, and/or documentation. 

Notwithstanding closure of these items, the NRC staff noted that work will continue in some of 

these areas for many years. For example, the NRC staff will continue to engage with the 

international community on long-term health studies in the areas around Fukushima Dai-ichi and 

will continue work to ensure post-Fukushima safety enhancements are appropriately 

incorporated into the NRC’s existing oversight programs. The NRC research activities related to 

improving the understanding and modeling of reactor behavior during severe accidents will 

likewise continue. The NRC staff intends to use established programs and processes to 

conduct these activities, including engagement with the Commission, if appropriate. For 

example, the Office of Nuclear Security and Incident Response will keep the Commission 

informed using the annual report to the Commission on emergency preparedness and incident 

response. 

Summary of Tier 2 and Tier 3 Items Included in Rulemaking Activities 

In COMSECY-13-0002, “Consolidation of Japan Lessons Learned Near-Term Task Force 

Recommendations 4 and 7 Regulatory Activities,” dated January 25, 2013 (ADAMS Accession 

No. ML13011A034), the NRC staff proposed that the Tier 2 activities related to spent fuel pool 

(SFP) instrumentation and makeup capability be addressed within the implementation activities 
- 2 - 

for mitigating strategies in Order EA-12-049, “Issuance of Order to Modify Licenses with Regard 

to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,” dated 

March 12, 2012 (ADAMS Accession No. ML12054A735), as well as in the station blackout 

(SBO) mitigation strategies rulemaking (which was subsequently consolidated into the mitigation 

of beyond-design-basis events (MBDBE) rulemaking). 

The Commission approved the NRC staff’s proposal on March 4, 2013, in the staff requirements 

memorandum (SRM) to COMSECY-13-0002 (ADAMS Accession No. ML13063A548). As a 

result, the NTTF recommendations below are no longer tracked as separate Tier 2 items. 

Tier Description Source of Action 

2 Require safety-related alternating current electrical 

power for the SFP makeup system 

NTTF Recommendation 7.2 

2 Maintain one train of onsite emergency power 

operable for SFP makeup and instrumentation 

NTTF Recommendation 7.3 

2 Seismically qualified SFP spray system NTTF Recommendation 7.4 

2 Initiate rulemaking NTTF Recommendation 7.5 

In SECY-14-0046, “Fifth 6-Month Status Update on Response to Lessons-Learned from Japan’s 

March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami,” dated April 17, 2014 

(ADAMS Accession No. ML14218A703), the NRC staff proposed that the following Tier 2 and 3 

emergency preparedness (EP) items be addressed through the implementation of the mitigating 

strategies Order EA-12-049 and the MBDBE rulemaking. The Commission approved the NRC 

staff’s proposal on July 9, 2014, in the SRM to SECY-14-0046 (ADAMS Accession 

No. ML14190A347). Since these are also being addressed through the MBDBE rulemaking, 

these NTTF recommendations below are no longer tracked as separate Tier 2 or 3 items. 

Tier Description Source of Action 

3 Initiate rulemaking to require EP enhancements for 

multiunit events 

NTTF Recommendation 9.1 

3 Initiate rulemaking to require EP enhancements for 

prolonged SBO 

NTTF Recommendation 9.2 

2/3 Order licensees to perform various EP enhancements 

until the rulemaking is complete 

NTTF Recommendation 9.3 

(partial) 

3 Improve command and control structures NTTF Recommendation 10.2

3 Enhance resources to bring response equipment on 

site 

NTTF Recommendation 11.1
- 3 - 

Summary of Group 1 Items 

In the SRM to SECY-15-0137 (ADAMS Accession No. ML16039A175), the Commission 

approved the closure of the following Group 1 recommendations: 

Tier Description Source of Action 

3 Capabilities to prevent seismically induced fires and 

floods 

NTTF Recommendation 3 

3 Evaluation of EP zone size and pre-staging of 

potassium iodide beyond 10 miles (16 kilometers) 

NRC staff 

3 Enhancements to the Reactor Oversight Process NTTF Recommendation 12.1

3 Enhancements to NRC staff training on severe 

accidents and severe accident management 

guidelines 

NTTF Recommendation 12.2

3 Various EP activities (with the exception of 

Recommendation 11.3) 

NTTF Recommendations 9, 

10, and 11 (except 11.3) 

“Potential Enhancements to the Capability to Prevent or Mitigate Seismically-Induced Fires and 

Floods” (Enclosure 3 to SECY-15-0137) was evaluated as a Group 1 item to be closed 

immediately. However, the NRC staff noted that work would continue to finalize the probabilistic 

risk assessment (PRA) feasibility study, with a goal of completing that study by the end of 

calendar year 2015. The NRC staff committed to inform the Commission if any insights 

obtained as part of the completion of that study change the results of its assessment. 

The final feasibility study has been completed and is documented in the Brookhaven National 

Laboratory report entitled, “Brookhaven National Laboratory Report—Scoping Study for a PRA 

Method for Seismically Induced Fires and Floods,” dated December 2015 (ADAMS Accession 

No. ML16004A250). The feasibility study identified a number of key issues associated with the 

development of qualitative or quantitative PRA methods for seismically induced fires and floods 

(SIFFs). Through the workshops and expert consultation, a number of unresolved technical 

issues have been identified that will require further evaluation to develop a fully usable PRA 

methodology. 

Before receiving the feasibility study, the NRC staff believed that the potential benefits of fully 

developing and piloting a PRA approach for SIFFs would not justify the costs of continuing this 

effort. The NRC staff from the Office of Nuclear Regulatory Research completed its review of 

the Brookhaven National Laboratory PRA feasibility study. The technical challenges noted in 

the report prevent modeling and quantifying the probabilistic risk with a level of confidence that 

is comparable to the “state-of-the-art” of current PRAs. Based on the NRC staff’s review, no 

additional insights were provided in the study that would challenge the NRC staff’s conclusions 

in Enclosure 3 to SECY-15-0137. 

 
- 4 - 

Summary of Group 2 Items 

In SECY-15-0137, the activities below were evaluated as Group 2 items, meaning the NRC 

staff’s initial assessment concluded that they should be closed, but for which additional 

interaction with the Advisory Committee on Reactor Safeguards (ACRS) or external 

stakeholders was warranted. These recommendations include the following: 

Tier Description Source of Action 

3 Reliable vents for other containment designs other 

than Mark I and Mark II 

NTTF Recommendation 5.2 

3 Hydrogen control and mitigation NTTF Recommendation 6 

3 Enhanced reactor and containment instrumentation 

for beyond-design-basis events 

ACRS 

The NRC staff proposed to interact with stakeholders, complete the assessments, and inform 

the Commission of the final results of its evaluation as soon as practicable and by no later than 

the end of March 2016. In the SRM for SECY-15-0137, the Commission approved the staff’s 

plan. 

The NRC staff’s assessments and final results of its evaluation have been documented in 

SECY-16-0041 “Closure of Fukushima Tier 3 Recommendations Related to Containment Vents, 

Hydrogen Control, and Enhanced Instrumentation” (ADAMS Accession No. ML16049A079). 

The additional interactions conducted since the completion of SECY-15-0137 did not change 

the NRC staff’s initial conclusions and recommendations, and the NRC staff determined that no 

additional regulatory action was warranted. These three Tier 3 items are closed. 

Status of Group 3 Items 

In SECY-15-0137, the activities below were evaluated as Group 3 items, meaning that the NRC 

staff’s assessment and final documentation of their conclusions was not completed, and that 

additional ACRS and external stakeholder interaction was needed before the NRC staff could 

complete its assessment: 

Tier Description Source of Action 

2 Evaluation of natural external hazards other than 

seismic and flooding 

ACRS and the Consolidated 

Appropriations Act, 2012 

3 Periodic confirmation of natural hazards NTTF Recommendation 2.2 

3 Efficacy of real-time radiation monitoring in EP zone 

and on site 

NTTF Recommendation 11.3

The status of the NRC staff’s activities on these Group 3 items is provided below. 

Evaluation of Other Natural Hazards (Enclosure 1 to SECY-15-0137) 

The NRC staff is further evaluating the risk to U.S. nuclear sites from other natural external 

hazards to determine if the associated risks warrant regulatory action. The NRC staff will 

provide the results of this evaluation to the Commission by the end of 2016. The final 

assessment will also consider the outcome of interactions with ACRS and external 
- 5 - 

stakeholders. Before completing its review of this recommendation, the NRC staff plans to 

discuss the results of this review with external stakeholders, including the industry and members 

of the public. The NRC staff will then conduct a focused briefing on this issue with ACRS, if 

appropriate, before providing its final assessment to the Commission. 

The evaluation process includes four tasks described in SECY-15-0137: 

(1) Define natural hazards other than seismic and flooding to determine those hazards that 

should be reviewed generically (complete). 

(2) Determine and apply screening criteria to appropriately exclude certain natural hazards 

from further generic evaluations, or exclude some licensees from considering certain 

hazards. 

(3) Perform a technical evaluation to assess the need for additional actions if the hazard or 

licensee was not screened out generically in Task 2. 

(4) Determine if additional actions are needed. 

As specified in the SRM to SECY-15-0137, the NRC staff is preparing an interim paper for the 

Commission on the results of the screening conducted in accordance with Task 2 of the 

evaluation process. The NRC staff will hold a Category 3 public meeting, brief the ACRS 

Fukushima subcommittee, and brief the ACRS full committee to receive feedback on the results 

of the screening. The interim report will be provided to the Commission no later than the end of 

May 2016. 

The NRC staff notes that the safety benefit achieved through Order EA-12-049 has been and 

continues to be considered in the evaluation of potential regulatory requirements to determine 

whether additional changes are necessary using the NRC staff’s risk-informed decision-making 

process. 

Periodic Reconfirmation of External Natural Hazards (Enclosure 2 to SECY-15-0137) 

The NRC staff has formed a working group and has begun work to develop and enhance 

internal processes to address the NTTF Recommendation 2.2. As discussed in SECY-15-0137, 

the NRC staff will leverage the information gained through the recent reevaluation of seismic 

and flooding hazards to develop a process to proactively obtain new information and assess its 

significance. The NRC staff intends to discuss the results of this review and development of the 

process with industry and other stakeholders. The NRC staff plans to have the process 

developed by December 2016. 

Efficacy of Real-Time Radiation Monitoring in Emergency Planning Zone and on site 

(Enclosure 7 to SECY-15-0137): 

The NRC staff is on track to provide their conclusions and recommendations to the Commission 

before the end of calendar year 2016. This will allow time for further documentation or 

stakeholder interactions as part of the process for closing this item. The NRC staff will further 

evaluate the lessons learned from Fukushima with regard to the radiation monitoring systems in 

use at the time of the event to discern whether this experience warrants reconsideration of the 
- 6 - 

actions taken with Regulatory Guide 1.97, Revision 3, “Instrumentation for Light-Water-Cooled 

Nuclear Power Plants To Assess Plant and Environs Conditions during and following an 

Accident,” dated May 1983 (ADAMS Accession No. ML003740282), and subsequent revisions. 

As part of stakeholder interactions, the NRC staff will be making presentations at several public 

conferences, including the joint NRC and Federal Emergency Management Agency Integrated 

Progress Review meeting at NRC headquarters; the National Radiological Emergency 

Preparedness conference in Charleston, SC; and the Nuclear Energy Institute Emergency 

Preparedness Forum in Indianapolis, IN. The presenters will discuss the NRC staff effort on the 

recommendation and the status of that effort and solicit input from these stakeholders.